Environmental Registry of…

Environmental Registry of Ontario #: 026-0302

Township of Oro-Medonte Comment

The Township understands that the purpose and intent of the amendments is to expedite home construction through private servicing infrastructure through a developer driven process. This approach is not a sustainable long-term model for critical wastewater infrastructure and can shift significant risk to municipalities, residents, and the environment. It represents significant risk to the Township as generally follows:

- Multiple servicing technologies across the municipality would be unsustainable if the municipality was required to take over responsibility for operation and replacement of non-municipal communal drinking water and wastewater systems.
- Unplanned residential densities serviced by non-municipal communal drinking water and wastewater systems would have an impact on municipal service levels and require additional resources.
- Financial risk associated with the need for municipalities to take over non-municipal communal drinking water and wastewater systems represents a significant tax implication to residents.
- Private communal systems often lack the lifecycle planning, capital reserves, and preventative maintenance required for multi-decade critical infrastructure. As these types of systems age, operators frequently face unplanned capital costs for major repairs or full system replacement, emergency operational spending to restore or simply maintain compliance and environmental remediation costs after system failures. Furthermore, when private operators become insolvent or systems fail, municipalities inherit the liability without adequate financial protections.
- Homeowners connected to communal systems often experience higher servicing fees due to limited economies of scale, large, unpredictable cost increases when systems deteriorate and special assessments to cover emergency repairs. These systems can create long-term affordability challenges for residents and can leave users paying more for less reliable service.
- Private communal systems create a fragmented network of small facilities that lack economies of scale, standardized technology, coordinated asset management and integrated monitoring. This results in higher per-unit treatment costs and reduced long-term efficiency compared to centralized municipal systems.

This approach is not recommended due to the above noted concerns as emphasis needs to be placed on municipal-wide servicing approaches to support growth in a co-ordinated manner rather than scattered growth supported by various communal systems. The amendments appear to have the effect of requiring municipalities to “consent” to such arrangements and accept the associated risks.

These types of systems require consistent and strong technical capacity, adequate funding, and robust compliance practices, which many small operators and municipalities already struggle with. Industry organizations such as AWWA note that small water and wastewater systems often face
significant challenges related to funding, staffing, technical capacity, and regulatory compliance. Likewise, OMWA consistently emphasizes the need for strong municipal oversight, sustainable funding, and long-term asset management for water and wastewater systems. These principles highlight the inherent risks of private small communal wastewater systems, which often lack the financial stability, technical capacity, and compliance frameworks required for long-term
sustainability.