Modernization of Municipal Wastewater Approvals Program Water Environment Association of Ontario – Utility Management Forum October 19, 2015

Purpose To provide an overview and update on the Modernization of Municipal Wastewater Approvals Program. 2

Wastewater Context Municipal Wastewater Approvals  There are approximately 470 existing municipal wastewater treatment plants in the province. The ministry currently issues approvals for each individual part of a sewage works (e. g. sewage treatment plant, pipes in the ground, pumping stations, etc.).  Each Environmental Compliance Approval lists separate unique requirements.  Municipalities are required to report a variety of wastewater-related data to several different ministry sources.  With aging wastewater infrastructure across Ontario, there is increased need for innovation and a streamlined approach to wastewater approvals. Need for Modernization  The goal of modernization of wastewater approvals is to provide greater transparency and create easier, more flexible and efficient approvals for municipalities.  As Climate Change adaptive and mitigation strategies continue to put pressure on municipal infrastructure due to events such as floods, there will be an increased need to ensure wastewater approvals address Climate Change challenges while also protecting the Great Lakes.  Currently, approvals are required as each part of a wastewater system is added, upgraded, or removed. Hundreds of separate approvals can exist for one municipal wastewater system. 3

Wastewater Modernization Considerations Government Priorities and Policy Direction Implications related to climate change will be taken into account as part of any decision-making process. This will include adaptation considerations for wastewater infrastructure approvals. Wastewater modernization will consider, and support where possible, government efforts in making the Great Lakes cleaner and safer. Stakeholder Consultation Commitment to engage and involve municipalities. This includes: municipal working group meetings; direct involvement in the development of the System-wide pilot project; and a broadly distributed survey. The development of a modernized approach to approvals could result in regulatory or policy changes but the project is not a policy review (e.g. no changes to existing effluent limits). Assessing and Leveraging Existing Resources The approach to wastewater will be developed with consideration to the existing Drinking Water Licensing system and will build on strategies such as one approval per system, financial plans, Sustainability Planning, Operational Flexibility and the role of Qualified Persons (which includes accreditation authorities). 4

Modernization Approach DocumentIdentifyExploreAssessSelectImplement 1. Document existing service delivery model 2. Identify areas for improvement 3. Explore ways to make the program more client-focussed, risk-based, and transparent while maintaining environmental standards ‒ Alternative service delivery options ‒ Increase program responsiveness and focus on impacts 4. Assess options against select criteria to determine viability ‒ Analyze and address risks 5. Select solution(s) to implement in everyday business 6. Implement ‒ Rollout of recommendations and leverage existing IT information where possible Stakeholder Engagement 5

Wastewater Approvals Modernization Overview Municipal wastewater has been identified as a candidate for modernization, using a risk-based, client-centered electronic service delivery model. Leverage existing IT infrastructure developed for the electronic Environmental Compliance Approval for municipal wastewater where possible. The intent is to modernize the approach to service delivery for municipal wastewater approvals while considering related ministry initiatives including: Ministry review and possible alignment with the Federal Wastewater Systems Effluent Regulations; Initiatives under development with the Environmental Innovations Branch (EIB) including: – System wide infrastructure approval pilot for London; and, – Southern Ontario Water Consortium/WaterTAP Lessons learned from the System-wide ECA pilot project: – Clearly defining the envelope for a ‘system’ since municipalities organized in first and second tier levels have two jurisdictional levels of responsibility: the first tier is responsible for the treatment, while the second tier is responsible for the collection system. – Opportunity for increased efficiencies including Limited Operational Flexibility. 6

Related Initiatives Limited Operational Flexibility: Allows municipalities to make certain changes to their wastewater systems without the need to come to the ministry for further approvals each time changes are required. Low Impact Development Project: The project, being led by EIB, aims to contribute to commitments made as part of Ontario’s Great Lakes Strategy, including developing guidance for municipalities and conservation authorities around reducing stormwater discharge to the Great Lakes. This project also aims to remove barriers to the development of innovative source control measures that reduce stormwater volume. The approach includes enhancing stormwater approvals with greater emphasis on effluent quality and quantity. This reduction in regulatory burden will have to align with the transformation of wastewater approvals initiative to ensure there is a streamlined wastewater approvals process for municipalities. System-Wide ECA Pilot: EIB is leading an initiative to pilot test an area-wide municipal ECA to enable long term performance of municipal stormwater systems to address subwatershed needs. This would apply to municipally owned stormwater infrastructure only; be bounded by subwatershed or municipal boundaries; and would shift ECA conditions from site-specific level (effluent) to system-level (tributary/receiver). Stormwater EASR: Most municipal, private, and industrial, commercial, institutional sewage works require an ECA in order to be constructed and operated. The goal of this project would be to determine the suitability of a self-registration type process within the modernized approvals service delivery model for some stormwater activities, for example new residential development. See Appendix A for a list of related projects 7

Project Scope at a Glance Current Phase – Policy and Program Review  Internal and external stakeholder engagement  Document and address linkages with other projects or branches within the ministry that have a wastewater interest to ensure process/policy integration  Continue functional model development to outline a modernized approach to wastewater  Host roundtables with various municipalities to review functional model and solicit feedback.  Finalize and post wastewater modernization options paper on Environmental Registry for public review and comment Program Development /Implementation o Propose legislative or regulatory changes if required. o IT component assessment - determine requirements associated with an electronic instrument o Guidance documents and training material Work Completed to Date Detailed understanding of current approvals processes required for wastewater treatment and collection systems, including municipal sanitary and stormwater in combined and separate sewage systems Comprehensive review of the System-wide pilot-project, Transfer of Review Program and prioritization of innovative technologies Completed municipal survey to gather information around possible service delivery models. 8

The ministry currently has processes and guidelines in place to help move applications through the system more quickly. Ministry encourages the regulated community to utilize these existing tools and resources. Existing best practices for a more efficient application review 1. Pre-submission meeting – provides information to MOECC and expectations can be made clear for the proponent on ministry requirements/expectations 2. Submission of a complete application – review and follow MOECC guidance documents to ensure information required is included in the submission (e.g., encourage use of complete submission checklist) 3. Ensure project is designed on a system-wide basis – approval can be granted for a system wide approach which minimizes minor amendments in the long term. 4. Innovative Wastewater Technologies – If you are using innovative technology – indicate this on the submission and it will change the application status to priority review. Supporting the Regulated Community 9

Appendix A: Summary of Related Projects *It is critical that modernization efforts align/ integrate with wastewater programs and initiatives underway in MOECC. Storm- water EASR Open for Business Modernization of Municipal Wastewater Approvals Provincial Response to Federal Wastewater Regulation System-wide Pilots Environ- mental Innovations Projects Municipal Infra- structure Strategy Municipal Drinking Water alignment Alignment with IT systems Low Impact Development Source Water Protection 10

Appendix B: Working Group Members Modernization of Approvals Branch Land and Water Policy Branch Environmental Innovations Branch Environmental Approvals Access and Service Integration Branch Environmental Approvals Branch Standards Development Branch Safe Drinking Water Branch Environmental Monitoring and Reporting Branch 11