Montreal, April 21, 2021
TRANSMISSION BY EMAIL
Mr. Benoit Charette, Minister
Ministry of the Environment and the Fight against Climate Change
Marie-Guyart Building
675 René-Lévesque Boulevard East, 30e stage
Quebec (Quebec) G1R 5V7
Subject: Projects to extend sewer networks causing an increase in discharges of untreated sewage
Minister,
The Rivières Foundation has been working for nearly 20 years to preserve, restore and enhance the natural and ecological character of rivers, as well as the quality of the water. We hereby wish to bring to your attention a problem regarding the authorizations given by the Ministry which cause an increase in the discharge of untreated wastewater into the receiving environment.
According to the Ministerial position on the application of Canada-wide overflow standards for municipal sewer systems, ? [?] no sewer network extension project likely to increase the frequency of combined, sanitary or pseudo-sanitary sewer overflows may be authorized without the applicant having provided for compensatory measures [?] ". However, the current administrative procedures have the effect that new sewer networks can be built, even if the downstream sewer network, which receives the additional water, does not have the capacity to convey it to the wastewater treatment plant without overflowing the route. Here's why.
Current procedure
The Ministry allows1the construction of network extensions even before the modifications to the downstream network are carried out. It gives municipalities three years to submit an action plan and five additional years to complete the necessary work. The action plan that developing municipalities must draw up must identify means so that overflows do not increase. And we're not talking here about a reduction in spills. The municipalities therefore have a maximum total period of eight years to compensate for the additional overflows which will have started from year 1.
For example, the City of Saint-Jérôme plans to develop huge residential projects, which will require the extension of the sewer network to serve some 4,200 new
residences in a first phase. Wastewater would then pass through structures whose waters already overflow in rainy and/or melting weather. This additional discharged water will then necessarily increase as soon as the first houses are connected if corrective measures have not already been taken.
In addition, the city of Saint-Jérôme's network has recorded a sustained increase in the number of overflows since 2011, as demonstrated by the interactive map of the Rivers Foundation. The number, duration and intensity peaked in 2019, the latest year of data currently available. The ministerial authorization process and the actions taken to date by the City have therefore not been sufficient to thwart the development of recent years.. The already too numerous spills have a certain environmental impact.
On the other hand, although the treatment plant generally has a good treatment performance, it is difficult to determine whether it would be as good if there were not so many overflows, and that all water was brought there. Its hydraulic capacity is exceeded each spring.
We reported this problem to your predecessor, Mrs. MarieChantal Chassé, in a letter addressed to him on December 6, 2018 (Ministry authorization for polluting real estate developments).
We therefore reiterate our request that your Ministry stop authorizing network extension projects that result in additional discharges of untreated wastewater, and this as long as the capacity of the infrastructures in question will not have the capacity to receive additional water. The current ministerial position, modeled on that of the federal government, is unfortunately limited to not increasing discharges instead of reducing them and, moreover, allocates a grace period of up to eight years to compensate for additional water inflows.
Hoping that this information will allow you to fully understand this issue, we remain available for any additional information.
Please accept, Minister, the expression of our best regards.
Alain Saladzius, P.Eng., FIC
President, Rivers Foundation
Photo: Anthony Jauneaud/Flickr
