1. The new regulations will…

1. The new regulations will exempt wastewater projects that process less than 50,000 litres per day. This should facilitate the development of small housing project under 50 units. At the same time, such projects are generally accompanied by the installation of a drinking water system which will still be required to proceed through a Municipal Project Assessment Process. As a result, the timeline for such combined projects may not be decreased.

2. While the less than 50,000 litres per day exemption is welcome, we would recommend that the Ministry consider increasing this limit to reflect residential housing developments up to 100,000 litre per day. This should incentivize developers to bring forward more efficient housing options, including multi-residential units.

3. The current approval process for municipalities within the jurisdiction of a conservation authority (there are four in Frontenac County), requires us to move through two parallel, non-coordinated processes under the EA process and source water protection requirement with our local conservation authority. Both programs are administered by your Ministry. This bifurcated process is time consuming, expensive and could result in the municipality receiving approval under one process and have a different decision in the other. We urge the Minister to consider harmonizing these two processes.

4. The planning process for subdivision development under the Planning Act, RSO 1990 should be utilized as the primary process for the approval of communal services for development. The subdivision process is open, transparent, and respectful of the environment. Municipalities have traditionally used this process to review, approve and facilitate the efficient development of housing in our communities.

5. Recommendation #44 from the Provincial Housing Affordability Task Force of 2022 recommended the establishment of municipal services corporations to facilitate servicing. The FMSC recommends that the Ministry recognize that service corporations are acknowledged as leading experts in communal servicing and be afforded status under the regulation.

6. Communal servicing solutions are utilized around the world. Much like a decentralized hydro grid, decentralized water, and wastewater services act as a hedge against failure by limiting the potential for large scale failures. The current state in Ontario is that each communal solution is treated like it is the first installation. Our analogy is that this is like treating every Ford F-150 truck as the first one. Our recommendation is that a system be pre-approved by the Ministry based upon a risk assessment matrix and that water taking and discharge be based upon the system meeting pre-determined source and discharge requirements. This action would greatly reduce development times and permit housing development to occur in a timely fashion.

7. In our experience, the servicing for housing utilizing communal services will cost between $15,000 and $20,000 per unit. Compared to $35,000 to $40,000 for a traditional well and septic solution, or more than $50,000 for traditional municipal services.

8. Finally, we are concerned that the current system exempts private developers. This places projects where the municipal, or service corporation is the proponent at a disadvantage. The County of Frontenac and our member municipalities have a 160-year record of responsible government. We will be here long after the developer exits the scene and will be the responsible owner. Frankly, it does not make sense that a developer would be exempt from provisions such as the source water protection component, while the municipality is held to a higher standard.