The Ministry of the Environment, in partnership with the Walkerton Clean Water Centre, is offering information sessions regarding the recent O. Reg. 170/03 amendments for owners and operators of drinking water systems serving designated facilities and non-municipal year-round residential drinking water systems. The sessions will run from October 23 to November 29, 2006. See the links below for more information:
On June 30, 2004, the Minister of the Environment wrote a letter to the Advisory Council on Drinking Water Quality and Testing Standards, requesting advice on O. Reg. 170/03 requirements for small systems, particularly private systems.
· Experts in drinking water, and specifically the area of risk presented by smaller systems;
· Parties concerned with the quality of drinking water and the impact on consumers;
· Parties responsible for compliance and delivery of drinking water; and
· The general public.
Interested parties were invited to make a presentation to a panel of the Council. In addition, other groups were welcome and the sessions would be open to the public.
Specifically, from October 25, 2004 to November 8, 2004, the Advisory Council on Drinking Water Quality and Testing Standards held stakeholder / public consultation sessions all across Ontario in order to gather further input and insights on Regulation 170/03, as it relates to smaller, private water systems.
Twelve sessions were held (Arnprior, Dunnville, Chatham, Kemptville, Goderich, Belleville, Elora, Bracebridge, Lindsay, Thunder Bay, Sudbury and Alfred), as well as well as another seven by videoconference (Geraldton, Nipigon, Fort Frances, Kenora, North Bay, Sault Ste. Marie, South Porcupine).
View the consultation summaries and individual presentations of these sessions
While the Council heard from a diverse range of groups and individuals, several key issues and concerns were common to both stakeholder organizations and members of the public; those issues tended to dominate the sessions, regardless of geographic location. Those key concerns and recommendations are summarized below:
Cost
General
· Costs related to initial system installation or upgrades, ongoing maintenance, testing and monitoring will be prohibitive for many small system operators, such as community centres, churches, fairgrounds, conservation authorities, small businesses, mobile home parks, campgrounds.
· Base treatment and testing requirements on assessed risk to the system, should be done as follows: assessment by public health units, funded by MOE.
· Costs cannot be so prohibitive as to force business closures.
· Systems that have been upgraded prior to regulation should not have to be upgraded again.
Equipment
· Require treatment for small-system operators only when adverse results are found.
Certification
· If a small system operator proves a long history of clean water test results, do not make them engage an engineer to produce a report or to upgrade their treatment system.
· Develop a pre-approved system template to help reduce engineering costs for small system operators.
Testing
· The lack of testing facilities in rural areas adds to the cost of testing.
· Testing in remote areas, especially for tourist operators is challenging and costly.
· Reduce the required frequency of testing in order to reduce costs.
· Reduce the required range of tests where there is little risk – e.g. testing for pesticides in the North may be unnecessary.
· Reduce the required frequency of testing for organizations with high technology filtration and security processes already in place.
· Allow operators of small systems to conduct the testing themselves and only require outside testing when there are adverse results.
· Allow daily turbidity monitoring versus on-line monitoring
Funding
· The province should provide funding for treatment equipment and testing for small system operators.
· The province should provide funding for smaller municipalities that can’t afford the system upgrades.
· The province should provide provincial tax refunds on water treatment equipment and expenses.
· There should be a similar commitment from the government as was provided with the Nutrient Management Act – no organization will be forced to close because they can’t afford the system upgrade costs.
· Mobile home owners should be subsidized due to low income and elderly, at –risk population
Responsibility
· There is a need for an arms-length body that can provide advice on compliance, equipment, monitoring, etc. without the fear of enforcement.
· Public Health Units should be responsible for water testing – under the purview of Ministry of Health and Long-Term Care.
· Public Health Units have experience in testing small systems; are accessible to small operators; and can do the job for less cost.
· Public health inspectors should enforce Regulation 170/03.
· Public health inspectors are good sources of information for operators of small systems.
· Public Health Units will likely require additional human and financial resources to assume additional tasks under Regulation 170/03.
Implementation
· Implementation timelines should be extended to allow organizations to absorb the treatment installation costs over two fiscal years.
· Some organizations felt the deadline of December 31, 2004 to notify the government of compliance or non-compliance should be extended.
Communication and Training
· MOE should communicate more proactively with stakeholders that must comply with Regulation 170/03 as many of them are unaware of the scope of the requirements.
· MOE should provide a clearly worded summary of Regulation 170/03 as most people do not understand the Regulation, how it applies to them, and what they must do to comply.
· A breakdown of the 8 categories would be useful, even to the point of splitting the regulation up into 8 new regulations.
· MOE should provide training for people who have not previously been responsible for water distribution.
· Operators of small systems may not know where to turn for advice when they receive adverse test results. More support is required from MOE.
· MOE inspectors should provide advice to operators to reduce consulting costs.
· MOE should provide further guidance on acceptable treatment systems and information on certified installers. Many small organizations are uncomfortable investing in treatment equipment if it will not be acceptable to MOE.
· The minimum requirement of a grade 12 education to become a certified system operator is problematic since many skilled system operators do not have a grade 12 education.
· Community Colleges may see this a new area of programming that they can develop
· Clean Water Centre of Excellence in Walkerton could / should be involved in training.
Legislation
· Bottled water should be as closely monitored and regulated as small non-municipal, non-residential systems.
· Source water should be regulated in conjunction with drinking water.
Exemptions / Options
· A number of organizations suggested that they should be exempt from Regulation 170/03, including:
- Churches and community centres, because many said they will be forced to close because they can’t afford the necessary system upgrades;
- Remote tourism operators, especially because of the difficulty and cost of frequent testing;
- Small bed and breakfasts, who are on residential water systems;
- Small businesses, because many said they can’t afford the necessary system upgrades; and
- Mining operations, which fall under Regulation 170/03 because they exceed the cut-off limit in pumping capacity, but not the actual distribution volume.
· A number of organizations asked to be allowed the option of permanent sign posting rather than treat the water, although several suggested that this would have effects on tourism and posed potential risks (i.e. for children who can’t read).
· Generally provide some options so that owners / operators can have a choice that suits their needs while still providing safe water.
Reporting Process
· Simplify the reporting process and make it less onerous by requiring annual summary reports of water test results.
Wells
· Well inspections should be emphasized to a greater degree; greater diligence in this area would reduce improper installation and susceptibility to potential groundwater contamination.
· Consider a well permitting system.
· Put greater emphasis on more frequent testing of the structural integrity of wells.
Treatment Options
· Participants expressed concerns about chlorination treatment due to its unknown effects on health, environment and septic systems.
Liability
· Clarify liability and insurance issues for small system operators, such as churches, community centres, etc.
· Clarify liability and insurance issues for private owners of communal wells.
Click on the links below to view the summaries. As well, each individual presentation (for which material was presented) is available by clicking on the links found in the summaries.
