| Mar 20, 2024


In response to recently proposed changes to the Ontario Environmental Assessment Act, aimed at accelerating housing developments across the province, Frances Smith, in her role as President of Frontenac Municipal Services Corporation (FMSC) sent a letter on March 7 to the honourable Andrea Khanjin, Ontario Minister of the Environment, Conservation and Parks.

In her letter, Smith explained how the FMSC, which is wholly owned by the four Frontenac County Townships, has a “mandate to facilitate the efficient construction and operation of de-centralized communal water and wastewater systems within Frontenac County” which is a key factor in providing a variety of housing options, in line with the government's housing objectives.

While Smith commended the minister for her “leadership on this important issue for municipalities and the provision of housing in rural communities like Frontenac County,” she pointed out how the Act will still make it difficult for FMSC to fulfill its mandate.

“Our current experience with the EA approvals process in Frontenac is that the timeline for approval is 18 to 24 months, even for modest development projects. We find this both frustrating and demoralizing,” Smith wrote.

She then recommended that ministry consider making some futher changes to the Act.

Chief among those is to streamline the approval process, which currently includes two parrallel, costly and time consuming processes to deal with the same water and wastewater system approvals, an environmental assessment and a source water protection process, both overseen by local Conservation Authorities,without any co-ordination.

“We urge the Minister to consider harmonizing these two processes, “ she wrote.

She also urged the Minister to consider an FMCS proposal “the Ministry recognize that service corporations are acknowledged as leading experts in communal servicing and be afforded status under the regulation.”

Currently, each time a proposal comes forward from FMCS, it will be treated as a one-off proposal, triggering a lengty process.

“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.”

Finally, Smith points out that private corporations are exempt from some of the provsions in the act, but a Municipal Service like FMSC must adhere to all of them.

“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,” Smith said.

“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.”

The FMSC, which was recently incorporated, provides an option for private developers to invest in a communal water and sewage system within their development, and then turn that system, as long as it conforms to FMSC standards, over to the FMSC to operate. This saves costs for the developer because they will not longer have to pay the local township for the replacement cost of that system should it fail, and it provides security for the local township because the corporation overseen by them will be operating the system over the long term, not matter what happens to the developer.

The FMSC is also involved with two municipal projects that are on the horizon in Frontenac County, the proposed former Sharbot Lake Public School site develop, and a Senior's Housing project in Verona.

The attempt to secure a more co-operative framework from the province is aimed at making development's using communal servicing cheaper and faster to get up and running, while protecting the water for those withing the development, and for neighbouring property owners as well.

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