CITY’S WATER BY-LAW AMENDMENTS: Insufficient time for public comment (from 12 Dec to 8 Jan)

* The City published its draft amendments on its Water By-Law on 12 Dec 2017.
* The deadline for submission of comments is 08 Jan 2018.
* The ACDP objects for the reasons below and requests the deadline be extended to 08 Feb 2018.

While this very short time period appears to be in-line with the City’s new Standard Operating Procedures for Public Participation (adopted on 5 Dec 2017), we are objecting to the timing and time limitations because:

(1) Since the year 2000, public participation processes have not been held over the December/January holidays precisely because too many affected ratepayers are on holiday and not paying attention. In our view the City is acting in extreme bad faith. The Public Protector has criticised the practice before and it undermines the principles and objectives of the Public Participation Framework (2013) and the Promotion of Administrative Justice Act (2000);

(2) Processing amendments to the City’s Water By-Law during the #WaterCrisis requires sensitivity, particularly when the City intends imposing new expectations on all ratepayers.
EG: Ratepayers will have to apply for and receive written permission from the City’s Director to use their own harvested rainwater, or borehole water, etc.

(3) The heavy legal jargon used in the Amendments and the By-Law are difficult to understand and ratepayers should be given time to grasp these legal concepts and language, to understand the implications, discuss it within their civic fora, draft substantive input and submit it before the deadline.

(4) Having an Open Day for the public to the amendments with City Officials, on the SAME DAY as the deadline for comments (8 Jan), and having only one such session at one venue is pointless and a slap in the face.

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