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Position Statements

CWWA’s position statements are developed in consultation with the CWWA Board of Directors and members of CWWA technical committees. They are developed in response to a specific issue or legislative direction.

2024 Advocacy

Written Submission to the Parliamentary Standing Committee on Finance for the Pre-Budget Consultations in Advance of the Upcoming Federal Budget

The CWWA  made  a written submission to the House of Commons Standing Committee on Finance. The submission outlined recommendations for more secure and reliable funding for water and wastewater projects.  

Read the full submission

2023 Advocacy

CWWA Submission: House of Commons Standing Committee on Environment and Sustainable Development’s Study on Freshwater – Addendum to CWWA/ACEPU comments

The CWWA  made a full submission to the House of Commons Standing Committee on Environment and Sustainable Development’s Study on Freshwater in May of 2021. That first letter focused on the potential for an effort to coordinate the multiple federal departments and agencies that address water and supported a consolidation of the databases for shared access and use.

This second submission highlighted the importance and potential of natural infrastructure and that this has emerged as a growing option for our sector. This submission specifically highlighted the risks to municipalities when selecting new and innovative methods of managing water and wastewater. The Association specifically would like to see the federal government take leadership in developing some kind of protection for municipalities who take a financial risk on new or emerging technologies – especially when these technologies are advancing green and sustainable methods.

Read the full submission

2022 Advocacy

National Adaptation Strategy

CWWA wrote to Environment and Climate Change Canada in response to the Discussion Paper – Preparing for Climate Change – Canada’s National Adaptation Strategy. The Association’s primary feedback is that:

  • Municipalities Need National (Centralized) Data Monitoring and Collection
  • Municipalities Need Equitable Funding Models

These points are expanded on in the letter

Download the letter 

2020 Advocacy

2020 Speech from the Throne - Canada Water Agency

CWWA and a coalition of Non-Government Organizations submitted a letter to the Office of the Prime Minister advocating for the new Canada Water Agency, hoping to see firm commitments for it’s development and focus in the upcoming Speech from the Throne. 

Read the letter – English or French

Covid-19

CWWA letter to Prime Minister – COVID-19 Stimulus Funding

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CWWA has issued press releases and compiled resources for members on the COVID-19 pandemic.

Learn more

CWWA Supports Expedited Creation of the Canada Water Agency - June 2020

CWWA added their name, with 20 other water organizations, calling for the expedited creation of the Canada Water Agency.  CWWA has long supported a more coordinated federal approach to water issues as various water issues fall into the portfolio of at least a dozen of the federal ministries and agencies.

The creation of the Canada Water Agency was identified in the mandate letter to the new Minister of Environment and Climate Change, Hon. Jonathan Wilkinson, following the last election.  The purpose of the letter was to support the creation of the Agency sooner rather than later. 

The COVID-19 pandemic has made it clearer than ever that water and wastewater services are essential to the health of communities, and to their economy. Now is the opportunity to focus federal infrastructure funding onto critical water projects.

Read the Letter

CWWA Promotes our Role in a new Canadian Water Agency - July 2020

In addition to the cooperative letter supporting the Canadian Water Agency, CWWA wrote a letter highlighting our strength and enthusiasm for the development and supporting the mandate of a Canadian Water Agency.

Read the Letter

2019 Advocacy

Lead in Drinking Water

About Lead

Health Canada today published revised guidelines concerning lead (Pb) in Canadian drinking water.  The most significant change is the reduction of the Maximum Allowable Concentration (MAC) of lead in drinking water from 0.01 mg/L to just 0.005 mg/L.

CWWA and our members, the municipal water professionals in Canada, fully support these new, science-based targets and support all efforts to one day eliminate all lead from drinking water.  But we all need to recognize that these are aggressive targets that cannot be achieved overnight.  There are significant challenges, mostly outside of municipal authority to address.  So this will require a combined effort from federal, provincial, territorial and municipal governments as well as individual property owners to achieve these targets.

