Please accept these comments…

*Also submitted via e-mail: waterpolicy@ontario.ca

Please accept these comments from Environmental Defence on Ontario’s proposed extension of the moratorium on the issuance of new or increasing permits to take water for water bottling (“Extending the moratorium on water bottling permits”, EBR Registry Number: 013-3974).

The moratorium was an important step to protecting Ontario’s groundwater, and since it was passed in fall of 2016, it has provided time for scientific review of our groundwater resources in the province. We are strongly in favour of the proposed extension, as the results of the review have not yet been delivered. Failure to extend the moratorium until the review is complete would be irresponsible. Any decision to issue water taking permits for water bottlers should be based in up to date and scientific data and as complete a picture of the state of the aquifer as possible.

There are currently many unknowns about Ontario’s groundwater resources and their vulnerability to overuse, and potential impacts from climate change such as extended periods of drought. Priorities for access to groundwater must be clear and ranked in the following order: priority access for drinking water, use in agriculture, then – if sustainable, use for industry. Without a sound scientific understanding of the state of Ontario’s groundwater, governments cannot make informed decisions on allocating the precious resource.

It is therefore essential that any new or extended permit for water bottling be weighed against the results of the currently ongoing groundwater review. The current moratorium must be extended until January 2020, and long enough for the review to be completed and consulted on with the public and with the Water Quantity Protection External Working Group.

In fall 2016, when the moratorium was originally proposed, we submitted several recommendations and priorities. We would like to once again urge the Ministry of Environment, Conservation and Parks to ensure this groundwater review process yields:
1. A thorough and comprehensive understanding of the hydrogeology of surface and groundwater resources throughout the province, that anticipates future demand from increasing population growth and the impacts of climate change;
2. A science-based, precautionary approach to approving water-taking permits where community, agricultural and ecosystem needs are prioritized over water bottlers;
3. Strong government oversight to ensure appropriate monitoring and timely responses to conditions that could negatively impact groundwater levels. Raw monitoring data and scientific analysis should be available to the public and to third party peer review and analysis; and

Thank you for the opportunity to provide these comments meant to support Ontario’s proposed extension on the two year moratorium on new water bottling permits, and to encourage further action to safeguard Ontario’s freshwater.

If desired, we are willing to meet to discuss our submission with you.

Sincerely,

Kelsey Scarfone

Water Program Manager
Environmental Defence Canada