STORMWATER PROPOSED…

STORMWATER PROPOSED REGULATORY REQUIREMENTS
• Spill Contingency Plan (SCP)
o Will a guideline or standard for SCP be provided for commercial, institutional and light industrial activities to follow to ensure plans provide the applicable information and details, ensure consistency across land-uses and sites, ensure costs to prepare these documents are optimized.
o Do you need an SWM ECA instead of an EASR if you are in a source water protection area for drinking water for commercial, institutional and light industrial activities?
• Operations and Maintenance Report (OMM)
o Will a guideline or standard be provided for OMM for commercial, institutional and light industrial activities to follow to ensure plans provide the applicable information and details, ensure consistency across land-uses and sites, ensure costs to prepare these documents are optimized.
• Effluent Limits
o Monitoring results have shown that stormwater management facilities can exceed 25mg/L for certain periods during any storm event. The 2003 MOE SWMPDM acknowledges this by requiring that development applications provide enhanced water quality treatment achieving 80% TSS removal instead of an effluent target. The proposed effluent limit for TSS concentration of 25mg/L conflicts with the MOE 80% TSS removal rate. Which one governs?
o Collecting samples for testing in a laboratory are expensive and time consuming. In-field turbidity meters would be preferred testing technique.
o Will a standard methodology be provided for determining the background turbidity levels for nearest water body?
o Will there be a standard methodology for type and duration of monitoring provided for sites that are EASR eligible?
• Transition for ECA Holders
o For existing sites that have an existing ECA’s for stormwater (i.e. private multi-unit residential, industrial, institutional, commercial) that are eligible to self-register must self-register under the EASR within 5 years of the proposed regulation taking effect or if modifying works on site that may require an ECA amendment.
 What is the benefit to the existing ECA holder to transition to the EASR? Is this process mandatory?
 Will all private ECA holders that may qualify be notified of this requirement? Will the ministry provide a list of the qualifications for EASR eligibility, as well as steps to be taken if works are to be registered under the EASR to the ECA holders?
 If an existing site with an existing ECA’s is transitioned to the EASR would the ECA conditions be replaced by the EASR requirements/conditions?
 Are there plans to phase these transitions over the 5 year period?