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Thank-you for the opportunity to comment. These are a collection of comments from the City of Kitchener.
Steve Allen, P.Eng.
City of Kitchener

1 General - City of Kitchener is supportive of the proposed changes subject to clarifications and suggested modifications
2 SAN/STM Schedule A 1.1 - System Information Form - Suggest giving municipalities more time to gather and compile the inventory and other data. 2 years is reasonable.
3 Revoking of old ECAs - Will the Ministry be providing a list of revoked ECAs or is it up to the Municipality to identify which historical ECAs are revoked under the new System Wide ECA? In order to keep record keeping accurate, any ECA's that are revoked should be specifically identified and communicated to the operating authority.
4 SAN/STM Municipal Wastewater System Profile Information Form referenced in Sch A 1.1 - Various forms including this one are reference throughout. If there are new forms can the draft of this form be posted to the EBR?
5 SAN /STM Sch A 3.0 and 4.0 - Reference Asset Management Plans. These plans are updated regularly. Clarity required around now the ECA is updated when the new version of the AMP is producted. What purpose does the Asset Management Plan serve bundled with the ECA when AMP are required through other legislation?
6 SAN/STM Design Criteria - Can the Ministry clarify statement in the Preface regarding existing local standards and specifications, specifically, is it only more stringent local standards that are considered acceptable, not just differing?
7 SAN Design Criteria Sec 2.12.5 - This should be reworded to clarify if cleanouts are required or is it simply saying where they should be located. Kitchener standards are not to install cleanouts on the sanitary laterals
8 SAN Design Criteria Appx A. Sec 2.3 - Leakage testing on sewers isn't always easy or practical. Consider removal of this as a requirement.
9 SAN Design Criteria Appx A. Sec 2.4 - Deflection testing - 30 days after backfilling but before paving could present a scheduling issue for projects, especially rehabilitations in existing areas
10 SAN Design Criteria 2.9.2 - We question the new requiement for pipes below the seasonal water table to be built to forcemain standards. Consultation with CSA standards and pipe manufacturers should be conducted to confirm this is justified
11 SAN Design Criteria 2.9.4 - Unclear on the requirement for water tight lids for areas of high groundwater.
12 SAN Design Criteria 2.10.13 - this is already covered in 2.9.3
13 SAN Design Criteria 5.7.1 - This should be clarified to exclude service laterals
14 SAN Sch E 4.1.1, 4.1.2 - Clarification on what constitutes "inspection" for SPS, storage tanks. Suggest wording to "visual inspection"
15 SAN Sch E 4.1.1, 4.1.2 - Moving to a 5-year cycle could be onerous for municipalities. Kitchener is on a 17 year cycle. Current industry benchmarks are no where near 5 year frequency. Propose 15-years. Multiple inspections of pipes less than 20-25 years old is not an optimum use of public funds.
16 SAN Sch E 5.6 - This reporting is onerous and will require additional resources to summarize across many different teams, and produce a document for Ministry consumption. Why does the Ministry feel this is something that needs to be added to the proposed system ECA? There is no reporting requirement now and the creation of the new ECA framework does not create a new risk that is mitigated by this requirement. Due to the workload required to set up the systems to track and report, a multi year phase in period is recommended before the reporting requirement is active.
17 STM Sch E 4.1.1. - clarify what constitues an inspection. Suggest adding "visual".
18 STM Schedule D - 4.1.3 and Schedule D - 5.2.2 - Please clarify how this will be assessed. Will every alteration need pre-construction and post-construction monitoring to prove this or based on best practices?
19 STM Schedule E - 4.2.2 - The O&M manual was not a requirement for most of our SWM facilities given they were older, so we would need to create this for many facilities – this will take a lot of time to accomplish. We also do not have as-built drawings for older facilities – could this be changed to recorded drawings to be consistent with terminology used by the PEO?
20 STM Schedule E – 5.5.1 - Could this be clarified that it is not all Works that provide quality and or quantity control that will be monitored, but only what is selected per the monitoring plan? It currently seems like every Works that provide quality and/or quantity control will have to be monitored which will not be feasible
21 STM Schedule E - 5.5.6 c) i - Should this wording be changed to Stormwater Management PONDS (if they are selected for the monitoring plan) given that it will be difficult to add visible water level gauges on OGS’s, LID’s and other systems defined in “Stormwater Management Facilities” in Table 3 of Schedule B?
22 STM Schedule E – 5.5.7 - Our monitoring program is currently set up predominantly around monitoring the receiving creeks within subwatersheds to determine their health, not monitoring individual stormwater management works aside from new LID’s that have been implemented, and one stormwater management pond retrofit. Would the program then have to be changed to incorporate an annual rotating monitoring program of all stormwater management works? (i.e. Stormwater management ponds [100+], outlets [400+], infiltration galleries and other LID [600+], OGS [90+] etc.?) If so this will require a complete overhaul of our monitoring program and be incredibly expensive to monitor them all.