In considering the proposed…

In considering the proposed regulation from a Perth County context, we respectfully provide the following comments for consideration:

1. The Chief Building Officials are supportive of some criteria proposed to regulate additional sewage systems, particularly limiting individual design capacity of systems to 10,000 L/d but allowing for multiple systems up to 50,000 L/d, as this aligns with the types and scale of systems that CBOs already have experience with. Further limiting the proposed systems to Building Code Class 4 sewage systems simplifies how CBOs will regulate such systems. Inclusion of other system types like holding tanks, privy and greywater systems would make it overly complicated to calculate design capacity and would open up a lot of questions about whether the proposed spacing between systems was necessary. As such, the Province is encouraged to maintain these design criteria to keep the regulation process simple.

 
2. Chief Building Officials have significant concerns surrounding the design criteria that places an acreage threshold on each allowed sewage system and requires the system to be located in the centre of 10 acre size minimum. As currently proposed, for each additional sewage system proposed above the existing 10,000 L/d threshold, an additional 10 acres of land would be required to locate each individual system on its own 10 acres of land. This is in conflict with the long standing concept of clustering of buildings and infrastructure to optimize farmland to be used for farming. These systems do not require 10 acres to function properly in all soil types and requiring them to have such separation from each other and other farm buildings needs to be explained. These separations would possibly separate 5 systems over 50 acres meaning that housing would dotted across a farm instead of clustered. Further, as heavy machinery cannot drive over sewage systems, large swaths of agricultural land will go unused. The internal road network alone would take up a lot of valuable farmland. Staff are requesting that the Province provide justification for why the systems require 10 acres of land to function and further request that the Province consider the implications of allowing for development to occur outside of existing farm building clusters.

The following general comment is provided regarding commenting timelines for Bill 60:

3. Over the past year alone, there have been at least 12 bills and regulations released by the Province that have significantly changed the planning policy and development framework within Ontario. The frequency in which policy changes have been released by the Province and the short commenting periods associated with each change are not conducive for meaningful feedback, as municipal staff are not provided an appropriate amount of time to understand the implications of Provincial directions before the next round of changes are released. The rapid-fire release of legislation changes, combined with limited staffing capacity and statutory review timeline requirements, negatively impacts County planning staff’s ability to provide meaningful comments on such policy changes. Meaningful comments are not possible where staff are only given a matter of days to review, digest, understand, and comment on legislative changes being made to dozens of Acts. Further, frequent release of omnibus bills at the Provincial-level takes away staff’s focus from local policy initiatives. A month spent on reviewing, understanding, and commenting on provincial policy changes is a month taken away from updating policies and regulations that are already outdated at the local level.

The above-noted comments have been discussed by County Council and endorsed for submission to the Ministry for consideration regarding the important amendments proposed through ERO Number 025-0900.