Comments On Updating…

Comments On Updating Ontario’s Water Quantity Management Framework

ERO 019-1340

I am pleased to have the opportunity to comment on the new policy framework for water management for Ontario. I view this opportunity as an important part of citizens helping make Ontario a great place to live as we go forward into the future.

First I want to recognize the clarity of presentation of the proposal and the presentation of the background materials. The proposal has some excellent suggestions for managing water supplies into the future.

Specific comments on the goals presented follow.
Goal 1. I agree with establishing priorities. I agree with the priorities as presented giving total environmental (water ecosystem), municipal, and agricultural needs highest priority.
I would strongly support consideration of long-term needs. Planning for water in the future certainly requires a long-term view. Decisions on water permits should absolutely include consideration of changes in population size over time.

Goal 2. I agree with considering water issues on an area basis. The definition of area could be refined. A watershed basis would seem to be an important definition of an area in many parts of the province. Much population growth and subsequent stress on aquifers in Ontario will occur in specific watersheds. For example, Guelph, Kitchener-Waterloo, and Cambridge all rely on water in the Grand River watershed. The impacts of increased water takings from any part of the watershed on waters in the aquifer should be included in assessments of water taking.

Goal 3. Availability of information is always important. There is no reason why any information on water taking should not be public. In part, municipal data on well depths, water levels, interference effects on other wells should all be available on line. Information relative to private or industrial water taking, depths of wells, and water levels should be readily available. Information from research groups should be available on line. Stream flow information should also be available on line. The policy being developed could include a requirement for permit applicants to supply information on data that is pertinent to the application for third party review. One useful management activity of the ministry could in fact be to develop water data bases . The ministry could also provide guidance and support for additional research on total water ecosystems, especially under future water usage, climate trends and variabilities such as drought. Such needs could be a part of the new management framework.

Goal 4. Water bottling companies should absolutely be required to have the support of the host municipality. The local municipality is the level of government that is most aware of the local needs in the short run and the long-term, and is the level of government most aware of the total water ecosystem of that area. That said, the provincial level should still maintain a final veto in terms of considering total water takings and needs on the larger provincial scale.
I would recommend deleting the exemption for the need for a permit for pump tests. Pump tests are an integral part of the water permit application process. Therefore the same requirement for municipal approval should be required as for the permit itself. Pump tests typically do not involve long-term pumping and impacts measured may have no relevance to adjacent municipal supplies over much longer time periods with increasing requirements over those time periods.
I would also suggest the policy should require municipalities provide reasons for rejections, but there should be no policy limitations on such reasons since such limitations may be overly narrow in the future and rather restrictive in meeting the goal of a strong water policy for the future.