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E-M:/ Michigan and Water Issues

Enviro-Mich message from "shirt sleeves" <ssleeves@hotmail.com>



Once in full production, Perrier will pump somewhere in the league of 24 
hours - 7 days per week, with occasional breaks ("Weekly 12-hour shut-down 
for routine maintenance and prevention activities," Perrier Presentation 

(What exactly are "maintenance and prevention activities"? What type of 
"maintenance and prevention activities" will an operation with many wells, 
and many miles of water distribution systems (4-10 miles of piping, 
depending on siting of the Bottling Plant) need? Where will the treatments 
and wastewater be discharged? These are unanswered questions. Do the 
Permitting and Zoning staffs know yet?

In a letter from Mr. Ron Schumacher, RS Type II Manager, District Health 
Department #10, to Mr. Shane McDonald, Malcolm Pirnie, Inc (Perrier's 
contracted hydrogeologic firm), dated January 11, 2001, Schumacher states, 
"All chemical processes to the service line piping and/or source water need 
to be provided to Cynthia Weaver, MDEQ-DWRPD. The chemical MSDS, operation 
procedures, employee instructions, log sheets and frequencies of such 
chemical treatments shall be forwarded to MDEQ. The details of 
"passification" of the service line piping was requested by MDEQ from Mr. 
Rod Allen on July 14, 2000 and December 13, 2000."   Note: "passification" 
is the chemical process that Perrier has told MDEQ it will use in its 
operation's cleaning. According to this, MDEQ requested "passification" 
details from Mr. Rod Allen, Perrier Natural Resource Manager-Midwest, on 
July 14, 2000 and December 13, 2000. The Schumacher letter was written 
January 11, 2001, apparently MDEQ still lacked the information on 

MDEQ requires a 72-hour pump test for permitting an operation like 
Perrier's. I am proposing that we need to look closely at the MDEQ's 
requirements for permitting an operation of this sort.

I propose that actual production pumping be considered a "test", of sorts, 
as well. A "test" that we decide fits our criteria, not Perrier's. In other 
words, the production pumping could be considered forever under the scrutiny 
of a panel of independent experts and concerned citizens. The production 
pumping could be subject to necessary adjustments due to findings, whether 
those findings are anticipated or not. This informed scrutiny could carry on 
throughout the life of the operation, and beyond, as deemed necessary.

I am not a modeller. I have heard that many of the "results" of modelling 
hinge on the quality and quantity of the data from which you are 
extrapolating. I have also heard that modelling is an art, with much leeway 
in many directions. Professionals in the business of modelling know that 
results based upon much number crunching can easily be manipulated. The 
element of time has tremendous impact upon calculated extrapolations. This 
is where and why long-term review by independent experts and concerned 
citizens is of the essence.

Predicting long into the future; seasonally, annually, on into the decades 
must be a trick when based upon three days (72-hours) of required/regulatory 

If any Corporation could afford "exhaustive" testing to fully reassure 
communities and their governing bodies of potentially sustainable levels, 
Perrier can. If any company could afford to possibly be tempered by 
long-term monitoring, Perrier can. According to a memo written by Dennis L. 
Schornack, Special Advisor for Strategic Initiatives for the Office of the 
Governor, to Michigan Governor John Engler and Sharon Rothwell, Chief of 
Staff for the Office of the Governor, "Perrier stands to clear $0.5 - $1.8 
million/day." (This same memo was cc'ed to Matthew Hare, Environmental and 
Natural Resource Policy Coordinator for the Office of the Governor, and Doug 
Rothwell, President of the Michigan Economic Development Corporation.)

Here is one full paragraph quoted from the September 25, 2000 Memorandum 
from Dennis L. Schornack to Governor Engler, and Sharon Rothwell (obtained 
through a Freedom of Information Act request), "The bottled water industry 
is highly profitable. Using industry figures (IWBA) for production costs 
(6-11 cents/gal) and retail prices ($3/six-pack of 24 oz bottles) for "Ice 
Mountain," the label Perrier uses for the Midwest, Perrier stands to clear 
$.5-1.8 million/day. Profitability is directly related to the price paid for 
the raw material, which in this case, is free."

Perrier has publicly stated: "Initial investment - $60,000,000 with 
pipeline, plant and machinery", and, "Full build out investment over 
$100,000,000" (Perrier Presentation Handout, dated September 2000). $60-$100 
million to establish their operation in Mecosta and/or Osceola. Once in 
production, it may not be long before Perrier has paid off this price tag.

