Background In July 2015 I…

Background
In July 2015 I retired from the MOE Central Region after 45+ years of service as a hydrogeologist and long standing member of Professional Geoscientists Ontario (PGO). Over my entire career from 1970 to 2015, I was actively involved in the review and assessment of 5000 or more Permit To Take Water (PTTW) applications including numerous water bottling operations within the Central Region territory that at one time included 10 counties or Regional municipalities surrounding the Greater Toronto Area (GTA). Since 2016, I have worked with the Oak Ridges Moraine Groundwater Program in an advisory capacity related to groundwater issues.
The PTTW program was introduced in March, 1961 primarily to deal with the intense competition for irrigation water within the tobacco growing areas of southwestern Ontario. I was therefore part of the program’s growth for more than 4 decades through many changes including the major overhaul in 2004 when charges were first introduced to cover costs.
I was involved with the review of various PTTW applications and the issuance of the Permits as well as the investigation and resolution of disputes related to the water takings. I frequently met with Permit Holders to assist them in the completion of applications or to establish monitoring programs. Whereas my primary involvement was with Permits for groundwater takings I also had extensive experience with surface water takings and their impact on wetlands and other surface features.
Although I found the majority of Permittees to be co-operative and compliant with their Permit conditions, in some highly competitive groundwater use areas I installed and maintained ministry water level monitoring equipment to support and verify data collected by the Permit Holders or their consultants.

Through my active involvement, I gained a good understanding of the impacts of the hundreds of groundwater operations including many bottled water operations throughout the Central Region area of coverage. I experienced many wet and dry years including the 1998-99 period that actually precipitated the intense focus on the bottled water industry from that point onward.
For more than a decade qualified Ministry staff and independent consultants have consistently cited conclusive evidence showing the minimal and rather insignificant impact bottled water and other consumptive groundwater takings have on the available resource. Both the BluMetric Environmental Inc. (BEI) independent review and the peer review of that study by PGO confirm that conclusion and I trust this will finally allow the ministry to end the moratorium and finally move forward.
While this has been a long drawn out process, in my opinion the issue with bottled water takings should never have been about sustainability of the resources but rather how to deal with the needless production of the non- returnable plastic containers that are the real threat to the environment.

Comments

Contrary to the major opposition viewpoint, the BEI report concludes that bottled water takings are not impacting the sustainability of GW resources in Ontario or other users. Although a few of the larger operations may have local issues with neighbouring well owners, those actually dealing with the Permit takings, myself included, continually provided evidence showing the relative insignificance of these withdrawals across the Province. Regrettably, the anti-bottling lobby refused to accept concrete evidence as to the true impact and the Permit moratorium persisted far too long. It was definitely heartening to finally see the independent BEI report and the follow-up PGO peer review both concur with ministry staff and trust that the ministry will now move forward.
From a personal perspective, of the numerous bottled water applications I dealt with, the majority were small operations with minimal if any, impact on surrounding resources. While the majority of the Environmental Registry mandatory pre-issuance Permit postings received no comments whatsoever, a few did involve intense opposition from local well owners. Each Permit application is supported by reports and studies by qualified consultants and is the basis for any Permit review. As a hydrogeologist and reviewer I also relied on my experience and knowledge of local groundwater conditions that included long term water level monitoring information.

When the PTTW program was first introduced in 1961, “hydrogeology” was a new science and the 10,000 Igpd Permit requirement implemented in the legislation was essentially untested criteria. Although the value was revised to the equivalent 50,000 l/day in the 1970’s, throughout my entire career with the ministry I was actively involved with pump tests large and small.
Since domestic wells are generally capable of 15 – 35 l/min, I therefore consider a domestic supply of 45 l/min or 10 Igpm to be a decent water supply. Industrial or irrigation wells tend to be at least 225 l/min or more with municipal wells generally in the 400 – 1818 l/min range. While you do see small communal system wells producing as little as 45 l/min, these systems tend to have multiple wells depending upon the size of the development served.

Although the Permit Legislation excludes domestic water takings, a continuous pump rate of 34 l/min could theoretically produce the Permit requirement of 50,000 litres over a 24-hour period. As domestic well usage tends to be intermittent normally under 10 minutes at any one time, the sphere of influence on local groundwater levels is generally limited to within 5 -10m maximum of the well head. From monitoring experience, I found that even sustained groundwater takings up to about 200 l/min still only had minimal effect on area water levels of perhaps 25m. In my reviews I therefore considered domestic well takings to essentially have insignificant impacts with those in the slightly higher range only marginal effects.

