Montreal, August 27, 2021
TRANSMISSION BY EMAIL
Madame Andrée Laforest, Minister
Ministry of Municipal Affairs and Housing
Jean-Baptiste-De La Salle Building
10, rue Pierre-Olivier-Chauveau, 4th floor
Quebec, QC G1R 4J3
Subject: Elimination of polluting cross connections
Madam Minister,
Cross connections of sewer pipes, that is to say sanitary connections flowing into the stormwater network (and vice versa), constitute a scourge against which the MAMH can play a crucial role. The resulting sanitary sewer discharges contaminate waterways. This problem was identified a long time ago by the MAMH and the solutions put forward do not produce results due to lack of adequate controls.
The MAMH Infrastructure Department produced a support guide for contamination screening for municipalities more than 10 years ago. The MAMH also introduced into all its agreement protocols for municipal infrastructure subsidies, a clause requiring municipalities to have an action plan for identifying and correcting cross-connections on their territory. This is a universal clause which obliges municipalities to take action, otherwise the subsidy may not be paid. Its compliance had to be verified when the financial assistance was paid, which is not done: neither the procedures nor the results obtained by the municipalities are submitted to the MAMH.
Fondation Rivières has observed that municipalities do not take the necessary actions to identify the sources of contamination or do not carry out the necessary corrective measures, even if they involve illegal pollutant discharges! Waterways thus remain polluted at all times (and not only during episodes of rain causing wastewater overflows) and the recovery of certain uses is impossible, despite the billions of dollars invested to date in the water sanitation.
The file of Meadowbrook Creek of Montreal alone demonstrates significant environmental and legal consequences: the City of Montreal is required, by a court judgment, to build a rainwater pipe which will have the effect of drying it out. Montreal is a victim of the decisions of the cities of Côte-Saint-Luc and Montreal West which have not corrected the cross connections on their territory. Their contaminated water thus flows into the territory of Montreal, into the stream. This problem, known for more than ten years, should have been dealt with by the MAMH which pays subsidies for infrastructure work without the clause present in the memoranda of understanding being applied.
Our studies and communications in a multitude of municipalities show that the problem is widespread in several municipalities. It is clear that the voluntary and responsible approach is not enough.
Recommendations to MAMH:
- Communicate with the MELCC so that it requires, in its sanitation certificates, measures to identify and correct inverted connections;
- Remind municipalities, which have a memorandum of understanding in force, of the presence of the clause requiring an action plan for the correction of reverse connections, a clause which makes the payment of financial assistance conditional;
- Review the internal file analysis process to ensure compliance with the clause, including the obligation to demonstrate compliance;
- Provide for a strengthening of the clause in future memorandums of understanding so that activities to identify inverted connections and their correction are carried out during the project and not when the file is closed;
- Provide in future financial assistance programs that eligibility for financial assistance is conditional on demonstration of the absence of reverse connections.
Thanking you for your attention to this letter, we remain available for any additional information.
Please accept, Madam Minister, the expression of our distinguished greetings.
Alain Saladzius, P.Eng., FIC
President, Fondation Rivières
Note: Fondation Rivières did not receive a response. The Foundation filed a complaint with the Sustainable Development Commissioner in the spring of 2023, and in the fall of the same year, she submitted the file to The Press.
Photo: Ben Lambert/Unsplash
