1) Staff would not be…

1) Staff would not be supportive of the Water and Wastewater Public Corporations Act as the proposed legislative framework raises serious concerns regarding accountability and governance, ratepayer protection, equity between municipalities, alignment with regional growth planning and financial sustainability.

2) The Province should establish clear governance frameworks ensuring municipal participation and ratepayer oversight in WWPC decision-making. There are no mechanisms for ratepayer representation or municipal input currently outlined in the WWPC proposal.

3) It is unclear if there will be safeguards or mechanisms to prevent excessive or sudden rate increases for ratepayers. The Province should include explicit ratepayer protections and local oversight mechanisms to ensure transparency, affordability and accountability.

4) The Province should provide explicit direction and transparency on cost recovery for infrastructure related to new development. Staff are concerned if WWPCs are restricted from collecting development charges while other municipalities retain them that developers may preferentially locate in WWPC-serviced areas, creating unfair competition. Municipalities retaining DCs may face slower growth, despite financial prudence and sustainability.

5) The proposed WWPC act does not specify whether WWPC’s must align investment decisions with municipal water and wastewater master plans, potentially resulting in misaligned priorities between growth planning and infrastructure delivery, delays or deferrals of essential servicing projects, and inefficient use of public funds.

If implemented, Staff recommend the Province establish a clear framework to coordinate WWPC capital investment with local municipal planning.

6) The Province should add a requirement to the proposed WWPC act to require joint servicing investment frameworks reviewed by municipalities and the Province.

7) The Province should consult further with municipalities to define accountability for infrastructure delivery when rate revenues are insufficient.

8) The Province should establish transparent mechanisms for prioritizing and financing growth infrastructure.

9) The Province should consider limited or super-regional models focused on high-level infrastructure (e.g., treatment and transmission), while leaving distribution and collection under local management. Staff are concerned that high-performing municipalities could be pushed to subsidize underperforming municipalities, as a centralized WWPC model(s) risk penalizing municipalities with well-managed, efficient systems by pooling reserves and debt.

10) Staff do not support giving the Minister legislative authority to use broad discretion to approve, reject or modify WWPC rate plans without mandatory consultation with municipalities or ratepayers. It is unclear if there is a mechanism to limit or phase rate increases or if there would be affordability safeguards established which may affect low-to-moderate income households.

11) Water and wastewater are essential public services. Staff are concerned about rate increases due to WWPC growth funding could double water bills in some areas,
exacerbating financial stress on households already facing high food, housing, and utility costs, and creating regional inequities, particularly for municipalities that purchase water from other regions (e.g., York Region buying water from Peel or Toronto).

The Province should conduct a thorough affordability and social impact assessment before implementing WPCs and ensure that cost allocation reflects service levels and geography

12) The Province should establish independent audit and reporting requirements

13) It is unclear in the proposal the accountability for infrastructure failures and ratepayer protection. Staff are concerned that the financial burden of deferred or poorly maintained infrastructure may fall on future ratepayers, with no local accountability.