As a member of the public,…

As a member of the public, the proposal seems reasonable overall. I am glad to see that environmental sustainability is a #1 priority consideration for water use and that recognition is given to the likelihood of changing water needs and circumstances as a result of climate change. I would hate to scrape by with the bare amount of groundwater needed for sustainability only to have climate change and the resulting population changes/migration show we didn't really have enough.
A few specific points:
- I think there is a much larger opportunity to involve (and employ) Indigenous people in water management. This would go beyond what is mentioned in the proposal, which seems to be more about consulting Indigenous communities when there is a specific duty to do so, and otherwise mentions it a few times but in a vague way. While water management is somewhat localized, it is also always interconnected. Indigenous knowledge in water management is a valuable resource we should not overlook. I am also concerned as to whether Indigenous communities' water supplies could be adversely affected by decisions about water that is strictly speaking outside their community, but that they rely on directly or indirectly.
- There was very little mention of the cost of taking water, though it did note it was under review and suggested the criteria was to have it at "an appropriate level to recover applicable provincial costs". I think the cost is both too low and that this is the wrong framing.
> In terms of the cost itself, $500/million litres is about 12% of what I pay in Toronto for personal water use, by my calculation. It doesn't make any sense to me why anyone would be able to pay less than a home user for water. (Let alone so ridiculously low). Volume discounts are a business/supply chain concept that don't make any sense in the context of natural resources. Water is water.
> Then if you consider that this water is being taken to sell, and make a profit, it makes even less sense that we would give it away for so little. Water is a precious resource, it is life. If someone wants to sell and profit from it, then there's no need for us to hand the natural resources, our collective resources, away for free. We can charge more. Then companies can decide if it's still profitable for them to do. This is money we can invest in the very, very expensive situation that is trying to adapt to climate change.
- I noticed that there is an exception to the proposed regulation around municipalities' input into water bottling decisions in the case of "a water bottling facility that gets its water from a municipal water supply." I'm not clear on why this exception exists and to what extent it happens already but this seems like a gaping loophole. Presumably if a water bottling facility is taking from the municipal supply it is paying more. However I also imagine they could be taking much more than what the system was designed to support. This loophole is a concern and I think it should be better addressed.