The Township of Ramara…

The Township of Ramara appreciates the opportunity to provide comments on the proposed amendments respecting communal drinking water and wastewater systems. While the Township recognizes the Province’s intent to improve clarity and consistency in the review of communal servicing proposals, there are significant concerns with the proposed approach set out in ERO 026‑0302.

As currently framed, the proposal risks:

constraining municipal discretion

shifting long‑term financial and operational risk to municipalities, and

facilitating servicing approaches that may not be economically or operationally sustainable over the lifecycle of the infrastructure.

These concerns are consistent and supported with findings from the AMO‑endorsed LAS Water and Wastewater Expert Panel, which highlights the systemic challenges faced by smaller and fragmented water and wastewater systems across Ontario.

Mandatory Municipal Consent and Loss of Local Decision‑Making Authority

The Township is concerned with the proposed framework that would require municipalities to grant consent to communal systems where prescribed criteria and conditions are met, particularly where those criteria have not yet been defined.

Municipal consent is a critical planning and infrastructure tool that allows municipalities to evaluate servicing proposals based on:

Local growth patterns,

Long‑term servicing strategies,

Financial capacity and staffing resources, and

Emergency management realities.

Requiring consent based on future regulations, without municipal input into those standards, creates uncertainty and limits the ability of municipalities to protect the long‑term public interest.

Notably, the LAS Expert Panel emphasized that any new water or wastewater governance or service delivery models must be voluntary, recognizing the varied capacities and contexts of Ontario municipalities. A mandatory consent regime runs counter to this principle and raises significant concerns for smaller and rural municipalities, such as Ramara Township.

Financial Sustainability and Economic Viability

Financial sustainability is the Township’s primary concern. The Township currently owns and operates six (6) individual drinking water systems and two (2) wastewater systems, which already present significant operational and financial challenges. These challenges are driven by aging infrastructure, limited economies of scale, increasing regulatory compliance requirements, and the geographic separation of systems. These all contribute to increased operating costs, staffing constraints, operational efficiencies, and complicated long‑term asset management and capital planning.

This challenge is not Ramara specific , as the LAS Water and Wastewater Expert Panel found that many water and wastewater systems, particularly smaller or lower‑growth systems, are already financially strained due to:

Aging infrastructure,

Rising construction and operating costs,

Increasing regulatory compliance obligations, and

Insufficient rate bases to support full lifecycle costs.

The Panel identified the prevalence of small, non‑economic systems as a key challenge facing Ontario’s water and wastewater sector.

In this context, the Township is concerned that the proposed framework could enable the creation of communal systems that:

Lack sufficient scale to be economically viable,

Are approved without robust lifecycle cost analysis, and

Depend on assumptions about future growth that may not materialize.

Without clear, enforceable requirements for full lifecycle costing, long‑term reserve funding, inflation‑indexed financial securities, and protection against phased or incomplete build‑out, communal systems pose a high risk of future failure or municipal takeover.

Risk Transfer to Municipalities

The Township strongly emphasizes that, regardless of ownership or governance structure, municipalities frequently become the system of last resort when communal water or wastewater systems fail or are not operated properly.

The LAS Expert Panel acknowledged that failures in smaller or fragmented systems often result in:

Municipal intervention to protect public health,

Emergency response obligations,

Pressure for municipal assumption of assets or operations.

The proposed amendments do not adequately recognize or mitigate this reality. Allowing communal systems to proceed under provincially prescribed criteria without ensuring alignment with municipal standards and capacity creates unavoidable long‑term risk exposure and cost implications for municipalities.

Operational, Emergency, and Governance Concerns

From an operational standpoint, communal systems can significantly increase municipal complexity and risk, particularly where they serve large geographic areas or operate independently of existing municipal systems.

The Township has concerns regarding:

Emergency response and operational coordination over dispersed service areas,

Limited operational redundancy,

Increased demands on already‑stretched municipal staff and resources.

The LAS Expert Panel reinforced that economies of scale improve system resilience, staffing capacity, emergency response, and long‑term asset management—advantages that are difficult to achieve in small or isolated communal systems.

Clear accountability, governance structures, and user communication protocols are essential, yet often lacking or insufficiently standardized in communal servicing models.

Strong Need for Provincial Best Practices and Design Guidance

Rather than mandating municipal consent through regulation, the Township strongly encourages the Province to develop a provincial best practices and design guidance document for communal drinking water and wastewater systems, in consultation with municipalities and sector partners.

Such guidance would align with the LAS Expert Panel’s emphasis on:

Financial sustainability,

Lifecycle asset management,

Operational resilience, and

Clear governance and accountability.

A best practices document could:

Provide proponents with clear expectations early in the planning process,

Promote consistent, high‑quality system design across Ontario,

Address financial viability, reserve funding, and phasing risks, and

Reduce the likelihood that municipalities inherit unsustainable systems in the future.

This approach would make communal servicing proposals more palatable for municipalities while preserving necessary local discretion.

Technical Standards and Long‑Term Integration

The Township also notes uncertainty regarding:

The definition of a “communal system,”

Appropriate monitoring and operational standards, and

Requirements for transition when municipal services become available.

The proposed framework does not clearly address how communal systems would be decommissioned, integrated, or connected to municipal infrastructure as growth occurs. Without clear provisions, there is risk of stranded assets and fragmented servicing that undermines municipal long‑term planning and investment.

Conclusion

The Township of Ramara does not support the proposed approach to communal servicing as currently outlined in ERO 026‑0302.

The Township’s concerns are supported by the findings of the AMO‑endorsed LAS Water and Wastewater Expert Panel, which highlight the financial fragility of small systems, the benefits of scale, and the importance of voluntary, municipally supported servicing models.

The Township respectfully urges the Province to:

Reconsider mandatory municipal consent provisions,

Clearly define financial, technical, and governance expectations upfront, and

Develop provincial best practices guidance to support sustainable and responsible communal system design.