The City of Kawartha Lakes’…

The City of Kawartha Lakes’ full comments are attached. These are the key points:

The City understands the proposal would establish regulation-making authority to prescribe conditions under which municipalities may be required to assume communal water and wastewater systems, with details to follow through future regulations.
The City has significant concerns regarding long-term municipal liability and financial exposure associated with communal systems.
Communal systems present a high risk of eventual failure or underperformance, and in practice municipalities are often required to assume responsibility regardless of original ownership or governance.
The Province should establish clear financial and operational backstops in the event of system failure, rather than relying on municipalities as the default provider of last resort.
Without such safeguards, municipalities may be required to assume significant long-term liabilities without corresponding authority or resources.
As a largely rural municipality with a dispersed settlement pattern, Kawartha Lakes is particularly vulnerable to cumulative infrastructure liability associated with multiple communal systems across the landscape.
Clarification is requested on whether communal systems would be considered “sewage works” under the Planning Act definition of “parcel of urban residential land,” and how this may interact with proposed minimum lot size provisions (e.g., ERO 026-0311).
It is important that municipalities retain the ability to require appropriate Planning Act approvals prior to the establishment of communal systems to ensure proper planning oversight.
There is a risk that communal systems could be constructed or initiated without full approvals, or left incomplete due to financial constraints, resulting in pressure on municipalities to intervene and assume responsibility.
The City supports enabling alternative servicing approaches, but emphasizes that any framework must clearly address long-term accountability, funding, and municipal authority.