Proposed amendments to the…

ERO number

026-0301

Comment ID

185924

Commenting on behalf of

DG GROUP

Comment status

Comment approved More about comment statuses

Comment

Proposed amendments to the Water and Wastewater Public Corporations Act, 2025 and consequential amendment to the Safe Drinking Water Act, 2002
ERO POSTING #: 026-0301
May 14th, 2026
Please review the attached comments against proceeding as currently outlined in this ERO posting:
• DG GROUP is a land developer that has been active in Peel Region for 40 years and continues to develop Residential, Commercial, Retail and Employment lands throughout Peel.
• DG GROUP believes the proposal to set up a WWPC is a monumental opportunity to address fundamental issues that persist today that challenge affordability and competitiveness in the Region of Peel and the Province of Ontario.
• DG GROUP believes that without changes to this proposal as outlined in the ERO posting, existing issues will be expanded.
CONTEXT:
• The Region of Peel is currently the forecasted to grow to approximately 2.5M people in 2051.
• The Region of Peel current Water and Waste Water Plan to meet this growth is:
o 2026 = $1.39 Billion(B)
o 2027 = $2.89 B(forecasted)
o 2028 = $3.17 B(forecasted)
o 2029 = $1.74 B(forecasted)
 Source Region of Peel Council report March 26, 2026
• Water and Waste Water Infrastructure Plan update.
• The Region of Peel is looking to construct and collect Development Charges for approximately $9Billion of infrastructure to 2030.
• Development Charges are a flow through cost to homeowners, collected at occupancy and financed through individual mortgages.
Challenges vs Opportunity:
Challenge: Development Charge Infrastructure has become unaffordable in Peel.
• Private sector investment is necessary to mitigate the cost of this infrastructure.
• The Province should be looking for Investors for the new WWPC while retaining ownership.
• Many Canadian and Provincial Pension plans already own/operate similar infrastructure outside of Ontario.
• Creating a corporation outside of the restrictions of the Municipal Act, funded in the same manner, with different debt capacities will not address affordability concerns.
• Without change the new homeowner will continue finance unaffordable Development Charges on their mortgages
Opportunity:
• The Province should consider “shifting” some or all the financial burden of Development Charges to the Private Sector. This will increase the affordability of houses in Peel.
Challenge: Political theatre in Infrastructure Planning.
• Short Political Terms and Local Political interests impact decision making.
• Municipal Standards have become "Gold-plated" as infrastructure projects are built beyond necessary requirements, incorporating excessive, costly features or over-engineered standards to lower maintenance cost.
Opportunity
• A professionally based board with no political interests must be structured to allow for efficient and affordable infrastructure delivery over a long period of time.
• Private Sector investment will create awareness to ensure lifecycle costs are considered.
• The new WWPC must adhere to the SDWA but can be managed appropriately by professionals.
The creation of the WWPC is too important of an opportunity to simply ignore private sector investment in Municipal Infrastructure. Creating a new municipal environment in Ontario to attract private investment in municipal infrastructure will establish a sustainable funding model moving forward that will provide safe and efficient infrastructure for future generations. This will create a more balanced financial burden beyond exclusively Development Charges to share growth costs and increase affordability across all sectors.