Pump tests related to…

Comment

Pump tests related to permits to take water for commercial bottling should not be included in the exemptions listed for low risk short-term water taking activities. While the pump tests on their own are short-term, there is no purpose in the test other than to establish long-term pumping activities. Pump tests are an integral part of the process of applying for a permit to take water. As such, pump tests should necessarily be managed in the same way as permits. Municipal concerns and citizen concerns about long-term stability of water supplies must be a part of any considerations for water permits right from the beginning. Short-term pump tests therefore should be subject to the same regulatory process as any water permit, and not simply be exempted from scientific or business analysis.