The reasons behind this…

The reasons behind this proposal seem to be misguided. The following bullet points outline my concerns with the proposed changes.

- Allowing people to apply for a permit in a “streamlined process” if they already have a permit, and will not being changing it, completely disregards the potential for conditions and knowledge to change. With climate change and increased urbanization, the conditions of a water course when a permit was initially authorized might be completely different. Our knowledge on the most effective ways to regulate water taking might also evolve. If too many water taking permits for a watercourse were approved, a streamlined processes will not allow for this to be resolved. Reduced water within a river or lake can decrease the biodiversity of riparian ecosystems and can increase flood risks. Without sufficient permitting processes by implementation of “streamlined processes” we remove the ability for our regulations to keep up with scientific knowledge, changing environmental and social situations. This will in the long run be detrimental to the environment and public safety and security.

- Providing relief for administrative oversight, it not a valid reason to remove purposeful environmental protections. If a person can be negatively affected by the complexities of the regulation, they should do their due diligence to know how to avoid these "issues". If the Ministry of the Environment, Conservation and Parks is concerned with proponents being negatively affected by this, instead of changing the regulation, they can increase public awareness on how the process works. For example, providing clear pamphlets, advertisements, emails (to existing permit holders) that outline how water taking permitting works (especially when selling a property)

- Stating that the municipal resolution would not be required for permits regarding bottled water disregards the potential for the municipalities position on the permit to change. A municipalities position might change for many reasons. Including i) As climate change causes uncertainty in the amount of water flowing through rivers, lakes, streams, wetlands etc increasing concerns with water taking might be established ii) Future research can shed light on the environmental and social effects of water taking iii) Negative effects of the pre-existing permit may have become evident after it was originally approved

- Creating more flexibility within a regulation makes it more difficult to regulate things consistently and will create the potential for more loopholes to be created