Hello, please consider the…

Comment

Hello, please consider the following comments:

For construction dewatering, we would consider the requirement for the discharge criteria to be 25 mg/L total suspended solids or 8 NTUs turbidity for any discharge to land to be overprotective for situations where excavations are located far from watercourses, and in situations where turbidity is high in the background watercourse condition. Would the MECP consider wording more in keeping with PWQO (where suspended matter should not be added to surface water in concentrations that will change the natural Secchi disc reading by more than 10%), like: For discharges to land within 30 m of a water body, where the receiving watercourse has a TSS concentration of 250 mg/L or less, the discharge criteria shall be 25 mg/L for TSS or equivalent 8 NTU for turbidity. Where the receiving water body has a TSS concentration of over 250 mg/L, the turbidity of the discharge shall not exceed 8 NTUs or 25 mg/L TSS above the background level of the receiving water body. Discharges to storm sewer must meet the applicable criteria stipulated by the owner of the works."

Where a record of precipitation events is required, we would suggest that the record of precipitation should only be kept over periods of increased discharge over 400,000 L/day.

Can you provide more information about grandfathering provisions/transition time for EASRs that have already been registered and Water Taking and Discharge Plans prepared under current requirements?