If Perrier can "clear $0.5 - $1.8 million/day" they are going to want to 
stay in full-scale operation as long as they can. Maybe even regardless of 
the shape and condition of the aquifers. Every day in production they stand 
to benefit big. Looked at in another way, Perrier can easily make it's 
stash. We might not be able to easily get Perrier to stop making it's stash, 
regardless of the cost to anybody or anything other than them. At this 
point, and with our statutes, what reassurance do we have that they will 
temper their operation in the face of declining aquifer and/or other natural 
system health (for eg, surface water bodies)?

Adequate study is lacking for our State's water resources.

""We're in a hole as far as our knowledge is concerned," Kincare said, 
"We've not had the money or the people to adequately map the state's glacial 
aquifers."" (Andrew Guy. The Paper. November 30 - December 6, 2000. page 8.) 
Kevin Kincare is a glacial geologist with the Michigan Geologic Survey.

If any Corporation could easily afford more thorough studies, possibly even 
contributing to greater understanding of our groundwater and surface water 
resources, it would certainly be Perrier.

If any Corporation could afford to guarantee the communitites and governing 
bodies of a longterm, safeguarded natural and cultural resource, Perrier 

According to Kim Eaton Jeffery, President CEO The Perrier Group of America, 
"Revenues at the Perrier Group will surpass $1.7 billion in 2000. We own 5 
of the top 10 brands in America and control 31% of all bottled water sold in 
America. In 1996, 1997, 1998, and 1999 The Perrier Group represented over 
40% of total industry growth thereby gaining 7 market share points through 
organic growth generated by a deep understanding of the category and where 
growth would come from."

Michigan Economic Development Corporation's "Governor's Briefing Memo : 
Perrier USA : April 6, 2001" Memo states, "Incentives to be offered will 
only include property tax abatement, job training and possible public 
infrastructure improvements." This may be part of Perrier's attraction to 
the Michigan area.

According to Dennis L. Schornack in the 9-25-00 memo to Governor John 
Engler, "Perrier does not enjoy a good reputation for environmental 
management; e.g., it is not ISO (Industrial Standards Organization) 14000 
certified. The ISO 14000 is the basic industry standard for environmental 

Continuing with exerpts from the Schornack to Engler and S. Rothwell 
memorandum, "Water is held by states in public trust, i.e., states act in a 
fiduciary capacity. Giving water away to a private firm so it can profit has 
been peddled as a breach of the public trust. Citizen concerns about adverse 
impacts on their own wells and the streams and wetlands fed by the spring 
also rank high. The fact that Perrier defended its right to extract water in 
Texas, despite nearby farmers' wells drying up, all the way to the Texas 
Supreme Court is used as an example of their ruthlessness. Under the Texas 
common law rule of capture, Perrier won because, according to the Court: In 
Texas, "The guy with the biggest straw wins." The Court stated it didn't 
like the outcome of its decision, but it wasn't in the business of writing 

What kind of long-term, guaranteed protection can the State of Michigan 
offer it's residents? Once Perrier is in and pumping for production, what 
will happen if impacts are found with ground water or lake levels? Who will 
be protected, Perrier's operation or our natural resources held in public 
trust by the State of Michigan?

Will we some day see legal battles in courts of law, with no Michigan laws 
standing behind residents? Will Perrier simply win because they're bigger? 
Is anybody in the business of writing laws interested in this theoretical 

>From the WI example below, which is not Mecosta or Osceola mind you, it is 
obvious that impact showed after a 72-hour span. What will happen in either 
Mecosta or Osceola long-term? Could any pump test adequately anticipate 
impacts five-ten-fifteen years on down the road? Is Perrier concerned about 
sustainability, or will they simply move on out of the Mecosta and/or 
Osceola sites to others, elsewhere?

Will Perrier be stuck with any potential long-term impacts, or will we?

Will they simply move on to another attractive economic opportunity? Will 
another township be courted, approached with an economic opportunity?

Nobody knows, nobody can quite know right now.

The Zoning and Permiitng staffs have little power to slow anything down to 
try to take a closer, longer look. We do not yet have the Zoning and/or 
Permitting infrastructures to properly slow a process down. This is 
problematic. Perrier certainly has the upper hand in this regard.

