Thank you for considering…

Thank you for considering this input on the proposal: Updating Ontario’s Water Quantity Management Framework. I have many comments, which I’ve attempted to organize under the questions posed in the report.

Goal 1 Questions

1. Do you support including priorities of water use in regulation? Why or why not?

Identifying priorities is a good idea. It looks like the priorities have already been identified in the report, which is problematic. The BluMetric report says: Ontario should require that watersheds proactively develop a prioritization scheme on a local scale with stakeholder involvement, as it is value-based and may change over time, and which should also be revisited and reassessed on a regular basis. What is the plan to develop a prioritization scheme and revisit and reassess it on a regular basis? What kind of input will the public have on the overall priorities?

It’s not clear where bottled water fits in the priorities identified in the government’s report (in the BluMetric report it is included under Commercial). I have an uneasy feeling that in some cases or at a future date, commercially-bottled water will be allowed to fall under the Drinking Water category, which would be a disastrous decision. Can this be clarified?

2. How should priorities of use be applied to water taking decisions? When should it be applied? What process should be followed? Who should be involved? What information should be considered?

Once the priorities of use are understood and agreed upon, they need to be applied immediately and consistently. We are currently in crisis, and we shouldn’t be waiting until there is a conflict or a dire emergency to operate according to priorities and principles.
Safe drinking water for everyone (not just in municipalities, and including First Nations) is the top priority, and commercially-bottled water does not count. The federal and provincial governments together should be putting in place the infrastructure and management that is needed to bring safe drinking water to everyone, and they should be providing water to those who don’t have it in the meantime. Letting companies take water and bottle it to sell at an immense profit is not effective or principled management.

3. Municipal drinking water supply is proposed as a highest priority use. What municipal drinking water needs should be considered a priority (e.g., current, planned growth, longer-term growth)?

The COVID-19 pandemic is forcing us to acknowledge the interconnectedness of environmental, social, racial and economic justice. The only way to create something better out of the current crisis is to apply an environmental and social justice lens to discussions and decisions. From that perspective, all three of the timelines mentioned need to be part of this top priority. As noted in the answer to question 2, the immediate need is safe drinking water for everyone. Planned growth needs to include consideration of how that growth will impact water quantity, and look at sustainable methods to address this (not to mention that some growth will be unplanned, such as rapid intake of large populations due to displacement from climate change, which we know is going to occur). We also know that drought, increasingly high temperatures and catastrophic weather events will impact systems and water quantity, and the time to plan for those changes has to be well before they happen.

All uses of water should be reviewed with this lens now. Bottled water is not essential, and should be phased out beginning immediately. Commercially-bottled water provides little in the way of economic benefits either in terms of income or jobs – not nearly the jobs that would be realized through construction and maintenance of the infrastructure needed for a proper water supply throughout the province, as well as system monitoring and management.

Goal 2 Questions

1. Under what circumstances should the ministry consider assessing and managing water takings on an area basis?

The BluMetric report seems to suggest that this be done under all circumstances. A provincial approach would also be helpful, along with regional approaches in areas that share watersheds interprovincially and/or with the US. Water is a universal requirement for life, and it is finite. If it is not taken seriously, it’s inevitable that conflict will result. That will not be the time to try and undertake regional approaches.

2. What suggestions do you have for the process of assessing and developing a strategy to manage water takings on an area basis? For example, how should local water users, stakeholders, and Indigenous communities be engaged?

There are processes in mediation and conflict resolution that begin from identifying common ground and proceed collaboratively. Along with environmental and resource management experts, we should be listening too and learning from Indigenous and First Nations communities who have thousands of years of knowledge and experience. We also should be listening to systemically disadvantaged communities who have historically and still experience insecurity with water supply and other utilities.

3. How can the province help water users be more prepared for drought?

As above, learn from Indigenous wisdom and experience. Look at ways to reduce consumption now, and provide incentives for individuals and businesses to reduce consumption. Apply the priorities referred to in the first section so that water isn’t spent on non-essential services until safe drinking water is available to all Ontarians. Build water knowledge and literacy so that people understand the factors implementing water quantity and supply. Involve people in planning for water shortages, not in an abstract way but with the recognition that it is an inevitable outcome.

