July 30, 2020 Submission to…

July 30, 2020
Submission to ERO
Province of Ontario

Re: Updating Ontario’s Water Quantity Management Framework
I am responding to the Ontario government’s proposed changes to the rules governing permits to take water (PTTWs) for bottling in Ontario. I understand that these proposals come four years after the moratorium on new permits imposed in 2016. In addition, this year marks the 10th anniversary of the UN resolution declaring water as a human right.

Proposal summary:
We are proposing regulatory changes for managing water takings to protect the long-term sustainability of surface water and groundwater and to ensure these important resources are responsibly managed and safeguarded now and for future generations.

The moratorium on new permits to take water for bottling should be made permanent and maintained beyond the Oct 1 planned expiry date. Bottled water is not a necessity and the health and environmental costs are enormous and far reaching. Some examples include: increasing numbers of plastic bottles in landfills, on land, water ways and in oceans; proliferation of plastic microfibers in everything from water, land, air and including levels found in human tissues; and ongoing pollution from water extraction and transporting and exporting bottled water.

I believe and ask that municipalities be required to provide consent to all permits to take water applications for all commercial operations in their communities, in particular for large scale extraction of water for bottling water for profit. Water as a common good and a public trust remains in conflict with water as a commodity and water for profit as with the government’s proposal requiring water bottling companies to have the support of their host municipalities only for new and increasing bottled water takings, with an exemption for small businesses. The proposal is inadequate as it does not include existing permits or renewals and so is a minor concession that signals business as usual for corporate large scale water extraction for profit.

I believe and ask for shared governance with Indigenous nations as a requirement for permits to take water for bottling in Ontario. Once again, the government’s proposal for only consulting with “Indigenous communities” is a minor concession that will ensure that Indigenous nations and communities have a limited voice and no real power to consent to permits.
I believe strongly that more in-depth scientific research is needed to understand and guide regulatory decisions being made about the quality and quantity of health, renewal and sustainability of Ontario’s groundwater aquifers.

Further to considerations for new permits, I believe and ask that water extraction for bottling water be phased out starting now, over a three to five year period. I believe water is a human right and a sacred trust. Water is a necessity for life, for humans and for health sustaining eco-systems. Current emergencies in health, climate and pollution signal the need to preserve and protect water as a common good and a public trust. Provincial action is needed now to protect the long-term sustainability of surface water and groundwater.

In closing, I ask and believe that large scale water extraction must be monitored and carefully regulated, and in the case of water for bottling deregulated and phased out, to protect the long-term sustainability of surface water and groundwater and to ensure these important resources are responsibly managed and safeguarded now and for future generations.