The following was submitted on the 27th of February 2021
The Council of Canadians’ position is that water is a human right and, as such, must be protected from privatization, pollution, and bulk exports. Universal access to safe, clean water and adequate sanitation must be a reality for all.
The province of Newfoundland and Labrador faces serious challenges with respect to freshwater resources. These involve municipal and regional-provincial levels of government and include matters within federal jurisdiction. A Canadian Water Agency has the potential to assist the Province in dealing with these challenges.
· Municipal and community water and wastewater infrastructure
· Regional surface and groundwater degradation from mining activities
· Hydroelectric installations
· Climate variability and change
· Accommodating a new “green” economy
Municipal Water and Wastewater
Larger municipalities, such as St. John’s, face potential shortages in water supply in the coming decades. Development of already designated protected freshwater bodies will be needed to meet demand, and water treatment and distribution systems will need to be expanded. Many smaller municipalities and unincorporated communities have inadequate water treatment or none at all, resulting infrequent and longstanding boil water advisories.
Provincial drinking water policies must have the goal of making safe public water supplies the standard for consumption in all communities, instead of commercial bottled water. A Canadian Water Agency could facilitate the development of alternatives to chlorination for treating drinking water supplies.
Municipal wastewater discharges are regulated under the Wastewater Systems Effluent Regulations (WWSER) and the Fisheries Act. For Newfoundland and Labrador, this includes 206 wastewater discharge points in 117municipalities, of which 184 are believed to have only partial treatment or none (ECCC, 2020) Enforcement is a problem and there is a lack of adequate funding for sewage treatment facilities and staffing. Consultations are ongoing regarding extensions and temporary authorizations.
It is clear that financial assistance will be required from the federal government if there is to be compliance with the regulations. This should be facilitated though loans from the Canada Infrastructure Bank, without resort to public-private partnerships, which result in higher costs in the long term.
Effects of Mining Activities
There are long-standing concerns locally as well as globally about the impact of mining on surface waters. The Metal Mining Effluent Regulations (MMER) of the Fisheries Act prohibits the deposition of “deleterious substances” into fish-bearing waters. However, a mining company can request that a lake or pond be designated a “tailings pond”, in which case dumping is permitted. Sixty-four such exemptions have been granted across Canada (Schedule 2 of the MMER), including at least four in Newfoundland and Labrador. The case of Sandy Pond exemplifies the conflict between industrial expediency and the need to conserve freshwater ecosystems . A Canadian Water Agency should place a priority on having the Schedule 2 option removed from the MMER and provide guidance through research on mine and mill waste disposal that minimizes effects on natural waters and watersheds in Canada.
The Muskrat Falls component of the Lower Churchill Hydroelectric Project was carried out with little regard for effects on methyl mercury levels in the resulting reservoir and downstream, despite evidence from other large northern hydroelectric projects. That project is virtually complete, though with a considerable cost overrun and remaining reliability questions. A next step envisions further dam construction upstream at Gull Island. We oppose further dam construction on the Churchill River. We recommend that a Canada Water Agency be the first point of review for any large dam project in relation to the protection of water quality, the disturbance of the natural hydrologic regime and the impact on Indigenous peoples living along the water course.
Climate variability and change
Projections of climate change in Newfoundland and Labrador include increases in seasonal temperatures and in the frequency and intensity of seasonal precipitation, with increased flooding resulting in damage to infrastructure and drinking water supplies and drinking water supplies.
A Canadian Water Agency should play a role in the planning and coordination of provincial and municipal responses to climate change impacts on water supplies and water and waste water infrastructure.
Accommodating a new “green” economy
Newfoundland and Labrador, like the rest of Canada, is facing an uncertain future, as we attempt to recover our economy following the effects of the pandemic. Many of us are calling for a green recovery – one that is responsive to the urgent need to reduce carbon emissions by changing our habits and technology, particularly modes of transportation. The downside of such innovation is the increasing demand for certain metals and minerals to support the electrification of our transportation sector – the extraction of which puts further pressure on our natural environment, including our waters. Our habits, technology and regulatory framework will need to adapt.
A Canadian Water Agency should play a central role in educating and assisting Canadians to move ahead with a “green” economic recovery while protecting the environment.
John D. Jacobs, PhD.
Avalon Chapter, Council of Canadians