1. MECP anticipates that…

1. MECP anticipates that existing documentation can be used for the application but would like to hear feedback from municipalities as part of this consultation: Much of the information regarding storm and sanitary infrastructure have been collected for the purposes of Asset Management. Depending on the level of detail required for application, the information may take some time to collect. All municipalities have asset management requirements as dictated by the province that includes inventory, inspection, condition rating, level of service, and financial impact. Submitting information regarding the sewer inventory to the MECP would be a duplication of effort and serve no purpose. Suggestion is to not require submission of any inventories but the MECP can always ask about a specific asset if needed.

2. MECP is seeking feedback from municipalities and interested parties on how much time will be necessary to transition to a Consolidated Linear Infrastructure Permissions Approach. The transition to a Consolidated Linear Infrastructure Permissions Approach could be implemented in a relatively short time-line, however, that is dependent on the level of detail required to initiate the process. The City anticipates that the transition to the proposed approach will require a significant time and financial commitment in order to generate Operations and Maintenance Manuals, Monitoring Plans, processes and procedures, have monitoring plans peer reviewed, generate annual reports and complete PPCP Studies, etc., in order to demonstrate compliance to the updated conditions within the proposed ECAs.

3. The ministry is proposing a 5 year renewal cycle for all Consolidated Linear Infrastructure ECAs and would like to hear feedback from municipalities on the timing of the proposed renewal cycle. The City would support a longer renewal period, such as 10-years. This would align with the undertaking of updates to various studies required eg. PPCP, which is when significant changes in understanding of the system may occur. Consider renewal periods based on serviced population or other metrics other than time (eg. # of alteration forms).

4. The ministry seeks your comments and feedback on the proposed templates.
With respect to the Sanitary ECA Template:
Schedule D, Section 6.1.3: The City would request that Pump Stations that meet the criterion for the current Transfer Of Review Program (TORP) be considered for pre-approval.
Schedule E, Section 3.1.1 b): The City would request that a definition of “state of good repair” be provided.
Schedule E, Section 3.1.1 c): The City would request that clarification be provided as to which prescribed standards are being referenced.
Schedule E, Section 4.1.1: The City would request clarification on the type of inspection being required for the sewage collection system identified in Schedule B, every 5 years. Each municipality is responsible for maintaining all their assets from watermains, to buildings, to sidewalks, etc. Each of these assets has a method and frequency of inspection that maintains a defined level of service. Suggestion is to leave the decision about inspection frequency as the responsibility of each municipality who funds the implications of those decisions.
Schedule E, Section 5.6.2: The City would request that the MECP review the reporting requirement for “any operating problems encountered and corrective actions taken”. The listing would be exhaustive. Further, our log books are available for Ministry inspection and capture all operating problems encountered and the corrective actions taken.
Schedule E, Section 5.6.6: The City would request that the MECP review the requirement to provide construction sign-off within an annual report. Consider use of the Director Notification Form for these sign-offs, if they are necessary.

With respect to the Storm ECA Template
Schedule B, Section 1.5: All municipalities have asset management requirements as dictated by the province that includes inventory, inspection, condition rating, level of service, and financial impact. Submitting information regarding the sewer inventory to the MECP would be a duplication of effort and serve no purpose. Suggestion is to not require submission of any inventories but the MECP can always ask about a specific asset if needed.
Schedule E, Section 5.3.4: The City would request that consideration be given to allow pre-approval for works servicing a drainage area greater than 15 ha.
Schedule E, Section 6.2.2: The City would request that the MECP review the reporting requirement for “any operating problems encountered and corrective actions taken”. The listing would be exhaustive. Further, our log books are available for Ministry inspection and capture all operating problems encountered and the corrective actions taken.
Schedule E, Section 6.2.6: The City would request that the MECP review the requirement to provide construction sign-off within an annual report. Consider use of the Director Notification Form for these sign-offs, if they are necessary.
Schedule E, Section 9: Appendix A: Water Balance and Water Quality: City has had several subwatershed studies completed in different parts of City, but entire City is not completed. We see that there are alternative methods as outline in Appendix A to take into account the criteria mentioned above, but there might be external factors that might not allow for water balance or quality to be met (ie. Heavy clay soils within St. Thomas does not allow for infiltration). Will MECP allow exceptions if this is the case? Will MECP force municipalities to complete additional studies to address these deficient areas? There are significant costs associated with such studies.

5. The ministry wishes to hear from municipalities to better understand the type of guidance and support that is required to move to this approach.
Financial assistance to complete City-wide storm-sewer catchments determinations, subwatershed studies, generate Operations and Maintenance Manuals, Monitoring Plans, processes and procedures, have monitoring plans peer reviewed, generate annual reports, develop electronic databases, and complete PPCP Studies, etc. would be appreciated. Guidance documentation related to monitoring plan development would be helpful. The transition may provide some efficiencies in the long run relating to development processes, however, the transition will be cumbersome to initiate from both a time and financial stand-point for the City.

6. The ministry seeks your comments on the proposed Design Criteria.
Undertaking of Leakage testing can be a difficult and costly task to perform in certain situations, especially when live service connections are already in place. We would request that the Ministry review when and where this requirement is reasonable to be undertaken.

The City would request that the MECP consider retaining the ToR framework for those works that do not meet pre-approved conditions. We would also provide a general comment that use of the term Combined Sewer Overflow (CSO) tanks to refer to storage tanks designed for the purpose of reducing Combined Sewer Overflows confuses the general public when referenced. Recommend using terminology that does not include an acronym or other that stands for overflow. Consider use of term ”Combined Sewer Inline Storage Facility”.