I work for the Federation of…

I work for the Federation of Sisters of St. Joseph of Canada. We are a Blue Community committed to protecting water as a human right, shared commons, and sacred gift. My comments on this proposal are for this entire organization. To address the four main proposals of this review, it is necessary to include some context.

A review of the water permit process was desperately needed since we now know:

The water permit process has not been updated in over 30 years and was never intended to foster the wholesale extraction of water for profit. Companies pay ¼ of a penny per litre to take from the commons and then charge over $1 in the store.

Canadian, International and Indigenous laws require decisions about land and water use be shared between the Crown (Ontario) and Indigenous nations. Consultation is not the same as shared governance. The time for reconciliation is now.

Groundwater taken during several days can take decades to recharge. Climate change makes water security even more unpredictable. Water crosses political borders. A water permit given within the Great Lakes watershed should integrate multiple Great Lakes jurisdictions and interests.

1 million plastic bottles are used every minute globally. No one knows how many plastic water bottles are produced in Ontario by all sources (groundwater and municipal) because no one is counting. Only half the bottles in Ontario are recycled and all of them eventually end up in landfills and the environment because recycled products only extend the waste-chain, rather than end it.

Bottled water is tested less for quality than municipal tap water and contains thousands of microplastics per litre.

Bottled water is a poor choice over tap water and largely a wasteful convenience. 75% of Canadians have clean, affordable, and plastic-free municipal tap water. Some rely on private wells and some (mostly First Nations) are denied the human right to water by the Federal government because of source water pollution and chronic underfunded water systems.

Water governance should never just be based hydrological studies. Water permits are an ethical balancing act based on the world we want and the world we want to leave for the next 7 generations. Policy needs to reflect the soul of society, not just data.

Water is a human right, shared commons, and sacred gift. No Province or community owns water and decisions must consider the needs of all life now and many generations into the future. The right to water is a social justice issue with society’s most marginal often going without. Water provides us with our physical and spiritual wellbeing and connects us to all of creation.

In terms of your four areas specifically, I have responded to each to highlight what is either missing or faulty in your priorities. We would like the Province of Ontario to address all these gaps before approving any new policies governing water permits.

"Requiring water bottling companies to have the support of their host municipalities for new and increasing bottled water takings, with an exemption for small businesses".

This does not include existing permits or renewals. Municipalities can only say “no” within narrow terms set by the Province (excluding commodification, plastics, Treaty responsibilities, the corporation's track record, public values, etc) and this does not guarantee a failed permit. No community support is needed for permits under 379,000 litres of water per day. Shared governance with Indigenous nations is not a requirement and the Province will only commit to consulting with “Indigenous communities” with no details with what this means.

"Establishing priorities of water use in the province that can guide water taking decisions."

Bottled water is a non-essential use of shared waters and has many negative ecological and health impacts. The Province should apply the 'Precautionary Principle' with all water to be left for future generations unless there is a proven positive social benefit unmet in any other way.

"Assessing and managing multiple water takings together in areas of the province where water sustainability is a concern."

Sustainability should be of concern across the entire Province because water is essential for life and livelihoods. Cumulative impacts from all water takings from the entire watershed should be assessed.

"Making water taking data available to the public to increase transparency of how Ontario manages water resources."

All water data and the capacity to understand it should be a priority and be based on watersheds not just political boundaries. The data on how much money the Province collects from water permits and how this money is spent should also be made transparent.