Proposed Actions Goal 1:…

ERO number

019-1340

Comment ID

47129

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

Proposed Actions
Goal 1: Highest Priority Use: Ministry proposes to assign Environment and Drinking Water as the highest priority use while considering a PTTW. Both Drinking and Environment are proposed to have equal priority.
Discussion Questions
1. Do you support including priorities of water use in regulation? Why or why not?

One use should have a higher priority than the other. There might be occasions where a decision has to be made in favour of one or the other. In my opinion, drinking water for human consumption should have a higher priority over all other uses.
2. How should priorities of use be applied to water taking decisions? When should it be applied? What process should be followed? Who should be involved? What information should be considered?

i) Municipal water taking monitoring reports, drinking water source protection studies should be considered before deciding on a water taking where municipal supplies exists.
ii) Municipal groundwater level monitoring report should be reviewed by the Ministry on annual basis for updating their groundwater use in the area.
iii) All stakeholders should be involved.
iv) As mentioned above, municipal groundwater use and PGMN data should be included in the decision-making process
v) Municipal drinking water needs long-term growth should be considered while making highest priority use.

Goal 2: Update Approach to Water taking in Stressed Areas: The Ministry is moving towards removing high watershed use maps that were included in Ontario Regulation 387/04 and moving towards response based on Ontario Low Water Response program administered by MNRF. It is proposing to develop guidelines on an area basis. Some areas may need high level of studies.

Discussion Questions

1. Under what circumstances should the ministry consider assessing and managing water takings on an area basis?

When drought conditions as indicated under OLWR are reported for an area for three consecutive years.

2. What suggestions do you have for the process of assessing and developing a strategy to manage water takings on an area basis? For example, how should local water users, stakeholders, and Indigenous communities be engaged?

Groundwater use data should be collected in stressed areas, including domestic use. Water users should be required to report their groundwater use data on an annual basis even if they have not obtained a PTTW.

3. How can the province help water users be more prepared for drought?

More education programs in areas where groundwater is in stress.

Goal 3: Making Water Taking Data Public: The Ministry intends to share the water taking data with public. It’s a commendable idea.

Discussion Questions

1. Is there any water quantity and monitoring information reported to the ministry that should not be made publicly available? If so, why?

All the information on water quantity and monitoring should be publicly available.

2. Would the proposed online resource be helpful to you? Why or why not? Are there other mechanisms for sharing this information that would be helpful to you?

On-line resources will be helpful to all stakeholders and will cut time wasted on unnecessary communication such as freedom of information requests.

3. What data would you like to see included in the online resource?

All data on groundwater quality, quantity and monitoring should be available through online resource.

4. How would you like to see water quantity data presented? What are the most useful formats (e.g. maps with embedded information, reports, tables, story pages)?

Water quantity data should be available for download in tables of monthly/ yearly use.

5. What water resources information and guidance would you like to see made available to the public?

The public should be able to see a summary report for the efforts put in permitting process before a PTTW is issued. Further, a list of Studies/reports required for future continuation of the permit will provide additional assurance to the public that a sustainable water use has been ensured and there are tools available to restrict it, if warranted.

Goal 4: Municipalities Involvement in water bottling decision: The Ministry intends to involve municipal governments in the decision making process while issuing PTTW for bottled water takings.

Discussion Question

1. Do you support the proposal to require water bottling companies to seek support from their host municipality when applying for a Permit to Take Water? Why or why not?

The municipality will now have a say on extending support or otherwise on bottled water taking for more than 379,000 litres per day. It is not known how this threshold was determined. The municipality will be required to provide reasons for their support or otherwise while deciding an application. The decision will include basis such as potential impacts to aquatic ecosystems, water supply needs and water quality.

Most of the municipalities may have no expertise of their own to conclude such an opinion. It may create a host of potential expenses to municipalities to hire consultants and a lengthy process of review at their end. A municipality either should provide their own reasons for refusal of a permit application or they should not be involved in the permitting process. Municipality support of a permit application should not change MECP permitting process, even if supported by Municipal Government.