Montreal, September 11, 2020
TRANSMISSION BY EMAIL
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: Municipal wastewater spills
Minister,
The City of Trois-Rivières is currently forced to discharge almost all of its wastewater into the Saint-Maurice River and the Saint-Laurent River following breaks in the main wastewater pipe. Despite its efforts, it is difficult to predict when the situation will be restored due to fears about the state of the pipe or the pumping system.
We were stunned to learn that the Ministry would have accepted that the City would not install floating barriers to capture solids that would otherwise end up in the river. We were informed that the decision was made based on drone images taken from the air.
How then can we explain that other cities such as Montreal in 2015 and Longueuil in 2018 had installed such barriers and sent teams to collect waste? How does the Ministry justify its decision?
This file reminds us of the importance of there being clear government guidelines for such situations, whether planned or accidental.
In November 2018 we wrote on the subject to Minister MarieChantal Chassé to recommend the measures that seem most appropriate to us to limit pollution during such events. These recommendations followed the events in Montreal and Longueuil. Here they are :
- Designate a ministerial manager for the technical evaluation and monitoring of such events. To our knowledge, it is currently the regional directorates which receive and evaluate the different situations. However, a technical assessment requires specific knowledge in civil engineering, network management and water treatment where applicable. This manager would also have the mandate to develop and maintain the expertise acquired by closely monitoring events. Relevant information should be posted online.
- Produce a list of activities which the operator must carry out, depending on the size of the spill and the location. These activities must be relevant and accompanied by precise and measurable objectives. We thus noticed, in the Longueuil file, that it is planned to carry out sampling of the waters of the St. Lawrence in 20 places before/during/after the event, even in certain places which would not be affected by the event, an inspection of the banks over an undefined distance and method before/during/after, a request to reduce water consumption by residents, etc. All this while specific sources of pollution, coming from industries, were not identified. This is why we want efforts to aim for concrete results.
- Identify mandatory measures that municipalities should respect, such as the installation of temporary works or treatment, the use of a quote encouraging contractors to carry out the work quickly, the identification of industrial or hospital discharges to be managed in a particular way, etc. .
- Require the production of an event report asking the operator for a report on the activities and measures carried out. This report should contain a recommendations section in order to analyze, develop, make known to the public and share between the different municipal authorities the experiences acquired during each event.
- Amend article 15 of the regulation on municipal sanitation works in order to make it compulsory to obtain ministerial authorization before carrying out a spill. This authorization would be issued subject to the accuracy of the information submitted.
- Introduce a fee on the volume of untreated wastewater discharged so that municipalities are encouraged to take serious measures to minimize it. This fee should be paid to the Green Fund, for water protection. It could be of the order of 1$/cubic meter spilled. This fee should, in this case, be sufficient to remain an incentive to reduce the volume spilled.
The frequency of such spill events encourages action to be taken to exercise better preventive control. The population must be reassured about the efforts made to constrain, limit and regulate these episodes of spills.
Thanking you for your attention to this, we remain available for any additional information.
Please accept, Mr. Minister, the expression of our distinguished feelings.
Alain Saladzius, P.Eng., FIC
President, Fondation Rivières
Photo: Zeynep Sumer/Unsplash