Goal 3 Questions
1. Is there any water quantity and monitoring information reported to the ministry that should not be made publicly available? If so, why?
I cannot think of any information that shouldn’t be publicly available. For questions 2-5, I don’t have the background to answer specifically because I don’t typically deal with this kind of data. I feel it would be helpful to make the data transparent and available, and it would be helpful to include some kind of analysis or online tool for analyzing the data.

The requirement to obtain support from the host municipality would apply to companies that are proposing a new or increased water taking for the purpose of producing bottled water. It would be limited to water bottling companies that have total maximum permitted daily water takings – cumulatively within the host municipality, including currently authorized and proposed amounts – of greater than 379,000 litres per day. C
The requirement would also not apply to: • A facility that needs to renew an existing permit for the same or lower permitted volume, the same purpose and the same location of water taking • A water bottling company that requires a short-term permit to conduct a pumping test • A water bottling facility that gets its water from a municipal water supply • A facility that is proposing a water taking within an unorganized territory (i.e., an area with no local municipality)

Goal 4 Questions

1. Do you support the proposal to require water bottling companies to seek support from their host municipality when applying for a Permit to Take Water? Why or why not?

This is not a yes or no question. In terms of consultation with local communities, yes. But water bottling companies should not be selling local communities or municipalities on the perceived benefits of their operations. Clearly they will promote the fact that they are bringing jobs to the area and not impacting the water supply, and they will have the money to pay for the reports and promotional material to back up their perspective. Municipalities will have to find funds to pay for research and reports to counteract the corporate information, as it is a requirement for municipalities to provide rationale for not supporting an application.

Along with leading to inconsistent decision-making across the province, this approach fosters conflict within communities and between municipalities and regions. Also, this question is disingenuous because the requirement for support is only for new or expanded permits; it doesn’t deal with current permits which are causing conflict in regions right now. It also doesn’t cover “small businesses” which can take up to 379,000 liters/day without the support of the municipality - and it doesn’t address unorganized territories, which leaves a gap for water bottling companies to exploit.

The BluMetric report says water bottling companies shouldn’t be treated any differently than other water-takers; decisions on permits should always be based on the impact the water-taking will have on water quantity, not the end use of the water. I disagree: the end use of the water is precisely the determining factor that should be considered. Water is not a manufactured commodity; it is essential to life and it is finite. The whole point of setting priorities for water management (in question 1) indicates that the end use of the water is in fact what is important. Bottled water is not a necessity.

During the COVID-19 pandemic, there has been significant public enthusiasm for embracing scientific analysis to better understand the pandemic. As a result, organizations and governments alike have begun to include terms like “evidence-based” and “scientific approach” exponentially in reports and statements. Listening to scientists is exactly what governments (and all of us) need to do, but it does not excuse any government from making policy that is for the common good. We listen to our public health officers because they represented scientific evidence and also because they brought the human element to their analysis, recommendations, and decisions. That is government’s job.

On p. 9 of this report, you note that
Looking to the future, changing climate and population growth may affect water sustainability in the province. Population growth and its accompanying demands for water raises questions about the future availability of water for municipal water supply, and the impacts of increasing municipal water takings on water resources and other water users over the long term. There is also some uncertainty as to how changes in climate and land use will affect the long-term sustainability of groundwater and surface water in some areas.

This is stated more clearly in the BluMetric report, in which BluMetric predicted that the sustainability of future groundwater and/or surface water supply in six out of the seven areas they studied is either uncertain or will be outright lacking. There is no reason to doubt that drought, heat, weather events, population and changing land use will not impact us in the near future. So there is no reason to treat our current situation as a crisis, and propose to manage our water supply accordingly.

I have many other observations on the findings in the BluMetric report and the proposals in this report, and would be appreciative of further opportunities to share those with you.