08/21/2006

Bill 43, The Clean Water Act, 2006: AMO Presentation to the Standing Committee on Social Policy. August 21, 2006.
Municipalities have fundamental concerns around the current structure of the proposed legislation. There is a lack of decision making at the front end of the process and at the development stage of the Source Water Plans. However, subsequent to plan development and approval, they face increased costs and exposure to liabilities in plan implementation.  The legislation fails to address funding for a mandate that goes on in perpetuity.

AMO has reiterated its concerns with the issue of roles and responsibilities from the beginning. Unfortunately, we have not been heard.  AMO continues to have substantive issues with the lack of a municipal role in areas of source water policy development.  On the other end of the spectrum, in the area of implementation, municipalities will be given a substantive, but apparently unfunded mandate. 

In respect to municipal decision-making, municipalities do not have a leading role in the development of any of the work leading to the development of the Source Water Protection Plans or decisions on the Plan.  The responsibility of preparing the Terms of Reference, Assessment Reports and the development of the Source Water Protection Plans falls to the Source Water Protection Authorities - Conservation Authorities - or the Source Water Protection Committees.  Not only is there a lack of direct decision making role for municipalities, there is also very limited representation of any one municipality on either of the 2 leading Source Water groups - the Source Protection Committee and the Source Protection Authority.