Re: ERO #025-0730 – Proposed…

Re: ERO #025-0730 – Proposed changes to water-taking permits.

It looks like these proposed changes have been spurred on by a recent purchase of a water bottling plant, with new owners hoping to side-step the important process to secure a water-taking permit for their operations, and being optimistic that the government decision would be retro-active?

It appears that lobbyists have had undue influence on government officials and the proposed amendments to the regulations, which focus on improving their bottom line. Alternatively, the public was given a brief 30 days to comment on these changes – that is, if people learn about this matter in time and if they can find/follow the ERO site/rules.

This process is flawed. It is alarming to see this government dismantling Ontario legislation at such a reckless pace, and with very little public awareness and input.

Environmental laws have taken years to bring into existence, and were made possible with input from diverse groups at open meetings with public participation, in-depth discussions and reviews. At that time, it was important to get the legislation right - since our very existence depends on clean water - it was a priority to keep this essential resource safe and public, for the present, and for future generations.

This government appears to have different priorities that focus on “providing greater flexibility and streamlining the process for proponents”. These “proponents”, or corporate lobbyists, pressure government officials to quickly adopt major changes to Ontario legislation that favour their private interests, not the best interests of the public.

The proposed changes aim to fast track water extraction and the transfer of permits. This sets a dangerous precedent that threatens informed reviews and the ability to reassess environmental impacts to safeguard the purpose of water-taking permits – to conserve and protect this essential public resource. It also creates a slippery slope from public to private control of our water. Water-taking permits are not transferable assets.

The changes are being made quietly through the ERO process, with limited public awareness or input. Indigenous communities and leaders have not been consulted, violating rights and treaties. Municipalities have been left out, which can have an impact on local decisions. Many communities in Ontario have serious water inequities and water quality issues. The changes being proposed do nothing to remedy this.

The role of our government is not to rally for corporate agendas that prioritize private profits and convenience over public and environmental safety, but to establish policies and procedures that provide effective oversight, compliance, and transparency in order to protect long-term environmental, social and economic well-being of public resources.

Any changes to the Ontario Water Resources Act (OWRA) must aim to increase and strengthen policies to protect and conserve water sources, not weaken those policies.

Water is an essential resource and a shared pubic trust. All permits to take water, including water bottling, mining and extraction, aggregate pits, industrial operations, and drinking water purposes, must involve public scrutiny and consent.

All applications for water-taking permits must include an effective review process that includes unbiased scientific input, participation from the public, indigenous communities and municipalities that may be impacted by the application.

Water-taking applications must consider the hierarchy of needs, with a focus on protecting the source for long-term human consumption for drinking and growing food, and ensuring the best environmental practices to achieve that.

Ontario water sources are increasingly experiencing increased stress from climate change, droughts, destruction of wetlands that help to filter our water systems, and increased population growth.

Water bottling plants are also a serious stress on water sources in Ontario, since more water is taken out of a groundwater source, than what goes back into it, causing accumulated effects and erosion of the water source.

Extracting groundwater to put into plastic bottles is unsustainable, and a waste of resources. These water bottling plants, mostly corporate conglomerates, make huge profits at the expense of public finances and our environment. Private ownership of our groundwater must not be permitted.

Most municipal water sources offer clean and safe water. Therefore, it is not a priority to extract water for the purpose of putting it in plastic bottles to sell to people who already have access to safe drinking water. Private convenience must not take precedence over public and environmental safety.

Water-taking applications must be transparent and involve information sharing, public forums, discussions and debates, and should include polling and surveys to reach the most favourable outcome for the community.

Our government needs to get serious about protecting public water for now and for future generations. This means no shortcuts. It means making water regulations stronger, not weaker. It involves encouraging the public to be part of the solution - offering unbiased education and information, open discussions and debates, and welcoming more perspectives and creative solutions that aim to keep this essential resource clean, safe, and public.

I oppose the proposed amendments to Water-Taking Permits (ERO #25-0730), and respectfully submit the following recommendations for consideration:

1. Improve and strengthen Ontario’s Lobbying Act to ensure that lobbyists do not exert undue influence over government officials.
2. When an ERO posting is made, include a list of lobbyists, who have communicated with public officials and topic details, under ‘Supporting Materials’.
3. Protect public interests and resources over corporate profiteering.
4. There must be no shortcuts. The priority for our government must be to keep essential resources safe and public, for the present, and for future generations.
5. Water is essential to life and must not be commodified. Any changes must improve and strengthen protections of this essential, shared public resource.
6. Corporations must not be allowed to own groundwater.
7. Our government must establish an effective process to consider all water-taking applications, which is transparent and includes education and unbiased information, public forums, discussions and debates, as well as polling and surveys, so the best decision is reached for the environment and the community.
8. Any water-taking application must focus on the purpose of taking water and the hierarchy of needs and must include an informed review process representing public, scientific, municipal and indigenous members.
9. Water-taking permits must not be transferable, and cancelled or revoked permits must require new applications and open reviews, as new factors could be relevant and this will help ensure operations meet the goals of OWRA.
10. Extracting water to put into plastic bottles is unsustainable and an irresponsible use of resources. Develop a plan to quickly phase-out the sale of water in plastic bottles, including bans and expanding public fountains and refill stations.
11. In order to reach the best decisions for Ontario, any changes to the Act must involve a transparent process that allows for full and informed discussions, healthy debate, and consent of the public, municipalities and indigenous communities.

I urge the ministry to reject the proposed changes to permits to take water regulations.