Firstly - it was a major…

Firstly - it was a major oversight not to include it from the beginning, when funding was available and planning activities could have adequately considered this item.

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?

Generally no. In my area, it's already being done. A better approach may be to empower source protection committees to locally establish policies regarding new sources, to ensure that the work is truly integrated into the local planning activities. A good plan should consider the NOW and the FUTURE.

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?

If this is a new rule, there really is no advantage for municipalities. Source protection considerations should be integrated into site selection and evaluation, during the Environmental Assessment - not undertaken after the fact. It would help to have clear guidance from the ministry on best practices or mechanisms for streamlining the protection activities related to a new source, to lower overall costs.

Additional funding opportunities would help to mitigate the impact of this proposed change.

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

What is the total projected cost of this change (impact)? Has this been considered? The process for adding a new well or adding a new intake is already quite expensive and requirement intensive for municipalities. Preparation of a source protection plan is not a short process - this could add both considerable time and cost to an already over-taxed user base.

[Original Comment ID: 211624]