Our greatest concern is how quickly these Guidelines might be implemented in each province and territory and how this might affect the public’s confidence in their drinking water.  We need all Canadians to understand that nothing has changed overnight regarding the safety of their water.  Rather, we have agreed upon even better targets.  We need the public to understand that safe drinking water leaves the treatment plant lead-free and is distributed through water mains down each street lead-free.  Drinking water only comes into contact with lead when it reaches the service line from the water main to an individual property and/or in the plumbing and fixtures within individual homes and buildings.  As the use of lead service lines was phased out in the 1960’s, this only affects older homes in older neighbourhoods.

So the bulk of our lead issue lies on or within private property, outside of the road allowance and municipal authority.  Aside from the significant cost and disruption to replace lead service lines, our greatest challenge is to engage the individual property owners to cooperate with municipal utilities to replace lead service lines and to address any other plumbing within their building.

To support our members in speaking about these Guidelines to their Council, their customers or the media, CWWA has prepared a Fact Sheet and Speaking Notes.  The Fact Sheet provides general details about Lead and the Guidelines, but more detail can be attained from Health Canada or your local public health authority. The Speaking Notes outline our key points we need to make as municipal water professionals.  We encourage members to use these speaking notes and to share these tools with their Communications staff and municipal Council.

CWWA Lead Fact Sheet

On March 8, 2019, Health Canada released revised guidelines, significantly reducing the maximum allowable concentration of lead in drinking water. While our municipal water sector fully supports these new targets, we need to identify the challenges inherent in moving to these new targets while maintain full public confidence in the safety of their drinking water. 

Fact Sheet on Lead

Speaking Notes on Lead in Drinking Water

New Guidelines:
On March 8, 2019, Health Canada released revised guidelines, significantly reducing the maximum allowable concentration of lead in drinking water. 

Read More on Speaking Notes on Lead

Other Advocacy Activities

2018 Advocacy

Submission on proposed changes to the NPRI reporting for releases to water

The Canadian Water and Wastewater Association (CWWA) is the national voice of the water and wastewater sector. The Association’s primary role is to monitor federal legislation and national policies for relevance and impact on the municipal water and wastewater sector and advocate on its behalf.

CWWA, as a member of NPRI’s Multi-Stakeholder Work Group has reviewed the proposed changes to how facilities report releases of pollutants to water. The Association and our members have several concerns with the proposed changes.

The first general change will be to develop an effluent volume-reporting threshold for releases to water. We note that the municipal wastewater sector already has an effluent threshold of 10,000 m3/day to determine reporting under the NPRI. This is working well for our sector, and we support the concept of expanding this requirement to other reporting sectors. We also note that the current reporting threshold is adequately capturing wastewater facilities, and if a lower threshold is proposed, we recommend that wastewater facilities should be exempt (ie: remain at the current reporting threshold).

Read More on Submission on proposed changes

Letter to Minister of Fisheries and Oceans - enforcement of Fisheries Act

2017 Advocacy

CWWA submits comments on Health Canada's proposed Guideline for Lead in Drinking Water
CWWA submits comments on Health Caanada's proposed Guidelines for uranium and enteric viruses in drinkng water

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CWWA 2016 Budget Advocacy Report: Our Impact, Our Opportunity, Our Position
Letter to Minister of Infrastructure and Communities - CWWA positions on Infrastructure Renewal

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Policy Statements

CWWA’s Board of Directors are reviewing all CWWA’s Policy Statements to update, and develop new more relevant statements. We will be updating this section as statements are approved by the Board of Directors.

Adoption of the IWSFG PAS for flushability and to support the development of a Canadian standard on flushable products

Adoption des PAS de l’IWSFG sur les produits pouvant être jetés dans les toilettes et appui à l’élaboration d’une norme canadienne en ce sens

Overview

For over 10 years, CWWA has been working with wastewater partners to address the negative impacts of so-called ‘flushable’ wipes.  We have taken our fight from a local effort, to a North American attempt to an international level and now back again.

