Goal 1 – Protect stream health and aquatic environments:

The BCAC recognizes the fundamental role of our water resources to the well‐being and proper functioning of ecosystems, which is why stream health and the protection of aquatic environments has been a major focus of the EFP and other environmental initiatives undertaken by the agricultural sector. Buffer zones, erosion control, riparian area management and enhancing wildlife habitat are just some of the examples of work recently undertaken. The agriculture sector should also be acknowledged for the existing reservoirs and dams that were created by farmers and ranchers for agricultural use – as this infrastructure has provided public recreation and enhanced fish habitat.

BCAC Recommendations:

2. That the Province provide resources and funds to further expand existing agricultural water storage structures and to build new water storage systems that will benefit both agricultural production capacity and fish habitat.

3. That current water allocations be recognized, respected and honoured. During water shortages, conflicts among users, drought or where large unlicensed use is occurring, we request that MOE have a plan in place to ensure all users are aware and understand what measures will be taken.

4. That clearly defined and predictable processes which fully consider agricultural user needs be established on a regional basis for dealing with conflicting requirements of fish and agriculture during periods of drought.

5. That the Ministry of Environment provide direct financial support towards the Environmental Farm Plan program established under the Federal-Provincial Growing Forward agreement, as the objectives of the program are fully consistent with MoE’s goals in protecting stream health and aquatic environments (http://www.ardcorp.ca/index.php?page_id=14).

Goal Two – Improve water governance arrangements:

The Water Act modernization process should address the broader issues of overlap with other provincial and federal Acts, and recommend mechanisms by which conflict and controversial issues can be effectively addressed. Improved, effective communication among all authorities and stakeholders is key for successful water governance in the Province.

BCAC Recommendations:

6. That the Province retain overall responsibility for water licensing, governance and enforcement of the Water Act. The BCAC also supports the delegation of water management functions to a local authority such as a Water District where there has been clear demonstrated support for this delegation by the farm community within the region.

7. That the extensive array of provincial legislation on water be consolidated into one concise Act dealing with all aspects of water and water uses and that the necessary funding and personnel to effectively manage, adjudicate and enforce all aspects of this new Act be put in place.

8. That the Province work with local and regional watershed groups to set priorities and guidelines, inform water users of these requirements, and ensure that they are followed. As part of this process, it is important that tangible benefits to water users of adopting conservation practices be identified and publicized.

9. That local agricultural water users be included in any regional watershed group or advisory board established for the governance of regional water issues.

Goal Three – Introduce more flexibility and efficiency in the water allocation system:

The BCAC recognizes that the wide range of regional needs with respect to water allocation strategies does require flexibility and the introduction of efficiencies, but any changes implemented must retain the key principle of establishing priority for water for agricultural purposes.

BCAC Recommendations:

10. That the First in Time First in Right (FITFIR) allocation system be maintained in a modernized Water Act, as it is a fundamental principle in providing security of supply for agricultural water users. In areas where there has been a delegation of responsibility to a local authority such as an Irrigation District, provisions should provide for the establishment of a water sharing plan involving all users during times of drought or water shortages.

11. That any transfers of water rights from an agricultural user to provide for flexibility not be transferred out of agriculture, but only to other agriculture water users. The concept of establishing an agriculture water reserve in watershed allocation systems would recognize the importance and value of water for agriculture production and discourage the transfer of water licenses to other purposes. It is critical from BCAC’s perspective that water does not become a commodity that is sold off to the highest bidder.

12. That the beneficial use of water requirements in the existing Water Act be amended to ensure that there is no disincentive to implement water conservation practices.

13. That all water fees for agricultural users be based on rates set appropriately for agriculture, and which consider the sector’s ability to pay.


Goal Four – Regulate Groundwater Extraction and Use:

The BCAC recognizes the significance of BC’s groundwater resources, and supports the development of an improved knowledgebase of this resource in order for both governments and users to make informed and rational decisions.

BCAC Recommendations:

14. That a provincial registry of wells be established in the province to obtain a better understanding of BC’s groundwater resources.

15. The BCAC supports the proposal to regulate groundwater use in priority (critical) areas.

16. That existing groundwater users be protected by recognizing their water uses in the development of any regulations for groundwater, with the objective of ensuring those who have already discovered, developed and maintained this water source will continue to have their privileges/rights respected.

17. That the practice of deep injection of water into wells for oil and gas extraction be either eliminated entirely or, at the very least, limited to the use of grey water.

Conclusion:

Amending this crucial legislation, the provincial Water Act, has enormous direct implications on the income and livelihood of literally thousands of farm and ranch family businesses across British Columbia.

BCAC Recommendation:

18. That the BCAC, on behalf of its members, be given the opportunity to provide further substantive input to the changes being contemplated by the provincial government as it moves to the next Phase of its modernization of the Water Act consultation process.

Respectfully submitted,

BC Agriculture Council