On behalf of the Design &…

On behalf of the Design & Development and Pollution Control Departments of the City of Windsor, we appreciate the opportunity to comment on ERO #019-2219 proposed amendments to the Director’s Technical Rules made under section 107 of the Clean Water Act, 2006. Comments provided below:

(1) Windsor IPZ-2 (vulnerability score 8.1) covers a large area of the City of Windsor with many different land uses (residential, commercial, industrial, municipal parks, institutional). To date, there have not been any implementation challenges in this vulnerable area. However, the proposed amendments will result in additional SDWTs in this area that could be burdensome and/or challenging to implement.

(2) There is ambiguity in the amendments where many of the rule changes to delineation and scoring of vulnerable areas (IPZs) are identified as enabling. While these Rules are enabling, it may be considered a necessary activity locally if changes to the proposed amendments to the Table of Drinking Water Circumstances are mandatory. Can clarification be provided? If items are considered enabling will the costs associated with source water plan updates be supported by the MECP.

(3) In regards to the “Storm Water Management Facilities and Drainage Systems”, the use of the terms “predominant land use” to an “outfall” in the new circumstances may have ambiguity with older sewage system often having split drainage. It may provide further clarity if “predominant outfall” is also used.

(4) The thresholds for the storage of snow are drastically reduced. Currently in the ERSPA, the storage of snow > 1 hectare is prohibited in IPZ’s with scores greater than 9. The new circumstances include thresholds where the storage of snow would be a SDWT in IPZs with scores greater than 8 (Windsor IPZ-2). The MECP should be prepared to defend these new thresholds, where there is potential for a significant number of commercial and/or industrial parking lots in large IPZ-2’s that may now require RMPs.