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Expert feels Perrier needs impact statement

By BRIAN LEAHY
of The Gazette
A local ground water expert disagrees with the Department of Natural Resources judgment that an Environmental Impact Statement (EIS) is not needed to approve high-capacity wells for the proposed Perrier Group of America bottling plant in Adams County.

"The EA (environmental assessment) was deficient," said George Kraft, director of the Central Wisconsin Groundwater Center at the University of Wisconsin-Stevens Point.

Pumping tests conducted by Perrier and cited in the EA were insufficient to determine possible impacts on wetlands near spring site and stream flow of Big Spring Creek, Kraft said.

"The test was not designed to measure those kinds of impacts … They were way too short and didn't have the proper instrumentation," he said. "We need to wait for the ground water model and the aquifer tests to discern what those impacts will be."

DNR officials issued their preliminary determination in a draft Environmental Assessment (EA) that the planned two or more wells with a combined pumping capacity of more than 500 gallons per minute is "not a major action that would significantly affect the quality of the human environment" so a more detailed EIS is not needed. An EA and EIS both have the same content requirements, but the EIS has more details. Not including attachments, the draft EA is 52 pages long. Copies are available for review at all Regional Public Library System Resource Libraries and on the Wisconsin DNR web site at www.dnr.state.wi.us.

Plans call for a Perrier subsidiary from Greenwich, Conn., Great Spring Waters of America, to use the water in its Perrier's Ice Mountain Spring Water brand marketed in the Midwest. Two or more 8-inch wells would be drilled to a depth of 200 feet in a sand aquifer. Each well would be located within 300 feet of either Jensen's Pond or Buckley Springs Pond. The wells would initially pump a combined 150-350 gallons per minute, but could increase to 500 gallons per minute within five years. A pipeline would carry the water to a bottling plant 1.75 miles away. At the end of the five-year project, the bottling plant could be more than 1 million square feet. Perrier estimates the project will cost $80 million when completed. It would employ 250 people and operate 24 hours a day, seven days a week, 365 days a year.

The EA compares that pumping rate to those of an average high-capacity agricultural irrigation well which pumps at between 500-1,500 gallons per minute, a manufacturing plant well at 100-3,000 gallons per minute and a well for a food processing or dairy plant at 50-500 gallons per minute.

Looking at the pumping rates without including the duration the pumps would be operating is "comparing apples and oranges" and gives "a false sense of security," Kraft said.

The EA found stream flow in Big Spring Creek would be reduced by about 5 percent, but that study was conducted about two miles downstream from the springs, Kraft said. As the stream flows downstream, it receives more water from sources like drain tile and other surface flows.

"They need to move (the study) back to the headwaters where the impact will be," Kraft said. "The fact of the matter is they don't have enough information to determine if (the project) is going to cause harm or not cause harm."

Perrier wants to know by late this summer if its Big Spring wells will be approved. It plans to start construction next summer. The DNR has 65 days from the time a complete application is submitted to make a decision. Perrier submitted its application on June 20.

To go ahead with its plans, Perrier needs DNR approval for the high-capacity wells near the springs plus a high-capacity well at the bottling plant for processing water, state Department of Transportation approval for the plant's driveway access to Highway 23 and pipeline highway crossing, state Department of Commerce approval of building plans and a sanitary wastewater treatment facility at the plant and possible state Department of Agriculture, Trade and Consumer Protection licensing to operate as a food processing plant.

Adams County officials must also give their OK. That county would need to rezone the plant site and possibly the well sites from A-1 Exclusive Agriculture to I-1 Industrial, permit the pipeline along the Adams County Highway G right of way and grant a septic system permit.

The town of New Haven, where the bottling plant would be located, passed a moratorium in February on any zoning changes until a land-use study and zoning recommendations are adopted, but Adams County is not bound by the town resolutions. In March, the New Haven Town Board opposed any large-scale extraction of ground water without a full EIS and a hydrogeological study guaranteeing a well would have no impact on water flow or quality.

Perrier has made promises up front about its operation.

"As a remediation measure, Perrier has gone on record that 'in the extremely unlikely event that anyone's well experiences a demonstrable adverse impact as a result of our operations, Perrier will fully reimburse their losses,'" according to the EA.

It also agrees to follow DNR imposed operating restrictions.

"If studies/monitoring indicate any significant adverse impacts would result, Perrier has agreed not to challenge DNR authority to initially impose limits or subsequently require operational changes to prevent such impacts. Perrier has also reserved the right to challenge the reasonableness of any such operational limits as DNR may impose, as is a permittee's right," according to the EA.

Current state laws don't provide specific authority to the DNR to restrict pumping rates beyond that needed to protect the water supply for a municipal water utility. The closest water utility to the spring sites is six miles away at Wisconsin Dells. The Wisconsin Supreme Court establishes landowners can withdraw, use or sell ground water in any amount provided that it doesn't cause "unreasonable harm" to others.

In the EA, the DNR calls for the legislature to expand the department's authority to require applicant studies and to impose operating conditions to protect environmental resources in addition to municipal water supplies.

Since the 1940s, the DNR has granted about 9,500 approvals for high-capacity wells across the state, including 4,175 for agricultural pivot irrigation systems, 1,700 municipal wells and 1,128 industrial wells. High-capacity wells are defined as having combined pumping rate of 70 or more gallons a minute from one property.

The DNR will accept written, electronic or verbal public comments concerning the draft EA until 4:30 p.m. Friday, Aug. 25. Comments should be directed to David Weitz, Public Affairs Manager, DNR West Central Headquarters, P.O. Box 4001, Eau Claire, WI 54702-4001.



