I am writing to provide my…

I am writing to provide my comments on the application to the Ministry by Parkbridge Lifestyles Communities to amend ECA # 0720-4MUQ8R. Before this application is approved, I believe that many questions need to be answered. I am a current Tenant residing at Albion Sun Vista.

1. The Number of Septic Systems Installed on the Albion Sun Vista (ASV) Property

There is a discrepancy on the actual number of septic systems contained on the property of 130 home sites (129 occupied and 1 unoccupied). In the ECA application (page 46) the figure is an estimated 71 systems. In the August 2023 MECP Inspection Report, (page 69 of the application), the figure is an estimated 69 systems. Finally, in the Burnside Technical memorandum dated November 30, 2023, the estimated number of systems is approximately 65.

The reason for this discrepancy is directly the result of poor record-keeping by both the current and former property owners. Although Parkbridge has owned ASV for more than 10 years no clear accounting of the number of installed septic systems exists. At the time of the August 2023 inspection by the MECP, the Inspector herself noted that “many of the septic systems on-site at Albion Sun Vista are not approved under ECA no. 0720-4MUQ8R and use permits cannot be readily located.” Parkbridge did tell the MECP Inspector that that an assessment of the septic systems in the park had been carried out in 2019 which was supposed to clear up the number and age of the septic systems currently installed. This report was to be forwarded to the Inspector by November 30, 2023. Whether or not this occurred is unknown. Regardless, the exact number of septic systems on the property remains unclear.

2. The New Installations Completed Under the Current ECA

Appendix D of the ECA application contains a chart showing the systems installed at ASV that are covered either by a permit issued by the Rideau Valley Conservation Authority or by the Certificate of Approval. Of the 65 to 71 septic systems on the property, only 45 of them are permitted.

What is especially curious to me is that, again according to Appendix D, no new septic installations have occurred since 2002. This is I know to be incorrect.

In December of 2020, Parkbridge was invoiced for a tile bed replacement at 1056/1060 Teena Colleen Private. And then in February of 2021, they were invoiced for a tile bed replacement at 1018/1020 Vista Barrett Private. Finally, in February of 2022, they received an invoice for a septic system replacement at 1038 Vista Barrett. I have copies of all these invoices because they form part of an application by Parkbridge to the Landlord and Tenant Board for an above guideline increase in which they are asking to be reimbursed for these capital expenditures.

All of which begs the question, why were these invoices/records not included into Appendix D? The three replacements mentioned above were all carried out prior to the preparation of the ECA application. I cannot help but ask how many more installations have occurred between 2002 and 2025 that are not included in Appendix D?

I would also like to point out that condition 1.2 of the ECA specifically states that “…the Owner shall prepare a statement, …, that the works are constructed in accordance with this Certificate of Approval, and upon request, shall make the written statement available for inspection by ministry staff.” Where are these statements and why were they not made available to Burnside? Has Parkbridge even prepared these statements as proof of work that has been carried out on septic systems? And because the original ECA only granted permission for the replacement of 27 septic tanks and 27 tile beds, has this total been exceeded?

It seems odd to me that you would hire an engineering company, at what I sure was great expense, to put together this ECA amendment application but not make available all documentation they required. Is Parkbridge trying to hide something?

3. Reporting of System Breakthroughs

One of the other deficiencies pointed out in the 2023 inspection was Parkbridge’s inconsistency in reporting septic breakthroughs to MECP’s Spill Action Center. This seems like a relatively easy and important, task. I would hope that, as part of the deliberation process for this application, that the Ministry would investigate to see whether or not Parkbridge was more consistent in this regard.

For example, was a breakthrough of the system servicing 6580/6584 Vista Patrick Private (which occurred in the spring of 2025) reported? (No work has been done on this system yet. It would appear that, as the septic tank is being pumped out every two weeks, the tank is functioning as a holding tank until the tile bed can be replaced. The tenants are being told that the work must wait until the engineer gives the go ahead).

If Parkbridge cannot be faithful to this regulation, what other regulations have they not followed?

4. The Proposed Amendments to ECA 0720-4MUQ8R

While I am not an engineer by training and certainly would never consider myself to be a septic expert, I do appreciate many of the amendments that are being proposed in this application.

I like the fact that this amendment will recognize that not all the septic systems in ASV service two homes. Adding specifications to allow for the installation of a smaller system for a single home system will put an end to Parkbridge’s current practice of installing a larger system to serve one home. (They do this so they don’t have to apply for a permit to install a smaller system!).

Similarly, it also recognizes that the distance between some of our home sites is limited making it very difficult to install a 90m tile bed. I think that having the option of using a filter bed is a prudent one that will ensure the efficient running of the septic system. As will the use (when required) of a pump tank.

I also am pleased to see the recommendation that a ground and surface water monitoring program be developed. As has been pointed out, water for ASV tenants comes from three wells situated around the property. With so many septic systems in such close proximity, it is imperative that very close attention be paid to the condition of the groundwater. This is a welcome addition to the ECA proposal.

One of the outstanding issues from the 2023 MECP inspection was the question of the approximately 45 “unpermitted” septic systems on the property and how to bring them into compliance with Section 53 of OWRA. I am very pleased to see the proposed commitment to work to that end with a firm deadline attached to it. This is a very important task which seems to have fallen by the wayside since the unfulfilled commitments made to the MECP Inspector in 2023.

Final Comments

In theory, I am not opposed to the approval of this ECA application granting Parkbridge the authority to replace non-functioning septic systems with new components as specified. In fact, the one thing that I have observed that I will give them credit for is they have consistently hired a qualified, reputable firm to carry out whatever work septic is required.

Nevertheless, Parkbridge has also shown themselves to be extremely unreliable when it comes to the administrative side of things – i.e. keeping records, reporting problems or in being proactive about maintaining the septic systems on this property. This an extremely important component of the privilege of being granted an ECA. The question that must be asked is can Parkbridge be trusted to carry out these tasks unmonitored?

I am not sure if it is within the Ministry’s power to impose financial penalties for a failure to comply with province’s regulatory requirements, but if it is, I would encourage you to make those conditions part of the amended ECA. Regrettably, this seems to be the only incentive that this company understands.

In addition, I would encourage the Ministry to put on expiry date on the amended ECA rather than a quantity limit. As was pointed out above, there is a question as to whether or not the company has exceeded the number of installations permitted in the original ECA.

I would also ask that you consider imposing regular, mandatory inspections by Ministry officials of Parkbridge’s performance for the duration of the ECA to ensure their compliance with ECA conditions, especially record-keeping obligations.

Thank you for the opportunity to provide my comments.