I appreciate the forward…

I appreciate the forward-thinking work that is being done towards Accelerating and improving protections for Ontario’s drinking water sources by proposing to amend the Clean Water Act, 2006. In particular, I am strongly supportive of efforts to streamline both the cost and time of the source water protection plan amendment process in order to adapt to a new reality wherein more agile land use planning systems are needed.

Nonetheless, I have questions regarding some of the specific changes that are proposed. For instance, why is it necessary to place limits on the content of prescribed instrument policies so that specific management measures cannot be prescribed? Would this restriction on the options available to regulators not be better placed in an internal implementation policy for how to apply the CWA rather than as a legislated restriction on regulators' authority? Similarly, why is it necessary to restrict the ability of regulators to prohibit existing activities? While it is understood that this would be inconvenient for some actors, it is possible that existing activities could be found to be a threat to source water; would it not be a more balanced approach to, for example, just mandate that there must be a transition period available for those actors to stop an existing activity?

In any case, while I am confused about the need for making these amendments in legislation (e.g. vs only in supporting policies and application), I do recognize the practical benefits that can be gained by setting an overall target to achieve rather than prescribing specific management measures. To that effect, I would like to also express support for the proposed requirement that instrument issuers must document and report on how an applied instrument / measure manages the identified threat.