In my past commercial or industrial Permit reviews I purposely excluded any small site “domestic well” listed in the application however I notice that many Permit reviewers still include these takings in new or Permit renewals even though records submitted indicate daily usage well below 50,000 litres.
There are likely hundreds of point sources of this nature listed within the various active Permits throughout the Province. Whether this inclusion is related to a commercial operation or considered to be part of cumulative water taking on the property, the taking is still domestic use with minimal if any impact and should be excluded as a consumptive source. The installation of monitoring equipment and maintenance of a daily log represent a needless cost to the Permit Holder. These sources could be easily eliminated on future Permit renewals.

Another problem I noticed past and present with many Permit reviews is the duplication of takings from sources listed in various Permits. In many cases, water may be pumped from a well or stream to a storage pond for later use in site irrigation. As a reviewer, I purposely listed only the original source excluding the storage facility on the grounds that the reuse was simply a duplication of the site water usage.

Despite public perception, each Permit application submitted for any purpose including bottled water must be supported by studies or reports prepared by qualified consultants. Each application receives a thorough assessment by qualified ministry personnel in a timely manner. The review includes any comments pertaining to the taking received from the public during the mandatory posting period on the Environmental Registry. This process applies to all applications and should not require any additional scrutiny for any specific sector.

I have some issues with Section 4 of the PGO review. While their criticism of the ministry’s “stewardship of water has no incentives to conserve water once a PTTW is issued”, in reality since there is a cost associated with each water taking during the year the “incentive” for any Permit Holder is and will always be to minimize their usage. Furthermore, water takings for most Permit Holders are highly dependent upon prevailing climatic conditions and will always be the determining factor when to pump.

PGO also recommends retaining the maximum rate and daily amount for each source in the Permit but limiting the daily total to a percentage for a specified period in dry conditions. While this may sound like a reasonable suggestion, from experience most Permit Holders put their own needs first and implementation of the reduction would be would be difficult if not impossible to enforce in drought conditions.

With regard to monitoring conditions, I generally always included a special condition in each Permit that I issued requiring the installation of continuous water level monitoring equipment within the Permitted source well or a nearby well or wells within the same aquifer unit. Submission of the data electronically was also a requirement with any future application for renewal of the Permit. From established contacts with the client or their consultant, I was also able to generally access the data at any time in areas of intense groundwater competition.

I found that data from the installation and maintenance of monitoring equipment often proved more valuable to the client and provided conclusive evidence as to their “true” effect thus protecting their extensive financial investment in developing a surface or groundwater resource for site needs. Long term continuous monitoring is important to establish water level trends and help identify threats to the sustainability of the resource particularly in areas of intense competition for water. I fully support the retention of monitoring equipment in any Permit renewal and the release of the data to the public to alleviate their concerns.

When the PTTW program was first introduced in 1961, Conditions of each Permit required Permit Holders to maintain a daily log of their annual takings and submission of these records the following year. Although the ministry provided forms for this information listing date, hours of operation and pump capacity, only a small percentage of these paper records were ever submitted annually and of these only a fraction provided any decent information. By the mid to late 1970’s the practice was eventually scrapped.

In 2004, the record keeping requirement was reintroduced and became mandatory for all Permit Holders by 2009. Although I believe these records are now submitted and stored electronically, they have only been accessible to Ministry staff. There was however a recent announcement that access to the information will soon be open to the public. As I used that information extensively prior to my retirement, I applaud that move since the information will be very helpful in calculating water budgets and transparency to the public as a whole.

Conclusion
As consumptive water takings like bottled water definitely do not have any significant and in most cases any measureable impact on ground or surface water resources and I agree that these takers should be treated the same as any other water taker. As mentioned earlier, I strongly believe that the real issue with the bottled water industry is the recovery and disposal of the plastic bottles used in marketing these products. Granted there needs to be a cheap container associated with its use however every time I see a sale on bottled water products at the grocery store I am appalled by the consumers rush to buy the product in bulk with little or no consideration for the end use of the containers.
While many municipalities operate programs to recycle the plastic containers, I’m sure the recovery percentage is small in comparison to the total sales. To support recycling programs and to encourage returns, I support the government’s idea to increase the cost of the taking but to ensure that bottled water operators are treated equally theoretically all water takers therefore would be subject to similar fees.

Having dealt with Water Taking Permits for so many years, I found that municipal water takings are by far the biggest users throughout the Province. Since the implantation of charges for water takings by many municipalities or small communal water systems could potentially bankrupt these operations, I strongly believe water for public consumption should be exempt and that fees should apply only to commercial or industrial operations. To fairly implement charges to all commercial and industrial users, all Permits including a duplication of pumping as described earlier would need to be revised. Release of the annual water taking records for Permit Holders to the public as proposed would provide transparency and a check on their usage.