(gpm = gallons per minute, gpd = gallons per day)

We have yet to hear definitive answers to exactly how much water will be 
pumped from each site, and/or if they will all be pumped to the same one 
plant site. (Though the Michigan Economic Development Corporation's 
"Governor's Briefing Memo : Perrier USA : April 6, 2001" Memo did state, "If 
Mecosta Township is selected as the processing facility, water drawn from 
Osceola County springs would be transported there by tanker truck.") I am 
going to assume that just like in other parts of the country Perrier will 
draw from many different well sources, something that Perrier has neither 
fully acknowledged nor fully denied, even when asked. And using the closest 
numbers that anyone has been able to gather for each potential location 
(from Perrier's words or publications, MDEQ Freedom of Information Act 
requests, or Bottling Plants elsewhere in the country), if Sanctuary 500 
gpm, if Spring Hill 300 gpm, and if the plant 200 gpm, then we've got a 
potential total of 1000 gpm. This could total 1,440,000 gpd.

1,440,000 gpd is twice the figure that Perrier has been publicly talking for 
Mecosta/Osceola! (Because they have not yet addmitted nor denied the 
possible combination of multiple sources, nor the quantity extracted at the 

This figure does not include the weekly 12 hour shutdowns, which daily would 
factor out to about 1.7 hours/day (12 hours divided by 7 days = 1.7 
hours/day. About 120,000 gpd less due to shutdowns. Daily extraction, taking 
weekly shutdowns into account, would be approximately 1,320,000 gpd.

Perrier has not yet committed total production levels to paper. No formal 
documented agreement on actual full build-out QUANTITIES. Correct me if I'm 

(Through Freedom of Information Act requests, I have found that two MDEQ 
sources have handwritten notations suggesting a 900 gpm extraction rate at 
just one well site. A single site extraction of that scale would just about 
hit the million/day mark alone, regardless of other potential site sources.)

If you have any comment whatsoever regarding the MDEQ's processes, the 
Michigan legal system, or this Perrier project in particular, let it be 

John Engler, Governor
P.O. Box 30013
Lansing, MI  48909
telephone: 517-335-7858
e-mail: follow "Contact the Governor" prompt at www.migov.state.mi.us.

Levin, Carl  (D - MI)
(202) 224-6221

Stabenow, Debbie  (D - MI)
(202) 224-4822

Russell Harding, Director
PO Box 30473
Lansing, MI  48909-7873
(517) 373-7917

(Below you will find a concerned and involved citizen's general appraisal of 
the Perrier situation in Adams County, WI. Following that is the Scot 
Ironside, WDNR, memo from the site visits on Nov 14 + 21, 2000 (the high 
capacity pump test began Nov 10, 2000. Therefore the noted observations were 
4, 10 , and 11 days after test began)):

