Feb. 5th, 2021 Brent Taylor…

Feb. 5th, 2021
Brent Taylor
Water Policy Branch
Ministry of the Environment, Conservation and Parks
College Park 5th Floor, 777 Bay St.
Toronto, ON M7A2J3

Mr. Taylor,
On behalf of Ice River Sustainable Solutions (previously Ice River Springs), we thank the MECP for the opportunity to provide comment on the proposed updates to Ontario’s Water Quantity Management Framework draft guidance (ERO 019-2017). These changes will have a profound effect on our business and we recognize the efforts made by the MECP to find common ground on this file. This has not been an easy task and we sincerely appreciate that the moratorium will soon come to an end.
We are pleased to see that the MECP will develop and manage an online platform that will allow Ontarians to access water permit information for all permit to take water (PTTW) holders. We recognize that many of the changes being proposed are based in science and fact with a focus on protection of the entire resource, not solely on bottled water taking. Our industry takes less than 1% of the permitted water-taking in Ontario and “the science does not support the need to regulate water bottlers any differently than other takers” .
Here are the areas we have concerns about:
Priority Use
We agree that drinking water is Priority 1, and bottled water is drinking water and should therefor also be priority 1. Whether from a tap or a bottle, it serves the same critical role; human consumption. Bottled water companies supply the healthiest beverage, in the most easily recycled packaging, with the most efficient use of water in the beverage industry. We are here during emergency situations and are called upon for donations on a regular basis, but we cannot only be here for emergencies. We need to be a healthy industry in order to fill the needs of Ontarians. This distinction could also put us at a disadvantage with our competitors that use municipal water for their bottled water and other beverages. The Professional Geoscientists Ontario’s Report states that “bottled water takings are not impacting the sustainability of groundwater resources in Ontario or of other water resource users” . We are drinking water; we should be classified Priority 1.

Quantity-Stressed Areas
We understand that the MECP will collaborate with stakeholders when developing a strategy for managing these areas. We ask that we be involved from the earliest stages of this development.

Municipal Input on PTTW
We recognize that the requirement for municipal approval on new or increased PTTW bottling applications was passed on December 7, 2020. The issue we take with this portion of the policy is that it once again singles out our industry. We do not agree with this decision, but if it is a requirement then we need clear evidence based criteria to guide municipal decision-making. These decisions impact Ontarians and can not be based on biases and unsubstantiated claims. We also ask that there be an appeals process to ensure fair application of the criteria and to resolve disputes.

Thank you for working with us through this very difficult and time consuming process. Since 2016 our industry has been unfairly targeted. It gives us some security to know that a resolution is coming soon. If you have any questions about our comments or require further information, please contact us.
Sincerely,

Crystal Howe
Sustainability Manager
Ice River Sustainable Solutions
chowe@iceriversprings.com