July 13 Letter to Laurence Lynch, DNR
Comments on the “Comment Summary and Response Related to a Proposed High Capacity Well Near Mount Sterling, WI “
On behalf of the 900 supporters of Crawford Stewardship Project, I am registering our opposition to granting approval of the high capacity well proposal of Darrell Long in Utica Township. Our opposition is based on the comments made by hydrogeologist Bob Nauta and the lack of study on effects on fish and other habitat of Copper Creek.
• The experience of Crawford Stewardship Project in working with the DNR is that all applications receive approval and monitoring of approved facilities of any type is minimal. Enforcement is poor at best. “Stepped enforcement” by the DNR includes helping applicants to meet their requirements, not necessarily protecting the environment or neighbors. Fines are rare and almost always so small as to be just the cost of doing business. As Mr. Lynch said on the phone call meeting on May 10, 2011, “We (DNR) don’t follow trucks”. So now, once again, some of the monitoring would become the job of the citizens by default.
• Condition 9 calls for a monitoring well on site, but then adds, after four years of monitoring, “the owner may request approval of the Department to discontinue operation of the monitoring well”. The DNR will likely grant that request. Without the monitoring well, effects on water levels on the North Branch of Copper Creek will no longer be monitored. This should be changed to include a monitoring well required ongoing as long as the well is in operation.
• More scientific study is needed on understanding the aquifer. Bob Nauta’s questions on the validity of the EA assumptions and conclusions should be seriously addressed in the form of further study.
• The lack of study of the fish and other wildlife habitat of Copper Creek is a major flaw. This approval should not be made without serious habitat study. Independent scientists will be bringing forward concerns. But it is the job of the DNR to address this very serious resource issue. To come to the conclusion that a 14% reduction I flow of the North Branch of Copper Creek would “likely have not significant impact” without adequate study of the habitat and fish and other wildlife is guessing. We would argue that any impact is significant to a class I trout stream. To exchange Mr. Long’s economic advancement over the trout tourism economy of the community without even studying the effects is not acceptable science and could have serious economic and habitat consequences to the community.
• Given the comments made publicly by owner Darrell Long, he plans to request changes in water use to include commercial water extraction. Again, the experience of Crawford Stewardship Project is that once a facility is built, approval is a given, changes to accommodate the operator over the community and environmental needs will likely be forthcoming.
• Given that the DNR does not protect neighboring wells, the burden of proof and burden of legal actions rests entirely with individuals in the community if wells have loss of water. This makes it doubly important that all suggested scientific concerns on water use, geology, and worse case scenarios be addressed, including those from Bob Nauta. We are given assurances, but no proof that our wells are safe from effects by this proposal.
In conclusion, Crawford Stewardship Project opposes the approval of this application. The risk to the community water resources and environment far outweighs the profits and use of one out of area landowner.
Crawford Stewardship Project Coordinator