January 18, 2019 Michael…

January 18, 2019

Michael Helfinger
Intergovernmental Policy Coordination Unit
900 Bay Street, Hearst Block
7th Floor
Toronto ON M6H 4L1

Re: Comment on Bill 66, Restoring Ontario’s Competitiveness Act, 2018

Dear Mr. Helfinger,

Thank you for the opportunity to offer comments on Bill 66, Restoring Ontario’s Competitiveness Act, 2018.

The need to attract business and industry to municipalities is imperative for economic growth and prosperity. The need for intelligent, science-based planning is imperative. Under Bill 66, there is the potential for the development of industry in areas that may negatively affect the environment and drinking water sources.

The Sault Ste. Marie Region Source Protection Committee has concern with the portion of Schedule 10 of the proposed Act, under jurisdiction of the Ministry of Municipal Affairs and Housing.

In Sault Ste. Marie, the Source Protection Plan and the Official Plan identify and recognize the significant groundwater recharge area (SGRA). The particular characteristics of the region indicate that all municipal groundwater sources originate in the SGRA. Under the Clean Water Act, 2006 regulations, an SGRA cannot be classified as a significant threat. As such, any policies developed for the area are based on municipal planning components. Therefore, existing source protection policies can be directly affected through Schedule 10 of Bill 66 under which Section 39 provisions of the Clean Water Act 2006 do not apply.

As well, under Bill 66, this SGRA area could be exempt from existing planning requirements as per: “Allow municipalities to permit the use without having to strictly adhere to existing local requirements”. In addition, the potential to remove the adherence to provincial policies and plans as noted in the EBR posting: “Remove the requirement for decisions to strictly adhere to provincial policies and provincial plans”.

The Source Protection Program of the Ministry of Environment, Conservation and Parks has developed, in partnership with local Conservation Authorities across the province, detailed science-based Source Protection Plans. These Plans are in place to protect the integrity of municipal drinking water sources, prevent contamination and encourage municipalities to proactively plan for development.

Please consider withdrawing the reference to Section 39 provisions of the Clean Water Act, 2006 from the final legislation for the safety and security of municipal drinking water sources.

Again, thank you for the opportunity to provide comments on Bill 66.

Sincerely,

Rhonda Bateman,
General Manager/Secretary-Treasurer
Sault Ste. Marie Region Conservation Authority

c.c. Kim Gavine, Conservation Ontario
Mark Howson, Chair, SSMR Source Protection Committee