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CWWA Writes to Mr. Samy Watson, Assistant
Deputy Minister of the Environment
November 3, 2004
Mr. Samy Watson,
Deputy Minister
Environment Canada
10 Wellington St., 27th floor
Gatineau, Québec K1A 0H3
Dear Mr. Watson;
I want to thank you for the opportunity last month to speak
frankly about our relationship with Environment Canada,
and to express our desire to continue working with the Department
as a key stakeholder group on water and wastewater issues.
Catherine Jefferson and I were heartened to learn that
you had analyzed and considered deeply the implications
of CEPA on the municipal sector, particularly as to the
instrument for managing ammonia, chloramines and chlorinated
wastewater effluent. We reported this to the CWWA Board
and members.
You recognized the paper and reporting burden on municipalities
in recent Environment Canada initiatives is significant.
Combine this with requirements of the provinces, and it
becomes unbearable. Both levels of government have or are
requiring detailed reporting of information and activities.
This does not in itself achieve identifiable improvements
to the environment. Penalties for improper or late reporting
are potentially huge. As a consequence, scarce municipal
resources are being diverted to paper work management rather
than for environmental improvement. I hope that we will
have future discussions on this aspect of Environment Canada's
regulatory role as it impacts municipal water and wastewater
operations.
CWWA is hoping that in probing and restructuring the Department,
consideration will be given to a life-cycle approach to
environmental management in addressing issues such as CEPA
toxics, particularly as these may relate to municipal systems.
Municipalities are bound by provincial legislation to provide
wastewater services, with limited powers and inadequate
funding or revenue generation. Municipal wastewater systems
are in many ways, simply a vector through which pollutants
and contaminants pass from a source to the environment.
In this vector there are limited technical abilities to
remove the contaminants. CWWA asks that the Department which
on one hand promotes water conservation and protection,
reduction of green house gases, creation of energy savings
etc. and on the other develops instruments to reduce one
substance while potentially generating a more widespread
problem. For example, ammonia reduction results in nitrate
formation. Switching from chlorination of effluents (for
public health purposes) or de-chlorinating following disinfection
or substituting UV for chemical disinfection creates other
environmental concerns. CWWA promotes the need for longer
term and life-cycle planning and a more holistic approach
to environmental management including what may be termed
environmental consequence analysis of proposed policies
and instruments. On a broader basis, some consideration
has to be given to the policy and practical balance (where
there is a conflict) between the achievement of public health
objectives and protecting the environment. We must establish
a hierarchy of benefits and risks.
On a recent very specific point, at the Western Canada
Water and Wastewater Association's Annual Conference last
month, Barry Munson of the Western and Northern Region made
a presentation on the ammonia / chloramine initiative. While
stressing the decision was still the Minister's, he indicated
that although a different approach was now considered for
ammonia, P2 Planning was still the preferred instrument
to address chloramines and chlorinated Effluents. This remains
a concern.
In view of our meeting and your statement that you were
not sure that P2 should be applied in the municipal circumstance
(it was not in the case of Road Salt), and that a different
approach was being contemplated for ammonia, I have to ask
why this analysis and approach cannot also applied to the
chloramine / chlorinated effluents situation. I will not
reiterate my statements made to you favoring a Guideline
approach for chloramines and chlorinated effluents as you
indicated that you had captured them. I also recognize that
the time is very close for the CEPA deadline, in which case
I would point out that subsection 92 (1) of CEPA does allow
the Minister to extend the deadline for publication of the
final instrument where substantive change is required to
the proposed instrument.
Mr. Watson, I also want to address the issue of the Expert
Advisory Group (EAG) which is often referred to in past
correspondence from the Department to the Association. The
EAG met only briefly and twice, the last time in early July.
We have been told that of the four expert groups invited,
CWWA is the only one that provided comments when requested.
Our original offer to the Department made last year and
again last November at the Window on Ottawa Workshop was
to assemble a true and representative group of municipal
wastewater experts (managers and professionals) to work
with Departmental Staff. Our goal would be to offer practical
advice on what could be achieved to meet the needs of the
Minister and Act, that would be practical and effective.
Regretfully, the Department has never taken up this offer.
It is still offered, but what is needed is the time to give
it effect. Extending the time frame under subsection 92
(1) would allow that. CWWA believes we can jointly develop
a mutually satisfactory solution and is committed to do
so.
Thank you again for your time and we look forward to future
discussions and your participation in the November 30 /
December 1 Window on Ottawa Workshop..
Sincerely,
T. Duncan Ellison,
Executive Director
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