I am concerned about ERO …

I am concerned about ERO #025-0730 and if the posting contains all relevant information for people to properly comment, which is what is needed for meaningful consultation. I'm worried that this proposal is another sweeping erosion of Ontario’s environmental protections, which also undermines public oversight and Indigenous rights, and accelerates water privatization and exploitation.

While I acknowledge that streamlining processes is often to improve efficiencies, I believe that this might be giving too much flexibility to corporations seeking profit. This posting would apply to all water-taking permits (e.g., water bottling, aggregate operations, mining, exploration, industrial uses, and other commercial extractions). Regulations should be applied to corporations so that profit is not taken at the expense of individuals, especially concerning water (a basic human right).

If this posting means the proposal would apply retroactively, maybe including expired permits, I worry about accountability, regulatory integrity, and continual water-taking. As climate change worsens, especially since the Ontario government is not combating it, water is going to become needed more and more by individuals. I do not want to see injustice over water. We are in a climate crisis and a biodiversity crisis.

If water-taking permits are transferable, this will raise concerns for environmental integrity, community protections, and public trust. Ontario’s current policy cancels a permit upon transfer of ownership, which I think allows Ontario to understand any changes in the company without blindly accepting that everything will be the same (e.g., intended use of water), that the company will follow rules (e.g., protection of ecosystems, wetlands and drinking water), that the company has good intentions (e.g., a good track record, no legal liabilities, proper facilities,proper scientific understanding of water processes), and allows for public engagement and transparency. Rules exist to avoid water exploitation. How is the proposal going to ensure water is not exploited? Granting automatic/retroactive permit transfers could erode regulatory standards, reduce effective monitoring, and create loopholes.

I'm concerned this proposal would bypass legal Indigenous consultation. Ontario is committed to the duty to consult, which should be furthered by free, prior and informed consent. Removing Indigenous consultation would go against Ontario's legal duty and be a step backwards in reconciliation.

As mentioned, we are in a climate crisis. There is so much instability, extreme weather events, and unknwon, that Ontario should not weaken its groundwater protections. it should strengthen them because aquifers are finite and can be over-extracted. Canada is home to 25% of the world freshwater (though only 7% is renewable). We have a responsibility to be responsible for the water we have access to.

Automatically renewing or not reviewing permit transfers may result in unsustainable withdrawals, degradation of wetlands and freshwater ecosystems (critical for filtering water, protection from erosion and flooding, saving us money, home for biodiversity, etc), and reduced agricultural resilience and amount of drinking water.

If this proposal allows permits to operate without oversight, this could be a national water security issue. Canada’s freshwater should not become locked into trade obligations under agreements like NAFTA/USMCA. That would restrict future governments’ ability to protect or reclaim control over water.

Is this proposal really in the public interest? I have very little faith in the Ontario government given its history of stripping environmental protection, a lot of which is essential for public health. Is it also ethical? I do not want to see corporations take advantage of a streamlined process for profit. I do not want to see land purchased just to extract water, reduced transparency about water users and activities, degradation of trust, regulations treating water as a privatized commodity at the expense of the public, ecological health, intergenerational equity, and democratic governance of water.

Many Ontarians have been voicing concerns about the environment, to which the Ontario government has not listened. I would like to see comments seriously taken into consideration for this proposal. I would like to see stronger oversight of large-volume water use, fewer water takings serving private profit over public need, greaterprotections for groundwater to help the climate and biodiversity crises that affect us all, consideration of cumulative impacts and place-based water availability in permitting, and a democratic process.

I am concerned that this proposal will allow for water extraction without oversight by allowing permits to be transferred without scrutiny, consultation, or environmental review. What if this propsoal leads to an endless system of permitting that sidesteps accountability and accelerates ecological harm?

I request that this proposal not be taken lightly, that all information is provided by the public, that new permit holders apply for new permits to allow a public, scientific and Indigenous-informed review. Please uphold Indigenous consultation. Please do not treat water as a private asset. That's not the kind of Ontario I want. Thank you