1. General Comments Through…

1. General Comments

Through the proposed changes, the Transfer of Review program will be phased out by the Consolidated Linear Infrastructure program. Please note the following comments:

• Generally, the Consolidated Linear ECA approach will require municipalities to have greater confidence in stormwater reviews and inspection during construction. Many municipalities will likely require additional staffing resources to meet the requirements of the new process.

• Under the current system, municipal works that are built by developers are owned by the developer as referenced in the ECA until an assumption process is undertaken by the Municipality. If developer built works are pre-approved by the Municipal ECA, there is an inherent risk to the Municipality that could necessitate more oversight by the municipality during the construction phase, thereby increasing burden to Municipalities.

• Our understanding is that many of the ToR items will not be included under the preapproved works as it relates to SWM treatment infrastructure and therefore may trigger more direct submission ECA applications to the MECP. As such, there should be consideration for maintaining a Transfer of Review program with qualified municipalities for lower risk SWM treatment infrastructure such as wet and dry ponds as well as Low Impact Development measures, all outside of industrial areas. Alternatively, these SWM infrastructure could be identified to follow a similar process as the current Transfer of Review program within the System-wide ECA.

2. Comments on the Design Criteria for Sanitary Sewers, Storm Sewers and Forcemains for Alterations Authorized under Environmental Compliance Approval Ministry of Environment, Conservation and Parks DRAFT November 2019 MECP Storm Design Criteria:

1.1.4 c If the reference of “Provincial Water Management: Policies, Guidelines, and Water Quality Objectives “ in 1.1.4 1 is to the 1994 publication, this document should be properly cited for clarity.

2.12.5 The City of London reviewed PDC policies and bylaws through extensive stakeholder consultation and ultimately supported the removal of the requirement for PDC cleanouts in our design standards. The current clause does not indicate that cleanouts are mandatory. However, for clarity, we recommend amending this clause to read "Cleanouts, if required by the municipality or permitting authority, should be installed at or near the property line to facilitate inspection and cleaning.".

5.2.2, Table 3 The range of runoff values in the Table should be clarified to vary based on land use, slope and soil conditions. More information should be provided to designers to help in the selection of an appropriate runoff values based on the specific site characteristics. The risk of providing the range without more information may result in developers arbitrarily selecting a value within the provided range that does not reflect the site conditions due to lack of understanding in what the values are intended to represent.

5.2.3 Similar to the comment above, greater range and context for the selection of runoff coefficients should be included in the design criteria. An important consideration for increasing runoff coefficients when accounting for major flow to review overland flow routes and potential urban flooding conditions. For example, the MTO Drainage Management Manual (1997), Design Chart 1.07 notes that “for urban areas, the values of the runoff coefficient may be increased for the high magnitude storms under urban conditions. For the 25, 50 and 100-year events, it is recommended to increase the coefficient by 10, 20 and 25% respectively (MTO 1986)”.

5.3.2 We recommend the minimum storm sewer size be increased to 300mm.