What is Happening
Nestlé Waters North America is taking groundwater near Evart, Michigan, from a sensitive area of springs, wetlands, and ponds, between the upper reaches of Twin and Chippewa Creek.
Nestlé is authorized to take groundwater at a rate of 400 gallons per minute (gpm) from a production well, and send the water to their water bottling plant in Mecosta County. This flow totals over 500,000 gallons per day, or 210 million gallons per year that will leave the watershed. Nestlé’s cost to take this water is next to nothing. What are the costs to Michiganders?
The production well is located such that Nestlé can label the water “spring water.” Groundwater near a spring is not any healthier or better tasting than any other Michigan groundwater supply, but the water’s description sounds like it is pure and natural. Federal Food and Drug Administration (FDA) requirements state that “Spring water shall be collected only at the spring or through a bore hole tapping the underground formation feeding the spring.” Taking the water directly from a spring yields a small volume of water, whereas taking water from a modern production well from Michigan’s permeable glacial aquifers next to a spring is a horse of a different color.
Impacts and Screening
The City of Evart’s community wells are located only a few miles away from the Nestlé production well along the Muskegon River. They are supplying virtually the same groundwater from the same unconfined aquifer. But the impacts are much different – the average flow in the Muskegon River is 500,000 gallons per minute, whereas the average flow from Twin Creek near the Nestlé well is 780 gpm. When a poorly located, pumped well removes 400 gpm from an unconfined aquifer, the result is a taking of close to 400 gpm from the springs and streams nearby.
The impact includes streamflow depletion, which affects fish and their food. The FDA rules basically require water bottling companies to negatively impact our sensitive water resources. To use an analogy, what if a company came and took 90% of your home water supply, instead of taking that same volume from the city water system? You would not be happy.
How then do we determine if a large well causes an unacceptable impact? The first step is to utilize the State of Michigan’s Water Withdrawal Assessment Tool. This is a supposedly conservative tool to determine whether a withdrawal will cause an “adverse resource impact.” The tool is required for large quantity withdrawals of over 100,000 gallons per day.
If the withdrawal fails the screening tool, a company can still do a site-specific review that provides a better picture of the water resource setting. These site-specific investigations include a field investigation, and complicated computer models, which are subject to error, especially in headwater stream areas. Interestingly, when Nestlé completed this site-specific review in the area near Evart in 2016, Nestlé’s very own report showed that the actual gaged stream flows for Twin Creek were only 36% of the Index Flow (summer average low flow) predicted with the tool, and the gaged flows for Chippewa Creek were 270% higher than the Index Flow predicted with the tool. What does this mean? The tool is not as accurate as needed, and results from sophisticated investigations, although more accurate, are still susceptible to significant errors.
The FDA rules basically require water bottling companies to negatively impact our sensitive water resources. To use an analogy, what if a company came and took 90% of your home water supply, instead of taking that same volume from the city water system? You would not be happy.
What’s a solution? Why don’t we just prohibit the taking of a large quantity of groundwater from near these headwater streams?
Aside from the larger bottled water debate, one thing is very clear to me: Nestlé is taking too much of Michigan’s groundwater, in a precarious and sensitive location. Instead, groundwater taken close to the Muskegon River would minimize the impact to the entire watershed, and reduce the uncertainty of the computer modeling. While this water could not be labeled “spring water” under the FDA definition, it might be a compromise that the citizens of Michigan would be more willing to accept alongside other stringent environmental precautions.
About the author – Bob Otwell is a hydrologist, civil engineer, and founder of Otwell Mawby engineering in Traverse City. Bob has been a member of the FLOW board since 2013.