**** and others in Michigan:
I just inputted the 4 memos that were obtained last week through an FOIA 
request from the Wisconsin Rapids, WI Department of Natural Resources 
Regional Office. These are the ones available at this time and we will get 
copies of the originals faxed to you as soon as possible.
These memos have to do with the 14-day test pumping in November 2000 at Big 
Springs, Town of New Haven, Adams County, WI. Pumped was 1,000 gallons per 
minute. There was immediate impact of several nearby artesian wells. Seven 
residents complained to the state DNR. An Associated Press article ran a 
story telling the problems experienced by two nearby farmers.
Perrier has been saying this was a "torture test" of the spring aquifer in 
Big Springs. However, in a press release by Lt. Gov. Scott McCallum last 
February 2000, he stated in the press release that Perrier intended in the 
Mecan Springs case (in Waushara County, WI) to begin pumping 500-gallons a 
minute and possibly double that amount within five years. So, we do not 
consider it a "torture test" at all. Perrier's proposal here is to pump 500 
gallons per minute (720,000 gallons per day) from two well sites; and 200 
gallons per minute from a high capacity well to run the one million square 
foot factory. That takes the figure over 1 million gallons of water a day.
A Village of Coloma official (Waushara County, WI) here told me Perrier 
needed two high capacity wells for the huge facility. At Big Springs they 
said only one well. A factory of that size (23 acres under roof) could 
possibly need the second well, as stated by the local official. But, I 
cannot confirm this.
Feel free to pass these around by e-mail. We will get the originals to you 
The Wisconsin State Journal tomorrow (Sunday, Jan. 7, 2001) will be
running a story on the Fox River situation here in Wisconsin and I
believe this information concerning the test pumping at Big Springs will be 
included in that story. So, you may find this information and quotes 
available on line.
DATE: November 21, 2000
TO: File
FROM: Scot Ironside
SUBJECT: Perrier Field Inspection Notes
On Tuesday November 7, 2000, Tim Ehlinger and myself inspected Big Spring 
Creek to look for brook trout spawning redds. We walked the stretch of 
stream below Jensens pond from the lower most machinery crossing, upstream 
to the dam, and found no spawning redds. We then walked the tributary above 
Jensens pond, where the young of the year trout were captured earlier. We 
identified one site where it appeared trout were spawning. Tim marked the 
site with a white flag and took pictures of the site.
Tim and myself felt the spawning sites in the upper tributary were likely to 
be in the area dominated with reed canary grass.
DATE: November 21, 2000
TO: File
FROM: Scot Ironside
SUBJECT: Perrier Field Inspection Notes
On Friday, November 10, 2000, I inspected the discharge pipe for the high 
capacity pump test, which began today at about 11:30 a.m. I looked at the 
large tank the water spilled into, and the protective plastic sheets that 
dissipated the energy and protected the banks from eroding. I felt these 
protection measures were excellent, and there was no indication of erosion 
or turbidity problems resulting from the pump tests. The stream did not 
overflow its banks, although it was full.
I also looked at the well site.
Overall, I thought the pump test started out real good with no obvious
problems that I could see.
DATE: November 21, 2000
TO: File
FROM: Scot Ironside
SUBJECT: Perrier Field Inspection Notes
On Tuesday November 14, 2000, Mark Hazuga, Bill Furbish, Jim Ihreg and
myself met onsite to look at the pump test. We looked at the outlet pipe.
The stream gauging stations above Jensens pond, below the pond, and at
Golden Ave. I indicated it looked like the flows above Jensens pond were 
noticeably less than what they had been on November 7, before the pump test 
was started. I mentioned that it had just rained all day on Sunday the 12th 
and you would have expected the stream to be higher. Jim Ihreg indicated the 
flows had dropped slightly.
I noticed the water level gauge on Golden Court was approximately 1/4
inch below the 6 mark when it had been completely covered with water on
the 10th.
DATE: November 27, 2000
TO: File
FROM: Scot Ironside
SUBJECT: Perrier Field Inspection Notes
On the afternoon of Monday, November 20, 2000, Jim Ihrig called me to say 
that the flows in the upper tributary to Big Spring Creek, had dropped by 
38%. He said they were continuing to drop, and was concerned that there may 
be detrimental impacts to the trout spawning. He wanted to notify us so that 
we could decide whether or not to stop the pump tests. I contacted Jack 
Zimmerman and he contacted Tom Jerow. A decision was made that Tom and I 
would make an onsite inspection the next day.
On Tuesday, November 21, 2000, Tom Jerow and myself met Jim Ihrig on
site, and we examined the upper tributary. Jim indicated the flow had
dropped further and was now reduced by 45%. The flow reduction was very
obvious to the eye. We examined the spawning redd found earlier and also 
found another obvious spawning redd just downstream. Both spawning redds did 
have a steady flow over them and it appeared the eggs would survive the 
temporary low flows.
We discussed whether or not to stop the tests and decided to continue the 
pump test, for the following reasons:
-the test was scheduled to end in only 3 more days anyway, and Jim
indicated it would be difficult to mobilize the equipment and manpower to 
stop the test much sooner than Friday since Thursday was Thanksgiving.
-completion of the pump test would give more reliable data for the
computer model, stopping the test could mean the test would have to be
-the existing redds and incubating trout eggs did not appear to be
threatened by temporarily lowering the flows. Tom Jerow indicated the
flow would quickly return to normal after the pump test ended.
-I indicated a flow reduction of this magnitude would have significant
negative impacts to the productivity of the stream if done over the long 
term, but the short term test should not cause long term harm to the stream. 
Therefore in the interest of getting good data I recommended the pump test 
continue as scheduled.
Tom and I examined the gauge at Golden Ave. and noted the stream level
was a tenth of a foot lower than it had been prior to the start of the

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