The British Columbia Ground Water Association (BCGWA) is dedicated to the protection, promotion and responsible development of groundwater resources in BC. We work closely with FLNRORD and ENV to advance the interests of those engaged in the groundwater industry for their own and public interest.
We are writing on behalf of our members, as well as the public, to express our concerns with respect to groundwater licensing in BC. In particular, we are concerned by:
We feel strongly that groundwater licensing needs to be a focus of the upcoming election, and a policy and operational priority moving forward. Simply maintaining the status quo is insufficient and puts the entire licensing program at risk.
Our concern regarding the issue of bringing existing groundwater users into the licensing system was outlined in our letter to the Honourable Doug Donaldson and Honourable George Heyman dated November 21, 2018. In that letter we requested an extension to the deadline for existing users as only about 10 – 15% of the expected applications in BC had been received. We also recommended that the government plan and implement a more vigorous communication strategy to accompany a deadline extension.
A three-year extension to the deadline was granted, however it is our understanding that with less than two years remaining still only about 4,000 of the estimated 20,000 existing groundwater users have applied for a licence. If this lack of compliance continues, not only will it be very difficult for the province to properly regulate and effectively manage groundwater, but many small businesses (a backbone of the private-sector economy) will become vulnerable to losing access to their water which is critical to their livelihood, especially during COVID recovery. It is our opinion that the government’s communication strategy continues to be insufficient and must be significantly improved.
Our second concern is the length of time required to process groundwater licence applications. Processing times of over one year are the norm, and our experience is that two years is not uncommon. Our members work with industry and the public who are unanimous in their belief that these wait times are unacceptable. Businesses, especially new businesses, simply can not survive waiting potentially multiple years to be granted a licence and are being forced to break the law by going ahead with water extraction. As an example, expanding the agrifood sector has been identified as a priority for BC, yet farmers simply cannot survive a two-year gap between their decision to invest in developing groundwater supplies and being able to put that investment to work.
Dependable timelines for groundwater licence applications need to be in place for the groundwater licensing program to succeed. FLNRORD and ENV need to be given enough resources to significantly speed up application processing times, or the groundwater licensing program is at risk of failure. The public sees current application delays as unworkable and is choosing to not participate, which contributes to the lack of licensing applications discussed previously.
We realize that challenges related to groundwater licensing are not new to members of the legislature and noted that was it discussed on the floor of legislature on July 13, 2020. In response to questions about the lack of applications from existing users, the Hon. D. Donaldson referred to “dedicated staff working on this” and ongoing measures being taken by the Ministry.
It is the opinion of the BCGWA that these current measures are not enough to ensure the successful implementation of groundwater licensing in BC. Increased resources need to be assigned to improve communication and outreach, streamline the application review process, and develop compliance enforcement. It is our observation that the public not only doesn’t understand the value of groundwater licensing, they consider it another government program that, like the gun registry, will go away if ignored. The public needs to be convinced of how licensing benefits everyone in BC and needs to understand that there are serious repercussions for not complying. We strongly recommend that groundwater licensing become a policy priority, both for the upcoming election and for the government that follows. As it stands now, the groundwater licensing program is at risk of failure, jeopardizing the Province’s ability to properly regulate groundwater use and to effectively manage water in times of scarcity.
The BCGWA fully supports the Water Sustainability Act (WSA). Groundwater licensing under the WSA is integral to the protection and responsible development of our precious groundwater resources in BC. As such, successful implementation of the groundwater licensing program is an important issue for all British Columbians, and the BCGWA is requesting that our political parties tell us how they intend to ensure its success.
Best regards,
Dave Mercer, PGeo
General Manager
British Columbia Ground Water Association