General comments: - I…

General comments:
- I support the practical and direct approach being taken by the MECP in regards to both documents and the overall initiative.
- A streamlined approach such as this is much needed
- The elevation of the design criteria is also much needed and greatly supported.

Design Criteria for Sanitary Sewers, Storm Sewers and Forcemains for Alterations Authorized under Environmental Compliance Approval
- Line 98: Definition from SDWA should be included here as should all other definitions referenced from other documents, acts, policies or regulation.
- Line 101: Definition of Appurtenances: Recommend that splitter and proprietary treatment units such as OGS units etc be included
- Line 651: Table 3: This list of runoff coefficients should be expanded.

ENVIRONMENTAL COMPLIANCE APPROVAL (ECA) For a Municipal Stormwater Management System
- Line 40: LID are noted here but included in subsequent sections. Consider added LID to the list for greater clarity. Perhaps “Stormwater Management Facilities (including LIDs)”
- Line 198 - Definition of Third pipe system missing
- Line 390: While Rooftop gardens are noted in 2003 manual, this terminology is outdated. Consider revising to “Green Roofs” or “Green Roofs/ Rooftop Gardens”
- Line 392: Consider adding ‘Hybrid Facility” to the list Per MOE 2003
- Line 415: 2003 manual is prohibitive to the implementation of LID (per 5.1.20) as noted in the MECP 2015 Interpretive Bulletin on LID. The satisfaction of Appendix A – Stormwater Management Criteria has proven to be problematic when the 2003 Manual is used as the primary design guidance (it is for this reason that the MECP 2015 Interpretive Bulletin on LID was issued. Inclusion of this statement or the lack of clarity regarding the appropriate use of LID design guidance will result in the majority of LID being approved via direct submission as Professional Engineers will not certify the design when it contravenes a condition as listed in 5.2.1. This needs considerable thought by MECP. Consider adding:
a) reference or provision that LIDs should be designed per the TRCA/CVC Low Impact Stormwater Management and Planning Guide (2010) or most recent (wiki).
b) Reference to the MECP 2015 Interpretive Bulletin on LID.
- Line 476: Through the application of this condition, it will prevent the retrofit of ponds with a DA greater than 15HA. This is highly restrictive and unnecessary. Most existing SWM ponds have drainage areas greater than 15ha. As an example, of the previous 17 ponds retrofitted by Aquafor Beech since 2008 to include water quality to current standards in the Cities of Kitchener (8), Barrie (3), Brampton (1), Vaughan (3), Richmond Hill (2) only 1 of 17 facilities had a DA smaller than 15ha. If the intent is to have all SWM pond retrofits to be reviewed as a Direct Submission – OK. But, a constant complaint for Municipalities is the excessive wait times for an ECA review or Amendment for SWM pond retrofits which are typically +6months. This is a significant barrier to implementation and improvement of the existing SWM system within municipalities.
- Line 506: Contradicts 6.1.1 of the Design Criteria for
Sanitary Sewers, Storm Sewers and Forcemains for Alterations Authorized under Environmental Compliance Approval, specifically: “shall be designed to collected water only from the foundation drains”
- Line 716: Permeable Pavement doesn’t have media or soil. Consider revising to “aggregate”. “Rain gardens” is not the correct terminology. Consider revision to “bioretention facilities” (see suggested Track Changes)
- Line 793: This statement requires additional clarity. Many faculties listed in Section 5.1 cannot accommodate a “water level gauge clearly visible to take readings” . Consider subsurface facilities such as soakway pits, permeable pavement, bioretention etc. Consider revision to “(manual with clearly visible markings take readings for surface facilities, or monitoring ports with manual or continuous loggers for subsurface facilities)” (see suggested Track Changes)
- Line 890: Why only 2 levels? This appears very limited. Consider the inclusion of: Level C - Stormwater receives treatment for water quantity only prior to discharge to the environment. Note: this category is very important for the identification of potential water quality retrofits within a SWM system.
- Appendix A: Table 1: What is a Class EA feasibility Study? – this does not exist and does not make sense. Typically, a feasibility study is completed as a non-EA study prior to completing the EA or is transitioned to an EA when appropriate.
- Appendix A: Table 3 - not referenced in the document.