February 3, 2010
Chairperson, Planning Committee for
Draft Southeast Regional Groundwater Management Plan:

Our organization Native Conservation Inc (NOCI) works to protect native orchids and their habitat and our work includes doing plant surveys to locate rare plant communities.  See www.nativeorchid.org.   

Most of Manitoba's 37 native orchid species are located in wetlands.  Orchids are very sensitive rare plants that require specific habitats to thrive and they are often the first plants to fail when their habitat conditions change or deteriorate.  Since 1998 when NOCI was formed, in the course of doing plant surveys we have noticed that many wetlands and the rare orchids that live in them have been lost or damaged by agricultural drainage, clear cutting, peat moss extraction, and residential and commercial development.  Wetlands provide important orchid habitat while they contribute to ecosystem biodiversity and stability.  We have lost a huge percentage of our wetlands in the twentieth century mostly due to agricultural drainage.  Southern Manitoba has been hit especially hard.  (See Manitoba EcoNetwork publication "Wetlands in Manitoba 2009" under Threats to Wetlands.) 

This is particularly unfortunate because many of the existing wetlands, as well as being good habitat for rare plant species like native orchids, are almost certainly involved in groundwater aquifer recharge.  The Brokenhead Wetlands near Scanterbury Manitoba on the east side of Lake Winnipeg and several bogs and fens in the Sandilands near Hadashville, south of East Braintree east of PR#308 near the Moose Lake end, and near Woodridge come to mind. 

We read in Section 2.0 of your plan that the population and subsequent residential development is projected to increase rapidly in southeastern Manitoba and that will certainly lead to increased demand for this water.  Ongoing agricultural practices that require large volumes of water to irrigate crops and raise animals like hogs, and drainage of land to make more fields to plant crops have the potential to drain groundwater aquifers faster than they can be replenished.  Meanwhile contamination of groundwater has become another huge issue in some areas and although we may have all kinds of water we may not have much fresh (drinkable) water left.  We need to be careful.

You mention in your cover letter that "there does not appear to be any clear evidence that the resources are in jeopardy" but there is also no clear evidence presented in the draft plan that shows us water resources are not in jeopardy.  Up-to-date data on groundwater resources would be helpful but in Section 3.2.4 of the draft plan we read that groundwater resource studies, aquifer maps, etc will not be ready until 2014.  In Section 2.2.8 we read that a 3-dimensional model for sustained yield will not be completed until 2011. 

Again in Section 2.2.4 we read that "It would be nice to completely define the magnitude and replenishment rate of a resource before beginning development according to an established, sustainable plan.  However this approach is incompatible with societies' interests in resource and economic development because the required study is expensive and would delay development considerably."  Going ahead with large-scale development of groundwater resources without these studies because it is expensive or because it would cause delay is risky.  If this approach results in groundwater resources being exhausted it may be hundreds of years before they are replenished especially with the effects of climate change and the potential for more frequent droughts in the Prairie Provinces.  If over-development results in damage to the aquifers it may be that they won't recover at all.  Both of those potential outcomes would not be in society's best interest and may turn out to be very expensive.  We need to consider the needs of future generations not just our own

Conclusion and Recommendations:

In view of our lack of facts, up-to-date maps of aquifers, recharge rates, etc, we should follow the precautionary principle until we know exactly what groundwater resources we have left and what condition they are in.  While we are waiting for studies to be completed we should resist the pressure towards large-scale development and proceed very cautiously with limited groundwater resource development while at the same time:

  1. Value and protect our remaining wetlands and the plants and animals that live in them
  2. Promote the conservation and protection of existing groundwater supplies
  3. Consider the effects of climate change and potential prolonged periods of drought on our groundwater resources
  4. Do not consider the export of water until we know what resources we have left
  5. Consider the needs of future generations.

Respectfully submitted,
Doris Ames, president
Native Orchid Conservation Inc
117 Morier Avenue, Winnipeg R2M0C8