Consent is not transferrable…

Consent is not transferrable. Think of it in terms of relationships and it makes it crystal clear. It is not just the first time you gave consent so now it is always yes. It is not I gave consent to this person and they can pass that consent to others. Creepy right!

Well this proposal to create 'flexibility' for water taking permits is creepy to those of us who care about water. It has the potential to lead to the abuse of water taking.

We need to respect water and the communities and environment affected when water taking permits are requested. Facts and considerations need to be made to make informed decisions as to whether or not a permit should be issued to the company, corporation or individual requesting it.

Indigenous communities from whose treaty lands this water is extracted, while many still experience water insecurity, need to be consulted. Canada has a commitment to UNDRIP and signed the act.

Passing on water taking permits to those who were not given direct permission and without Indigenous and public consultation sounds like serious red flags that could lead to both market monopoly and ecosystem problems.

Ontario’s current rules rightly require that a new owner must apply for a new Permit to Take Water (PTTW). This process ensures:

· Environmental assessment of changing conditions;

· Public consultation and transparency;

· Review of purpose, volume, and ecological risks;

· Adherence to Indigenous rights and duty to consult.

Allowing automatic permit transfers bypasses all of these safeguards.

Do not bypass prior informed consent by passing on water taking permits.

Remember, consent is non-transferable.