February 16, 2017
To: Heidi Grether
Director, Michigan Department of Environmental Quality
P.O. Box 30473, Lansing, MI 48909-7973
Governor of the State of Michigan
P.O. Box 30013, Lansing, MI 48909
From: Michigan Citizens for Water Conservation
RE: Nestlé Permit for Production Well PW-101, WSSN20166-67
White Pine Springs Site, Osceola County
WE are formally requesting an extension of the comment period for permit for PW 101 in Osceola County and a moratorium on further withdrawals from this well until at least July 1, 2017 for the following reasons:
1. Citizens have not had sufficient time to respond to the impact of the increased withdrawals made from the well since January of 2016 under an incorrectly drawn permit.
2. Citizens have not yet received the extensive FOIA-requested information from the MDEQ and therefore have not had access to the information needed to carefully evaluate the Nestlé request to increase pumping from 150 gpm to 400 gpm.
3. Numerous flaws in the permit and inaccurate Nestlé-supplied data on the present impact of withdrawals demand that citizens be given more time to gather real time data and independent environmental assessments.
4. No public hearings have been scheduled to date and citizens are requesting that there be at least 6 of them around the state because Nestlé water takings are a state-wide issue of concern. At minimum, there must be a hearing in Evart with time given for the community to assess real data beforehand. Further hearings are requested in Flint, Detroit, Muskegon, Traverse City, and Sault St. Marie. Michigan Citizens for Water Conservation
5. Nestlé is in the process of buying further land use agreements in the area near the PW 101 well, apparently preparing to drill three more wells to feed into the currently unused 8” pipe running parallel to the 5” pipe in use from PW 101. Nestlé has yet to acquire the necessary permit for a booster station from the township, an issue that is on hold until at least April. Affected citizens have only recently become aware of these additional plans, with no time to hold public comment.
6. Nestlé may be attempting to cover up evidence of current damage to the streams in the area by offering at a township public meeting to replace culverts and “fix” easements for the township. Since the Water Assessment tool was applied and scored a D, we would like to see the results of the sitespecific review before Nestlé is allowed to alter any evidence of damage.
7. The only stream monitoring and environmental impact assessments MDEQ appears to employ in the decision for permitting are those conducted by
Nestlé. Citizens expect that independent study must be employed. Specifically, we request that a species inventory be conducted by the US Fish & Wildlife Service or at least the MDNR. We also request that future monitoring be done by the USGS and that such monitoring agreement be in place before any permit be considered.
8. Citizens have not been given the data requested on the actual withdrawals from this well since the improper increase of January 2016 from 150 gpm to 250 gpm, and therefore do not know how much water Nestlé took from the well which must be returned to the aquifer by a halt to withdrawal. We are requesting an immediate halt to withdrawal from this well until it is properly permitted.
Board of the Michigan Citizens for Water Conservation
Peggy Case, President
Jeff Ostahowski, Vice-President
MCWC, P.O. Box 1, Mecosta, MI 49332