Thank you, Madam Chair and members of the committee. My name is Carl Yates. I'm general manager of Halifax Water.
Halifax Water is the water, waste-water, and stormwater utility serving 360,000 people in the greater Halifax area. I am accompanied by Reid Campbell, our director of water services, who has been leading much of our work on lead in drinking water for the past several years.
We want to thank the committee for the invitation to appear here today and for taking the time to look into this issue, which we believe needs more attention by water utilities and their provincial regulators across Canada. The issue of lead in drinking water is manageable, but a regulatory framework is needed to enable utilities to develop approaches to address the unique circumstances in their community.
We believe that lead in drinking water is a more serious issue than many utilities in Canada and their provincial regulators understand. Current regulations do not provide adequate public health protection and do not require utilities to truly investigate and understand the occurrence of lead in their systems.
Halifax Water has had programs to remove lead service lines since the 1970s. At one point, we may have had as many as 15,000 lead service lines, and today we have as few as 2,000 lead service lines remaining in the public system. We have provided corrosion control treatment since 2002 and have always provided free in-home sampling for customers concerned about lead. For any customer who requested it, we would replace the public lead service line once they replaced the private property portion.
Around 2010, as you've already heard, through our research partnership and the industrial research chair at Dalhousie University, we encouraged Dr. Graham Gagnon to look into the occurrence of lead in our system. Dr. Gagnon's work gave us new insights into the occurrence of lead in our system and directed us to enhance our approach to managing lead. We discovered that to properly address lead, we needed to completely remove lead service lines and stop doing partial replacements. We also needed to increase our level of corrosion control and to treat each customer with a lead service line as a customer who needs assistance.
This created quite a challenge, considering that the customer owns a portion of the line, the constraints on utilities getting involved in private property issues, and the barriers to customers renewing lead service lines, including costs.
In January 2017, the American Water Works Association, AWWA, adopted a new policy on lead service line management. While AWWA is based in the United States, most Canadian utilities are members, and AWWA is considered the authoritative technical resource relied on by utilities across North America. The new policy calls on utilities to undertake complete removal of lead services lines in a reasonable period of time and to provide corrosion control treatment. Most importantly, it calls on utilities to work in partnership with their customers to achieve removal of lead from the distribution system by developing locally appropriate solutions. It is our belief that the best way for utilities to protect their customers from lead is to follow the guidance of the AWWA policy. This also includes initiatives like creating an inventory of lead service lines, communicating with customers, and providing the sampling that they require.
We believe the role of government in this issue is to provide a framework to support utilities in this approach. The occurrence of lead in any given system is much more complex and locally variable than are traditional drinking water parameters, such as bacteria and arsenic. Simply creating a compliance level and requiring utilities to meet it will not improve public health outcomes. Our experience is that a high lead level in a home requires both the utility and the customer to take action together to address the lead service line that they jointly own.
Government has a role to assist homeowners and utilities with the many barriers to private lead service line replacement, such as cost, insurance, and liability issues related to work on private property. The federal government has an opportunity to provide leadership by dedicating national funding programs for water and waste-water infrastructure to this issue. This would have national impact and direct work to many small business contractors that typically do service work.
Assistance to homeowners could also be provided to help them deal with the private portion of the service through tax credits or homeowner assistance programs.
Government also has a role to ensure that the presence of lead service lines is identified for properties at the point of sale, when it can be dealt with as part of the real estate transaction.
In January of this year, Health Canada proposed a new guideline for lead in drinking water. We believe this is timely and appropriate and will cause utilities to look more closely at lead in their system.
We have urged Health Canada to consider the points that follow.
If a provincial regulator finds a utility non-compliant on lead, the predominant way to achieve compliance in most systems is to remove the entire lead service, part of which is on private property. Today, many utilities do not have mechanisms to work on private property.
Changing the guideline in one big step, as is proposed, will result in many instances of utilities not being able to achieve the guideline levels. This will create the impression in the eyes of the public of a health crisis where none existed before.