The following recommendation…

The following recommendation was passed by the General Committee of the Township of Ramara on March 29, 2010: CW.69.10THAT we respond to the Environmental Bill of Rights (EBR) by April 3, 2010 with the following statements with regard to the Lake Simcoe Protection Plan: a)Phosphorous Reduction Strategy (EBR Registry No. 010-8986) XThe Township of Ramara is supportive of efforts to improve Lake Simcoe water quality. Resident associations, such as the North Mara Beach Resident Association, monitor on a regular and ongoing basis the water quality in the streams that discharge to Lake Simcoe. This data is made available to the municipality and to the Lake Simcoe Region Conservation Authority. XThe Township cannot support a Phosphorus Reduction Strategy that requires STPs to reduce their phosphorus contribution to a point that is not currently technically achievable. It is not realistic to rely on innovation and new technology to bridge the gap between what is currently achievable and the objective for the STPs. The currently available sewage treatment technologies for phosphorus removal are already reaching the limit of what is physically and chemically possible. XIn the absence of promising and cost-effective new phosphorus removal technology, the draft Strategy for the STPs therefore relies on obtaining phosphorus credits from other sources to achieve the overall STP objective. This strategy is weak and may not succeed because a decision has not even been made to implement a Water Quality Trading Program. Should the Water Quality Trading Program not be implemented, or not be successfully implemented, the phosphorus reduction objective for the STPs will not be met. XThe requirement for all STPs to be upgraded to incorporate the most sophisticated level of treatment technology is very onerous to municipalities. The burden to the existing residents (increasing the level of treatment at an existing STP must be paid by the existing residents) and for developers of small subdivisions, is significant for a very small overall reduction in the phosphorus loading to Lake Simcoe. XThe Township cannot support a plan that requires a roll-back in the MOE-approved phosphorus loading to the lake without a commitment from the provincial government to assist with the costs of upgrading the sewage treatment plant. The Lagoon City STP was recently expanded and upgraded with MOE¡¿s approval, which we believe was based on considerations of the impact of the effluent on the lake¡¿s water quality, to serve a community that was until then serviced by on-site sewage systems. The Lagoon City/Brechin sewage works project was entirely funded by the existing residents and future growth through development charges, and will result in improvements to surface water quality. The costs of further upgrades to the Lagoon City STP to meet the PRS proposed effluent quality would be an unfair burden on the residents. XThe draft Strategy does not address the higher need to reduce phosphorus loads to priority areas with lower lake water quality. It is not clear how the sub watershed specific targets, which we understand have not yet been developed, will be implemented as part of the PRS. In our opinion, establishing the priority areas and the sub watershed targets should precede the establishment of effluent loading limits for the STPs. Janice McKinnon, Clerk Township of Ramara

[Original Comment ID: 125645]