Wednesday, March 16, 2016

So why should we object? Many reasons... For many of us, the dropping of the well levels in the area are only the tip of a very large iceberg...

Some folks from Many Lakes said this on their DNRC Form 611.  Link to DNRC Form 611

Criteria 3. Adverse Effect.
  • We feel that the analysis to determine no adverse impact has been insufficient. The modeling methods used are old and outdated. We suggest you look at data from at least 3 different models to determine impacts to the surrounding area.
  • The list of affected wells includes only one well under 100'. We believe there are potential impacts on wells in the area, and the shallower wells should not have been omitted.
  • Adverse impacts are not limited merely to area well levels. The groundwater in the Many Lakes Community is very closely tied to lake levels and local wetlands. As our groundwater drops, so do our lake levels. Differences as small as four feet show dramatically in lake level fluctuations. As our lake levels drop, nursery habitat for fish populations is eliminated, wetland habitat is degraded, and our property values drop correspondingly.
  • Evidence from the well-log and water pump test suggest the well is not located in the deep aquifer as suggested in the permit. It appears it is in an intermediate aquifer connected to the shallow aquifer. Clear and convincing evidence that the well is in the deep aquifer has not been provided.
  • We are concerned that the permit includes no thresholds for ceasing operations should it be found that unanticipated adverse impacts occur following issuance of the permit.
  • The proposed water use is not comparable to the Creston Hatchery use or agricultural use that are permitted to draw similar acre-feet per year. Agricultural permits use only about 25% of their allotment in a typical year. Also, the water pumped is used on site and drains back into the same aquifer or condenses into clouds that generally precipitate in state. This proposal is to remove more than 200 million gallons of water per year and ship it out of state. In no way, should this be considered a beneficial use for the citizens state of Montana.
  • We are one year into an El NiƱo cycle and may be facing unprecedented drought conditions in the coming years. We suggest that before issuing a 710 ac-ft permit that removes the bulk of the water from our region, that you include the potential for climate variability in your modeled recharge rates. Keep in mind that all glaciers in the Flathead Basin headwaters are predicted to melt in the next decade or two, decreasing the reliability of aquifer recharge rates in coming years. This is not a time to sell our limited water resources out of state.
  • No general data or analysis has been provide to the public that demonstrates that no damage would occur to existing wells and groundwater fed lake and wetland systems. You have also failed to conduct and provide the public with a detailed environmental assessment that provides a comprehensive study of possible impacts with adequate notice for a comment period. The Environmental Analysis prepared by DNRC is woefully inadequate. At a minimum, the EA should meet standards for the Montana Environmental Policy Act, and we request that it be submitted to the public for at least a 30-day comment period.
  • We object to the wording on DNRC form 611, that limits objections merely to impacts on groundwater wells. In this particular instance, the issue is much bigger, and the potential for adverse impacts extends far beyond a simple water right.

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