Comment on “Applying a science-forward approach to groundwater regulatory design”: Paper published in Hydrogeology Journal (2023) 31:853–871, by Deborah Curran, Tom Gleeson and Xander Huggins

Excerpt

The subject article (Curran et al. (2023)) used, as a case study, the British Columbia (BC), Canada’s recently enacted (in 2016) Water Sustainability Act (WSA; Water Sustainability Act 2014) to illustrate the failure of regulatory design to licence groundwater use. For disclosure, two of the authors of this Comment were part of the team of BC government staff involved in the development of the legislation for regulating groundwater use in the WSA. This Comment presents an alternative perspective to balance the analysis of the regulatory design presented by the subject article, that a science-forward approach was lacking and that area-specific considerations were “ignored” in the regulatory design of the WSA. The goal is to highlight the inclusion of flexibility through the enabling provisions in the regulatory design of the WSA. …