ORA submits that Schedule 5 of Bill 66 is a regressive, unwarranted and potentially risky proposal that is inconsistent with the public interest and does not adequately safeguard the health and safety of Ontarians. Does the MECP really want to set the stage for another Grassy Narrows mercury disaster? Instead, the MECP should be focusing on improving the TRA and its regulations to better protect communities.
The government’s proposed P2 Plans on triclosan are inadequate to address its continued use in consumer products and presence in the environment. Rather, the government’s proposal will ensure the on-going use of triclosan in consumer products. Unless there is a prohibition of triclosan in personal care products and other consumer products, the substance will continue to be released into the aquatic environment, including the Great Lakes and waterbodies across Canada, creating unnecessary risks to aquatic and terrestrial species. The US Food and Drug Administration (FDA) requested data demonstrating that consumer products containing antimicrobial ingredients are effective in their stated purpose – to prevent infections. The FDA did not receive such data and therefore passed its final decision to prohibit the use of triclosan and triclocarban along with 18 other antimicrobial chemicals in consumer antiseptic wash products that are rinsed off after use, including hand washes and body washes, starting in September 2017.20 The State of Minnesota passed a regulation to prohibit the use of triclosan in sanitizing or hand and body cleansing products starting in January 1, 2017.21 If regulatory measures to prohibit the use of triclosan in consumer products are not taken in Canada, it may become a dumping ground for products containing triclosan and other antimicrobial chemicals that are subject to these regulations. Continue reading
While the focus of this submission is on urban stormwater in the draft plans and regulation, we have included observations and recommendations related to complementary freshwater and natural heritage issues and other policy needs and opportunities. Ontario needs to transform the way rain is managed on the urban landscape and one important step forward is changing our land use planning framework to address stormwater management.
The VRS clearly recognizes the serious concerns of the SLCSG, however; we urge caution in the City’s approach to mitigating the algae issue. VRS agrees that action must be taken by the City of Sudbury to resolve the long-standing issue of algae blooms once and for all; however, we differ in the recommended approach.
Water is a renewable, but finite resource. Climate change will impose some of its greatest effects on both the long-term availability and the short-term variability of water resources in many regions of this province. These effects have already been felt in many areas through increased frequency and magnitude of droughts, extreme rain and flooding, duration of accumulated snowpack, and changes in soil moisture and runoff. These effects have created havoc on municipal waste water treatment facilities that were never built with climate change in mind.
The City of Sudbury recently passed a unanimous Council Motion to implement a Sewage Bypass Alert, whereby the public will be informed in real time when there is a sewage bypass or spill at any of their 13 wastewater treatment facilities. Sewage bypasses are becoming more frequent due to the extreme rain events associated with climate change, and this contaminated freshwater could pose a risk to residents who take their drinking water or swim downstream of these facilities. Ontario Rivers Alliance also made a request to the Ministry of Environment and Climate Change, in October of 2014, to incorporate this important public safety measure into policy throughout the province. All Sewage Bypass Alerts will be posted on the City of Greater Sudbury website here.
There are numerous Waste Water Treatment Facilities (WWTF) across the province releasing treated, untreated and partially treated effluent into streams and rivers that run through large and small communities that also rely on river water for their public and private drinking water and general household uses. Increasing incidences of extreme rain events are making overflow and bypass of sewage a common and necessary strategy for many WWTF’s in Ontario. ORA understand that in the short-term this is done in order to avoid back-ups into their treatment facilities as well as individual residences; however, in the long-term there must be a province-wide strategy to avoid untreated and partially treated releases of sewage effluent into the environment.
For example, in the Greater City of Sudbury, there are nine wastewater treatment facilities releasing treated, partially treated and untreated effluent into the Vermilion River watershed. On 13 and 14 April, 262,999 m3, and again on 15 May, 59,778 m3, of partially treated sewage was released into the Vermilion River and its connecting lakes. During 2013, 427,235 m3 of partially treated sewage was released through bypass and overflow from one Sudbury facility alone. Many residences rely on the Vermilion River for their drinking water and general household water usage, and public health and safety is placed at risk if untreated and/or partially treated sewage is present in their private water intakes or children and adults are swimming in affected river water. There must be a standardized policy in place that sets out when and how the public is to be alerted when their water supply has been compromised.
ORA is confident that this is not an isolated problem, as very few WWTF were made to handle the extreme rain events that are becoming more and more prevalent with the effects of Climate Change. The cumulative effects of numerous bypass and overflow events on the creeks and rivers feeding the Great Lakes also contribute to the prevalence of Cyanobacteria blooms on area lakes, as well as the Great Lakes.
The City of Kingston has a great model for other municipalities to follow through their Sewage Alert System and on-line Bypass Log which reports bypass and overflow incidents on their website. Facebook and Twitter communications should also be utilized in an effective strategy.
The bottom line is that local downstream residents need to be notified at the earliest possible moment of any potential risk to their water source and/or their health and safety. When an overflow or bypass is reported to the MOECC and local health unit, at the same time the public must also be notified through an alert so that precautions can be taken.
The City of Sudbury is now in the process of implementing this policy; however, we are awaiting a decision by MOECC on whether this policy will be implemented throughout all of Ontario.
This is our new National Anthem!! Thank you Neil!!
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