January 30, 2006

Ms. Sarah O’Keefe, Policy Advisor
Strategic Policy Branch
Ministry of the Environment
135 St. Clair Avenue West, 11th Floor
Toronto, Ontario
M4V 1P5

Dear Ms. O’Keefe:

RE: Proposed Clean Water Act, 2005
EBR Registry #AA05E0001

This letter is in response to the request for comments on the above noted EBR posting.
The Waterfront Regeneration Trust commends the Province for the development of this proposed legislation; and we support its speedy passage. Also we would like to offer our thanks for the opportunities that we have received as part of the NGO coalition to provide comments and input into the development of the legislation, through the document NGO Statement of Expectations. We believe that this input has lead to an improved Bill for the protection of existing and future sources of drinking water.

In summary, and with the exception noted below, we support this Proposed Act as it provides significant gains for end users of municipal and private drinking water in this province. The approach to this protection, through source water protection, will go a long way to protecting all of the values of the water resources of this Province. Clean healthy watershed tributaries to Lake Ontario and the St. Lawrence River are the cornerstones of Lake Ontario waterfront regeneration, which is the principal goal of the Waterfront Regeneration Trust. Our area of particular concern is that important provisions relating to the Great Lakes (see sections 74-76) are left to the discretion of the Minister. Given the critical importance of integrating source water protection with existing Great Lakes programs, projects, and negotiations, these sections must be strengthened and upgraded into mandatory obligations. We recognize that the legislation does contain many promising provisions relating to Great Lakes protection, such as establishing targets for source protection areas which contribute to the Great Lakes, forming advisory committees, and requiring the preparation of reports; and that one provision is mandatory: those source protection areas which contain waters that flow into the Great Lakes are required to consider a number of Great Lakes agreements in their terms of reference. The Waterfront Generation Trust recommends all provisions related to the Great Lakes should be mandatory - the new source water protection regime must be fully integrated with Great Lakes protection. When participating in inter-jurisdictional negotiations regarding the Great Lakes, the province must work to incorporate the principles of source water protection. Pursuant to these objectives, sections 74-76 of the Clean Water Act should be made into mandatory requirements.

Our support for this Act is premised on the fact that the implementation details that will be laid out in the regulations will also be consistent with the NGO Statement of Expectations.

Yours truly,

(Ms). Vicki Barron
Executive Director