Governments have a responsibility to manage water as a public trust
Mike Schreiner issued the following comment on EBR Registry Number: 012-9151 - Bottled Water Technical Guidance Document.
Supervisor, Ministry of the Environment and Climate Change
Southwestern Regional Office
Dear Patrick Spezowka,
I appreciate the steps the government is taking to protect our long-term water supply.
Water is a finite resource.
Governments at all levels have a sacred responsibility to manage water as a public trust, in the public interest and in a way that ensures everyone has a right to access clean drinking water.
The moratorium on new water bottling permits is a good first step, and there is a great deal in the new regulations that will help protect our water. To name a few of the good things:
Increased discussions with the Ministry, online reporting and public consultation - these will both help address concerns early, provide off points if a permit should not go ahead, and increase accountability
Mandatory reductions for bottlers in times of drought. This is a no-brainer.
Increased fees for permits to take water. Fees should cover the cost of water management programs, and with the new regulations will come new expenses for monitoring.
The most essential item missing from the new regulations is explicitly prioritizing public drinking water for community needs over corporate consumption for water bottling. The new regulations must prioritize human and ecological needs over commercial uses for water.
Consumptive water bottling for export will compete with drinking water as our population grows and climate change causes more droughts. The new regulations need to take a forward looking approach that considers population growth, including targeted growth established by the Places to Grow Act.
As well, the regulations should establish a water taking priority list that puts local water use for drinking and food production above other uses such as water bottling and aggregate extraction.
Finally, it’s essential that the cumulative impacts of water taking on present and future generations is studied properly and without bias. It is better for the Ministry to handle this analysis independently rather than relying on the proponent, as is currently proposed. Water taking fees should be set at a rate that covers these costs.
And while it is outside the scope of this posting, it’s important to keep in mind that Ontario must also develop a plan to eliminate plastic bottles from the waste stream.
Just six per cent of the groundwater around the world is replenished and renewed within a "human lifetime" of 50 years. Only one per cent of the Great Lakes water is recharged from rainwater and snow melt. We must ensure the sustainability of our water supply for present and future generations.
Thank you for listening to our demand and the public’s demand to protect our water. The proposed regulations are an important step forward. I encourage you to strengthen the new regulations by putting water for communities first.