Comment
It is most encouraging that the Ontario government is giving consideration to the preservation of ground water quality at a time of deregulation by the Progressive Conservative Party of Ontario. The following comments are offered:
1) Taxes on bottled water in single use containers should be increased to cover all externalized costs including the recovery and recycling costs of the plastic containers. On the assumption that Ontario drinking water standards will be maintained in most parts of the province, bottled water is a very profligate use of resources and should be taxed accordingly for general consumption. The current pricing and marketing strategy reinforces it as a necessity when, in fact, it's a convenient luxury with highly negative environmental credentials.
2) Only new landfills located on deep clay strata, distant from watercourses should be permitted. Landfills on fractured bedrock and/or adjacent watercourses, similar to the Richmond Landfill in Nappanee, have polluted ground and surface water resulting in seriously adverse public and environmental health issues.
Given that the Government of Canada has confirmed that all polymer dump liners eventually leak any commitments given by landfill proponents that a landfill is secure in perpetuity lack crediblility. A landfill on any type of porous sub strata should not receive any consideration by MOECP except outright rejection.
Landfill leachate poses considerable risk to surface and groundwater. In addition to banning all landfill developments on porous or fractured bedrock, any existing landfill or those new developments on deep clay strata must have an absolute guarantee from the developer that the leachate treatment system has very high levels of redundancy and capacity and will meet municipal water discharge guidelines until the dump is completely inert. The landfill developer must provide an irrevocable commitment to this that cannot be relieved through bankruptcy or subsequent sale of the operating asset.
3) Salification of watercourses adjacent highways seasonally treated with salt or other toxic compounds need high-profile consideration. Salification of rivers, streams and lakes is a growing environmental problem particularly when they are drinking water sources like Lake Simcoe. Saline water intake by humans can cause hypertension and other chronic ailments. Salt limits must be considered in highway planning, maintenance and construction.
4) The discharge or leakage of organic compounds into watercourses resulting from human activity must be strictly controlled to prevent toxic algal blooms and harmful compound accretion that are becoming increasingly common because of deregulation and lack of political will to invest appropriately in pollution control facilities.
5) Privatization of water distribution and wastewater treatment must not be considered as it has failed in most countries. High quality fresh water is a right to all Canadians and must not be a vehicle for profiteering by private sector interests. It should remain in public ownership.
Given that fresh water is more valuable than oil as a resource it falls on both senior levels of government to ensure we protect what we have for the benefit of all Canadians.
Supporting documents
Submitted July 5, 2020 1:58 PM
Comment on
Updating Ontario’s Water Quantity Management Framework
ERO number
019-1340
Comment ID
46866
Commenting on behalf of
Comment status