EBR Registry Number: 013…

EBR Registry Number: 013-3974

Comment Ice River Springs is an Ontario based company headquartered in Shelburne, ON with six plants in the province of Ontario: one recycling plant, one film extrusion plant, one recycled plastic outdoor furniture plant and three Ontario bottling plants, three plants in Quebec, Alberta and British Columbia and six plants in the USA. Since IR started in 1995, it has created rural jobs in the
Province and currently employs 550 associates in Ontario.
Ice River Springs is a leading innovator in environmental sustainability while providing consumers with healthy products. IR is the only beverage company in North America to operate its own closed­loop system; it has an in­house plastic recycling facility that takes in baled, post­consumer plastic from municipal recycling centers, purifying and transforming the PET plastic into brand new bottles again and again. IR is completely vertically integrated from the water source to bottle and cap manufacturing, producing beverages in 100 percent recycled PET bottles.
Ice River Springs’ closed­loop recycling plant located in Shelburne, Ontario is unique and makes IR the only North American bottler capable of producing 100% recycled content bottles in a closed­loop system. IR purchases over 85% of the plastic #1 (PET) picked up by municipal curbside recycling programs in Ontario. It also keeps green plastic (mainly soft drink bottles) out of landfills as it makes the Ice River Green bottled water brand in 100% green recycled bottles.
By purchasing used plastic from municipalities, Ice River Springs has created, through its own private investment, a stable market for recycled plastic in terms of volume and market price to the benefit of these municipalities and their recycling partners. Ice River Springs is the only beverage company having implemented a circular economy in Ontario.
Ice River Springs is fully committed to good health, the environment and the Province of Ontario.
At the same time, Ice River Springs feels that provincial regulation misses the real value in the local bottled water industry and unfortunately adopts disproportionate regulations causing negative effects for the industry and threatening local Ontario manufacturing jobs.
Please consider the following examples:
1­ EBR 013­3974 targets a category which is healthy and which is an alternative to soft drink and other sweetened beverages. The fact water is the healthiest beverage option available is important to note. Health providers and policy makers are struggling with sharply increased rates of diabetes and obesity. Water, both bottled and tap, is the healthy choice. According to a study conducted by Probe Research Inc., 70% of adults buy bottled water as an alternative to buying other packaged beverages.

2­ EBR 013­3974 targets an industry which accounts for less than two­tenths of one percent (<0.2%) of all permitted water taking in Ontario. The bottled water industry in Ontario uses only as much water as ten (10) golf courses, and there are 822 golf courses in Ontario. The bottled water industry is only one among thousands of food, beverage, recreational, and commercial users of water. Ice River Springs supports comprehensive ground water management practices that are science­based, treat all users equitably, and provide for future needs of this vital resource. Sustainable water management is a crucial part of the bottled water industry's business. We fully support protecting Canada's precious resource and have environmental, health, and economic reasons to do so. If the government is serious about water conservation, it must review takings and permitting for all water takers.
3­ EBR 013­3974, via the limitation of water permits, would prevent local Ontario companies from growing and would encourage the imports from other provinces and countries. Why would the government of Ontario support growth of companies not located in Ontario? The existing permit conditions for bottled water are based on scientific best practices, and the technical understanding and input of regulatory staff and professionally licensed hydrogeologists. Ontario’s MOECC is already regarded as having one of the leading water management regimes in North America. Suggestions that the MOECC is not already doing enough to regulate and manage the province’s water is without foundation.
4­ EBR 013­3974 would impose requirements which are not science or fact based. From a technical standpoint, Ice River Springs does not support: a) the use of mandated water use restrictions for only bottled water takings, b) attempts to limit the gathering of information such as the use of pumping tests through onerous consultation requirements, c) non­science based permit limits, and d) targeted requirements for updating Source Water Protection plans. These requirements are not supported by groundwater science or based on the existing monitoring results from current bottled water operations.
5­ EBR 013­3974, via the implementation of new charges, would increase the cost of Ontario bottled waters to the Ontario customers, making the bottled water imported into Ontario more competitive. This policy would put the local spring water companies at a severe and inequitable financial disadvantage vs. the imports, other Canadian provinces and bottled water manufacturers buying water from municipalities and wells, because they avoid paying the fees and new regulations!
6­ While not unique to bottled water plants, power cost in Ontario is one of the most expensive in North America, and threatens future investment in expanding IR recycling operations.

Ice River Springs, as a leader within the bottled water industry, embraces the protection and management of groundwater resources. IR believes that the management of the province’s water by the MOECC is appropriate and science and fact based.
Ice River Springs does not support the use of mandated water use restrictions, permit limits, and targeted requirement for updating Source Water Protection plans specifically targeting bottled water. These requirements are not supported by groundwater science or based on the existing monitoring results from current bottled water operations in Ontario. Decisions with respect to managing groundwater resources should be based on scientific best practices, and the technical understanding and input of regulatory staff and professionally licensed consultants.
Finally, only about 4% of permitted water takers are paying the permit fees today in Ontario. If the Government’s goal is to protect water, this should not be about the bottled water industry, which is a very small user. We believe that all permitted water users should abide by the same rules and pay a fee.