 

CWWA was instrumental in forming an international coalition, the IWSFG, and developing a scientifically-supported definition for the term flushable.  This international standard, the IWSFG-PAS3, and its logo, are supported by the wastewater associations in several countries and now the CWWA formally adopts is too.   CWWA also encourages its members to recognize this standard and to promote the logo in their public communications concerning flushing.  CWWA also supports the development of a formal Canadian standard through the Standards Council of Canada – hoping this could lead to enforceable regulation of such products.

Natural Infrastructure

Overview

Position 1: NI should be given equal consideration as that given to more traditional measures (i.e. “grey infrastructure”) and its environmental and community benefits should be fully considered when evaluating alternatives. 

Water management challenges, however, are place-based and context-based.  Generally, NI approaches are not plug-and-play infrastructure components. Rather they must be integrated into the built and natural system in which they are proposed. As such:

Position 2: Appropriate NI solutions must be selected for the specific goal or problem of the specific location. 

Most organizations are in the early stages of NI adoption and, not surprisingly, there is a lack of knowledge as to what roles NI can play and how it can be planned, designed, implemented, and maintained most effectively. Federal and Provincial Governments have a key role to play in helping facilitate knowledge exchange through programs and targeted funding to promote NI.

Position 3: Decisions on which NI approaches are appropriate should be made with an asset management viewpoint, including best estimates of lifecycle costs.

Sustainable Water Services

Overview

A sustainable water service recognizes and incorporates
social (service level and affordability), environmental and
economic factors while ensuring full cost recovery and
intergenerational equity. There are many benefits to
communities where utilities provide sustainable water
services (water, wastewater and/or stormwater). Over the
long‐term, there may also be significant risks to public
health, local economies and the environment if water
services are not truly sustainable. However, there are a
number of key challenges or barriers to achieving
sustainable water services. Utilities should plan to move
closer to sustainable water services, recognizing those
challenges, and monitor their progress to that objective.
Communication with, and engagement of, the public and
elected officials as to the social, environmental and
economic value of water services will be essential in that
process.

Joint Statement of Canada’s National Professional Associations: Advancing Integrated Climate Action

Overview

The recently released IPCC SR15 report is unequivocal: we are beginning to experience the impacts of climate change, and it will take “rapid, far reaching and unprecedented changes in all aspects of society” to keep global warming below the crucial threshold of 1.5C. As professionals, we have the opportunity and responsibility to address both climate change mitigation (emissions reduction) and adaptation (responding to the impacts we cannot avoid). Our associations have a crucial role to play in advancing ethics, awareness, practices and policies that support integrated action on climate change, due to our prominent roles in many aspects of the development and management of resources, ecosystems and communities.

As such, we acknowledge that climate change is causing a variety of unavoidable impacts, many of which are projected to increase in duration, magnitude and severity. In the years ahead, these impacts will affect the outcomes of professional decisions made today. There is widespread recognition that we must plan ways to adapt, and that reducing greenhouse gas emissions is crucial if we are to minimize the risks – both types of actions are urgently required. Typically, mitigation and adaptation have been addressed separately; however, every opportunity to mitigate or adapt must be explored. Can an adaptation solution incorporate mitigation? Can a mitigation solution incorporate adaptation? Can thinking that incorporates both action streams as one process lead to transformative approaches?

Integrating these perspectives in a “Low Carbon Resilience” lens to guide decision-making and best practices, where appropriate, can save time and resources, increase returns on investment, and generate economic, environmental, social, and health co-benefits. Ensuring the two streams of action are coordinated and cross-evaluated can also help to avoid risks and unintended consequences associated with advancing them separately.

Issues Analysis Papers

Food waste Grinders

Overview

This paper is focused on food waste grinder use by the residential sector. Food waste grinders may also be used by the Commercial and Institutional (C&I) sector, particularly food service establishments (e.g. restaurants, cafeterias in hospitals, schools, etc.). As food waste grinders used in the C&I sector are typically larger units, the issues discussed in this paper can be magnified. It is considered best practice for jurisdictions to require, through their Sewer Use Bylaw or other regulatory means, that C&I food waste grinders and similar equipment used in the preparation of food be connected to a solids interceptor (prior to connecting to a grease interceptor). Jurisdictions can also consider a prohibition on commercial food waste grinders. The Canadian Council of Ministers of the Environment (CCME) Model Sewer Use Bylaw (2009) contains an optional additional requirement for prohibition of food waste grinders and other pretreatment requirements in the Advanced Clauses, Section 7.

