Triton Water Canada Holdings, Inc. - Permit to take water

Comments relevant to the water taking proposal were considered as part of the review of the application. A summary of the comments and how they were considered follows:

• Comments were received urging the ministry to consider a limited permit duration in consideration of future municipal demands and potential interference with other water users over time. In response, the ministry has issued this Permit to Take Water (PTTW) for a period of five years. This will allow the ministry to review and confirm that this taking remains sustainable, and to adjust the monitoring program, if required to ensure protection of the environment and the fair sharing of water. It should also be noted that the ministry utilizes an adaptive management approach as part of the PTTW program and can amend permits at any time to reflect changing conditions.
   
• Comments were received in support of ongoing monitoring and transparency through monitoring and reporting conditions in the PTTW. The ministry has conducted a fulsome review of the monitoring program and are satisfied that the conditions included in the PTTW continue to achieve the goal to assess for potential impacts to natural heritage features and other users and overall sustainability of the taking. Annual reporting to the ministry will be required to allow for ongoing assessment for potential impacts associated with this taking, and to allow for permit amendments should any issues be identified. Conditions are also included in the PTTW that require that Triton make annual monitoring reports and application materials available to the public on a website and require Triton to host annual stakeholder meetings to receive comments and present findings of the monitoring program.


• Comments were received expressing concern regarding water taking during drought and low water advisories. Comments expressed support for including conditions requiring the mandatory reduction of water takings during low-water advisories. The ministry’s technical review has concluded that there are no unacceptable long-term or short-term (including during drought or low-water advisories) effects from this water taking, including impacts to existing water users or the environment. To address the concern, a condition has been included in the PTTW requiring that Triton increase monitoring and the review of monitoring data during a low-water advisory, and report to the ministry if any impacts are observed and recommend mitigative measures should these impacts be identified.


• Comments were received urging the ministry to consider the potential for impacts to natural heritage features (surface water features, wetlands, etc.). Triton has an established monitoring program designed to assess for the potential impacts to local environmental features, creeks, wetlands, etc. Based on our technical review of monitoring data collected under condition of previously issued PTTWs, no unacceptable impact to these features has been observed.
   
• Comments were received requesting consideration of cumulative impacts of the water taking. As part of their application package, Triton considered their taking in the broader regional context by assessing the proposed water taking using the City of Guelph’s Tier 3 Model, which helps to consider potential impacts to other water users in the area. Ministry technical reviewers have reviewed the results, along with data from the ongoing monitoring program at the Site and have not identified any concerns with respect to the proposed water taking as part of the broader cumulative regional takings.
   
• Comments were received that were supportive of the applications citing the Professional Geoscientists of Ontario report and the Blu Metric Report, commissioned by the ministry. These comments focused on the report’s stated position that evidence to this point in time showed that water bottling activities are not affecting the sustainability of groundwater resources.
   
• Comments were received urging the ministry to consider priorities of water use and climate change. To protect the long-term sustainability of surface water and groundwater, the province brought forward changes to its water quantity management framework to establish priorities of water use in the province that came into effect on April 1, 2021. These changes guide water taking decisions, assess and manage multiple water takings together in areas of the province where water sustainability is a concern, and make water taking data available to the public to increase transparency of how Ontario manages water resources. A condition identifying priorities of use has been included in this PTTW, identifying how these may be considered by the director in the event of a local shortage of water.


• Comments were received in support of banning water bottling as a commercial activity in Ontario, concern with the commodification of water and siting water as a human right. Over the past years, the ministry has thoroughly reviewed the province’s water taking policies, programs and science tools and held an independent third-party review of the findings on bottled water takings, which was completed by a panel of experts from Professional Geoscientists Ontario. The independent third-party review validated our findings that water takings for bottling are managed sustainably in Ontario under existing legislation, regulation and guidance and are not impacting the sustainability of groundwater resources. Ontario has strengthened groundwater protection by:
  • enhancing Ontario’s water taking program through regulatory amendments and providing new guidance to help permit holders to understand the new rules and how to operate within them
  • giving host municipalities more direct input on allowing bottled water companies to withdraw new or increased amounts of groundwater in their communities
  • charging a water bottling fee for water bottling companies that take groundwater, effective August 1, 2017
  • hiring an experienced water resources consulting firm, BluMetric Environmental Inc., to assess water resources in the province, in addition to our own ongoing review and analysis of water taking in Ontario, and
  • validating the ministry’s findings on water bottling through an independent third-party panel from the Professional Geoscientists Ontario.
     
• Stakeholders submitted concerns with plastic waste associated with the water bottling industry. The ministry is working to address the issue of plastic waste and litter by ensuring that plastics are recovered or recycled so that this valuable resource does not get sent to landfills or released into our environment.

Notification to Indigenous Communities

The following Indigenous communities were notified and provided details of the proposed permit renewal:

• Six Nations of the Grand River
• Mississaugas of the Credit First Nation
• Haudenosaunee Confederacy Chiefs Council

A response indicating no concern at the time was received from the Mississaugas of the Credit First Nation, they also indicated that they would like to be informed of any changes to the application. No comments or concerns were received from the other two communities notified.