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Letter to the Ministry of Municipal Affairs and Housing and the Ministry of the Environment and the Fight against Climate Change: Green infrastructure work

Montreal, December 22, 2020

Madame Andrée Laforest, Minister
Ministry of Municipal Affairs and Housing
Jean-Baptiste-De La Salle Building
10, rue Pierre-Olivier-Chauveau
Chauveau Wing, 4th floor
Quebec (Quebec) G1R 4J3

Montreal, December 21, 2020

Mr. Benoit Charette, Minister
Ministry of the Environment and the Fight against Climate Change
Marie-Guyart Building
675, boulevard René-Lévesque Est, 30e floor
Quebec (Quebec) G1R 5V7

Subject: Green infrastructure work – Ineligibility for subsidy programs

Madam Minister,


We hereby wish to bring to your attention an element of a solution to the problem of spills of untreated wastewater during periods of rain and melting: the financing of green infrastructure which uses different natural processes and vegetation. It is high time that these are no longer categorized as “innovations”, but considered as solutions in their own right.

All experts in water management, particularly those in your Ministry, agree on the importance of investing in such green infrastructure to better manage stormwater. In addition to reducing discharges of untreated wastewater, they help avoid pollution caused by contaminated rainwater transported to waterways and recharge the water table, to name just these benefits. These green infrastructures can be built using proven techniques which are carefully described in the Stormwater Management Guide produced jointly by the Ministries of the Environment and Municipal Affairs a decade ago.

However, the three main financing tools available for such infrastructure do not recognize this type of project. Eligible work only targets usual civil construction (sewers, aqueduct, treatment systems), both for the Gasoline Excise Tax (TECQ) program with an envelope of 3.4 G$ and for the Infrastructure Fund municipal water supply (FIMEAU) with 1.5 G$, which benefit from a federal financial contribution. It is the same with the Municipal Water Infrastructure Program (PRIMEAU) managed by the government of Quebec.

Municipalities and their citizens are deprived of the support they need to choose the best solutions available for improving their water management. Some of them use other research-based programs, but these are much less funded and smaller in scope, whereas green infrastructure is proven, but
as are traditional solutions.

During this time, water stakeholders, including the Regroupement des organisms de bassins versants du Québec, are producing design guides, raising awareness and promoting these simple-to-implement techniques. Cities are incorporating this dimension into their projects, such as Montreal with the renovation of Papineau Street and Trois-Rivières for Saint-Maurice Boulevard. And cities, like Quebec, go even further by adopting the concept of “sponge city”.

The Municipal Water Infrastructure Fund (FIMEAU)

FIMEAU presents the same shortcomings. In sub-components 1.1 and 2.2, FIMEAU accepts
only the following domestic or rainwater wastewater infrastructures:
• Collection and interception conduct;
• retention pond;
• pumping and treatment station;
• emissary.

We should not be surprised that of the 280 FIMEAU projects announced on August 20, 2020, none included green infrastructure despite the fact that these sometimes constitute an optimal solution. The next call for projects is planned for 2022 and we strongly recommend that it be improved immediately to allow the construction of green infrastructure.

The excise tax on gasoline and the Quebec contribution (TECQ) 2019-2023

This program provides for the payment of large sums and for the work to be completed within three years, December 31, 2023. This work must target, as a priority:

1) Installation and upgrading of drinking water and sanitation equipment;
2) studies aimed at improving knowledge of municipal infrastructures;
3) renewal of drinking water and sewer pipes;
4) local roads and other municipal infrastructure (buildings, internet, etc.).

As the choice of work and its implementation is still not advanced, we recommend immediately modifying the rules to make the construction of green infrastructure eligible in the current 2019-2023 program. It should be noted that such a modification of the rules for these two financial assistance programs does not require a budgetary addition.

Resolving the various issues associated with climate change and water sanitation poses major challenges that must be addressed according to best practices and scientific knowledge. Some of them are already well described in the documents produced by the MELCC jointly with the MAMH. We invite you to recognize them as part of your department's financial assistance programs.

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

A similar missive was sent to Catherine McKenna, Minister of Infrastructure and Communities, on December 2, 2020. Check out his response.

Photo: Scott Webb/Unsplash


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