Thank you for the…

Thank you for the opportunity to briefly comment on the ERO 019-1340, Updating Ontario’s Water Quantity Management Framework. My comments are informed by reviews of the BluMetric reports completed in Ontario.

I echo some of the sentiments of the Canadian Environmental Law Association submission in supporting the overall direction of the changes to further strengthen water protection in the province, which is certainly required given many compounding pressures related to forestry management, water extraction, mining, warming temperatures, and increasingly unpredictable weather. We recognize more than ever the need to manage our limited water resources carefully to ensure they will be available and safe for future generations.

Pressures faced by our water systems are not equal. While the majority of the Ontario population receive water from surface water, areas as such as Waterloo-Wellington rely only on groundwater supplies to serve their growing populations and areas such as Quinte have faced low water and limited water protection for those not using municipal water systems. There is a need to ensure these vulnerable areas and populations are prioritized with specific language and protections in regulations that consider all potential impacts to the water supply and the current threats to a sustainable supply of groundwater.

This regulation has also added language to limit water taking, however, allowing any extraction in communities with threats to the sustainability of their water supply is not reasonable or safe. For this reason, the regulation must ensure that vulnerable areas are protected and no water extraction is allowed before thorough study of the cumulative impacts of the many industries, activities, and natural factors that influence water supply in these regions. Furthermore, allowing any continued water extraction for water bottling does not align with serious concerns regarding ongoing plastic pollution documented in a recent report by Environmental Defense titled “No Time to Waste.”

The need for meaningful collaboration was described by the BluMetric report titled “Lessons Learned.” Water protection regulations must integrate collaboration and agreements with all decision-making levels and communities that could undermine or complement water protections in Ontario.

Thank you for your consideration of these comments and for your work to protect the water that sustains us all.