May 10, 1999

To:   Mayor Scholtens and Langley Township Council

Dear Mayor Scholtens:

The Salmon River Enhancement Society would like to comment on the moratorium on development in the Salmon River Uplands/Hopington Aquifer area.   This issue was raised for review last fall and is an issue which has significant long term ramifications.

Our society was actively involved in 1996 when council instituted the moratorium in response to drinking well tests showing higher nitrate levels than Public Health standards.  We have reviewed the Gartner-Lee report and many of our members attended last fall's meetings of the Planning and Engineering committees when the moratorium was discussed.  The November meeting of the Engineering Committee included presentations from many of the government agencies involved in water issues and was particularly informative.  Council is to be commended for devoting this time to review the problem and consider public input.

At the November committee meetings, the lack of a provincial Ground Water Act to protect and regulate the quantity and quality of our water resources was a recurring theme.  (BC is the only province which does not have a Ground Water Act.)  This is a particularly important issue for Langley as so many households in the municipality rely on well water and thus ground water for drinking and other uses.   Even areas that presently depend on GVWD water have an interest in healthy ground water as an earthquake or similar problem could disrupt GVWD pipes at some time.   This would leave Langley and other areas "at the end of the line" to fall back on groundwater sources for a prolonged time before repairs could be made.  Council should, therefore, strongly consider lobbying the provincial government to enact Ground Water legislation as soon as possible.

The November Engineering Committee meeting also clarified the concerns about nitrates.  We heard that high nitrate levels may be associated with other pollutants such as pesticides which are difficult to measure but are known health hazards.  Nitrate is therefore a "marker" test for overall water quality.   Increased nitrate levels have been associated with a small increase in cancer risk likely due to these other pollutants.  (A small increase in cancer risk has also been identified with chlorination of drinking water so bringing in GVWD water is not necessarily the solution.)

It is clear from the Gartner-Lee report, from concerns expressed by various agencies at least fall's committee meetings and from the results of recent testing that water problems still exist.  These concerns include both quality and quantity in the aquifer.  (While the moratorium was originally proposed due to quality issues, the issue of quantity may be at least as important.  The quantity issue will be addressed in a subsequent letter from our Society to council.)   Until these problems are addressed we feel that the moratorium on development over the Aquifer should remain.

The Gartner-Lee report does include one new set of water quality testing from local wells which was somewhat better than the previous set.   However, Gartner-Lee point out that one set is inadequate to judge the trend.   Samples done by our Society in Coghlan Creek near where it joins the Salmon River in Williams Park actually showed higher nitrate levels in the summer of 1998 than in previous summers.  (Gartner-Lee state in their report that this type of in-stream sample performed in the summer, when the lack of rain means that water flow is mostly from the aquifer itself, may be the most accurate test.)  Coghlan Creek is considered the best spot for nitrate testing as it has the highest proportion of groundwater flow from the aquifer and thus the lowest temperature in the summer.  Even more worrisome are samples performed last summer by Dr. Schreier of UBC from several small springs further upstream that feed into Coghlan Creek.  Some of these showed nitrate values well above 20 (or twice the Public Health limit).  These date indicate that overall water quality may be declining and that there may be "hot spots" in the aquifer with unacceptably high nitrate levels.

Dr. Schreier's previous work suggest that quality declines are partly due to septic tank outflows but that agricultural issues are somewhat more important.  We would suggest that a septic tank bylaw and progress on the agricultural part of the problem are needed before consideration is given to changes to the moratorium.  These issues were discussed at length in 1996 and our Society participated in the creation of a septic tank information brochure.  Concrete progress by the Township in these areas has, however, been lacking.

Continuing testing is also required to determine whether the problem is worsening (work by Schreier et al suggests that changes in surface conditions may take 5 to 10 years to show up in ground water so testing needs to be comprehensive and ongoing).  Our Society plans to continue our regular water quality tests and would be pleased to assist in such a program.

Sincerely,

Doug McFee, Director, Salmon River Enhancement Society

cc:  Mr. David Erickson, Township Director of Engineering

      Mr. Terry Lyster, Township Director of Planning

      Mr. Paul Crawford, Township Senior Planner

      Mr. Guillermo Giannico, Chair, SRWMP