TO: Brian Underhill, Executive Director, Agricultural Land Commission

RE: ALC File 36081 (Strachan) and File 51632 (Brown)

Dear Sir,

At the board meeting on Aug. 28, Gabriola Groundwater Management Society (GGMS), unanimously voted to request that the Agricultural Land Commission (ALC) not renew any permit to pump bulk groundwater for commercial sale from the Agricultural Land Reserve (ALR) land on Gabriola Island. We also ask that with the lack of permitting the regulation against bulk groundwater pumping for commercial sale on ALR land be enforced.

GGMS has a position on bulk groundwater pumping for commercial sale and we present that position here:

Submission to the Gabriola Local trust Committee, the Official Community Plan review, June 24, 2010

GGMS POSITION on Bulk Groundwater Extraction

1. The first requirement for a permit for Bulk Groundwater Extraction is an independent assessment of the subject location for ground water availability by an independent, registered, professional engineer/geohydrologist who has a proven history of planning a community water supply and who has liability insurance to cover potential damages or shortfalls.
2. The perimeter limits of the subject aquifer shall be delineated by a similarly qualified professional engineer/hydro-geologist.
3. A dedicated monitoring well shall be in place on the subject aquifer for a minimum of one year before bulk groundwater extraction can take place. The monitoring well shall be capable of recording daily baseline groundwater/aquifer levels and these shall be recorded in a log. This log shall be a reporting tool to the agency that oversees the extraction permit.
4. All residents shall be notified one year in advance of application to extract bulk groundwater, to provide existing residents an opportunity to establish pre-existing groundwater conditions in their residential wells.
5. No single-source bulk groundwater extraction shall be permitted as a long-term supply.
6. Until these issues are satisfactorily resolved in the Islands Trust Area, emergency deliveries of bulk groundwater shall be supplied from existing municipal sources on Vancouver Island in order to protect the sustainability of gulf island aquifers.
7. For sustainability issues regarding food security there shall be no bulk groundwater extraction from the ALR for non-agricultural use.

Submitted by Jeremy Baker, GGMS Board

RECOMMENDATIONS:

Bulk groundwater extraction for sale should not be an approved practice in the Islands Trust area.

There should be no bulk groundwater extraction from the Agricultural Land Reserve for non-agricultural use.

This is in line with the Islands Trust policy as stated below, a quote from their submission to the Water Act Modernisation in 2010.

“Summary of Issues and Recommendations Relevant to the Islands Trust Area, Surface water/Groundwater, April 2010”

“Issue: Groundwater and surface water are interrelated and need to be treated as such, including regulation and licensing of both groundwater and surface water as one system.

Recommendation: Integrate the management of groundwater and surface water. Avoid conflict by updating the water allocations system. Move beyond first-in-time-first-in-right system to a system that promotes conservation, discourages overconsumption, and prioritises water for ecosystems, functioning watersheds, and basic human needs”.

It is also in line with Islands trust bylaw 232 e) ii) ‘The applicant must provide a report prepared by an independent qualified professional with experience in groundwater hydrology to the satisfaction of the Gabriola Local Trust Committee identifying the zone of influence, stating that the property is capable of producing the stated amount of water with no detrimental effects on wells within the zone of influence, the aquifer and the natural environment.’

Based on these two positions we ask again that no permit to pump bulk groundwater for commercial use be issued on ALR land on Gabriola and that the cessation of this activity be enforced.