What is the Value of Water?


UPDATE, 9 April 2014: The deadline for feedback on water pricing under the Water Sustainability Act was 8 April 2014. We submitted our comments on the WSA blog. In addition, 81 people used the letter writing tool that we and Community-reVISION.org provided. It is always energizing to see people take the time to respond when opportunities arise to act. We were also pleased during the feedback period to receive a call from BC government staff thanking us for encouraging people to comment and asking for more!

The WSA leaves a lot of details to regulations, a process that typically does not involve transparent public participation. Look for us to continue to follow this legislation with more analysis and on-going calls for regulations to be developed in a public process. With your continued support, together we can ensure that the voice of everyday residents is heard above the noise of industry lobbyists and short-term political interests.  Water is too essential for decisions like these to be made behind closed doors!

Thanks for your interest and support. What follows is the original blog entry that was posted here during the WSA pricing comment period.

This is a big blog post!

But water law is a big subject! Wade through or skim across the water issues presented here and help us engage with the government in a good way during the water pricing feedback opportunity (till April 8th).  Comment directly to the Water Sustainability Act (WSA) blog or Send in a Comment Directly with our handy Letter Writing Tool.  You might also want to look over the comments of others on the WSA blog, such as those of the POLIS Water Sustainability Project (scroll down to find their posts of March 31 & April 1)

Bringing Water Law into the 21st Century

For the first time in more than 100 years, the BC Government has decided to update the Water Act legislation that relates to the waterways in the province we call home. For decades water users of community and corporate interests alike have been able to access water with no respect for First Nations rights & title, minimal restrictions on what the water was used for, or how the use was impacting the environment and the quality of water we leave for our children. The consequences of the lax regulation have caused the beautiful waters in BC to be threatened by multinational corporations accessing water sources without paying a cent, the degradation of watersheds and an overall lack of accountability to those of us who call the region home.

zeitgeist-moving-forward_600.jpgThanks to people like you, the BC Gov’t has recognized that they can not continue on with business as usual. Over the years thousands of BC residents have spoken up to demand that we see protections for the environment and restrictions on water users who consume and pollute water. From the Fraser Valley alone, more than 2000 people have joined in the call to ensure local residents have the right to say ‘yes’ or ‘no’ to decisions that affect our home waters and demanded that the BC Govt enact stronger laws to protect the aquifers, rivers, lakes and streams that we rely on. Furthermore hundreds of us Valley folks participated in the feedback on the proposed Water Sustainability Act pinpointing the changes that we wanted to see to bring the legislation into the 21st century.

Although there is still much work to do to achieve the goal of world-class water legislation, the Government has made improvements to the 1905 Water Act and we commend them for responding to some of the public demands. For example the proposed Water Sustainability Act contains new groundwater legislation, protects water for ecosystem needs, provides for agricultural water reserves, introduces water sustainability plans to regulate water use in specific watersheds, and opens the door to regional watershed governance and local control.

Our Home Waters Need Us

It is essential that we continue to engage with the BC Gov’t and hold them accountable to the values that we have as local communities. First Nations rights & title must be respected to uphold the laws of our constitution and to ensure effective legislation for water protection. Reforms need to be made to the ‘First In Time, First in Right’ allocation system, and we need to see more accountability in the renewals of short-term water approvals for industrial use (as seen in the case with the fracking company Encana currently before the courts).

One way we are communicating these values is through feedback on the water pricing plan that the BC Government is seeking to implement. Here is a link to a handy letter writing tool to make the process easier. We know the Government responds to numbers so we need you to join us!


Water Fees Must Make Public Sense

A common current ran through many of the thousands of submissions on the Water Sustainability Act (WSA), as British Columbians from environmentalists to industrialists called on the province to use new water rental fees to fund strong, responsible management of water in the province.

dollar_ten.jpgCurrent water rates range from $0.08 to $1.10 per million litres. That's a maximum of $1.10 for enough water to wash more than 19,000 cars at a self-serve car wash. The province has released a document titled 'Pricing B.C.'s Water', outlining seven principles for pricing water; Simplicity, Fairness and Equity, Implications for Water Users, Impact on the Water Resource, Cost Recovery, Efficiency, and Food Security and Public Health. Residents of BC are invited to comment on these principles until April 8, 2014.

water_words.jpgWater is seen by the vast majority of British Columbians as our most valuable resource. Many speak of water in terms of it being life-giving and even living. From baptism to sacred bathing, water holds a special place for people of all walks of life. The new Water Sustainability Act holds great promise for taking care of water in a way that reflects those values.

