Policies to date have as…

Policies to date have as noted addressed pipeline mapping, emergency planning, spills prevention and integrity testing. All of which are generally accepted as required elements in a pipeline integrity and emergency management program under both federal and provincial legislation.

The proposed amendment suggests that drinking water sources should be considered during planning of furture pipeline, however, I believe that the drinking water sources should be identified as an area of high consequence as defined in the TSSA's O.Reg 210 Code Adoption Document (CAD). They are not currently noted as such, however, it could be argued that it is covered by the term "an unusally sensitive area, as defined by the pipeline's integrity management program", further source protection committees could be identifed by the CAD as an authority that should be consulted with during required communication meetings. The TSSA should consider these additions to a future CAD to align with source protection progams.

A gap that should be addressed if new policies are to be implemented is to strenghten notification and information coordination. Currently, most municipalities do not have a one window approach to priority non-emergency notifications. Emergency would be 911 and Fire local number. Non-emegrency would be those communities that have established 311 windows (Toronto, Ottawa, etc) the gap lies with such things as water emergencies, environmental emergencies (spills), etc. While the legal requirement of a responsible party is to notify the MOECC; via the Spills Action Centre, the owner of the pollutant and the municipality. The municipality notification can be met by calling 911 which often does little in the way of ensuring that the appropriate authority having jurisdiction over source water protection or water distribution is advised of the potential threat.

A one window for priority non-emergency notifications and information sharing, potentially between responsible parties, other agencies, publich health officials, source protection committees/ CAs etc. might reduce the response time and ensure good decision making based on timely and credible threat data.

[Original Comment ID: 212753]