The portion of the proposal…

The portion of the proposal which looks to make additional amendments to Ontario Regulation 525/98 made under the Ontario Water Resources Act is of particular interest. The exemptions which are in place for LIDs on residential lots are appropriate given the small drainage areas and low risk. Where our Municipality has encountered an issue is that the exemption for LIDs on residential properties does not apply when the property also contains a sewage system - O.Reg. 525/98 Section 4.(2).

Like most municipalities, we would prefer to see growth occur on full municipal services however we do have some areas within our existing settlement areas where municipal services do not exist but there is the potential for some limited infill development on private services. This creates a situation where individual lots will each be serviced by private wells, private sewage (septic) systems and LIDs to assist with stormwater control. Since these lots will require a private sewage system on each lot this results in each lot also requiring an ECA for the proposed LID (infiltration galleries). These lots are generally 0.4 acres or larger.

The requirement for individual ECAs for each lot is onerous for the MECP and not desirable for the developer or future lot owner. We would like to see the MECP provide some guidelines for these types of developments, that if met, the LIDs could still be exempt from an ECA. This could be as simple as a minimum separation distance between the septic system tile beds and the edge of any infiltration systems or varying minimum distances could be specified depending on the soil type, percolation times or hydraulic conductivity. This would make it easy for designers to layout the site services to avoid the need for an ECA.