Comment
Allowing municipalities to weigh in on water taking for water bottling is a small step but is definitely not adequate! Giving host municipalities “a say” in the permitting process – isn’t the same as granting them the right to refuse. They actually need to be granted veto or limiting powers to such applications, under land planning. Also, if they allow a permit, they should be required to demonstrate they have considered any potential negative impacts to their community.
Inputs on water taking need to be extended to operations beyond just water bottling. Cannabis crops should be scrutinized, as well as any other industries that seek massive amounts of water from the watershed or water table and may affect municipalities.
The Canadian government has legalized Cannabis as an agricultural crop. But this is turning out to have a huge impact on our watersheds as Cannabis is a hugely water intensive crop and diverts water resources from mainstream agriculture. With increasing droughts affecting regular crops and concerns about food security, managing water for traditional crops is a much greater priority then diverting it for Cannabis.
As scientists from Berkley point out we’ve brought ‘a commodity into the mainstream that outstrips the value of everything else on the market, and the potential windfall profits produce opportunistic land use, and have environmental degradation as a result.” Other jurisdictions with Cannabis crops experienced such deleterious effects on their water they implemented new water taking legislation as their watersheds were being depleted. They require growers to collect their own water during dry seasons. They realized they had to treat Cannabis crops differently.
Cannabis operations seek similar amounts of water from the watershed that bottled water companies do and should be considered in that category.
Any excessive water taking permits needs to have high levels of scrutiny by townships and governing environmental bodies.
A troubling example:
In our township we have a risk to municipal water supply with an Industrial Hemp operation. This operation began production even though it is an illegal land use that sits directly next to a highly sensitive area. Technical studies show this Hemp operation has 3 of the 4 risks under the Clean Water Act. It sits on a highly vulnerable aquifer, it is on the wellhead protection area of the water that supplies the village, and it happens to be also an area of significant groundwater recharge. Besides that, it is less then ½ km from Lake Simcoe which will be the unfortunate recipient of its’ run off.
The operator is proposing to take in excess of 2 million litres a day and is currently undertaking a water study in order to obtain permits. This is a similar amount of water taking as water bottling companies. Under this example, the municipality - which has already issued stop work orders to the operator, would be able to veto the permit for water, and help to ensure or village water supply is protected. Perhaps the operator will succeed with the permit for water taking under “agricultural use” and the current standards of water taking. However the consequences to such a decision remain to be seen. A scandal could be on the horizon if it compromises our village or the lake.
Current science cannot fully predict the impact of climate change on this situation or our groundwater resources. Therefore we should treat any excessive water taking differently, with scrutiny and a cautious approach.
NASA has already sounded the alarm in 2015: the water table is dropping all over the world and it warned us - we're on the path to global drought. With 1/3rd of Earth's largest groundwater basins being rapidly depleted and 21 of the world’s 37 largest aquifers past their tipping point of more water being removed then replaced, we need to get our heads together on how we manage groundwater...because we're running out of it'.
Furthermore, according to some studies, scientists say that some of these aquifers may be even much smaller than previously thought. Only a few of the aquifers have been mapped in detail and most estimates of aquifer water reserves have “uncertainty ranges across orders of magnitude,” according to the studies. (Water Resources Research journal., Familglietti)
The Environmental Commissioner of Ontario’s work “Every Drop Counts” makes the salient point that even though Ontario is considered rich in water resources, climate change is having its impact on our water supply.
"In 2016, much of southern Ontario experienced serious drought, with eastern Ontario reaching Level III (the most severe level of water stress) under the Ontario Low Water Response program (Figure 5.1). This meant that water supply was officially inadequate to meet demand, and resulted in conservation authorities requesting users to reduce their water use.“
The sentiment has historically been in Ontario we have tons of water - don't worry. But actually it shows even in Ontario we have to be careful to manage our watersheds. Water is a finite resource, and a precious one.
In 2008, a study done in collaboration with the David Suziki Foundation offered an economic valuation of the Lake Simcoe Watershed Ecosystem. Accounting for inflation, it is now as an asset worth in excess of over 1.1 billion in services annually to the province of Ontario. Protecting this and other extremely valuable watershed assets is going to require diligence.
"Forests, wetlands and rivers that make up watersheds are like giant utilities providing ecosystem services for local communities as well as regional and global processes that we all benefit from. Ecosystems provide many services including carbon storage and sequestration, water storage, rainfall generation, climate buffering, biodiversity, soil stabilization and more1. However, as we do not pay directly for these services, they are undervalued in our market economy. They are worth billions of dollars per year, but need to be valued more accurately because their loss has massive economic impacts, threatening health, food production, climate stability, and basic needs such as clean water."
“It is critical that the true value and the costs of potentially damaging these ecosystem services be taken more directly into account in municipal and provincial government, and business decision-making. We also have the opportunity to build on existing ecosystem services by enhancing the natural capital of the watershed through restoration of woodlands, wetlands and other forms of natural cover as well as through stewardship activities."
As the government interprets the current findings of the BluMetric report and sets new policies in place it’s imperative it factors in the reality - this kind of environmental assessment is a developing science. There is a lot of room for error as it makes references and comments on sustainability going forward into the future. We don't actually know the future of our climate's impact on our water, but logic suggests we will have less, rather then more of it to go around.
The effects of climate change on our groundwater resources are still being learned, and only a few regions in Ontario were studied in the Environmental Assessment. Errors in management of water could be disastrous for our Province.
Allowing these water resources and assets to be exploited by any industry, either water bottling, or Cannabis, or others would be a grave mistake for all involved - individuals and industry included. As water resources around the world become stressed, demand for Ontario’s water will grow. Water is a human right and we have to protect it for current and future generations.
Then there is this reality - 82% of people in Ontario don't want our water going to water bottling anyway! It is not one of our priorities. Having enough water for current and future generations is.
The new report states that municipal groundwater sources have generally been sustainable. However, going forward into the future, this same statement cannot be said with confidence. Population growth, climate change, development and water hungry industries such as Cannabis will place an increasing burden on our watersheds.
Ontario government’s new legislation needs to go further with its effort to protect our water then proposed.
Using a conservative approach to water taking makes sense. Trying to put the responsibility on individuals for water use in priority over excessive water hungry industries does not. They should be required to have a reasonable water footprint, and if they don't, use creativity and innovation until they do.
We want the province to be even more rigorous in its environmental assessment process for companies applying to take groundwater than it has in the past. As a family, we live in a rural area dependent on well water, and are relying on the government to make sure we continue to have access to a safe an adequate water supply.
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Submitted August 2, 2020 9:32 PM
Comment on
Updating Ontario’s Water Quantity Management Framework
ERO number
019-1340
Comment ID
47464
Commenting on behalf of
Comment status