City council should have a say about water bottling permits beyond city limits if they potentially threaten the supply here, now or into the future, say city officials in a letter to the Minister of the Environment, Conservation and Parks.
That comment, among others, comes in response to a series of proposed provincial changes to the water bottling permit process which includes giving more weight to consideration by the “host” municipality. Without council’s approval, the permit won’t proceed.
However, under the Ontario Clean Water Act (CWA), protected water supply areas extend beyond city limits.
In the case of Guelph, that includes the Nestle Waters Canada water bottling facility in Aberfoyle, part of Puslinch Township. Taking water there, impacts the supply here.
“Therefore, Guelph ... should have input into bottled water decisions in this particular case,” states the letter dated Nov. 20 from Jennifer Rose, the city’s general manager of water services.
“As an example for our rationale … Puslinch does not have municipal water supply systems and relies on private water systems to service the community. Therefore, Puslinch may make decisions on a bottled water company based on the economic benefits of the water taking rather than the environmental impacts on water resources or water supplies for other municipalities.”
As a result, Rose suggests any municipality that could be impacted by a water-taking permit be included in the approval process “to preserve the concept of priority of use and ensure protection of existing and future municipal drinking water as is the purpose of the Clean Water Act.”
She goes on to state Nestle’s current water-taking doesn’t interfere with the city’s drinking water but increased or new water-taking could reduce what’s available to the municipal system which “has been determined to be at significant risk of not being able to meet its water demand in the future (2031) under drought conditions.”
If approved as-is, the proposed requirement for council’s approval would apply only to permits for new or increased water-taking, not renewal of existing operations. However, all permits have an end date and the province re-assesses all renewal applications.
“It would stand to reason that a council resolution in support of a bottled water company should be re-evaluated in a timeframe consistent with a permit renewal,” the letter notes.
“With continual growth in the province as mandated by Places to Grow, requirements for water supply will change with time. Municipalities should have the option to consider the use of water in its municipality and to determine if a bottled water use is still a priority use of the water.”
The city also recommends changing when municipal council approval is sought in the permit process. At the moment, council’s are asked for their support early in the process, before the province conducts technical reviews of the proposal.
“The application, studies and reviews, presumably, would provide information on the potential impacts of the water taking including well interference and environmental impacts as well information on cumulative effects and water resource sustainability,” said Rose.
“This process approach may mean municipalities may be unaware of all potential impacts of the water taking through their independent technical reviews and therefore would be at risk of making a poorly informed recommendation to their councils to approve such water takings."