WHEREAS municipal governments are responsible for providing and managing wastewater collection and wastewater treatment services; AND WHEREAS municipal governments are committed to protecting water sources in the conduct of these responsibilities;AND WHEREAS municipal governments are subject to controls, regulations and sanctions of their respective provincial or territorial governments in respect of these substances and of the performance of their wastewater services;AND WHEREAS the proposed federal legislation covers substances and activities already subject to provincial or territorial control, yet impose different or additional requirements which will increase municipal operating and infrastructure costs, will result in additional legal liabilities and potential for non-compliance through confusion and complexity;AND WHEREAS the proposed federal legislation is not conditional on defined and measurable improvements in the environment;

THEREFORE BE IT RESOLVED that the Alberta Association of Municipal Districts and Counties urge the federal government not to proceed with proposed federal legislation respecting the preparation and implementation of pollution prevention plans in respect of ammonia dissolved in water, inorganic chloramines and chlorinated wastewater effluents, and to work with the provinces and territories to establish a common standard through provincial and territorial control instruments already in place.

P2 Planning Requirements on Ammonia, Chloramines and Chlorinated EffluentsAs the national voice of municipal water and wastewater utilities in Canada the Canadian Water and Wastewater Association (CWWA) has an objective that federal legislation impacting municipal utilities is well thought out and not in conflict with provincial and territorial regulations. Environment Canadas proposed new pollution prevention legislation will require many municipal wastewater utilities to prepare and implement pollution prevention plans in respect of their discharges of ammonia dissolved in water, inorganic chloramines and chlorinated wastewater effluents. These substances are included in the list of toxic substances in Schedule I of the Canadian Environmental Protection Act, 1999. The 20-page proposal can be found at http://www.cwwa.ca/ammonia.htm.CWWA does not object to managing the discharge of these substances to protect the environment but its concern is that this initiative clearly infringes upon provincial and territorial jurisdiction, establishes requirements different from current requirements, imposes new mechanisms to regulate the sector and will increase the operating costs of wastewater utilities across Canada. The initiative will also likely lead to some municipalities becoming confused and therefore liable to not comply with one or the other or both the federal or their provincial/territorial regime. CWWA is requesting the support of all municipalities in Canada to defeat this proposed legislation. Municipalities already manage the release of the above substances through existing provincial and territorial control instruments. CWWA and its members prepared a technical assessment of the proposal and have submitted comments to Environment Canada. However, it is also necessary to follow a path of political intervention.CWWA and municipalities across Canada are committed to promoting environmentally responsible activities and to ensuring that environmental waters are healthy and safe. While this legislation is consistent with these objectives, it simply duplicates and interferes with provincial and territorial regulations already in place. If Environment Canada feels these provincial and territorial regulations need improvement, it should work with the provinces and territories to do so, and not impose separate requirements that overlap, duplicate and conflict with them. CWWA is ready to help Environment Canada in this task.Together we can defeat this legislation and help Environment Canada understand they must work with and through the provinces and territories to meet their environmental objectives, and not impose directly requirements on municipalities already subject to provincial or territorial regulation.

The AAMDC has no resolutions currently in effect with respect to this issue. However, Resolution 6-03S, endorsed at the spring 2003 convention, calls on the Government of Alberta to meet with stakeholders to review standards for small water systems, and consider the possibility of setting different standards for those systems. In its response, the province stated that having different standards apply based on community size presents an extremely high risk to public health. It said Alberta Environment recognizes the financial and operational pressures experienced by small waterworks system owners in meeting the established drinking water quality standards, and would be undertaking a comprehensive risk assessment of smaller waterworks systems to determine needs for upgrading, improving or consolidating operations.