Response to ERO 019-2422 Nov…

Response to ERO 019-2422
Nov 18, 2020
Ministry of Environment, Conservation and Parks

The team at Ice River wants to thank you for the oportunity to comment on this proposal to require municipal support for new or increased bottled water takings.

When the BluMetric and Professional Geoscientists Ontario reports were released, we were encouraged to see that what we have known since we started was validated. We were proud to read that water resources in Ontario were being managed well under existing legislation. Also, the finding that the end use of the ground water does not result in a different impact on the resource reinforced that all permits to take water should be treated the same. True protection of the resource should not be focused on less than 1% of the water taken.

Although we currently hold permits and are not expecting a need to increase our volumes, we cannot say with certainty that this will never be the case. We work very well with our local communities in Ontario, but we can’t predict future municipal government opinions. Therefore, we need to advocate for ourselves at this time to ensure that our business is viable in the future.

Municipalities already have a lot of control over how businesses operate in their areas. For example, we recently invested in a new plant in Shelburne, ON and site plan approval was a long process. We worked with them on everything from the size and design of our storm water retention ponds, landscaping, and even the colour of our siding. Decisions on permits to take water should lie with a professional geoscientist and remain a science and fact based decision by the MECP. If municipal approval is required, we ask that there is clear and consistent science-based criteria to guide their decision making.

The water source in Feversham, ON was found on my grandparent’s fish farm. We now own over 3000 acres around the spring to protect it from contamination. That spring is what allowed us to grow our business and innovate into the first closed-loop beverage company in North America. It has led our family business through 25 years of innovation, entrepreneurship, and sustainable growth. We believe in our statement that “what nature provides, we have a passion to preserve”.

While making this decision please keep in mind that water bottlers in Ontario are not all large, multi-national organizations. We are family businesses, farmers turned water bottlers, and a clean, responsible rural industry providing vital employment opportunities.

Best Regards,

Crystal Howe
Sustainability Manager
Ice River Sustainable Solutions