The following comments apply…

The following comments apply to Goal 2 of the proposal Updating approach to managing water taking in stressed areas.

(1) The proposal does not provide the necessary clear statement that all water-quantity management decision must be made in the context of a watershed approach, The management unit to be used is always a wattershed or subwatershed as defined by the Source Water studies for the area under review.

(2) The proposal does not acknowledge that where an aquifer is used as a water source and the aquifer extends beyond the surface boundary of the watershed or subwatershed where the proposed withdrawl is located the boundaries of the aquifer will define the study area and all the watersheds which the aquifer underlies will be included in the analysis of the proposed undertaking.

(3) In the preliminary assessment of an undertaking done on a watershed or aquifer scale it may be determined that only a smaller portion of the watershed or aquifer area will be affected by the proposed withdrawl. In this case a project area covering only a portion of a watershed will be selected for more detailed analysis.

(4) The proposal does not acknowledge that integrated surface/groundwater models are now sufficiently advanced in Ontario that they are the core analytic tools to be used in determining the environmental consequences of a proposed withdrawl. In many cases, and for small volume applications, there may already be sufficient information on the effects of small withdrawls to not require further modelling.

(5) The proposal does not acknowledge the need for continuous improvement of the integrated watershed models developed in the Sourcewater Studies. Millions of dollars has been spent in developing these models and the models are structured to allow updating as further data from field investigations and monitoring systems becomes available. The province must establish a centre for model maintenance to provide easy access to the models and to supervise continuous updating.

With regard to Goal 3 making water taking data more available

(6) The water-taking data for large water takings as well as related monitoring data for groundwater levels should be available in real time on the web in the same way that streamflow data and precipitation data is available. There should be web access to all past data sets, again in the same way streamflow and precipitation data is already available.

Comment on the need for secure adequate funding for maintenance of monitoring data and for management costs for providing analysis of proposed water takings.

(7) Other jurisdictions, for example British Columbia, have recognized that a secure and adequate budget is required to provide the skilled staff and to cover the data management costs that must occur if data-driven science-based management is to be practiced and wise management achieved. These costs are a necessary part of providing a safe sustainable water source for all residents of Ontario. An appropriate funding source used in other jurisdictions is a per volume water charge on all large-scale permit holders. Such a charge should be included in the changes proposed for water-quantity management in Ontario

(8) For example in France at a national and regional level, responsibility for the management of water capacity and the control of water pollution resides with six water agencies (Agences d’eau), organized on the basis of river basins, ie, Adour-Garonne, Artois-Picardie, Rhin-Meuse, Loire-Bretagne, Rhône-Méditerranée and Seine-Normandie.

These six authorities charge the local councils and others for abstraction of water and pollution management, some of which is then recycled to the councils to assist in investment in water treatment plants, as well as providing support to farmers and industrial users.

I attach a review paper on Water Access Charges (WAC's)