Montreal, April 15, 2021
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: Pollution caused by waste snow – Request for review of standards and procedures
Minister,
Images captured by citizens over the past few days in Longueuil and broadcast on the social networks show polluted water leaving a City settling basin. The outfall flows directly into a stream of clear water, in the Tremblay woodland, an important wildlife refuge for the chorus frog in Quebec. Dead frogs and fish were observed there and complete silence reigned while normally the cry of tree frogs is heard in the middle of the spring season.
In 2018 we had already observed a worrying situation along the Magog River and, after analysis, we carried complaint to the Ministry of the Environment in July 2018. The results showed major exceedances of suspended solids. A table of Guide to the development of snow disposal sites and implementation of the Regulation respecting snow disposal sites mentions that it is sufficient to respect one or other of the criteria and not all of the criteria, to comply with the requirements. This is too lax a framework. The Ministry unfortunately limited itself to monitoring the operation with the City of Magog, without however tightening the environmental standards of the site.
However, it is precisely the weakness of the standards which leads to the intense pollution observed in Longueuil. The design criteria must be tightened for certain sites to take into account the fragility of the receiving environment and an inspection, with adequate sampling, must be carried out at critical times and not randomly. Simple settling basins, which are also too small, only allow the main coarse materials to be removed, such as sand and plastic waste. Many other contaminants (chlorides, salts, metals, oils and greases, microplastics, etc.) from contaminated snow escape into watercourses. Such inputs also suddenly modify the physicochemical conditions (e.g. pH, conductivity, dissolved oxygen, temperature) and pose risks of sudden mortality for several aquatic organisms.
The standards are the same everywhere, nonsense, when they should be based on environmental objectives for discharges specific to the receiving watercourse, as is scrupulously done for all municipal wastewater treatment systems.
Our other recommendations are summarized as follows:
- Establish a list of sites and their discharge points, make it public on the Water Knowledge Portal;
- Request changes to deficient facilities, or their management;
- Require that discharges be non-toxic and ensure that the values of pH, conductivity, temperature and dissolved oxygen within the receiving environments are maintained within a range that does not threaten the immediate survival of aquatic organisms (e.g. fish mortalities were observed in Longueuil);
- Review the standards taking into account periods of intensive melting and the effect of climate change.
We ultimately request that the authorizations issued be reviewed so that the modifications made to the Guide in September 2020 are integrated.
We remain available for any additional information.
Please accept, Mr. Minister, the expression of our distinguished greetings.
Alain Saladzius, P.Eng., FIC
President, Fondation Rivières
Photo: Joy Real/Unsplash
