I’m Tom Brennan, the Project Development Manager for Nestlé Waters North America. On this section of the site, I will be posting some of the most interesting questions from those I’ve received at Dear Tom, along with my answers.
My goal for this effort is to correct, clarify and comment, as well as answer your questions as directly as I can.
Q. What, if any, considerations has Nestle and the Town of Clinton given regarding the findings of the Nashua River Watershed Association\'s review of the Wekepeke aquifer done as part of its 5-year plan, which states:
"Additionally, there is concern of potential negative impact on Wekepeke Brook from potential increased aquifer withdrawals"
A. During peak operations at the Clinton Water Works, the Town of Clinton withdrew in excess of 1 million gallons per day from the site.
The proposed withdrawals will be less than 25% of those historic volumes.
Identifying potential impacts on stream flows was a major component of our 15 day pumping test and streams in the area will be monitored during the operations at the site to ensure that there are no significant impacts.
Q. Also, any further development of the Wekepeke Aquifer - from residential septic systems and farming operations could affect the Town of Lancaster's well near the North Nashua River. Note that Lancaster does have a Water Supply Protection District By-law."
A. No septic system will be installed on the Clinton Water Works property as part of our proposal. In addition, the Town of Clinton owned land will be protected by a conservation restriction which will further limit residential development in the area.
Q. What, if any, considerations has Nestle or the Town of Clinton given to the Aquifer and Watershed Overlay District Bylaw enacted by the town of Sterling
in 1993?
A. The Town of Sterling’s Aquifer and Watershed Protection Overlay District establishes land use restrictions in certain designated areas in the Town of Sterling to protect the quality of underlying ground water. This by-law does not prohibit water withdrawals. Actually it complements the Nestle Waters proposal by advancing one of our own core objectives: protecting the quality of groundwater resources.
Q. The legislation which authorized the Town of Clinton to acquire the Wekepeke (Chapter 14 of the Acts of 1882) refers to an earlier special act (Chapter 14 of the Acts of 1882) which states that the original purpose of the acquisition was to allow Clinton to “supply itself and its inhabitants with pure water to extinguish fires, generate steam and for domestic and other uses ….” Does this legislation prohibit the sale of water to Nestle Waters?
A. No. The legislation authorizes Clinton to acquire the lands in Sterling to supply itself with water for unlimited, “other” uses. The legislation does not restrict Clinton’s choice of customers for its water.
Q. How can the Town of Clinton “own” the Wekepeke aquifer when parts of that aquifer are under properties owned by the Sterling Land Trust and by
private citizens?
A. In truth, no one person “owns” the water in an aquifer. But each owner of land over an aquifer has the right to withdraw water from the aquifer in a manner that is consistent with other existing uses of the aquifer and with applicable permitting requirements. Nestle’s pump testing results indicate that its proposed withdrawal quantities fall well within Clinton’s rights to withdraw water from its Wekepeke lands.
Also, Nestle’s proposed withdrawals will need a water withdrawal permit from MassDEP, which will set withdrawal limits and monitoring requirements designed to ensure that the withdrawals do not adversely impact other users, nearby streams, or the aquifer itself.
Q. Existing legislation does not permit any water to be withdrawn for any purpose other than its supply to Clinton and its inhabitants as a municipal water supply. In addition, the land in question is not even zoned for this purpose. Why would Nestle respond to an RFP issued by the Town of Clinton, knowing this to be the case?
A. As indicated in response to Question XX, the legislation that authorized Clinton to purchase the Wekepeke lands for the purposes of water supply does not restrict Clinton's choice of customers for the water.
Clinton's use of those lands as a water supply long predate Sterling's zoning bylaws, and Sterling's zoning by-laws do not regulate withdrawal of ground water. Under Nestle's proposal, all water withdrawn from the Wekepeke lands will be transported through Clinton's existing pipeline to a loading station located in a commercially or industrially zoned district along the pipeline.
Also, a response to Clinton's RFP by Nestle will include conditions that its purchase of water from Clinton will proceed only if all applicable permits are obtained.
Q: "Results yielded approximately 105 total gallons per minute, which, according to Northeast Geoscience Inc. hydrologist Jay Billings, is below expected standards." When you couldn't get the desired 350 gpm you logically attempted lower and lower rates until you reached stability at 105 gpm. How then can you can extrapolate the number for higher permit rates and intended rates of 180 to 200 gpm based on mathematical modeling methods. Commentary: I have seen careers ruined over extrapolations and erroneous modeling techniques.
Second part of the question, what rate did you pump at when you failed to get 350 gpm? Why can't you run your tests at the rates that you want to pump?
Private wells: How can you state that they will not be affected when you don't know their depth. All wells are not deep wells. The number of houses and wells that have been built since 1964 are considerable so the old Clinton consumption comparisons are not valid as to what affect they will have on new residences that were built since then. I have seen neighbors put in wells of extreme varying depth before they hit water when they are within 200 ft of one another.
A: Prolonged pumping tests are typically conducted with smaller diameter test-boreholes. These test-boreholes are temporary and provide a practical method to estimate the yield and water quality characteristics of the aquifer using tried and true hydrogeologic techniques. In addition, these data also enable us to design the most efficient final borehole configuration.
