Leo Luong, Manager
Ministry of the Environment and Climate Change
Climate Change and Environmental Policy Division
Land and Water Policy Branch
40 St. Clair Avenue West
Re: Regulation Proposal Notice – A regulation establishing a moratorium on the issuance of new or increasing permits to take water for water bottling (EBR Registry # 012-8783).
Dear Mr. Luong:
The North Pigeon Lake Association (NPLA) is located in the Municipality of Trent Lakes and the City of Kawartha Lakes. NPLA supports actions that preserve and promote the welfare of the shoreline and the waters of north Pigeon Lake, its catchment area, and more broadly across Ontario. We promote good government, including environmental stewardship.
NPLA supports the Ministry’s proposal for a two-year moratorium on new or increased permits to take water and appreciates the opportunity for public comment via posting the proposal notice on the Environmental Bill of Rights Registry.
NPLA is pleased that the proposal acknowledges that parts of the province targeted for population growth have concerns related to future water security and there is, therefore, a need, to prioritize water-taking uses. We support stricter policies and regulations for the water bottling industry.
With respect to the Actions planned during the moratorium, NPLA offers these specific comments:
Examining water pricing and other tools:
NPLA strongly supports charging rates for water taking that more appropriately reflect the value of the resource, and the cost of administering the water management program. We look forward to seeing proposed pricing options that reflect the true cost of water resources when proposals are posted for public comment.
Reviewing water taking rules:
NPLA supports establishing new water taking rules, and setting priorities for water taking, especially when water resources are stressed (including mandatory reduction in water taking during drought). We strongly suggest that these actions be framed within an ecosystem context. First priority for water allocation should be to sustain ecosystem structure and function. Assessing the water needs of ecosystems should be a prerequisite of any water taking. We recommend this be undertaken at a broad landscape scale – ideally, at a catchment or watershed scale. The cumulative impacts of all proposed water taking (including both surface and groundwater) should be taken into account in water budgeting exercises prior to issuing permits. We look forward to seeing the Ministry take an ecosystem approach to setting priorities for water taking when these proposals are posted for public comment.
Advancing knowledge of water resources:
NPLA supports the proposed action to increase knowledge of Ontario’s water resources, especially the potential impacts of climate change (e.g. increased droughts, storm events, and floods). These actions should include an inventory of recharge areas that could be protected through planning tools to sustain both groundwater and surface water resources in the face of increased impermeability of watersheds, particularly in urban areas. Additional knowledge about our water resources could be acquired by establishing and requiring applicants to follow standard scientific protocols for assessing the impacts of water taking as part of the permitting process. Ideally these studies should be conducted by an independent third party, however, if undertaken by proponents, these studies should be subject to independent peer review, and available to the public. We look forward to seeing the results of the Ministry’s efforts to improve understanding of groundwater in Ontario.
Thank you for the opportunity to comment.
North Pigeon Lake Association