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1. Municipal Input

- Under the proposal, municipalities will have input on whether water bottling can occur in their area. Municipalities should have the power to reject an operation. This is more democratic and reflects the will of the residents affected by the bottling operation.

- Municipalities will only have input on new permits. They will have no influence on renewals. Municipalites should have input on the renewal of permits as well. This should be added to the proposed changes.

- Under the proposal, municipalities can only object to a bottling operation based on its potential harm to water quantity or water quality. Municipalites need funding to research how the bottling operation will affect water quality and quantity. They should be able to object based on moral and ethical reasons as well. Given climate change concerns about plastic pollution, do we really want to maintain the water bottling business?

- Indigenous people should have the right to informed consent regarding bottling operations on their land.

2. Water-use Prioritization
This is great but this process should anticipate the impact of climate change on groundwater. Assessing environmental needs is a complex process. Funding for research is required for informed decision-making regarding new permits.

3. Area-based management
This is a good change given localized drought occurrences. Conservation authorities should continue groundwater and surface water management on a watershed scale.
Who will be on these stakeholder committees?

4. Transparency - making data public
This is a good idea. A database is important not only for water managers, conservation authorities and ministries, but also to ensure Indigenous and public involvement and participation in any issues and conflicts regarding water.

Other Comments
The water-raking industry should be phased out over the next five years. It is not sustainable. Save our Water pointed out the concerns about the future of the plastic water bottling industry as outlined below. I could not say it any better.

If this government is committed to fighting climate change, it must consider that combining all of the energy input totals from the use of plastic, to production, to transportation, “bottled water requires as much as 2,000 times the energy cost of producing tap water.” (P. H. Gleick and H. S. Cooley, “Energy Implications of bottled water,” Environmental Research Letters, 2009)

- If this government is committed to fighting plastic pollution, it must consider that “more than one billion plastic bottles are not recycled in Ontario and are lost to disposal every year” (Recycling Council of Ontario). And plastic lasts forever in the environment.

- We are still waiting for the study that will take societal and cultural values into account, including widespread opposition to the transformation of a public common good into a commodity.

Water is for life, not profit!