Re: Proposed PTTW renewal made by Nestle Canada EBR registry number (010-0224)
Dear PTTW Coordinator:
I would like to state my opposition to the requested renewal of Nestle’s Permit to Take Water at Aberfoyle, Ontario.
I completely disagree with the extremely limited parameters upon which the Ministry of the Environment appears to be poised to make a decision regarding the renewal of the permit, but I will attempt to first address the narrow criteria you have identified.
1) When Nestle last applied to renew their permit, the Ministry received a letter from Harden Environmental, authored by Stan Denhoed. In his letter, Mr. Denhoed stated that while Nestle is pumping, the flow of Mill Creek is reversed and essentially the surface water is sucked back into the aquifer. Given the Walkerton water tragedy, I find it shocking that the Ministry did not act on this information and that renewal of Nestle’s permit was granted in 2005. Not only does this situation place the groundwater at risk of contamination, it is a violation of the Riparian rights of other users.
2) I am not confident that the Ministry of the Environment has a big picture understanding of how much water is available in our region nor a clear idea of the underground flow patterns of our water. In fact, in a May 2nd article in the Guelph Mercury, our local MPP, Liz Sandals, stated the following: “The Clean Water Act focuses on source water protection. As required by this act, the Grand River Conservation Authority is currently mapping groundwater and surface water flows and groundwater regeneration areas. When this work is complete, each municipality will be required to develop a source water protection plan.” I would have anticipated that the Ministry would have already been in possession of this information. I find it disturbing that this work is now only getting under way. In light of this situation, no new water taking permits or renewals should be granted until this groundwater, surface water flow and groundwater regeneration area mapping is complete. In the absence of this mapping information, I am not sure on what basis claims are being made that Nestle is not drawing from the same water source as the City of Guelph.
3) I am not confident that the Ministry of the Environment has the necessary resources to properly monitor what is happening with groundwater in this region. On April 24, 2007, Environmental Commissioner Gord Miller released a report in which he warned that “funding cuts spanning 15 years have left Ontario vulnerable to a catastrophe similar to the Walkerton tainted water tragedy.” (Guelph Mercury, April 25, 2007). The Mercury reported that Miller also told a press conference in Sudbury that, “Our present course puts our ecosystems, our biodiversity, our health and parts of our economy at serious risk of deterioration and catastrophic events.”
In literature recently distributed in the Guelph area, Nestle poses the question: What is the long-term impact of Nestle Waters Canada’s water-taking on the local water table and surrounding wetlands? Response: Our ongoing investigations do not indicate any adverse effects on the water table, on Mill Creek or on surrounding wetlands from our operations. We support the need to investigate water balance and cumulative impacts on a regional basis.
Ontario citizens should not be required to depend on data put forward by Nestle on the long-term health of local water sources. Independent, government-funded investigation is required.
According to the Infant Feeding Action Coalition (INFACT) in Toronto, Nestle is the single most prolific violator of the World Health Organization International Marketing Code for infant formula. This is not a corporation which has earned the public trust.
4) Catherine Moreau, a member of the local Chapter of the Council of Canadians, raised concerns with a previous Guelph City Council that water bottlers have allegedly been visiting farms in the region to privately contract with landowners and send trucks to take water from their wells. If this practice is in fact happening, it would indicate that total water taking from local aquifers by perhaps Nestle, or other water bottlers, could greatly exceed the amount requested in the permit renewal. I would request that the Ministry of the Environment investigate this situation to find out if this is indeed happening and which water bottlers are involved. It is important to get a picture of total water taking in the region, including private wells, before granting a renewal to Nestle.
5) Glossy information delivered to my door by Nestle indicates that their “business is seasonal, and we use less water in the winter.” I find this concerning, since Guelph citizens have been subject to summer water use restrictions as a result of drought conditions. Aquifer recharge requirements would indicate that water taking should be reduced during dry summer conditions. If the Ministry decides to renew the permit, conditions should be added which would require reductions in Nestle’s water taking in the event of summer drought.
6) The preamble of the Environmental Bill of Rights states that “The people of Ontario have as a common goal the protection, conservation and the restoration of the natural environment for the benefit of present and future generations.” The Ministry of the Environment must consider the future needs of citizens of the region, not just whether Nestle’s water taking is impacting current supply.
Under Places to Grow legislation, the Ministry of Infrastructure and Public Renewal has mandated a population increase of 120,000 people in Wellington County between 2001 and 2031. Population growth targeted for Guelph is currently higher than what is envisioned in Guelph’s own official plan.
The most fundamental infrastructure requirement for any human population is drinking water. The City of Guelph has sought to plan for this requirement through a 50 year Water Supply Master Plan. Given the growth projections for this region, the City must consider both expanding current capacity and implementing widespread conservation measures. Consideration of a pipeline to Lake Erie was an issue in the recent municipal election and taxpayers indicated little support for such mega-project which would heavily impact their tax bills.