Support and Funding for a Canadian Standard for Flushable Consumer Products

in partnership with the:

All of us in the wastewater sector understand the harmful impact that so-called flushable products have on our municipal wastewater systems. From additional maintenance, to equipment damage, to clogs and system failures to contamination of sludge, this issue is costing Canadian municipalities over $250 million each year. The inappropriate labeling of products and counter-education of our customer’s needs to be addressed. Currently, there are no standards, regulations or official definitions for the use of the term ‘flushable’. A solution is needed that supports jobs and free trade, but not at the expense of our wastewater systems. MESUG and CWWA have combined forces to address this situation for Canadian utilities, but we need your support.

    Read More

    MESUG, the Municipal Enforcement Sewer Use Group, is a non-incorporated group of municipal enforcement professionals working together to address common issues regarding sewer use in Canadian municipalities. MESUG spearheaded this effort to bring awareness and then invited CWWA to be a partner to assist with financial administration and national/international outreach. CWWA, the Canadian Water and Wastewater Association, is a registered not-for-profit corporation that serves as the national professional association for our municipal sector. Together, MESUG and CWWA have been working on this issue for a few years, and working at it from various angles.

    An ISO (international standard) initiative was commenced in 2014 by Canada through ISO’s Technical Committee (TC) 224. Considerable progress was made on the development of a Technical Specification regarding the quality and characteristics of products that might be considered “flushable” and how products, flushable and non-flushable, might be clearly labeled. This international committee consisted of both utility representatives as well as those in the wipes manufacturing industry. This work was nearing completion when it was halted by a challenge from the manufacturers concerning test methods.

    Over the same timeframe, INDA, the US-based trade association for non-woven products, sought collaboration with the major North American wastewater associations (CWWA, NACWA, WEF and APWA), to review and improve their voluntary Code of Practice and their Guidance Document for Assessing Flushability (GD3) of their products. A task group of wipes industry and municipal utility representatives worked to develop a more stringent fourth edition of the INDA Guidance Document – GD4, but this work halted by the end of 2016 when the manufacturers failed to accept proposals for new tests and pass/fail criteria provided by the wastewater associations.

    INDA and the utility associations did however come to agreement on a new voluntary Code of Practice with better guidelines for labeling of any product that could likely be flushed – although we did not agree that any products could be considered flushable yet. You can obtain the new Code of Practice at: http://www.inda.org/code-of-practice-download/ .

    So this leaves us with the original question of “what is flushable?” With the suspension of the ISO work and collaboration with INDA failing, the wastewater associations joined together to form the International Water Services Flushability Group (IWSFG). This informal coalition put together a position statement on non-flushable and flushable labelled products which is now supported by wastewater services in 25 countries and by over 300 stakeholders. You can see the position statement and the entire list here.. The IWSFG is also developing a flushable product standard that would be acceptable to wastewater services.

    CWWA publishes a position statement to support the development of a Canadian standard on flushable products

    For over 10 years, CWWA has been working with wastewater partners to address the negative impacts of so-called ‘flushable’ wipes.  We have taken our fight from a local effort, to a North American attempt to an international level and now back again.

    CWWA was instrumental in forming an international coalition, the IWSFG, and developing a scientifically-supported definition for the term flushable.  This international standard, the IWSFG-PAS3, and its logo, are supported by the wastewater associations in several countries and now the CWWA formally adopts is too.   CWWA also encourages its members to recognize this standard and to promote the logo in their public communications concerning flushing.  CWWA also supports the development of a formal Canadian standard through the Standards Council of Canada – hoping this could lead to enforceable regulation of such products.

    L’ACEPU publie son énoncé de position sur les produits jetables dans les toilettes

    Pendant plus de dix ans, l’ACEPU a travaillé avec des partenaires du secteur des eaux usées pour traiter des impacts négatifs des lingettes soi-disant « jetables dans les toilettes ». Nous nous sommes mobilisés de l’échelle locale à l’échelle nord-américaine, puis internationale, pour revenir à l’échelle locale.

