Comments on Updating Ontario…

Comments on Updating Ontario’s Water Quantity Management Proposal

Environmental Registry # 019-1340

Erinn Lee
Ministry of Environment,
Conservation and Parks

Dear Ms. Lee:

Please accept the following comments regarding the proposed changes for managing water taking in Ontario.

GOAL 5: MUNICIPAL CONSENT:

I support a policy that requires water-bottling companies to have support of their host municipality as a condition in applying for a new or expanded Permit to Take Water for water bottling purposes. Municipal water managers are the right people to guide the council and residents in this situation, and it is assumed that this support, or non-support would be in the form of a Council resolution. It is essential, and a given, that municipalities have the studies in place to be able to adequately assess a proposal for water taking. Water Supply Master Plans and Tier 3 studies are part of this, as well as the necessary environmental studies.

GOAL 1: PRIORITIES:

I support regulations that include prioritization of water use in guiding water-taking decisions. I agree that the highest priority uses should be Environment and Drinking Water, with Agricultural needs as most important in areas where there is the potential for insufficient water for this use.

Drinking water should be a priority whether this is municipal, private domestic wells or for Indigenous communities. Given Provincial growth targets, ensuring municipalities have the water security to support mandated growth should be a high priority.

I support that planning for water needs for municipalities has to be long-term. I also support that water permits for water bottlers be limited to 5 years.

GOAL 2: MANAGING WATER TAKINGS IN STRESSED AREAS

I support regulation to manage water on an area basis rather than a permit-by- permit basis, focusing attention on water-quantity stressed areas. This strategy worked well for BluMetric’s study of areas with stresses related to population growth and land use, and recurring low water conditions.

I also feel that Conservation Authorities have management knowledge of the whole watershed, and that water management on a watershed scale under C.A.s is essential.

GOAL 3: MAKING DATA MORE ACCESSIBLE

I support regulation that would make data available online to the public with an accessible database platform to increase the transparency of how Ontario manages water resources.

A database is essential not only for water managers, Conservation Authorities, Ministries and water users themselves, but also to ensure Indigenous and public involvement and participation in any issues and conflicts regarding water.

This database is especially important since scientific knowledge and mapping of aquifers is incomplete and continually being updated. At the same time, data from monitoring environmental flows and water levels have to show historical as well as current details. The report acknowledges the shortage of adequate groundwater data, as well a lack of local funding to support data collection and analysis. These factors, then, make plans for situations such as climate change and drought difficult.