Environmental Compliance…

Environmental Compliance Approval in respect of Sewage Works Regulation
ERO-019-0005

These comments are in support for ECA's with pre-authorization.

1. Barrie Pilot:

With respect to stormwater, it is recommended that the MECP take the program much further than the pilot with Barrie.

The following comments on the stormwater pre-authorization are based on the Barrie pilot with ECA number 8130-ACUPHF.

The Barrie ECA basically covers what is found in the current Transfer of Review (ToR) agreements for standard and additional works.
If we go from the current ToR to the preauthorization based on Barrie pilot the main thing gained is only the very last part of the process in which the MECP issues the ECA.
Under the current agreement the MECP has 30 business days to issue the ECA.
Practice has been more in the 10 to 15 day turn around.
The proposal states that the MECP wants to “eliminate the need for developers to obtain separate approvals for pipe by pipe construction thereby speeding up new home development and eliminating duplication and reducing financial and administrative burden for developers”

Therefore the time gained by going to pre-authorization based on the ToR is minimal.

2. Reducing the timeline for the ECA’s under the ToR are appreciated, but not the priority for the some. The priority should be to address the long processing time for ECA’s under direct submission which are currently taking up to a year for the MECP to review and approve. This can have a significant impact on economic development.

Under pre-authorization the municipalities will have to do slightly more work than they are doing now under the current ToR.

Under pre-authorization the MECP will have to do less work freeing up resources that will “allow the Ministry to focus its resources on activities which pose the greatest risk to human health and the environment.”

It would be of benefit to all municipalities within the province if the MECP will be able to use the resources gained by pre-authorization to help review and process ECA’s under direct submission with the objective of significantly reducing the turnaround period for these types of applications.
Would ECA applications under direct submission fall under “activities which pose the greatest risk to human health and the environment” thus allowing resources to be applied in this area?

3. Consolidation of existing ECAs
Consolidating existing ECAs and adding pre-authorizations is a good idea. It will bring a consistency to the ECA especially when it comes to items such as monitoring. It will also allow for expansion of the municipal collection systems to be simplified in the future - similar to how the water distribution system is managed under the existing water works permits.

4. It is recommended that the following be considered for pre-authorized works:
a. Allow for private works to be included in the pre-authorizations when the Municipality has the same design standards and review process for public and private works. With the form 1 for watermains associated with the municipal water works permits, approval of private water works is routine.
b. Allow combined sewer works or works connecting to combined sewers under pre-authorization when there is no increase in the combined sewer tributary area ( if this is not acceptable then no increase in combined sewer flows).
c. Pre-authorization for storm sewers up to a diameter 3600 mm (a limit of 1200mm is shown in the provided Barrie ECA) and the existing range of TSS removal for all existing SWM ponds.
d. Pre-authorized approval for storm ponds with 70% TSS removal when supported by the conservation authority.
e. Pre-authorization for LID features meeting similar levels of quality control as supported by the conservation authority. This will incentivize the use of LID based designs in urban areas where direct submission ECAs would then not form a requirement.

Thank you.