Thank you.
My name is Michèle Grenier. I'm the executive director of the Ontario Water Works Association. We're a section of the American Water Works Association, which is the largest organization of water supply professionals in the world. The Canadian section was founded in 1916 and currently represents over 200 utilities across Canada that supply drinking water to more than 50% of all Canadians.
Our response to the proposed Health Canada guidelines was submitted as part of the AWWA Canadian affairs committee. We recognize that lead exposure from other sources has decreased significantly since the 1970s, and as a result the impacts from drinking water are now much more significant. In general, the committee's comments support the health-based approach for establishing the new objective, but we also want to emphasize the importance of corrosion control as part of the strategy, in addition to lead service line replacements.
The four key recommendations that were outlined in the Canadian affairs committee's remarks are around the interpretation of the proposed maximum acceptable concentration of lead, and that it must be representative of the water that people are consuming. Clarification is needed in terms of the application of the MAC as it relates to standing versus flush samples and the duration of the required stagnation period. The increased cost of the sampling analysis and the processing time must also be recognized.
Second, the achievability of the new MAC is an issue. The regulatory standard in Ontario is consistent with the existing Health Canada guidelines, and there are over 30 utilities that are already under orders to implement corrosion control. With the decrease in the proposed concentration, the number will increase by an additional 20. These represent significant costs that will be transmitted directly to ratepayers.
In addition, we have limited data so far that would determine whether or not the implementation of these corrosion control programs will allow municipalities to reliably achieve a reduction in lead levels from 10 parts per billlion to five parts per billion.
On the issue of lead service line replacement, we feel this is really the key area in which the federal government can have a role. As Bernadette mentioned, funding is a big issue, given that the private-side replacement is as important as the public-side replacement when it comes to the lead service line. There's been limited uptake so far on private-side lead service line replacement, mainly because it's difficult to explain to a homeowner why the replacement is required. In addition, the municipality has limited funding tools available to it in order to ensure that this portion of the work is completed.
We'd also like to highlight the timing of the implementation of the new standard. In many jurisdictions, the new guideline will come into effect immediately by reference in operating permits or existing regulations, whereas corrosion control studies can take months of planning and piloting before it's possible to roll them out at full scale. We request that additional time and guidance be provided to transition to the new framework.
Similarly, there's a requirement in the Safe Drinking Water Act in Ontario that makes elected officials personally liable for the operation of the drinking water system. The new standard in the proposed Health Canada guidelines for achieving lead levels that are as low as reasonably achievable becomes essentially indefensible for a municipal councillor unless additional guidance is provided to document and determine what is considered reasonably achievable.
In general, OWWA's position has been described as a three-pronged approach, whereby we would advocate for public-side lead service line replacement and private-side lead service line replacement, in addition to monitoring and sampling water quality and implementing effective corrosion control. The corrosion control element is often overlooked and is really essential, especially in larger buildings such as schools, where there is extensive plumbing and also contributions from lead components in the system, such as brass or lead solder, in facilities constructed pre-1980. It's an important focus that shouldn't be overlooked.
Last but not least, we highlight other similar federal programs, such as the Energy Star rebate programs, which provide incentives for homeowners to upgrade their existing appliances and whatnot to improve their energy efficiency. A similar program would allow homeowners to fund their lead service line replacement other than through municipal tax rolls or municipally offered financing.
Thank you very much.
Madam Chair, I will be pleased to answer questions in French as well.