Proposed Moratorium Comments for EBR Electronic Registry

The Proposed Moratorium, what it means, and what we have to do!

The provincial government has listened to the citizens! As residents concerned about the water issues in our area and in Ontario, SaveOurWater.CA applauds the Ministry’s proposal for a two-year moratorium. This time period will allow for new improved policies and regulations to be put in place with regard to permits for water bottling companies using groundwater.  It also allows Municipal and Regional governments time to update their plans and catch up to the new water reality in Ontario, Nationally and Globally.

The moratorium means there is no possibility of a pump test at the Middlebrook well until January 2019!

We appreciate that the proposed moratorium was posted on the Environmental Bill of Rights Registry, allowing the opportunity for public comment.

Now is the time to have your voice heard to safeguard our water! Please support the moratorium!

Please take a moment to craft your comment to the Ministry in support of the moratorium and what changes you want to see in a revamped permitting process. Use the comments below as suggestions for your own personal statements. Commenting period ends December 1, 2016.


Points worth acknowledging in the current proposal:

* It will lead 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 more needs to be understood with regard to groundwater reserves.

But this current proposal has not gone far enough in some areas. There are several important pieces missing:

- Ecosystems have to be better assessed before granting these water-taking permits.

- Studies required by applicants should follow scientific protocol standards.

- Cumulative impacts of total water takings should be assessed on a watershed-wide scale, and over the long term.

- Rates charged to water bottling companies should be increased to more fully reflect the cost of administration of the water management program.

The Important Details:

1. Water is For Life, Not for Profit. Fundamentally, we support a Ministry position of water as a public trust, not a commodity to be sold.

2. Prioritization of water permits. There is a need for a meaningful tiered water approach. A clear ranking of the permits would determine when the tap gets shut down or reduced, in the event of droughts or climate uncertainty. Agricultural and municipal drinking water uses as well as ecosystem needs rank well above commercial water bottling. Clearly, an industry that creates billions of bottles made of plastic that will never biodegrade, and of which approximately 34 percent end up in landfill, needs to be assessed separately.

3. Population growth and water security for residents. 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 requires more consideration.

4. Where does the water come from? Along with population growth is further land development, with more water run-off into rivers and a reduction in permeable surface area for water absorption. Of the two calculations, population increases and loss of recharge of our aquifers, there is more uncertainly with the second. We recommend that recharge areas for water takings be clearly identified and that more comprehensive methods be used for calculating the estimates of cumulative changes in groundwater recharge long into the future.

5. Better resilience to climate change. Increased incidents and duration of droughts, as well as the increased intensity of storms, mean increased uncertainty with respect to both surface and groundwater. The Environmental Commissioner has made recommendations that would improve the water permit program with respect to responsiveness to climate change, including mandatory reduction in water taking during drought. We recommend that these recommendations be implemented.

6. An ecosystem approach is essential. We note that ecosystems receive inadequate mention in this proposal. For environmental protection it is critical to factor in the needs of the ecosystem, composed of air, land, water and living organisms, as a priority. The Environmental Commissioner recommended that the Ministry develop a more comprehensive methodology to assess the water needs of ecosystems when reviewing applications for Permits to Take Water. We would like to see such methodology become part of the application evaluation process.

7. Need for better understanding of health of the Aquifer. Water permits have been issued for vast amounts without full comprehension of reserves in the deep aquifer. We are encouraged that the proposal notes that current water budget studies, which are based on estimates and modeling, are not entirely adequate with regard to understanding groundwater reserves and replenishment of the deep aquifers. It should be recognized that with these water budget exercises, the smaller the area being studied the more exact the modeling has to be, which makes water estimates at a local level more difficult.

8. Cumulative impacts of total water permits. 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 over the long term.

9. Scientific standards for permit applications. Regarding scientific reports in applications for new water-taking permits or renewals, we are concerned about the validity of study results that are prepared solely by the applicants, as these would not be disinterested studies. Such studies should be third party, not proponent-driven research, and peer reviewed similar to scientific protocol standards. We recommend that these studies focus on the health of the aquifer, the wider environment and public need.

10. Water management program requires periodic review. 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 publically and offer user-friendly avenues for submitting comments.

11. Cost recovery through water charges. Historically, water-bottling permits require disproportionally high amounts of Ministry time and effort to evaluate and process. We recommend that rates being charged to highly consumptive users such as water bottling companies be increased to more fully reflect the administration costs associated with managing the permits and the risks they pose to the environment, as well as the costs of third-party studies on water sustainability.

12. Impact 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 water from the deep aquifers while imposing billions of pieces of plastic waste onto current and generations to come.

To view the draft proposal enter Registry Number 012-8783 on the Environmental Bill of Rights Registry here:


Deadline for commenting is December 1, 2016

Environmental Registry



Link here to read A regulation establishing a moratorium on the issuance of new or increasing permits to take water for water bottling










Submit your comment here:






Or by email to:, refer to EBR Registry Number:   012-8783


Or in writing here:

refer to EBR Registry Number:   012-8783

Leo Luong, Manager

Ministry of the Environment and Climate Change

Climate Change and Environmental Policy Division

Land and Water Policy Branch

135 St. Clair Avenue West Floor 6

Toronto Ontario M4V 1P5

Phone: (416) 314-4708

Fax: (416) 326-0461