Minister of the Environment,…

Minister of the Environment, Conservation and Parks

I would like to respond to the following item:

Proposed changes to provide flexibility for water taking activities

ERO # 025-0730

Posted on July 2, 2025, Comment Period July 2, 2025 – August 1, 2025.

I have a number of concerns regarding this proposal. The suggested changes to existing regulations will have the following negative impacts:

- Reduce the ability of municipalities to assess the appropriate level of water taking in their district;

- Sidestep the requirement that the province engage in meaningful consultation with Indigenous Nations in advance of making policy changes;

- Commercialize water-taking by allowing companies to simply pay a fee as though our groundwater were a commodity like any other – rather than treating water as a precious resource to be guarded on behalf of the citizens of Ontario, as well as future generations;

- Compromise environmental regulations and the ability of appropriate agencies to make ongoing assessments that protect the quality and quantity of water in our aquifers;

- Establish the precedent that private companies’ access to resources is more important than safeguarding and protecting the public good.

Bottled water could be regarded as a frivolous industry. The province already spends substantial sums of money to ensure the quality and quantity of drinking water for citizens of the province. Pumping water out of aquifers with no regard for the sustainability of our groundwater is fundamentally irresponsible. To take that water and then continue to squander resources by pouring it into endless plastic bottles is incredibly wasteful. All the more so, considering that the vast proportion of this plastic ends up in landfills - not to mention the litter, polluted waterways and natural areas, and the risks to wildlife. The Limits to Growth is not a new concept. Why exactly is the advancement of this industry so necessary in the face of our urgent need to avoid climate change, to reduce and eliminate plastic pollution, and to decrease our dependence on petroleum resources?

The current proposal is reminiscent of the government’s negative changes to the Conservation Authorities Act, their interference with governance by local municipalities, their interference with bike lanes in municipalities, and other similar actions which generally disrupt the functioning of democratically elected local governments. It seems unlikely that the Ontario government would wish to see the federal government interfere in a similar fashion in areas of provincial jurisdiction.

One assumes that the public good is considered the top priority for our elected MPs, rather than commercial interests.

Recommendations:
I would urge the Minister to:
- Discard the changes that have been proposed to the regulations to take water;

- Stipulate that new owners are required to make an application for a new permit. This process should allow for public scrutiny and scientific assessment;

- Make a clear and unambiguous commitment to enter into consultations with Indigenous Nations, as legally required;

- Disavow proposals that envision water as a saleable commodity, and instead consider it public trust.

Thank you for considering my submission.