Montreal, September 18, 2019
TRANSMISSION BY EMAIL
Mrs. Nathalie Provost, Director
General Directorate of Estrie and Montérégie
Ministry of the Environment and the Fight against Climate Change
201, Place Charles-Le Moyne, 2nd floor
Longueuil (Quebec) J4K 2T5
Subject: City of Varennes – Authorization from the Ministry leading to polluting real estate developments
Madam Director,
The Fondation Rivières has been working for 17 years to preserve, restore and enhance the natural character of rivers, as well as the quality of the water.
A committee of citizens from the city of Varennes informed us in August that the city had taken steps to allow the construction of a housing project in Saint-Charles Park, on the banks of the Saint-Charles River.
On the one hand, we consider that this project would destroy a significant part of the quality ecosystem which is also mentioned in detail at the entrance to the park. Montérégie must preserve the few rare natural environments that still exist and we consider that an in-depth examination of this issue should be carried out before beginning such work. They did not receive the support of the surrounding population. This project is also located in a landslide sector according to the MRC mapping and a portion also appears to be located in a humid environment.
On the other hand, we found that the existing wastewater treatment system does not allow all the additional wastewater to be transported during rainy times to the treatment plant. In fact, pumping stations No. 1 and 2 of the network do not have sufficient capacity and are already frequently overflowing. There were more than 100 overflows across the City in 2017 and 2018, a significant increase from previous years.
The hydraulic capacity of the treatment plant is also significantly exceeded. Unfortunately, current Ministry of the Environment procedures allow new sewer networks, carrying additional wastewater, to be built without the existing system even having sufficient capacity to transport it for treatment. This way of doing things causes more numerous and larger overflows in rainy weather, since the network is already not enough to transport the water.
The Ministry allows the construction of network extensions and allows municipalities a period of three years to submit an action plan aimed at limiting overflows to those currently existing. Municipalities are not asked to reduce overflows. Another maximum period of five years is then allocated to them to carry out the work, which brings to eight years the maximum period allowed during which additional overflows occur.
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 such measures to be required.
Concerning the town of Varennes, work in progress at the Municipality's pumping station mainly aims to replace pipes. They would not allow its capacity to be significantly increased by a single reduction in flow friction. The existing pumps are retained.
We therefore ask that the regulations be applied so that there is no increase in pollution caused by the increase in overflows and the insufficient capacity of the treatment plant.
We remain available for any further information.
Please accept, Madam Director, the expression of our distinguished feelings.
Alain Saladzius, P.Eng., FIC
President, Fondation Rivières
Photo: Cristi Goia/Unsplash