1.In your opinion, is the…

1.In your opinion, is the proposed regulation under the Safe Drinking Water Act for municipal drinking water systems in source protection areas necessary to ensure source protection work is completed prior to bringing new or expanded drinking water systems online?

Understanding the benefits of completing source protection work ahead of intake construction/modification, such as potential threat identification and the delineation of impacted areas, the municipality has already established a process to ensure source protection work is completed as part of the Class Environmental Assessment Process for future capital projects. With this in mind, the municipality feels that completing source protection technical work prior to bringing new or expanded drinking water systems online is meaningful; however, it has implemented this process without a mandate from regulation.

2.What advantages are there for municipalities and system owners with the proposal to require source protection zones to be delineated around new wells or intakes before a drinking water works permit is issued? Is there anything that the ministry should consider including in the regulation that would assist municipalities?

The municipality feels that completing this work is important but somewhat unrelated to the issuance of the drinking water works permit. To explain, this flagging mechanism is more directly related to the permit to take water (bringing new or expanded drinking water systems online— the ability to put into service) than the drinking water works permit (approval to construct and operating limitations).

The municipality would like the Ministry to consider several exemption circumstances within the regulation such as work planned by federal entities, potential loss of external funding (provincial, federal, municipal cost-share), and other forces outside of the municipality’s control (emergency), which would allow construction to proceed concurrently with source protection technical work.

3.Is there anything else that you wish the Ministry to consider with respect to the proposed regulation outlined in this posting?

The municipality would like the Ministry to consider a grandfathered approach for capital work affecting intakes that have already undergone the Class Environmental Assessment Process. This could be facilitated by issuing the drinking water works permit with requirements to complete source protection work, to the detail outlined by the proposed regulation, before placing the infrastructure into service.

[Original Comment ID: 212782]