John Emerick, Ph.D., Professor Emeritus of the Colorado School of Mines, Division of Environmental Science and Engineering gave comments before the Chaffee County Commissioners at the recent Nestlé public hearing. His unedited comments appear below:
I would like to thank the commissioners for this opportunity to comment on the Nestle Project 1041 Application, as well as on other documents related to this application and in review of it. While at the Colorado School of Mines, most of my research activities and much of my teaching duties were related to wetland ecology, geochemistry, and hydrology.
Therefore, I want to focus mostly on the wetland part of the application.
I have three topics: wetland quality and composition; impacts of water withdrawals on wetland sustainability; and climate change.
Topic 1: Wetland quality and composition
There are a handful of small wetlands along the Arkansas River in the project area, with the largest being the #2 wetland in the Bighorn Springs area. This is also the only one of the wetlands that the Nestle consultants have classified as “high” quality.
Now, I have not personally been to these wetlands, but I am familiar with other wetlands of roughly similar settings a short distance across the river, that is, on a glacial outwash terrace. Those wetlands have probably been in existence since early post-glacial times, which means that they are perhaps 10 to 12 thousand years old, judging from the accumulation of peat in the soils. They harbor at least 1 state-ranked plant species that I know of, and we may know more once CNHP’s Chaffee County report is released.
I don’t know if wetland #2 has peat soils (the application wasn’t that detailed) but I suspect it does, with my clue coming from Geomega’s review of Nestle’s Draft Wetland Monitoring plan, where they mention peat soils. If peat soils are present, and over a foot or so thick, then these wetlands, also could be of the same age as the wetlands across the river, perhaps 10 to 12 thousand years old. They could also harbor rare plant species, but none were found. Why?
Perhaps none exists; however, the consultant’s methods don’t appear amenable to the conduct of an appropriate search. The wetlands were apparently delineated using standard USACE methods which require identification of only the dominant species to determine whether the wetland is subject to the jurisdiction of Section 404 of the Clean Water Act.
The methods are inappropriate to developing a comprehensive list of species or to provide the sort of quantitative data for use as a baseline and monitoring purposes. Furthermore, this field work was apparently done during a three-day period from April 30 to May 2, 2008. During that part of the season, plant growth probably would not have been sufficiently advanced to allow proper identification of many of the plant species that grow in these wetlands. (And as an aside, several breeding bird species might not yet have been present as well. Their bird list is a bit skinny).
The point is that these wetlands may well be special, but we won’t know how special until a more comprehensive investigation with qualified botanists is done. I recommend getting a crew in from the Colorado Natural Heritage Program this summer to do a full evaluation.
Topic 2: Impacts of the proposed water withdrawals on wetland sustainability
I am skeptical of the applicant’s conclusions that the wetlands will be minimally impacted by the withdrawals. I think a similar skepticism is also reflected in the reviews by Wheeler and Geomega. We don’t really know how these wetlands function, and to what extent the species present are tolerant of fluctuating groundwater discharges. It is the groundwater discharge, of course, that these wetlands depend on.
First, there needs to be sufficient baseline hydrologic information from the wetlands themselves prior to the startup of Nestle operations. I would start by installing monitoring wells in the wetlands. My review of Nestle’s Wetland Monitoring and Mitigation Plan indicates they intend to do this. (This may be one of the few things I agree with in the plan). The wells are called piezometers, and they are small diameter wells that, if enough are properly installed and monitored, they will tell you the depth to the water table, how it fluctuates, and what direction it is moving. These things are cheap, usually a 2” diameter PVC pipe. I would put several in each wetland (not just 7-10 suggested in their Plan).
I would monitor them for two full hydroperiods (two years) BEFORE commencement of commercial pumping operations. Once baseline conditions are established, conduct sustained pump tests of ca. 140 gpm for at least 5 days during the period of lowest discharge of the springs. Then we would have a much better idea of the hydrologic impact of the proposed operation. The piezometer field should then be retained for later monitoring purposes.
Regarding monitoring of the wetland plant communities. Nestle should forget using the USACE delineation methods for long-term vegetation monitoring. In my mind, that is a rather naïve selection of methods and there are more appropriate techniques out there. I won’t bore you with the details of technical alternatives, but suffice it to say that they need to use methods that are better matched to the vegetation types they are dealing with, and the objectives of a long-term monitoring program. The bottom line is that we need to have a better idea of the species present, and how they respond to fluctuating hydrology.
I think they should also permanently stake the existing margins of the wetlands to make it easier to monitor fluctuations in wetland margins over time, should they occur due to changes in hydrology.
So, install a field of piezometer wells in all the wetland areas, monitor them for 2 years, then conduct longer, sustained pump tests; use more appropriate vegetation monitoring methods, and stake the existing wetland margins.
Finally, Nestle needs to come up with a set of criteria that defines how much degradation of wetland hydrology or vegetation is allowed before mandatory cessation of pumping activities should occur. Depending on the species present, these criteria may need to be fairly conservative.
Topic 3: The inconvenient truth: Climate Change
Colorado Natural Heritage Program, in their review of the Nestle application, recommended that the county and Nestle Water view this proposed project in the context of climate change. I couldn’t agree more. Lots of reputable scientific organizations and a growing host of really smart scientists around the world tell us that climate change is not only a possibility, but that it is a reality. CNHP’s review refers to climate trends in the Arkansas Valley that, if they continue, may well be inconsistent with the assumptions of this application.
Now, as smart as those Scientist guys are, no one really knows what the eventual result of climate change will be. I’m sure there are some here who believe that no applicant, including Nestle, should be held hostage to someone’s climate change scenario, which is only a prediction, albeit with lots of solid data.
However, there is a way to get around this. In the project area, you have a groundwater system that may be amenable to the development of a hydrologic model that accurately depicts the system’s boundary conditions (e.g. provides a reasonable prediction of the discharges, given withdrawals and recharge rates).
There are a few hydrologists out there who are capable of developing such a model that eventually could provide insight as to what might happen to the system’s hydrology (including its wetlands) given various climate change scenarios. This is not rocket science, though it could be close. But it is a tool that is becoming increasingly common.
The timing might work out. During the two years of wetland monitoring, a hydrologic model could be developed and tested, though a few more wells might be needed to fully understand aquifer characteristics.
In the absence of this type of proactive approach to assessing the impact of climate change, I would recommend a really conservative path in your actions on this project.
I guess the bottom line is this. During times of economic uncertainty, lots of us become more conservative in the management of our finances. During uncertain climatic times, government might do well to be conservative in the management of its natural resources.
Thank you for your time and consideration.
Thanks to John Graham of Chaffee Citizens for Sustainability for forwarding these comments.
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