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We Have A Voice!

Talking Points for the Ministry’s Water Management Policy

The Ministry of the Environment, Conservation and Parks has posted its Water Quantity Management Program on the Environmental Registry of Ontario and is seeking public input!


We have drafted the below comments for you to pick and choose from, and put into your own words:

Point #1 is critical – the ministry wants to know if you support the proposal to require water-bottling companies to seek support from their host municipality when applying for a Permit to Take Water. Why or why not?

1.  Municipal Consent:

The ministry is giving municipalities a say as to whether a water bottling facility or taking water for that purpose can be established in their community.


New regulation would require water-bottling companies to have the full support of their host municipality as a condition for an application for a new or expanded Permit to Take Water for water bottling purposes.


Regulation would also say that a host municipality can refuse to support a proposed water taking for water bottling, if there are sound scientific grounds for that refusal. This refusal will be a condition considered in the decision about a water permit.


- This support will not be required for smaller water takings. Within stressed areas, like Centre Wellington, the threshold for host municipality input should be reduced to the permit to take water threshold of 50,000 litres per day so the cumulative impact of all permitted takings can be considered.


- The Township of Centre Wellington has been requesting that the Ministry give consideration to the fact that this is not a willing host community for such a permit. And Save Our Water has supported our council in this.


- Our Council has unanimously passed a resolution stating: “the Township of Centre Wellington is not a willing host community to any new commercial water bottling operation or the taking of water for that purpose under any circumstances.”


-Requiring this input from the municipality is democratic and gives residents, councillors and communities a louder voice.


- It is abundantly clear what the will of our municipality is.


- And we have scientific grounds to refuse.


- Our future water supply has been identified at “significant risk” so it is only right that we have a voice. The ministry’s proposal document states: “the sustainability of future municipal water supplies in Guelph, Fergus and Elora is uncertain.”


- Centre Wellington’s urban area was mandated to double in population from 2016 to 2041, and the province has just issued higher numbers to 2051. This is a huge challenge to provide water service to these new residents.


- We now know that we need at least 4 new wells, and that the best place for those wells is west of Elora.


- The province mandated growth, and therefore the province has to allow us to get our water infrastructure in order.


- Large-scale water taking water west of Elora would remove from our options the best source water area for this municipality.

2.  Prioritizing Water Uses:

New regulation would prioritize water use in guiding water-taking decisions. The highest priority uses would be Environment and Drinking Water, with Agricultural needs as most important in areas where there is the potential for insufficient water for this use. And then Commercial and Industrial uses, such as water bottling.




- This is something that Save Our Water has asked for.  During the moratorium, we requested that regulations rank ecosystem needs and municipal drinking water uses as well as agricultural requirements above commercial and industrial water taking and specifically for water bottling.


- The proposal lists environmental needs as a high priority, but the science report indicates that assessing environmental needs is a difficult, complex problem. It expresses the need for improvement in understanding the cumulative effects of total water takings on surface water, groundwater, and deep aquifers over the long term.


- It expresses the need to better understand the environmental flows of rivers and streams.


- The report also expresses the need for improvement in how to prepare and manage water takings during a drought.


- Therefore, we suggest that funding for research and expertise are needed for decisions about permits.

3.  Managing Water Takings on an Area Basis:

The proposal recommends that water be managed on a regional area basis rather than a permit-by-permit basis, focusing attention on water-quantity stressed areas.




- This seems like a good idea. We would also encourage groundwater and surface water management still be continued on a watershed scale, under conservation authorities.



4.  Transparency

The proposal recommends making data available online to the public with an accessible database platform to increase transparency of how Ontario manages water resources.




- This is a good idea. A database is important not only for water

managers, conservation authorities and ministries, but also to ensure

Indigenous and public involvement and participation in any issues

and conflicts regarding water.

Additional Comments:


- The policy study and report on how to better manage Ontario’s water appears to make good sense from a groundwater management perspective.

- However, Ontarians understand that for any water taking there are environmental trade-offs, and societal values are important, particularly about bottled water.

- With water taken from an aquifer, we end up with a product that is, for most, unnecessary and is in fact harmful to the environment.

- If this government is committed to fighting climate change, it must consider that combining all of the energy input totals from the use of plastic, to production, to transportation, “bottled water requires as much as 2,000 times the energy cost of producing tap water.” (P. H. Gleick and H. S. Cooley, “Energy Implications of bottled water,” Environmental Research Letters, 2009)

- If this government is committed to fighting plastic pollution, it must consider that “more than one billion plastic bottles are not recycled in Ontario and are lost to disposal every year” (Recycling Council of Ontario). And plastic lasts forever in the environment.

- We are still waiting for the study that will take societal and cultural values into account, including widespread opposition to the transformation of a public common good into a commodity.

- We are still waiting for the study that will recognize the need to meaningfully include Indigenous peoples and Indigenous interests, knowledge systems and values in water planning and in protecting and conserving water for future generations.

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