I appreciate the proposed…

I appreciate the proposed Regulatory changes for accelerating and improving protections for Ontario’s drinking water sources under the Clean Water Act, 2006 that aim to streamline the cost and time to process source protection plan amendments in a world where more agile land use planning systems are needed.

In particular, I would like to express my support for a few key changes to the CWA's supporting regulations that seem likely to bring low-cost benefits. Namely, I would like to support the proposed amendment for source protection authorities to be able to approve the application of an existing protection plan to newly-identified source areas (especially given proposed protections that the MECP Director has assured the assessment report is adequate and other implicated parties are notified with comprehensive information), as well as the proposed amendment to use a streamlined process for administrative-only amendments (where the specific administrative-only cases identified seem very reasonable).

At the same time, one area where I would like to express concern is with the proposed amendments to consultations. Specifically, while I would support the removal of requirements for outdated consultation practices like mandatory newspaper notifications, I would only support the removal of these requirements on the condition that a requirement for notifications in some format be maintained. As well, I would like to express strong opposition to the full removal of a pre-consultation phase.

Finally, unrelated to the specific amendments proposed, I would like to also comment in advance of the regulatory impact assessment that will be conducted for these regulatory changes. While the existing framing of the proposed regulatory changes focuses on facilitating new housing development and infrastructure, I would like to suggest that consideration also be given to how proposed regulatory changes could support better providing reliable, high-quality drinking water to Indigenous communities, who are highly underserved in their access to clean drinking water.