The 350 gpm rate was the maximum rate we estimated this portion of the aquifer might yield based on information available without any test wells. After reviewing the yields from the test-boreholes, the final pumping rates were selected for the 15 day pumping test and, as expected, were lower than that initial maximum rate. - The data collected from the 15 day pumping test were then used to estimate the yield of the larger diameter production-boreholes.
The test-boreholes do not have sufficient yield to pump at the final rates we can expect from the production-boreholes due to their smaller diameter and to the borehole design and construction techniques.
The boreholes withdraw water from the upper 40 feet of the sand and gravel aquifer, which is located above the bedrock aquifer. Nearly all the private wells in the area withdraw water from the deeper bedrock aquifer. As a result, these boreholes would run dry long before any impacts were observed in the private wells.
Also, to sell water from the boreholes as spring water, federal rules mandate that the springs at the site must continue to have a surface flow at all times. In the event of any overpumping by NWNA, these springs would stop flowing and pumping by NWNA would cease long before the private wells were impacted.
Q: Dick Sheppard of the Sterling BOS has several times in my hearing hinted that if Nestlé is allowed to pump water from the Wekepeke Aquifer located in Sterling, that the Town of Sterling might well benefit from that deal (eg, possibly our real estate tax would be lowered by $200 per family per year.) When I met with you I asked about what benefits Sterling might expect from such a deal, and you said possibly the dams in the Wekepeke would be repaired and/or maintained, and that the pending CR might be finalized.
Is there any more that Sterling might realistically hope for other than the dams and the CR, or is Dick Sheppard being unrealistic? If there is more, what might it be and how likely would that be? Would you be willing to make a public statement to that effect and to put it in writing?
A: The short answer is yes. Nestle Waters is an active, contributing member of the communities in which we have a presence. As this process moves along, we look forward to working with Sterling town officials to develop a municipal host package that we expect would include significant annual benefits to Sterling.
Q: I have a well on my property that I paid a lot of money for. If Nestlé gets to pump the Wekepeke Aquifer and my well goes dry, what will Nestlé do for me? I do NOT want town water, I want my own well. Will Nestlé re-drill private wells that are over the aquifer if they go dry after Nestlé starts pumping?
A: We are confident our proposal will not dry up any wells-not the wells we would install at the Wekepeke, nor the wells of any neighbors. Our whole approach to spring water resources is to maintain their quality and sustainability. The bottom line is we must be protective of the spring water resource and operate in a sustainable manner. That being said, we would go the extra mile and sign written well protection agreements with neighbors who have concerns. We have signed similar agreements in other parts of the country.
Q: I don't understand how you say your drawing 240,000 gallons a day will not impact the environment or ground water tables. in Oct. of 2007 I was walking the shoreline of the upper & lower reservoir and I was walking 10 -12 feet below where the springtime water level is.This is without drawing any water from the reservoir. You seriously want the public to believe that this will have no impact? I personally think this is no ones interest to run any part of this system dry. I have no doubt that 240,000 gallons a day will seriously impact the reservoirs and streams along with the fisheries and wildlife habitats involved.
A: In the late summer and early fall of 2007, the Town of Clinton Department of Public Works lowered the water level in Lower Lynde Basin (by use of a siphon) to make repairs to the Lower Lynde Dam as directed by the Massachusetts Department of Conservation and Recreation Office of Dam Safety. Once the repairs were made the siphon was removed and the water level returned to normal.
Q: How do you envision the contract between Clinton and your firm will be worded regarding the ownership of any land, water, etc. and under what circumstances Clinton could cancel such a contract? I'm greatly concerned about the world wide trend of the privatization of water supplies by multi-national corporations such as yours, Coca Cola, and others.
A: The Town of Clinton has not completed its RFP process and Nestlé Waters does not yet know if the Town will decide to enter into a water sale agreement, or under what terms. We can confirm that under our proposal, the Town of Clinton will continue to own the entire Wekepeke site; NWNA wants simply to become a water customer of the Town.
Q: Isn't the comparison of "gravity fed surface water at 1.2 million gal/day" with pumped spring aquifer at 240,000 gal/day" water misleading and incorrect? And in fact you are pumping 240,000 gal/day which exceeds the only stable results that you could achieve during your tests, namely 151,000 gal/day.
I therefore think you should retract the comparison and correct that in print. If Clinton had been pumping 1.2 mm gal/day spring fed water then you could make the comparison, or if you were planning on pumping 240,000 gal/day of surface water then it follows. By your own comments in the meeting you don't even want pump at lower depths for fear that the water would need to be purified, so why make the comparison in the first place?
A: Nearly all of the surface waters at the Clinton Water Works, including Wekepeke Brook, are fed by groundwater discharge which comes to the surface in the form of "springs". The best example of this concept can be seen during dry periods when the streams continue to flow even though there is no rainfall. Spring water is groundwater that comes to the surface, but the through the use of boreholes the spring water is intercepted before it come to the surface which eliminates the need for filtration and other means of treatment. In addition, since all of the reservoirs and streams are fed by groundwater discharge, the historic withdrawals can be considered spring water. We hope that this clarifies any misunderstanding.
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