Every alternative considered in the Water Supply Master Plan will impose conservation and costs on local citizens, whether it is for new wells, surface water from Guelph lake, or a pipeline to Lake Erie.
It is now time for the Province to really look at the big picture. The Ministry of Public Infrastructure and Renewal cannot mandate increased growth for Guelph if at the same time the Ministry of the Environment makes decisions which impair the ability of our municipality to service that growth. The needs of agriculture, property owners, urban dwellers and the preservation of natural habitat all must factor into current and future decisions around local water use. Renewal of Permits to Take Water in this region can no longer simply be a technical matter.
7) Current agreements governing Great Lakes water and recommendations from the report of Justice Dennis O’Connor now focus on a need to manage water on a watershed basis. Water bottled by Nestle is shipped out of the local watershed. I do not consider their activity to be equivalent to water used in the production of food and beverage products. With limited exceptions, most Canadians have access to clean drinking water from their taps. Water bottling is unnecessary, frivolous and environmentally damaging on many levels.
8) There is no perceivable benefit to Ontario citizens in granting a 5-year renewal of this water taking permit. The only benefit would be to Nestle Waters Canada. If the Ministry grants renewal of the permit, it should not be for more than a 2-year period.
Broader Issues:
Ministry of the Environment spokesperson, John Steele is quoted in a May 5th Guelph Mercury article as saying, “What you’re looking for is a technical reason why an applicant should not be permitted to take water….’I don’t want them to’ is not a good enough reason.”
Ontario citizens expect the Provincial Government and the Ministry of the Environment to exercise leadership in attaining stated goals. Artificially narrow criteria for decision making on water permits allow those making decisions to ignore critically important issues in the broader context.
1) The Ministry of the Environment has as a guiding principle the encouragement of “Reduce, reuse, recycle”. The granting of water taking permits to water bottlers encourages just the opposite. Massive amounts of plastic waste are generated. Water bottles are not (and should not) be reused. A recent Macleans article stated that 88% of water bottles are not recycled. “According to the Environment and Plastics Industry council, Canadians sent 65,000 tonnes of PET beverage containers, many of them water bottles, to landfill or incineration in 2002.”
In a May 5th Guelph Mercury article, Guelph environmental services director, Janet Laird, puts the recycling figure at 30 % in Ontario. While Nestle’s brochure claims that they pay 50% of the cost for recycling their products through Stewardship Ontario, in effect, they are only covering the cost of disposing of 15% of their waste. Taxpayers are picking up the tab for landfilling or incinerating the rest.
The water bottling industry increases waste, it does not reduce it. Bottles are not re-used and recycling is minimal. This scenario is enabled by the water taking permits issued by the Province.
2) There is mounting evidence that toxins are leaching from plastic containers into the water and beverages that people are drinking. In particular William Shotyk, a Canadian scientist, has identified significant levels of antimony in PET bottles stored for six months. The concern about toxic chemicals also extends to what may leach out of a landfill site once these bottles hit the dump.
3) It is only May, yet the Guelph region has already had its first smog advisory day. The truck traffic generated by the needless shipping of bottled water contributes to deteriorating air quality. Water can reach the general public by public transit – our municipal water systems. On a worldwide scale we are facing a global warming crisis. We can no longer afford the luxury of the frivolous and needless movement of goods and consumption of resources. The Ontario government is taking steps to phase out incandescent bulbs and disposable plastic bags to reduce waste and save energy. The same goals can be achieved by phasing out water bottling.
4) The transportation systems used by water bottlers are financed by the taxpayers of Ontario. Increased traffic translates into increased motor vehicle collisions and increased health care costs. The Ministry of Transport is currently contemplating an additional transportation corridor between Highway 7 and Highway 400. The Province needs to focus on transportation demand management and the reduction of traffic pressures on existing highways, not the construction of new ones. Traffic pressures can be reduced by insisting that local water travel to end users by public municipal systems, not through long-distance trucking by private water bottlers.
4) It is time for the Government of Ontario to revisit the Ontario Water Resources Act. This legislation is more than 40 years old. When water taking permits were first considered, no one would have dreamed that water would be bottled, shipped huge distances, and that people would pay for something they could get for free from their taps.
Water bottlers have executed highly successful marketing campaigns to create a demand for their products. Water is a public resource, but multi-national corporations are internalizing profits from our water while externalizing the costs onto Ontario taxpayers. In Guelph the financial costs will include locating and building the infrastructure for new water sources (up to and including a pipeline); transportation networks; health costs associated with motor vehicle collisions and respiratory ailments as a result of poor air quality; and the costs of disposing of tonnes of plastic waste annually. The environmental costs of depletion of local water sources and global warming are even more serious.
The current scenario is a raw deal for Ontario citizens. It is time for a change in Provincial Policy.
In closing, I wouldlike to restate my position that the Ministry of the Environment not renew the existing Permit to Take Water EBR registry number (010-0224). SW