Thank you for the opportunity to speak to the committee. As I understand it, Bill C-326 at its core simply requires the Minister of Health to conduct a review of drinking water standards in OECD countries, and to make recommendations for amending national guidelines for drinking water in Canada.
As you know, my work has been exclusively with first nations on safe drinking water, so all of my comments to the committee will be in that context. My overall opinion of the bill, having taken time over the weekend to review it, is that at best it's a distraction and perhaps a waste of time, and at worst, it may place additional burdens on first nations that they are not prepared to meet.
As the committee probably knows, in 2011 there was a national engineering assessment of first nation drinking water and wastewater systems that recommended roughly $5 billion in investment over 10 years. Although the former government and the current one have made additional investments, neither has come anywhere close to meeting that pressing and decades-long need in first nation communities.
It's been my experience that first nations across Alberta, British Columbia, and the rest of the country are already struggling to meet federal drinking water standards. Just to list off a few of these standards, first nations are already expected to comply with the protocol for centralized wastewater systems in first nation communities, the protocol for decentralized water and wastewater systems in first nation communities, design guidelines for first nation waterworks, guidelines for effluent quality and wastewater treatment at federal establishments, and Health Canada's guidelines for Canadian drinking water quality, as well as INAC's level of service standards for water and sewer systems.
As a practical point, when I read the bill, it's not clear to me how the recommendations from the minister's review would apply to, or impact, that long list of guidelines that first nations are already expected to meet.
Most first nations systems, as identified by the national engineering assessment, are struggling to meet those guidelines already. If additional reporting and monitoring requirements are placed on plant operators and those in the communities, they will just have to do more with less already.
There's also the question of what this means for the implementation of the Safe Drinking Water for First Nations Act. It's enabling legislation, and as I understand, the federal government has not yet taken significant steps across the country to develop regulations under the act. It's not clear to me how the review of drinking water guidelines that would happen under this bill would impact the development of those regulations.
There's also the question of whether the act is going to stay in place. I worked closely with first nations from Alberta, and former minister Bennett, when she was in opposition, actively coordinated and helped us oppose that piece of legislation, and committed to repealing it and replacing it with something developed in true collaboration with first nations across Canada. We haven't seen that yet. In fact, we really don't know what the fate of the legislation will be at all.
It's also unclear to me what all of the work put into this bill would really mean for the protection of drinking water. We have overlapping jurisdictions around the country with varying standards. In Ontario there's legislation that protects source water; in Alberta it's done by voluntary guidelines, as an example. Source water protection is really fundamental to protecting drinking water for first nations and non-first nations—it doesn't matter where you are in the country. It's probably the weakest component of the regulatory guidelines and legislation in this country. I think if any bill regarding drinking water is not sharply focused on the protection of source water, then it's not really worth the time.
Those are my comments.