General: We are generally…

General:

We are generally supportive of the proposed consolidation of the ECA processes, subject to further clarification of some items and suggested modifications, as noted.

In terms of timing to implement, we request a time frame to develop a limited scope Sani and Storm QMS program for start on Jan. 1, 2023 and longer if a more in depth scope program is required. Our primary concern is ensuring we have time to approve budgets for the increase in workload that is anticipated as part of these programs.

Design Criteria – Preface:

The language states that municipalities may have other more stringent criteria than the MECP, which would be acceptable. What if a municipality has criteria that are not necessarily less or more stringent, just different? Local standards should still apply as long as they are not clearly less stringent.

Design Criteria – 2.9.2:

We question the need for this new requirement and suggest that MECP consult with CSA and manufacturers with respect to water tightness requirements of the current gravity standards.

Design Criteria – 2.9.4

What is the rationale for this requirement? This clause is related to high groundwater, not surface water inflow.

Design Criteria – 2.10.11:

Is this a significant problem for most municipalities? This is not our requirement currently.

Design Criteria – 2.12.5:

Please clarify if this is intended to be a requirement or simply guidance where cleanouts should be located, if provided/required. Installation of cleanouts at property line is not a current requirement, as they are installed elsewhere per the OBC.

Design Criteria Appendix A – 2.3:

Leakage testing is not typically very practically achievable for sanitary sewers with multiple connections. It is difficult to perform, is time consuming and adds cost. Recommend removing this requirement.

Design Criteria Appendix A – 2.4.1:

A minimum 30-day waiting period after backfilling but before paving could introduce scheduling issues, particularly for road reconstruction projects in certain scenarios/existing locations.

SAN/STM ECAs – General:

A number of new forms are mentioned in the templates (e.g. the System Profile Information Form in S1.1). Can these be posted to the registry for viewing/comment?

SAN/STM ECAs – 3.0:

Asset management and other master plans etc. may not be updated at the same time/on the same cycle ECAs would be. Is this section simply noting a reference to those documents or is the expectation that the ECA would need to be updated every time an asset management plan is updated? This would create an additional administrative burden. Further, an AMP should not be integral to/required for the ECA approval, as its requirements are already legislated via O. Reg. 588/17.

SAN ECA – Schedule E 4.1.1 & 4.1.2:

Clarification on what qualifies as an inspection would be helpful. The best wording could be “in accordance with the operations and maintenance manual.”

STM ECA – Schedule E 4.1.1 & 4.1.2:

Please clarify the language that the frequency for cleaning does not necessarily need to follow the inspection frequency. For example, municipalities will not be able to remove sediment from all SWM ponds on a 3-year cycle.

STM ECA – Schedule E 4.1.3:

What constitutes a “significant” flooding event? Will this be related to a certain return period storm or other measure?