Subject: Submission…

Subject: Submission Regarding ERO 025-1098 – Proposed Amendments to the Municipal Act, 2001 and Establishment of Water and Wastewater Public Corporations
Dear Sir/Madam,
On behalf of the City of Brampton, we appreciate the opportunity to provide comments on the proposed legislative changes outlined in ERO 025-1098, which seek to transfer jurisdiction over water and wastewater services from the Region of Peel to the lower-tier municipalities of Brampton, Mississauga, and Caledon, and to authorize the establishment of water and wastewater public corporations.
The City of Brampton supports the modernization of service delivery and the principle of local accountability. The proposed transition presents a significant opportunity to enhance coordination, strategic investment, and alignment with local growth and infrastructure priorities. However, we respectfully submit the following considerations and recommendations to ensure a successful and equitable transition:
• The transition must be carefully managed to ensure uninterrupted service delivery and critical infrastructure development. We recommend a phased and collaborative approach with clearly defined timelines, funding mechanisms, and operational protocols. Coordination with the Region of Peel and the Province is essential to maintain servicing capacity and project continuity;
• The proposed skills-based board under provincial oversight should include meaningful municipal representation to ensure local priorities are reflected. Clarification is needed regarding the role of municipalities as shareholders or partners and how governance decisions will be made collaboratively.
• The proposed self-financing, rate-supported model must be designed to ensure affordability for residents and businesses. Municipalities should not be required to guarantee corporate borrowing unless explicitly agreed upon. The rate-setting process should include municipal input and transparency to reflect local economic conditions and infrastructure needs.
• A clear and equitable mechanism is needed to transition development charge (DC) collection and allocation from the Region to the new corporation. The City emphasizes the importance of maintaining funding continuity for growth-related infrastructure and ensuring accurate reconciliation of DC reserves.
• The legislation should support integration of water and wastewater systems with broader municipal initiatives, such as energy recovery (e.g., biogas, wastewater heat recovery), climate resilience, and smart infrastructure. We encourage enabling provisions that facilitate innovative opportunities and sustainable infrastructure solutions.
• Clarity is required on the process for transferring assets and employees from the Region to the new corporation, including valuation, compensation, and labour relations considerations. A fair and transparent framework is essential to ensure operational readiness and workforce stability, including continuity of pension plans.
The City of Brampton is committed to working with the Province and regional partners to ensure a successful transition that enhances service delivery, supports growth, and reflects local priorities. The new entity’s governance structure, processes and funding mechanism will have significant impacts on the local municipalities, and it is critical the province works collaboratively with all involved parties. We welcome further consultation and request that the Province provide detailed regulations and guidelines to support implementation.
Thank you for the opportunity to provide input on this important initiative.
Sincerely,

Marlon Kallideen
Chief Administrative Officer
City of Brampton