To realize the promise of the new Act we need to find the funds to enable administration, planning, licensing, citizen involvement, local and traditional knowledge, science, monitoring, conflict resolution and more. All while Provincial ministries' budgets are 'flat-lining'. Many have called upon the government to place the funds raised from licence fees and water rental rates into a fund specifically for water governance. Government has responded that the Financial Administration Act requires all public money to go into one consolidated revenue fund. However there is an option to establish trust funds for specific purposes and so one could, and should, be established for water.

The WaterWealth declaration includes the words “No matter the ideology of government, the state of the economy, or the laws of the day, we will always need water.” A statement almost no one disagrees with. One way that could play out in practice is to have water rates in the province set and regularly reviewed by an arms-length commission. Such a commission should remove water pricing from the interference of short-term political priorities of the government of the day. It should fairly represent the diversity of the province in terms of both geography and interests in the waters. It should be guided by a mandate to help ensure the quality and quantity of water for our children in the future.

At WaterWealth we think that the number one priority of the Water Sustainability Act has to be the sustainability of the water! We have a tendency to take water for granted in BC, for example British Columbians personal water use is 1.5 times the national average, and that national average is one of the highest in the world! We need to change the way we think and act about water. At present most water licences charge for a set volume of water, whether the user needs the full amount or not. Most users do not use their full allocation. We need to change our pricing model so that water is paid for based on volume used rather than like an all you can eat buffet. Pricing should encourage not only efficiency and conservation, but innovation to reduce water needs and impacts on water in the long term. With water fast becoming a global priority, leaders in water innovation will have a strong position in global markets thirsty for knowledge and technology that can help them go further on the water they have.

loonies.jpgThe table below provides the seven principles presented by the province, in the order of priority we at WaterWealth think they should have, from highest to lowest. We join the government in asking you to review these principles. Ask yourself; Are the principles complete? Which are most important to you? Then have your say via the Water Sustainability Act blog or use our Handy Letter Writing Tool to email [email protected] and your elected representatives directly.



WaterWealth Comments

1. Impact on the water resource: Water pricing should reflect the impact of the intended purpose or activity on the resource. For example, water that is consumed and removed from the watershed or aquifer should be assessed differently than non-consumptive uses.

Impact on the resource has to be number one. As a basic of life, water must be protected for the long term. An example where pricing should reflect the intended purpose or activity; water for consumptive uses, eg water for fracking, that is contaminated and removed from the water-cycle, should be priced much more heavily than water licenced for conservation.

Pricing should incent use of non-potable water sources where possible, with precautions against and monitoring for any resultant interactions between non-potable and potable sources.

Impacts cannot be considered only in terms of province-wide categories. Impacts of particular uses may be small as a percentage of total impacts province-wide, but might be very large on local scales.

Historically most licences required users to pay for a total licensed volume regardless of how much was actually used. To encourage conservation and innovation pricing should be based on the volume actually used. Not an 'all you can eat buffet'.

It is troubling that the WSA prioritizes water use purposes with conservation second to last. Perhaps having pricing reflect impact can partially balance that ranking of priorities.

Water allocated through short-term use approvals under section 10 of the WSA should be priced to discourage abuse. It is particularly important to balance the use approval provision now since the WSA explicitly states that repeated use approvals to the same user from the same source for the same purpose are allowed. Already the current water law is being challenged in the courts over the use of these approvals. This is one area where the WSA seems to make matters worse.

2. Food security and public health: Water pricing should recognize the essential contribution of water to food security. Food security is a prerequisite for healthy nutrition and foundational to human and community health.

