From the Ministry of Environment, Conservation and Parks - Additional Information for the Designation Request of the Erin Wastewater Treatment Plant Project - May 7, 2021

Hi Christine,

Thanks for your patience as we draft up a response to IAAC’s questions regarding the proposed Town of Erin WWTP.  Please see MECP’s response below to IAAC’s questions.

Have a good weekend.

IAAC Questions

• We understand the ECA will require monitoring of temperature and chlorides, but will not set regulatory limits on those variables. Will this feed into an adaptive management framework?
• Will the ECA include a threshold beyond which changes to temperature and chloride levels are deemed unacceptable?
• Will the ECA include specific contingency measures to be implemented if those thresholds are reached, to return to acceptable levels?

Proposed response:

• MECP’s permissions framework allows for site specific and case by case considerations to be included into Environmental Compliance Approvals (ECA), which includes the ability to include an adaptive management framework with monitoring and thresholds for certain parameters which would trigger further actions (i.e. cause analysis, remedial measures, notification, impact assessments).
• MECP’s Environmental Permissions Branch works closely with the Regional Technical Support staff on these case by case considerations to address local issues effectively and with input from numerous experts. These case by case considerations can include the monitoring of chlorides and temperatures of effluent or stream temperatures to ensure that the establishment of the plant will not cause serious environmental harm in the receiving waterbody.
  • For the Town of Erin’s ECA, monitoring of temperature and chloride, amongst other parameters will feed into an adaptive management framework where contingency measures will be implemented based on trigger concentrations of the parameters of concern.  It has been decided in the Class EA that temperature, chloride and a few other parameters will be monitored in the influent, effluent and in the receiver and trigger criteria will be developed based on concentrations observed in the receiver to activate a contingency plan.
• MECP also has a well established regulatory framework and compliance program for municipal treatment plants, including regular inspections by Provincial Officer’s trained in municipal systems, who also play a role in reviewing the monitoring programs and reports required by ECA’s either through annual monitoring reports or the on-site inspections.
  • If it is found that a facility is not complying with the requirements of the ECA, the Officers have a well prescribed compliance framework to bring the facility into compliance, which can include voluntary compliance or, when required, Provincial Officer’s Orders and referral for prosecution under the Ontario Water Resources Act or the Environmental Protection Act.
  • Likewise, if a facility’s operations are found to be causing an adverse effect on the natural environment, the Officers powers under the applicable regulation can be applied to require the facility take actions to mitigate or ameliorate the adverse effects.

Andrew Evers (he/him) | A/Manager  

Environmental Assessment Services 

Environmental Assessment Branch  

Ontario Ministry of the Environment, Conservation and Parks
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