On behalf of the Water &…

On behalf of the Water & Wastewater Subcommittee of the Regional Public Works Commissioners of Ontario (RPWCO), I respectfully submit the following comments on ERO 019-8728.

RPWCO is generally supportive of the proposed changes to Ontario Regulations 208/19 and 172/03, allowing transit authorities to make alterations to municipal sewage and drinking water systems. Designating transit authorities as “prescribed persons” will allow changes to be made under the authority of the municipality’s Consolidated Linear Infrastructure Environmental Compliance Approvals or Drinking Water Works Permit.

Recognizing transit authorities will allow municipalities to review and approve changes to its system in the same manner as those done by entities authorized via an agreement with the municipality under the Planning Act or the Development Charges Act. The regulation needs to make it clear that the municipality has the authority to review and approve the design before the work begins and that the municipality will have to sign the Form 1 or Form SS1 to consent to the modification to the system before it is placed into service.

RPWCO recognizes that this change will streamline the approvals process for transit authorities as it will remove the need for all proposed alterations to be submitted to the Ministry of Environment, Conservation and Parks and be subject to a lengthy approvals process. We look forward to participating in the consultation on the draft regulation.

Regards,

Ashley Rammeloo, MMSc., P.Eng.
Co-Chair of the Water Wastewater Subcommittee, RPWCO