On behalf of the Board of…

On behalf of the Board of Health for Peterborough Public Health I am writing to express my concerns with Bill 66, Restoring Ontario’s Competitiveness Act, 2018. If passed, this legislation could have deleterious effects on the health of our residents and all Ontarians. Given the risks to public health, I am hoping you will give serious reconsideration to some of the proposed changes.

One of the goals in the Ontario Public Health Standards, 2018 is to “reduce exposure to health hazards and promote the development of healthy built and natural environments that support health and mitigate existing and emerging impacts.” Our staff work with First Nations and area municipalities to achieve this goal and the changes proposed in Bill 66 stands would threaten this work. As it is currently drafted, the bill will allow municipalities to exempt proposed development from a wide range of planning and environmental protection legislation. This has the potential to open the door to large scale development in vulnerable areas which may threaten groundwater and surface water sources.

Furthermore, the successful passage or Bill 66 would result in the repeal of the Toxics Reduction Act and Regulation 455/09 on December 31, 2021. This Act, passed in 2009, increased the protection of the public and environmental health by reducing the use and creation of toxic substances and informing Ontarians about toxic substances. I can attest that the historical chemical contamination of local soil and water continues to pose a health hazard and an outstanding health concern for present day residents here. Peterborough’s industrial legacy further demonstrates the need for a strong regulatory framework to protect the health of our community from toxic substances. Peterborough Public Health strongly urges the Ontario government to reconsider the repeal of the Toxics Reduction Act.

It is deeply concerning that Bill 66 proposes to exempt Planning Act decisions from the source water protection section of the Clean Water Act, 2006. This section requires that land-use planning decisions protect drinking water sources from threats such as landfills, sewage systems, and the storage and handling of fuel, fertilizers, manure, pesticides, road salt, organics solvents and other substances. Communities in Peterborough County and City, including Curve Lake and Hiawatha First Nations, rely upon both surface water and groundwater sources for their drinking water. The source water protection clause of the Clean Water Act arose from the recommendations of Justice O’Connor in the Walkerton Inquiry and is intended to prevent the type of source water contamination which occurred in Walkerton resulting in the death of seven residents and made over 2300 seriously ill.

Source water protection plans include a requirement to re-inspect sewage systems falling within source water protection zones. We partner with our area municipalities to deliver septic re-inspection programs for all sewage systems in those municipalities to ensure that sewage systems are working properly and to protect the health of residents. We work tirelessly to advocate for and implement these re-inspections programs and are alarmed by the potential of Bill 66 to allow development to occur in a source water protection area potentially negating the impact of our work.

In our review of the proposed changes in Bill 66, my staff and I believe that this legislation will dangerously weaken the source to tap regulatory framework currently in place which ensures the provision of safe and potable clean water for the residents we serve.