Source Water Protection
The City of Brantford is committed to the delivery of safe, high quality drinking water to the residents and businesses of our community. Brantford’s Source Water Protection Program is managed under the Clean Water Act which provides the necessary regulatory framework to effectively protect our source of drinking water so that we will continue enjoying the Grand River for generations to come!
The Clean Water Act:
The key focus of the Clean Water Act (CWA) is to ensure that specific activities, which have the potential to contaminate municipal drinking water sources cease to be or never become significant risks to the quality and quantity of drinking water supplies in Ontario. The CWA provides a framework for the development and implementation of science-driven and watershed-based Source Water Protection Programs. Most raw water supplies such as the Grand River are located in populated areas and human activity invariably generates wastes that render water sources vulnerable to contamination. Agricultural runoff, industrial waste, chemical spills, and municipal sewage discharges introduce a plethora of pathogenic and chemical contaminants also known as threats into raw water, which in turn can potentially taint a drinking water supply.
Brantford’s Source Protection Plan:
City staff, the Grand River Conservation Authority and the Source Protection Committee worked diligently for the past few years to prepare the proposed Brantford’s Source Protection Plan and Explanatory Document.
The Plan was locally developed and contains policies to either prohibit or manage activities that have been prescribed as significant drinking water threats in accordance with the CWA. There are 21 threats, 19 of which address activities that have the potential to release chemical and pathogenic contaminants; the remaining two activities (#19 and #20) are considered to be threats to the quantity of Brantford’s source water. A list of the 21 prescribed threats to drinking water sources is summarized herein:
- Waste disposal sites – their establishment, operation, or maintenance
- Sewage systems – their establishment, operation, or maintenance
- Agricultural source material – application to land
- Agricultural source material – storage
- Agricultural source material – management
- Non-agricultural source material – application
- Non-agricultural source material – handling and storage
- Commercial fertilizer – application
- Commercial fertilizer – handling and storage
- Pesticide – application
- Pesticide – handling and storage
- Road salt – application
- Road salt – handling and storage
- Snow – storage
- Fuel – handling and storage
- Dense non-aqueous phase liquid – handling and storage
- Organic solvent – handling and storage
- Chemicals used to de-ice aircraft – management of runoff
- An activity that takes water from an aquifer or a surface water body without returning the water taken to the same aquifer or surface water body
- An activity that reduces the recharge of an aquifer
- Land associated with livestock – use of land for grazing, pasturing, confinement, or used as farm-animal yard
Mandatory actions can only be directed towards existing and future land use activities identified as significant drinking water threats within delineated highly vulnerable areas also known as Intake Protection zones (IPZs).
IPZs have been delineated in accordance with the Ministry of the Environment’s Technical Rules and represent specific areas of land and water where there is a potential risk for contaminants to adversely affect a municipal drinking water source. Each IPZ area has been assigned a vulnerability score (VS) based on the likelihood and severity a contaminant could impact Brantford’s raw water supply. Within City limits, Brantford has two Intake Protection Zones, IPZ-1 and IPZ-2 with vulnerability scores of 10 and 9 respectively and there are two Intake Protection Zones belonging to Ohsweken, IPZ-2 and IPZ-3 that were both assigned a vulnerability score of 8 (more in-depth information can be found in Brantford and Ohsweken Assessment Reports). Brantford’s IPZ-2 and IPZ-3 extend into Brant County and Region of Waterloo. Figure 1 illustrates the area covered by each IPZ within City boundaries (PDF 571kb).
Increasing VS in a given IPZ reflects the likelihood of a contaminant adversely impacting a raw water supply, which translates into more restrictive policy measures in the SPP. IPZ-1 has the highest VS because this area is the most susceptible to high-impact contaminant intrusion hence, activities that have the potential to release chemical and pathogenic contaminants are the most regulated. In turn, IPZ-3 has the lowest VS of the three delineated areas and as such, is the least regulated.
Source Water Protection Enforcement Tools:
Under Section 47 of the Clean Water Act, it is the responsibility of the City of Brantford to administer, implement and enforce Part IV of the Clean Water Act within its boundary. This section specifies that any single tier, lower tier and higher tier municipality that has the authority to pass by-laws under the Municipal Act in relation to the production, treatment and storage of water is the enforcement authority.
There are three main tools by which the City of Brantford will enforce Part IV of the Act in order to address activities considered Significant Drinking Water Threats (SDWT) within City boundaries:
- Section 57, enforcement of a prohibited activity by the Risk Management Official (RMO) from the time the SPP takes effect.
- Section 58, requires a person engaged in an activity considered a SDWT, to prepare a (site-specific) Risk Management Plan (RMP). Once approved by written notice from the Risk Management Official, the person carrying out that activity will be subject to routine inspections by Risk Management Inspectors.
- Section 59, restricted land uses, requires a person to seek approval from the Risk Management Official prior to the issuance of a development permit or building permit as part of the complete application requirements under the Planning Act and the Building Code Act respectively.
Public Consultation Process:
Source Water Protection Policies were drafted and submitted to the Ministry of the Environment and Climate Change in 2013 after an initial round of public consultation. The Plan was reviewed by the Ministry and two batches of comments were received in June and July of 2014. Input into the revision of the draft policies has been received by the Environmental Services Department of the Public Works Commission. Further, changes have been discussed in detail with staff from the Grand River Conservation Authority.
Revisions to the Plan included adding missing policies such as waste disposal sites and improving on the clarity of the policies and definitions such as the meaning of existing and future activities. The changes were reviewed and accepted by the Source Protection Committee at a meeting held in November 2014.
The updated Plan was posted for a 40-day public consultation period starting March 16th to April 24th, 2015. During this period, the document was available on-line and at the Grand River and Long Point Region Conservation Authority Offices. Notices announcing the 40-day public consultation period appeared in local newspapers and on the Lake Erie Region Source Protection Program website. Furthermore, the Grand River Conservation Authority mailed notification letters to all impacted properties within the source protection area. Any interested member of the public was to submit comments on the Plan during this time.
What is the City of Brantford Doing to Protect Local Intake Protection Zones?
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Drinking Water Protection Signs
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For more information on Brantford’s Source Water Protection Program, contact Patrick Halevy, Risk Management Official by phone at (519) 759-4222 Ext. 5822 or by email: firstname.lastname@example.org. To contact the GRCA please call 519-621-2273 or click to be redirected to the Drinking Water Source Protection Website for more information
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