Congratulations to all Wellington Water Watchers!
The Wynne government has heard us and is responding. This is great news and we deserve to celebrate together!
We are encouraged by the recent announcement by the Ontario Ministry of Environment and Climate Change (MOECC) of its intent to overhaul the permit to take water process, particularly as it pertains to the packaged water sector.
The 2-year moratorium on new permits of this kind is a big step. It means there is no possibility of a pump test at the Middlebrook well until January 2019! The Aberfoyle renewal is also now on hold until there are new regulations in place.
Points worth acknowledging in the current proposal:
- It will lead directly to stricter policies and regulations for the water bottling industry
- It acknowledges that parts of the province targeted for population growth have concerns related to future water security
- It recognizes the impacts of climate change on our water resources
- It acknowledges the need to prioritize water taking uses
- It acknowledges that Ontario’s groundwater needs to be better understood so that it can be effectively protected.
But this current proposal has not gone far enough. There are several important pieces missing.
It is possible to deny Nestlé more water and to have current permits turned down for renewal – and it has happened where communities fought really hard to get government to listen to the people and not listen to Nestlé. But this is not just about one corporation’s insatiable demand for our water, it is also about strengthening provincial regulations in order to help protect water across this beautiful province.
Now is the opportunity to have your voice heard to safeguard our precious water.
Please take a moment to craft your comment to Kathleen Wynne on what changes you want to see in the revamped permitting process and to show your support for the proposed moratorium.
It is important that your comments express your own opinion, but it might be helpful to review the points listed below and include those that resonate most with you when drafting your submission:
- Water is For Life, Not for Profit. Permitting water extraction for bottled water is “not appropriate” and we recommend that Ontario’s Permit-To-Take-Water policy set a leading example in the world and refuse permits for 100% consumptive uses. We call on the Ministry to promote water as a public trust, not a commodity to be sold.
- Adopt an ecosystem approach. We note that ecosystems receive inadequate mention in this proposal. For environmental protection and best resource management to ensure climate resilience, it is critical to factor in the needs of the ecosystem itself as a priority – composed of air, land, water and living organisms, including humans and the interactions among them, using risk management principles. We support recommendations of the Environmental Commissioner that the Ministry should develop a more comprehensive methodology to assess the water needs of ecosystems and have this become part of the application evaluation process.
- Consider cumulative effects. We recommend that water budget methods be applied to assess impacts of total water takings on a watershed-wide scale. We also see a need for improvement in the understanding of the cumulative impacts on surface water, groundwater and deep aquifers of total water takings within a watershed over the long term. Each permit request must also be assessed not just on the water taking alone but also on the cumulative environmental impact (trucking, plastic production and disposal, carbon emissions etc.) in accordance with the Climate Action Plan. A priority must be placed on preventing pollution and minimizing the creation of pollutants that can adversely affect the environment. We further suggest that trucking regulations be tied to the permits as in the Aggregate industry.
- Apply and honour the pre-cautionary principle. The Ministry has been operating with eyes blindfolded, issuing water permits for vast amounts without fully comprehending the groundwater availability. This is akin to writing cheques from a bank account without knowing the balance. The Ministry’s own Statement of Environmental Values includes a need to use a pre-cautionary, science-based approach in decision making to protect human health and the environment before any harm is done. When in doubt, no permit should be issued.
- Prioritize community use over industry use. There is a need for a meaningful tiered water approach. There needs to be clear ranking of the permits to determine when the tap gets shut down or reduced, in the event of droughts or climate uncertainty. Clearly, agricultural and municipal drinking water and sanitation uses as well as ecosystem needs rank well above commercial water bottling. Permits for water bottling must be vetted separately and it is our recommendation that they be refused.
- Align permit deadlines within watersheds. If all permits within a particular watershed were being considered at the same time, it would allow for regional planning on an ecosystem basis, using the best and most up-to-date science and adaptive management principles.
- Set fees to recover full costs. The costs paid for water taking permits need to balance the administrative costs associated with managing permits and the risks to the environment they pose. Not all permits are similar with many having no to low impact and others induce harm to local ecosystems and aquifers. Some permits require a lot more resources (i.e. staff time) and should therefore pay more. Historically, water-bottling permits require disproportionally high amounts of Ministry time and effort to evaluate and process, and the related charges should reflect this.
- Require independent third party, peer reviewed science. For increased transparency, timely reporting and enhanced ongoing engagement with the public as part of environmental decision making, it is important that raw science be openly available to third party peer review and analysis similar to scientific protocol standards. Reports from applicants are often bias in nature and can omit key negative findings.
- Require returnable, reusable beverage bottles. There is too much plastic in our world. There is no excuse for creating more when we see our world drowning in existing plastic that will never fully degrade. Recycling alone is not the solution. We need to stop creating it. Permits for all bottled beverages should be tied to a regulation that bottling is in returnable, reusable glass containers.
- Account for any extensions of an expired permit. If a permit extension is granted, and if the renewal decision is delayed more than 90 days past the existing permit expiry date, there should be notice given on the Environmental Registry and precautionary conservation restrictions should put in place by default.
- Weight municipal comments more heavily. The report recognizes that areas mandated for growing populations have heightened concerns related to water security. Assessments for permits should take into account interference with the orderly expansion of municipal water systems that will be required to efficiently service that increased population. As well as water quantity, municipal water quality issues and vulnerabilities should be assessed. Potential interference with private wells, as well as risks to the well field from large numbers of nearby private wells need consideration. It is imperative that where a potential water-taking permit would directly impede reaching projected growth targets, the municipality’s comment on the Environmental Registry be weighted more heavily, and that municipal comments be compiled through meaningful public consultation.
- Require periodic review of Water Management Program. Understanding of climate change is evolving and continued growth projections and groundwater science are continually improving, therefore it is important to periodically review permitting policy to best reflect the science and local agency. These reviews should be promoted publicly and offer user-friendly avenues for submitting comments.
- Phase out this sunset industry and provide employment transition support for all employees. Recognizing that the Permit-to-take-water policy was never intended for the direct bottling of and selling of our water, there is a responsibility on the Ministry’s part to acknowledge that some jobs were created within this loophole industry. We also suspect that when the water runs out, the corporations will just close shop and leave. Although outside of it’s usual purvey, the Ministry could proactively help transition employees of this industry to facilitate the phasing out of the water bottling permits.
- Evaluate impacts on current and future generations. When presented with any new or renewing permit, the Ministry should consider the effects of its decisions on current and future generations, consistent with sustainable development principles. It is clear that not only do these consumptive permits provide no benefit for future generations, they put them at risk by removing vast amounts of precious groundwater from Ontario while imposing billions of pieces of plastic waste onto current and generations to come.
- Improve access to safe, clean, reliable public water. A priority of this Ministry should be to rebuild trust in water as a public commons by making clean, safe, public water available for everyone in the province. Public water fountains should be mandated in all public spaces, eliminating the need for single-use, plastic disposable water containers and drastically diminishing the downloaded costs of plastic down-cycling.
- Consult with Treaty holders. When water-taking permits or permit renewals are requested, the Ministry must follow a full consultation with Treaty holder(s) on the lands in question. Permission from the Treaty holders(s) is imperative moving forward in a climate of reconciliation, recognizing that water is a sacred trust among First Nations peoples.
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NOW IS THE TIME TO SPEAK UP!
Deadline for commenting is December 1, 2016.
Or by email to: firstname.lastname@example.org
Or in writing here:
Ministry of the Environment and Climate Change
Climate Change and Environmental Policy Division
Land and Water Policy Branch
135 St. Clair Avenue West
Phone: (416) 314-4708
Fax: (416) 326-0461