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Letter to the Ministry of the Environment and the Fight against Climate Change: Planned discharges of municipal wastewater

Pollution de l'eau

Montreal, November 12, 2018

Madame MarieChantal Chassé, 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: Planned municipal wastewater discharges

Madam Minister,

We would first like to congratulate you on your appointment. We assure you of the full availability of the Fondation Rivières team to collaborate with your ministry to advance environmental protection. During our meeting at the SCABRIC anniversary evening, I was able to particularly appreciate your attachment to the water issue which was the subject of your first speech as an MP.

This week, the city of Longueuil will carry out a planned discharge of wastewater from part of its municipal sewer network, for a maximum duration estimated at 8 days. This situation is caused by the completion of replacement work on a main pipe located in the bed of the St. Lawrence. The explanations provided by the City at a press conference appear valid at first glance. However, it is clear that additional efforts must be made to limit these spills, mainly at the government level.

The planned spill in the city of Montreal in 2015, which we studied carefully, made it possible to chart a course in the measures to be taken by municipal institutions. Following the other spills that have taken place, and now ahead of that in the city of Longueuil, we encourage you to implement better control of these. The population must be reassured once and for all about the efforts made to constrain, limit and regulate these episodes of spills.

Thus, in light of the events in Montreal, Gatineau, Quebec and Longueuil, we recommend that the Department assume better preventive control of such events by:

  1. By designating 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.
  2. By producing a list of activities which the operator must carry out, depending on the importance of the spill. These activities must be relevant and accompanied by precise and measurable objectives. Some activities may turn out to be superfluous if there is a lack of supervision. We currently note, in the Longueuil file, that it is planned to sample the waters of the St. Lawrence in 20 locations before/during/after the event while some may not be affected by the event, shoreline inspection 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, did not seem to have been identified. This is why we want efforts and budgets to be allocated to obtain concrete results.
  3. By identifying 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. .
  4. By requiring the production of an event report at the end of the activity requesting from the operator 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.
  5. By amending 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.
  6. By introducing 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, which would correspond in the case of Longueuil to 162,000 $ for the 162,000 cubic meters to be spilled. The operator could also, at his option, pay an increased fee for additional infrastructure work which would improve the performance of the sanitation system. The fee should, in this case, be increased sufficiently so that it remains an incentive to reduce the volume spilled.

Thanking you for your attention to this, we remain available for any additional information.
Please accept, Madam Minister, the expression of our distinguished feelings.

Alain Saladzius, P.Eng., FIC
President, Fondation Rivières

Photo: Dmitry Bukhantsov/Unsplash


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