Re: ERO#019-1340 Goal 1 I…

Re: ERO#019-1340

Goal 1

I support including priorities of water use in regulation. I agree that the environment/ecosystem needs and municipal drinking water should be the first two priorities, followed by agriculture, as these uses of water are essential for human and ecosystem survival. Industrial/commercial and aesthetic uses are not essential for survival, and should therefore be prioritized lower (this includes water taking for water bottling). Municipal drinking water needs should reflect current use as well as planned growth. Conversely, growth should be limited with water availability and risk.

The proposal lists environmental needs as a high priority, but the science report indicates that assessing environmental needs is a difficult, complex problem. It expresses the need for improvement in understanding the cumulative effects of total water takings on surface water, groundwater, and deep aquifers over the long term. It also expresses the need to better understand the environmental flows of streams and rivers.

The report also expresses the need for improvement in how to prepare and manage water takings during a drought. Therefore, funding for research and expertise are needed for decisions about permits. Conservation authorities should also be involved.

Goal 2

The proposal recommends that water be managed on a regional area basis rather than a permit-by-permit basis, focusing attention on water-quantity stressed areas. This seems like a good idea. We would also encourage groundwater and surface water management still be continued on a watershed scale, under conservation authorities.
The policy study and report on how to better manage Ontario’s water appears to make good sense from a groundwater management perspective. However, Ontarians understand that for any water taking there are environmental trade-offs, and societal values are important, particularly about bottled water. With water taken from an aquifer, we end up with a product that is, for most, unnecessary and is in fact harmful to the environment.

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.

Local water users should be consulted in accessible formats, such as Town Halls and online feedback portals, newspaper bulletins, etc. There must be a study that will recognize the need to meaningfully include Indigenous peoples and Indigenous interests, knowledge systems and values in water planning and in protecting and conserving water for future generations. The study must also take societal and cultural values into account, including widespread opposition to the transformation of a public common good into a commodity.

Goal 3

An accessible database platform for 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.

All data should be made publicly available. Water is a public resource and absolute transparency around its use is required. Information and guidance around topics such as watersheds, aquifers, ecosystem uses of water, and water quality should be made available, as well as information/guidance on Ontarians’ water-related rights and legal/procedural options.

A map format through which area-based information/reports/tables/story pages are accessible would be a user-friendly way to present data.

Goal 4

I support the proposal to require water bottling companies to seek support from their host municipality when applying for a Permit to Take Water. Requiring this input from the municipality is democratic and gives residents, councillors and communities a louder voice.

It is not the right of water bottling companies to extract water from a municipality. The municipality’s drinking water needs should be prioritized over eater taking for bottling, as this is a commercial use of water from which the bottling companies profit. If a company wishes to apply for a permit, it should do so only after extensive consultation with the municipal Council as well as the community itself.

It should be noted that this support will not be required for smaller water takings. Within stressed areas, the threshold for host municipality input should be reduced to the permit to take water threshold of 50,000 litres per day so the cumulative impact of all permitted takings can be considered.