    L’ACEPU a contribué à la formation d’une coalition internationale, l’International Water Services Flushability Group (IWSFG), et à la formulation d’une définition scientifique de l’expression « jetable dans les toilettes ». Cette norme internationale, IWSFG-PAS3 et son logo, a reçu l’appui des associations d’assainissement des eaux usées de plusieurs pays et l’ACEPU l’a maintenant adoptée officiellement. L’ACEPU encourage également ses membres à reconnaitre cette norme et à promouvoir le logo sur les produits jetables dans les toilettes dans leurs communications adressées au public. L’ACEPU appuie également l’élaboration d’une norme canadienne officielle par le Conseil canadien des normes, en espérant que cela puisse mener à une règlementation exécutoire de ces produits.

    How you can help

    Comment vous pouvez aider

    Any developed standard (whether international or North American) would require adoption within Canada, as a Canadian Standard, to be enforceable. The ISO and continuing IWSFG work has paved the way, and saved much time, on the development of a Canadian national standard. However, funding is required to continue this work and move us forward toward the implementation of a standard into legislation.

    We are requesting Canadian wastewater utilities to contribute to a common fund for the development, adoption and implementation of a Canadian Standard for ‘Flushability’. Previous quotes from standards associations estimate a cost in the range of $150,000 over 18 months to develop a Canadian standard. Additional funds would be required to support lobbying efforts and the process to have such a voluntary standard adopted as an enforceable regulation. Given that the annual cost to Canadian utilities for responding to inappropriately flushed products is assessed at $250 million, the cost-benefit ratio of this investment is clearly evident.

    Toute norme élaborée (qu’elle soit internationale ou nord-américaine) devrait être adoptée au Canada, en tant que norme canadienne, pour être exécutoire. L’ISO et les travaux de l’IWSFG ont ouvert la voie et permis de gagner beaucoup de temps dans l’élaboration d’une norme nationale canadienne. Cependant, des fonds sont nécessaires pour poursuivre ce travail et nous faire avancer vers la mise en œuvre d’une norme dans la législation.

    Nous demandons aux services publics canadiens de traitement des eaux usées de contribuer à un fonds commun pour l’élaboration, l’adoption et la mise en œuvre d’une norme canadienne de « jetabilité ». Des citations antérieures d’associations de normalisation estiment qu’il en coûterait environ 150 000 $ sur 18 mois pour élaborer une norme canadienne. Des fonds supplémentaires seraient nécessaires pour soutenir les efforts de lobbying et le processus visant à faire adopter une telle norme volontaire en tant que réglementation exécutoire. Étant donné que le coût annuel pour les services publics canadiens en cas de produits évacués de manière inappropriée est évalué à 250 millions de dollars, le rapport coûts-avantages de cet investissement est clairement évident.

     

    Support and Funding for a Canadian Standard for Flushable Consumer Products

    It is well past time that Canada had a recognized definition of the word ‘flushable’ and an enforceable standard to address what can and cannot be labeled as ‘flushable’. This can be an expensive effort to develop a Canadian standard and then have it recognized by governments and by the public, but with your support, we can accomplish this together.
    With this letter, we are asking Canadian wastewater utilities and private sector partners to contribute to a common fund to push through to the final steps for the development, adoption and implementation of a Canadian standard for ‘flushability’. For too long we have left it to manufacturers to decide what is acceptable in our municipal wastewater systems. With your support, we have the potential and means to change that.

    With this letter, we are asking Canadian wastewater utilities and private sector partners to contribute to a common fund to push through to the final steps for the development, adoption and implementation of a Canadian standard for ‘flushability’. For too long we have left it to manufacturers to decide what is acceptable in our municipal wastewater systems. With your support, we have the potential and means to change that.