Food security will become ever more important as climate change impacts the growing regions we have historically relied upon, eg the droughts in California and the U.S. Midwest in 2012-2014. The Peace River & Fraser Valley area, with their class 1 soil, will grow increasingly valuable as growing regions move northward.

A high quality of drinking water sources is another necessary prerequisite that must be accounted for to ensure lasting public health.

We rank this principle below impact on the water resource in hope of avoiding unsustainable industrial farming practices.

3. Efficiency: Water pricing should motivate users to demand only the amount of water that is required for the intended purpose. Pricing should incent the use of non-potable water, encourage freshwater conservation, promote innovation and facilitate government’s efficient administration and management of the resource.

Encouraging efficient use is part of stewarding water for the long term. Pricing should be based on actual amount used and should be set high enough to achieve the goals of this principle.

The earlier WSA Legislative Proposal suggested leaving deep saline aquifers (non-potable water) unregulated. This would be problematic in several ways. The government seems to have responded to concerns raised and the WSA appears as though it will regulate deep saline aquifers along with other groundwater. Pricing should incent use of non-potable water where possible, but that use should be carefully managed and monitored to ensure no harmful interactions with freshwater aquifers.

4. Cost recovery: Water pricing should support sustainable water management and generate sufficient revenue to recover the costs of managing the water resource. This includes science, monitoring, planning and facilitating community involvement, regulation and enforcement. Costs to users should also reflect a fair return to the Crown for use of a public resource.

This is another area where the government seems to be responding to input received in the public comment period last Fall. We like the things included under cost recovery here, particularly science and community involvement.

We are uncomfortable with the last line, “Costs to users should also reflect a fair return to the Crown for use of a public resource.” This is in direct conflict with unresolved First Nations Title. In so far as the government has authority to regulate water use (something that is questionable in BC so long as treaties with First Nations remain unresolved), we look to government to steward water honourably for now and for the future.

5. Fairness and equity: Fairness is reflected in surface and groundwater being treated as one resource and subject to the same pricing structure. In addition, similar uses of water should be subject to similar pricing. Equitable pricing should reflect differences in the value of water based on the type of right granted, intended use, location or scarcity of the resource.

Surface and groundwater are by and large one system and so should be treated as one resource, but recognizing the unique characteristics of each such as seasonal variability and aquifer refresh rates. Prioritization of user water rights based on the criteria stated in this principle would be even better, but pricing based on these is a good start. Pricing should reflect the reality that polluting water or depleting aquifers imposes a cost on other users and even on future users. No price should be allowed to enable the permanent detriment or loss of a water source.

6. Simplicity: The approach and rationale for water pricing should be easy to understand and predictable. Individuals and businesses should also know how and when pricing could change so they can plan and budget their costs accordingly.

Simplicity is nice, but let's not get too hung up on it. At the current rates the Nestle bottling plant in Hope, BC would pay $225 dollars per year for the 265-million litres of water they draw from the aquifer. Were water rates to triple, Nestle would pay $675. Fees are not a hardship. Failure to manage water sustainably is. We should beware of exemptions offered to water license holders in the name of 'simplicity' as they can often lead to the marginalization of important factors, while providing little benefit to the public and environment.

7. Implications for water users: All British Columbians benefit directly and indirectly from B.C.’s water resources. Pricing of water should distribute the costs of water management across users so that the effect on licensees and citizens is reasonable and manageable and enables business competitiveness.

Not all water users are created equal. Water must be ensured as a free human and ecological right.  However all commercial water users should pay a fair share based on the volumes and conditions of their use. At the same time we must balance the need to cover costs with the reality that water is a necessity of life and must not be commodified in any way that would deny basic needs. “Business competitiveness” must not trump sustainability, or in other words Priority 7 must not trump Priority 1. Further, given the implications for all water users, there should be opportunity for feedback once the government has draft fees and rates established.  This should not be the only opportunity for public input.  We all need water for the long term.

Fresh water is our most precious natural asset, flowing through all living things and essential to our survival. Add your voice on the issue of water pricing in BC on the WSA blog or by email through our Easy to Use Letter Writing Tool.



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