ERO Number: 019-1340 First…

ERO Number: 019-1340

First of all, I would like to congratulate you for some of the changes you’ve proposed. I fully support requiring water-bottling companies to seek support from their host municipality when applying for a Permit to Take Water (PTTW). However, I have concerns regarding the particulars of the proposal. The proposed threshold of 379,000 L/day (>138,000,000 L/year) would still allow significant amounts of water extraction without host municipality approval, and I would suggest that all new and renewed PTTW (50,000 L/day) require municipal support. Allowing substantial municipal input for all significant water takings (PTTW threshold of 50,000 L/day) is democratic, allowing communities to be heard more meaningfully than under the current system. Additionally, I am concerned about the proposed ‘grounds on which a host municipality could refuse to support a proposed water taking’ as there is potential for municipalities with limited resources being disadvantaged in their ability to adequately examine the possible impacts of a PTTW. This is especially true regarding potential impacts on local ecosystems, which themselves are very complex systems. The Bluemetric report indicates the same issue, expressing the complexity and need for improvement in understanding the cumulative effects of total water takings on surface- and groundwater, and deep aquifers over the long term.

I support the prioritizing of water uses; I agree that the highest priority uses should be the Environment and Drinking, followed by Agricultural Irrigation. I would encourage the Ministry to consider long-term planning horizons for water management, especially for communities relying on groundwater for local water supplies (eg. Fergus/Elora and Guelph). Climate change and population growth have a very high probability of affecting water sustainability in the coming years in communities like Centre Wellington Township. As our aquifers are replenished over extended time frames (on the order of decades and longer), impacts on water availability are likely to lag behind reductions in recharge. I would therefore encourage a conservative approach to PTTW and requiring Environmental Assessments for all large-scale water taking permits.

I support managing water takings on an area basis rather than as individual permits, with additional attention on water-quantity stresses areas. However, I would encourage managing water (groundwater and surface water) on a watershed scale, allowing consideration of the cumulative impacts of all water takings on the watershed as a whole. For the Grand River, threats to the watershed are accumulating. Watersheds are a more meaningful scale for ecosystem planning and for water management, allowing greater anticipation of the effects of multiple pressures on our watersheds, including population growth, and consideration for groundwater as part of complex and intricate ecosystems. I also support continued Provincial funding for ongoing management of Tier 3 Studies and the critical work of Conservation Authorities in the management of local waters.

I also support the proposed improvements to transparency and the enhanced availability of water taking data for public use. This data is critical for ministries, water managers, conservation authorities, and water users themselves. Additionally, I believe this data will be beneficial for enhancing Indigenous and public involvement and participation in issues and conflicts related to water and water taking. This will also enhance our knowledge of Ontario’s aquifers and may aid in our ability to forecast future water shortages where they may arise.

Lastly I would like to encourage the Province to enhance consideration of the water end-uses and associated environmental impacts when evaluating PTTW. Water taking for bottling is a consumptive use where the water is not being returned to local springs, streams, wetlands, or lakes, where it can fulfill a hydrological function. Bottled water is additionally harmful to the environment through the industry’s significant contributions to greenhouse gas emissions (eg. Botto et al. 2011) and plastic pollution (eg. Recycling Council of Ontario 2019). While there are certainly emergency scenarios where bottled water may be useful, I believe the full impacts of the industry need to be weighed when considering new and renewed PTTW. We cannot compromise the ability of future generations to grow and prosper within the Province of Ontario, especially not for the benefit of an unnecessary and damaging industry.