The majority of comments on the proposed regulation generally supported the province taking action related to water bottling. Some comments expressed interest and support for the actions the government is proposing to take during the moratorium, such as groundwater research, a review of water-taking rules, and the development of water pricing and other tools. Related to groundwater research, the comments supported the need for additional action to protect groundwater and for additional science to understand groundwater. Some comments supported a comprehensive evaluation of groundwater and a review of the cumulative effects of groundwater takings in the province. Other comments supported improving the understanding of the impacts of water takings and climate change on groundwater.
Comments were also received expressing that a temporary moratorium should go further and suggested a permanent ban on new water takings for single-use bottled water facilities and a phasing out of current permits for that purpose. Many comments also recommended that the province intervene locally to secure specific water sources for future use by municipalities. Some municipalities commented that they supported the proposed moratorium.
While the majority of comments supported a moratorium, a few comments were not supportive. A small number of comments noted that the bottled water industry in Ontario makes up an important part of the province’s food and beverage sector and that the proposed moratorium would run counter to Ontario’s goals for encouraging growth in that sector. A few comments suggested that there is not sufficient scientific justification for prohibiting water takings for bottled water or related pumping tests while the province undertakes its proposed water-management initiatives over the next two years.
Some comments recognized the need for bottled water in some cases, such as for communities facing boil-water advisories or during emergencies and noted the advantages of having local sources of bottled water in those situations.
Some comments recommended changing the scope of the proposed moratorium. For example, the ministry received the following suggestions:
- Broaden the moratorium to include other water users that worsen low-water conditions within watersheds, including those that take water from surface water sources.
- Expand the moratorium to include water bottling facilities that take water from surface water sources.
- Restrict the moratorium to southern Ontario because that is where issues related to water bottling are most pronounced.
- Do not apply the moratorium to pumping tests because these tests help increase understanding of groundwater resources.
Some comments recommended that the province encourage the reduction of packaging waste wherever possible and require product producers to assume the full cost of diverting their products from waste. Other comments recommended establishing a deposit-return system for plastic bottles.
All comments received during the Environmental Registry posting were considered in the development of the final regulation. The final regulation is consistent with the proposal.
The province is also seeking public input and feedback on tools that could help protect groundwater. A proposal on the Environmental Registry about proposed stricter rules for existing water bottling companies that use groundwater is open to public comment until January 31, 2017. Please refer to the “Additional Information” section of this posting: Bottled Water Procedural and Technical Guidance Document.