Montreal, December 6, 2018
TRANSMISSION BY EMAIL
Madame MarieChantal Chassé, 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: Authorization from the Ministry for polluting real estate developments
Madam Minister,
The Fondation Rivières has been working for 15 years to preserve, restore and enhance the natural character of rivers, as well as the quality of the water. We are constantly looking for measures that can reduce wastewater pollution.
We hereby wish to offer you the beginnings of a solution to the increase observed in the number of wastewater overflows in waterways, these having increased from 43,000 in 2013 to 62,000 in 2017. Beyond Due to the fact that more precise recording of overflows has been carried out by municipalities since 2015, there is a real increase in their number, caused by laxity in the procedures and decisions taken in the past at the Ministry.
Thus, current procedures allow new sewer networks carrying additional wastewater to be built, without even ensuring that the downstream sewer network, which must receive this water, has sufficient capacity. . This way of doing things causes more numerous and larger overflows in rainy weather, since the network is not enough to transport the water.
Current procedures
The Ministry allows immediate construction of network extensions and gives municipalities a period of three years to submit an action plan. This plan must identify ways so that overflows do not increase. Without even aiming for their reduction. Municipalities then have five years to carry out the actions, which brings to eight years the maximum period allowed during which additional overflows will occur.
Procedures to consider
In our opinion, no extension of the sewer network should be carried out until the capacity of the sanitation works is sufficient. Section 22 of the Environment Quality Act, and more specifically sections 25 and 26, allow you to require such measures.
As a factual example, the city of Mirabel is currently building, in the Saint-Canut sector along the Rivière du Nord, an extension of the sewer network to serve some 185 new housing units.
However, it is known by City officials, and by the mandated engineering office, that the Saint-Canut sewer network already had insufficient capacity before the current extension. A note from the City manager, dated January 8, 2015 (Appendix A), explicitly mentioned that “the City will have to carry out network work in order to reduce capture and infiltration” and thus reduce overflows at the water station. purification. The water will also have to pass through another overflow structure which will inevitably pollute in times of rain and melting.
This project is, moreover, located largely in a humid environment and in a flood zone.
It should be noted that no person from the Ministry authorized this work: it is governed by the new accelerated procedure requiring that a simple declaration of conformity from an engineer is sufficient to undertake the work.
In summary, the Department's direction should aim to reduce overflows. This currently limits itself to not increasing them, and, in addition, allows a grace period of up to eight years to correct new spills.
We hope that this information will help you understand this particular problem and provide sufficient motivation to resolve it.
We remain available for any further information.
Please accept, Madam Minister, the expression of our distinguished feelings.
Alain Saladzius, P.Eng., FIC
President, Fondation Rivières
Photo: Ross Sokolovsky/Unsplash
