While the ministry should be…

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While the ministry should be applauded for attempting to ensure Ontario’s water resources are both protected and maintained, there still is some confusion as to how this goal will be achieved.

There is the claim that the ministry desires to make water taking data available to the public to increase transparency of how Ontario manages water resources. It also indicates the need to assess and manage multiple water takings together in areas of the province where water sustainability is regarded a concern.

While these goals are commendable there is little information given as to how the ministry will actually accomplish this. Goals are well and good but if there is a lack of action they are nothing but pipe dreams. From where will the data be derived? Who will obtain and assess data and inform the public?

On April 1st, 2021 the Provincial government will end the moratorium on the issuing of new permits to take water (PTTW) for bottling that has been in effect since December 2016. What has been learned during the moratorium that gives the ministry confidence to end it?

The assumption has been made by the ministry that there is sufficient water to meet the needs of most Ontarians but is that truly the case? Water is finite. Consequently, if we grow in population and develop more and more natural land and if a particular community that lies far from a large body of water is already experiencing insufficient water, can there not be a presumption that the community will be threatened even more so; particularly if the community has a commercial water bottler holding a well and petitioning to obtain a PTTW to pump a large volume of water for bottling purposes?

If we accept that in some cases certain communities are more at risk of exhausting their water supply than others, should the ministry therefore not deduce that making broad statements concerning water quantity could lead to possible calamity?

In the MECP report of May 19th, 2020, Ontario’s Bottled Water Moratorium, there is the bold statement “Bottled water takings are not impacting the sustainability of groundwater resources in Ontario or other water resources users.” However, the evidence supplied relates to the findings of a third party that reviewed just ten current bottled water permits that were based on original hydrogeological work conducted by the proponent, that in some cases were several decades ago. Based on the evidence supplied, the conclusion reached by the ministry that water bottling does not impact groundwater resources is optimistic in the extreme.

In all likelihood there would never have been a moratorium in the first place if it had not been for the purchase of the Middlebrook well, located in Centre Wellington, by a major water bottling company. This well was purchased after it became known that the local township had shown interest in buying the well to expand its municipal water system.

The community outcry was such that government initiated, possibly begrudgingly, the moratorium. Thus, a province wide moratorium was enacted due to a single local event.

In the case of Centre Wellington, a subsequent Tier 3 Water Budget study conducted by the Provincial government determined that Centre Wellington was at a significant risk of having insufficient water to meet its future population expectations and to attract future new business. Centre Wellington’s own Water Supply Master Plan (WSMP) has determined that the township needs a minimum of four new municipal wells by 2026.

In this new proposal the ministry states it will establish priorities of water use in the province that can guide water taking decisions but gives no information as to how this will be accomplished. It does suggest there be a requirement for water bottling companies to have the support of their host municipalities for new and increased water taking for bottling. This is a positive step, especially for a community already experiencing a water shortage. However, the ministry diminishes this positive step by the creation of a threshold of 379,000 litres per day that will be permitted even if the host municipality objects to a permit being issued.

In the case of Centre Wellington, nothing has changed. It is still a community with a significant risk of running out of water. It can ill afford the potential loss of 379,000 litres each and every day to a business that is not welcome. Why is the threshold so high? Why 379,000 litres? Why not 50,000 litres, the level at which an actual PTTW is required?

For the past five years the Township of Centre Wellington has stated on many occasions to the Provincial Government that “it is not a willing host community to any new commercial water bottling operation or the taking of water for that purpose under any circumstances”. How much clearer can that be?

In essence the government is implying that the municipality has a veto on water taking and can withhold its support but in reality the ministry is permitting a water bottling company to remove much needed water from a community in dire straits. So much for making the claim that it is ensuring the protection of water resources!

Municipal water supply is categorized as Priority Two by the ministry. Water bottling operations is categorized as Priority Three. Centre Wellington requires four new municipal wells by 2026. Yet the ministry is suggesting that it is acceptable for a water bottling company to remove approximately half the quantity of what a current municipal well might pump each day.

It is possible the ministry is correct in determining that water bottling does not impact the sustainability of groundwater resources but to suggest that sustainability is province wide is both reckless and incorrect; it is not based on sound data. Determining groundwater quantity is an inexact science at best.

There is much supposition exercised by the ministry in this proposal, particularly around the new parameters of ministerial governance and public transparency. While it may sound good on paper, much of the new procedures will take resources the ministry may not have.

For instance:

a) What does the ministry actually mean when “an area-based approach is needed”?

b) What is meant when it is stated “a strategy for assessing and managing water takings in such an area will be developed”?

c) How will the ministry “implement the proposal that sets out priorities of water use that would be taken into account when considering whether to renew, cancel, or amend existing permits in situations where there are competing demands for water among established users that cannot be resolved through other means”?

d) How will the PTTW Director determine if a proposed water taking site is appropriate? What are the parameters that determine a yea or a nay?

e) Once a permit is issued to an applicant what ministerial control exists and how is it exercised? With the proposed change whereby the water permit holder will no longer be required to “create and maintain a website to post their water taking records”, how will the ministry be able to provide public transparency on the water taking?

Considering the ministry’s emphasis on the need for public transparency, it is surprising that it is proposing further changes that actually reduce transparency. Suggesting that postings of renewal applications on the Environmental Registry of Ontario be reduced from 90 days to 30 days will certainly do nothing for public trust. Why the need for such a dramatic reduction in response time? If the ministry truly wants input from the citizens of Ontario, it needs to allow a reasonable amount of time for research and documenting valid responses.

Likewise, what is the intention of issuing a PTTW for a maximum period of ten years from the present five years? With global warming and population growth, it is most likely that groundwater levels will deteriorate during the term of the permit. Why then extend the terms of the permit? Again, this proposed change could be viewed as reckless.
Whenever a community experiences drought conditions, the municipality can enact bylaws to reduce water taking on the part of its citizens, yet the ministry is proposing to remove the mandatory reductions in water taking by a water bottler during a drought. Why does the ministry place more importance on water bottlers than citizens by exempting bottlers from these restrictions?

The statement that the PTTW Director would retain the authority under the Ontario Water Resources Act to order decreases in water taking at any time is disingenuous at best. It is very unlikely the Director will take this action unless there are widespread complaints from the municipality or members of the public. There needs to be a proactive response structure in place for this situation and nothing within this document suggests that exists.

Finally, in the past year the Provincial government has initiated policies that could be viewed as contrary to the protection of Ontario’s environment. The pro-business stance the government has seemingly taken gives no environmentally conscious citizen confidence that the path taken is one where actual protection of groundwater has been truly considered.

The weakening of Conservation Authorities power by this government is a direct assault on protection of Ontario’s ecosystem, namely “protection of instream flows (streams, rivers) and water levels (lakes, aquifers) for the purposes of sustainable water management, such as the protection of aquatic ecosystems or mitigating impacts of water quality degradation”. This falls within Priority One of the ministry’s Water Quantity Management Implementation Guide.

Therefore, how then can citizens view the content of ERO-019-2017 with anything other than scepticism?