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, boulevard René-Lévesque Est, 30e floor
Quebec (Quebec) G1R 5V7
Subject: Sewer network extension projects causing an increase in untreated wastewater discharges
Minister,
The Fondation Rivières has been working for almost 20 years to preserve, restore and enhance the natural and ecological character of rivers, as well as water quality. We hereby wish to bring to your attention a problem regarding the authorizations given by the Ministry which cause an increase in discharges of untreated wastewater into the receiving environment.
According to the Ministerial Position on the application of pan-Canadian standards for overflows from municipal sewer networks, “ […] 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, 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 transport it to the treatment plant without overflowing onto the route. Here's why.
Current procedure
The Ministry allows1the construction of network extensions even before modifications to the downstream network are made. It grants municipalities three years to submit an action plan and five additional years to carry out the necessary work. The action plan that developing municipalities must develop must identify ways to ensure that overflows do not increase. And we're not talking about a reduction in spills here. Municipalities therefore have a maximum total period of eight years to compensate for the additional overflows which will have started in 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. The wastewater would then pass through structures whose water already overflows during rain and/or melting. This additional water discharged will then necessarily increase as soon as the first houses are connected if corrective measures have not already been carried out.
In addition, the city of Saint-Jérôme network has recorded a sustained increase in the number of overflows since 2011, as demonstrated by the interactive map of the Fondation Rivières. 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.. Spills that are already too numerous have a definite environmental impact.
On the other hand, although the treatment plant generally has good treatment performance, it is difficult to determine whether this would be as good if there were not so many overflows, and all the water was piped there. Its hydraulic capacity is exceeded every spring.
We had reported this problem to your predecessor, Madame MarieChantal Chassé, in a letter addressed to him on December 6, 2018 (Authorization from the Ministry for polluting real estate developments).
We therefore reiterate our request that your Ministry stop authorizing network extension projects which result in additional discharges of untreated wastewater, and this as long as the capacity of the infrastructures in question does not have the capacity to receive additional water. The current ministerial position, modeled on that of the federal government, unfortunately limits itself to not increasing spills instead of reducing them and, moreover, allows a grace period of up to eight years to compensate for additional water supplies.
Hoping that this information will allow you to fully understand this issue, 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: Anthony Jauneaud/Flickr