	Expert feels Perrier needs impact statement By BRIAN LEAHY of The Gazette A local ground water expert disagrees with the Department of Natural Resources judgment that an Environmental Impact Statement (EIS) is not needed to approve high-capacity wells for the proposed Perrier Group of America bottling plant in Adams County. "The EA (environmental assessment) was deficient," said George Kraft, director of the Central Wisconsin Groundwater Center at the University of Wisconsin-Stevens Point. Pumping tests conducted by Perrier and cited in the EA were insufficient to determine possible impacts on wetlands near spring site and stream flow of Big Spring Creek, Kraft said. "The test was not designed to measure those kinds of impacts … They were way too short and didn't have the proper instrumentation," he said. "We need to wait for the ground water model and the aquifer tests to discern what those impacts will be." DNR officials issued their preliminary determination in a draft Environmental Assessment (EA) that the planned two or more wells with a combined pumping capacity of more than 500 gallons per minute is "not a major action that would significantly affect the quality of the human environment" so a more detailed EIS is not needed. An EA and EIS both have the same content requirements, but the EIS has more details. Not including attachments, the draft EA is 52 pages long. Copies are available for review at all Regional Public Library System Resource Libraries and on the Wisconsin DNR web site at www.dnr.state.wi.us. Plans call for a Perrier subsidiary from Greenwich, Conn., Great Spring Waters of America, to use the water in its Perrier's Ice Mountain Spring Water brand marketed in the Midwest. Two or more 8-inch wells would be drilled to a depth of 200 feet in a sand aquifer. Each well would be located within 300 feet of either Jensen's Pond or Buckley Springs Pond. The wells would initially pump a combined 150-350 gallons per minute, but could increase to 500 gallons per minute within five years. A pipeline would carry the water to a bottling plant 1.75 miles away. At the end of the five-year project, the bottling plant could be more than 1 million square feet. Perrier estimates the project will cost $80 million when completed. It would employ 250 people and operate 24 hours a day, seven days a week, 365 days a year. The EA compares that pumping rate to those of an average high-capacity agricultural irrigation well which pumps at between 500-1,500 gallons per minute, a manufacturing plant well at 100-3,000 gallons per minute and a well for a food processing or dairy plant at 50-500 gallons per minute. Looking at the pumping rates without including the duration the pumps would be operating is "comparing apples and oranges" and gives "a false sense of security," Kraft said. The EA found stream flow in Big Spring Creek would be reduced by about 5 percent, but that study was conducted about two miles downstream from the springs, Kraft said. As the stream flows downstream, it receives more water from sources like drain tile and other surface flows. "They need to move (the study) back to the headwaters where the impact will be," Kraft said. "The fact of the matter is they don't have enough information to determine if (the project) is going to cause harm or not cause harm." Perrier wants to know by late this summer if its Big Spring wells will be approved. It plans to start construction next summer. The DNR has 65 days from the time a complete application is submitted to make a decision. Perrier submitted its application on June 20. To go ahead with its plans, Perrier needs DNR approval for the high-capacity wells near the springs plus a high-capacity well at the bottling plant for processing water, state Department of Transportation approval for the plant's driveway access to Highway 23 and pipeline highway crossing, state Department of Commerce approval of building plans and a sanitary wastewater treatment facility at the plant and possible state Department of Agriculture, Trade and Consumer Protection licensing to operate as a food processing plant. Adams County officials must also give their OK. That county would need to rezone the plant site and possibly the well sites from A-1 Exclusive Agriculture to I-1 Industrial, permit the pipeline along the Adams County Highway G right of way and grant a septic system permit. The town of New Haven, where the bottling plant would be located, passed a moratorium in February on any zoning changes until a land-use study and zoning recommendations are adopted, but Adams County is not bound by the town resolutions. In March, the New Haven Town Board opposed any large-scale extraction of ground water without a full EIS and a hydrogeological study guaranteeing a well would have no impact on water flow or quality. Perrier has made promises up front about its operation. "As a remediation measure, Perrier has gone on record that 'in the extremely unlikely event that anyone's well experiences a demonstrable adverse impact as a result of our operations, Perrier will fully reimburse their losses,'" according to the EA. It also agrees to follow DNR imposed operating restrictions. "If studies/monitoring indicate any significant adverse impacts would result, Perrier has agreed not to challenge DNR authority to initially impose limits or subsequently require operational changes to prevent such impacts. Perrier has also reserved the right to challenge the reasonableness of any such operational limits as DNR may impose, as is a permittee's right," according to the EA. Current state laws don't provide specific authority to the DNR to restrict pumping rates beyond that needed to protect the water supply for a municipal water utility. The closest water utility to the spring sites is six miles away at Wisconsin Dells. The Wisconsin Supreme Court establishes landowners can withdraw, use or sell ground water in any amount provided that it doesn't cause "unreasonable harm" to others. In the EA, the DNR calls for the legislature to expand the department's authority to require applicant studies and to impose operating conditions to protect environmental resources in addition to municipal water supplies. Since the 1940s, the DNR has granted about 9,500 approvals for high-capacity wells across the state, including 4,175 for agricultural pivot irrigation systems, 1,700 municipal wells and 1,128 industrial wells. High-capacity wells are defined as having combined pumping rate of 70 or more gallons a minute from one property. The DNR will accept written, electronic or verbal public comments concerning the draft EA until 4:30 p.m. Friday, Aug. 25. Comments should be directed to David Weitz, Public Affairs Manager, DNR West Central Headquarters, P.O. Box 4001, Eau Claire, WI 54702-4001.