    Read the full letter and learn how to support these efforts /Lisez la lettre complète et découvrez comment soutenir ces efforts

     

    Show your leadership by adding your logo to the Canadian Wastewater Statement on Flushables - Read More

    Show your leadership by adding your logo to the Canadian Wastewater Statement on Flushables

    Please contact Kara Parisien at CWWA for support information:

    Kara Parisien,
    CWWA Communications (613)747-0524 ext 4 or kparisien@cwwa.ca

    Payments are to be made to the Canadian Water and Wastewater Association with a note to direct funds to flushable standard campaign.

    Canadian Water and Wastewater Association
    1010 Polytek Street Unit 11
    Ottawa, ON, K1J 9H9

    Contact Account Receivable Clerk Louisa Spina for payment details, electronic banking, invoices and receipts.

    Louisa Spina, CWWA Accounts Receivable
    (613)747-0524 ext 226 or lspina@cwwa.ca

    Soutien et financement pour une norme canadienne des produits de consommation jetables dans les toilettes

    Nous demandons, avec cette lettre, aux services publics d’eaux potables et usées au Canada et aux partenaires du secteur privé de contribuer à un fonds commun pour aider à franchir les dernières étapes pour l’élaboration, l’adoption et la mise en œuvre d’une norme canadienne sur ce qui peut être « jetable dans les toilettes ». Nous avons laissé durant trop longtemps aux fabricants la décision de juger ce qui est acceptable dans nos réseaux municipaux d’eaux usées. Votre appui nous donnera la possibilité et les moyens de changer ça.

    Lisez la lettre complète et découvrez comment soutenir ces efforts

     

    Links and Supporting Documents

    Forcing ‘Flushability’ Innovation

    Article from Water Environment Technology Magazine

    Municipal wastewater utilities have always dealt with grease and feminine hygiene products, and they have tried their best to educate customers to only flush the 3Ps — pee, poop, and toilet paper. But the introduction of so-called flushable products has resulted in clogged sewer lines, damaged pumps, covered screens, and — in many cases — the creation of fatbergs. These clogs could shut down sewer systems, add tremendous costs in staffing to clear lines, and necessitate equipment replacement.

    La Ville de Terrebonne - Devenez la bolle des toilettes

    La Ville de Terrebonne assure une saine gestion des eaux usées afin de préserver l’environnement. Comme d’autres villes au Québec, Terrebonne est aux prises avec des objets et des résidus qui bouchent les canalisations d’égouts, ce qui a pour effet de bloquer et de briser les pompes et autres équipements en contact avec les eaux usées en plus d’être un fléau pour l’environnement.

    What's in your toilet'?

    A survey was conducted to determine the London community’s knowledge about what can and cannot be flushed down the toilet.

    Global Committee of Water Experts Presents Consumer Flushability Guidelines

    REVIEW OF BABY WIPE COMPLIANCE
    WITH THE INDA/EDANA 2017
    2ND EDITION LABELING CODE OF PRACTICE

    International water industry position statement on non-flushable and ‘flushable’ labelled products

    EFFECTS OF FLUSHABLE PRODUCTS ON WASTEWATER INFRASTRUCTURE AND NATURAL AQUATIC ENVIRONMENTS

    Ryerson University Report: Defining Flushability

    Western University: Nonwoven Fabric Product Analysis Summary Report

    The Road to a Standard for Flushability: March 2019 Update

    Canada wide wastewater statement release

    Suggested donation levels, donation instructions and project details

    International Organization
    for Standardization

    CWWA has suported the development of several standards that support water utilities and related industries.

    ISO standards cover almost every water issue, from pipes and irrigation to water quality, management and sanitation

    ISO and Water

    Out of a total of more than 21,300 International Standards, ISO has more than 1 ,200 related to water, with many more in development.

    ISO/TC 224

    Service activities relating to drinking water supply, wastewater and stormwater systems

    ISO/TC 224 Water Utility Service Activities

    This Committee website includes the latest activities and updates from the Committee

    CWWA is a non-profit national body representing the common interests of Canada’s public sector municipal water and wastewater services and their private sector suppliers and partners.

    Head Office
    CWWA, Unit 11, 1010 Polytek Street, Ottawa, ON K1J 9H9 Canada

    (613) 747-0524
    admin@cwwa.ca