Re ERO 025-0900: Increasing…

Re ERO 025-0900: Increasing the Building Code’s sewage system cumulative design capacity limit, subject to certain enhanced protective measures, such as greater setbacks (distances) from sensitive features such as wells, is intended to allow for more timely construction of on-farm housing for workers under the Building Code Act while ensuring human health safeguards and environmental protections are in place.
Comment: More timely construction of on-farm housing for workers is a positive goal. Currently the ECA process can take several years from start to finish. However, the ‘certain enhanced protective measures’ mentioned above are not clearly defined in ERO 025-0900 and therefore it is difficult to evaluate if they provide sufficient protection. The protective measures are more detailed in ERO 025-0899, however I would suggest additional clear measures to balance both timely construction and public health and safety:
- a method to provide additional level of treatment beyond standard building code requirements, such as level IV treatment for all systems over 10,000 L/d.
- a larger septic tank (3 x daily design flow) to add additional treatment capacity for potentially high strength flows
- grease traps on the kitchen of any newly constructed on-farm housing for workers
-design by a professional who would be qualified to understand the larger picture of risks in the specific area
- nutrient removal to a particular standard (e.g. 10 mg/L for nitrogen) to reduce risk to ground and surface water from these larger systems.