Comment
It is necessary to consider the implications of source water protection policies on landowners at the earliest planning stages when locating a new municipal supply well or intake. Early notification, consultation and engagement are in the best interest of the municipality. This should not be overlooked. The MCEA process provides an existing framework in this regard. The proposed regulation must be accompanied by ministry outreach, guidance and frequent communication to ensure a clear understanding of the risks of postponing technical work to the drinking water works permit application stage including possible delays.
A core component that is missing from the proposed regulation is a commitment to timely approvals for amendments to Assessment Reports and Source Protection Plans to align with the technical work. We are therefore concerned about timelines for approvals by the ministry. There are opportunities to improve the flexibility of the approval process to allow section 34 amendments to be submitted to the ministry as necessary to reflect drinking water system changes. This will ensure that the source protection plan policies which rely on the Part IV tools enabled under the Clean Water Act are legally valid and enforceable without unreasonable delays.
[Original Comment ID: 212773]
Submitted February 28, 2018 4:19 PM
Comment on
Establishment of a regulation under the Safe Drinking Water Act, 2002
ERO number
013-1840
Comment ID
2849
Commenting on behalf of
Comment status