Hello, please find below…

Hello, please find below comments on behalf of Toronto Water concerning ERO-019-2377.

1. Comprehensive EA Criteria

We understand the proposed Comprehensive EA project list will include projects with the most significant impacts taking into consideration the following criteria: a) magnitude of the effect; b) geographic extent of the effect; c) duration of the effect; d) frequency of the effect; e) degree of reversibility of the effect; and f) possibility of occurrence of the effect.

These criteria make sense from an impact and risk assessment perspective to distinguish projects with potential significant impacts which should require a comprehensive EA vs. municipal projects with well understood and predictable impacts and mitigation, which would follow a streamlined EA.

2. Comprehensive EA Project Types

We understand project types proposed to be included in the Comprehensive EA include Conservation Projects, Mining, Electricity, Transportation and Waste.

Toronto Water supports the exclusion of water and wastewater projects currently undertaken under the Municipal Class EA from the types of projects that are proposed to be included in the Comprehensive EA.

3. Conservation Projects Subject to a Comprehensive EA and Proposed Thresholds/Target criteria

We understand MECP proposes to include "Conservation Projects" that are unique and may be of high public interest as they may involve substantial in-water works and have the potential for greater environmental effects. These projects have significant remedial flood and erosion control projects that facilitate or anticipate development. Major flood and erosion control projects , such as multipurpose projects.

Examples of criteria proposed by MECP that could be used to refine the above include:

- land area in number of hectares
- total shoreline affected
- proximity to major settlement areas, amount of river realigned
- extent of fish or wildlife habitat impacted
- Is it within an Area of Concern
- impact to significant natural heritage features.

The criteria are quite general and Toronto Water is concerned they may require a Comprehensive EA for City of Toronto watercourse erosion control projects to protect vulnerable sewer infrastructure from the impacts of watercourse erosion.

These watercourse studies and projects are currently undertaken as Geomorphic EA Studies (some on a stream-by-stream basis and some on a watershed basis, e.g. Highland Creek Watershed Geomorphic Master Plan) under the Municipal Class EA. Recommended works from these Class EA studies may include the realignment of watercourse reaches within valley lands and ravines.

It is recommended that more detailed criteria be considered by the MECP so that watercourse erosion studies to protect sewer infrastructure in the City's valley lands are not included in the Comprehensive EA project list and remain subject to a Streamlined EA process.

Suggestions for refining criteria:

- length of river or stream realigned - set a minimum total length of 1.5 km to exclude smaller reaches of rivers and streams requiring realignment to protect vulnerable sewer infrastructure

- the magnitude of impacts and ability to mitigate impacts through design and construction and current permit approval requirements (e.g. TRCA permits), as per the current Municipal Class EA process, should be considered in refining this criteria

Thank you for your consideration of these comments.

James Yacoumidis
Senior Project Manager (A), Water Infrastructure Management
Toronto Water, City of Toronto
Tel: 416-392-8834
Email: james.yacoumidis@toronto.ca