Environment Canada has proposed the enactment of a Wastewater Systems Effluent Regulation to address the ongoing and serious problems caused by sewage pollution in Canadian waters. The most significant aspect of the proposed change is that the regulation would decriminalize sewage discharges that are currently illegal under the Fisheries Act. The regulation would allow wastewater systems to discharge substances in quantities and locations that would otherwise violate s.36(3), one of the main pollution prevention provisions of that Act, and one of the strongest sources of environmental protection in Canada.
Due to the national significance of this issue, Lake Ontario Waterkeeper wrote a joint comment on the proposed regulation with Fraser Riverkeeper and Ottawa Riverkeeper. Based on our organizations’ considerable experience with sewage policy and law, we reviewed the proposed regulation and made 16 specific recommendations to Environment Canada.
We emphasized the importance of enforcing Canada’s environmental laws while achieving real solutions to sewage pollution. We submit that Environment Canada can achieve these dual purposes by preserving the applicability of section 36(3) of the Fisheries Act, while also providing detailed requirements for wastewater systems operators that focus on transparency, access to information, enforcement, and solutions for the full array of pollutants in sewage.
Canada must improve wastewater systems regulation without decriminalizing sewage pollution. Ottawa Riverkeeper, Fraser Riverkeeper, and Lake Ontario Waterkeeper submit that to effectively address sewage pollution in Canada, section 36(3) should apply in tandem with a regulation that addresses the following issues:
A strong regulation would address substances of emerging concern found in wastewater effluent rather than focusing solely on traditional contaminants.
A strong regulation would set enforceable targets for the reduction and elimination of combined sewer overflows (CSOs) and sanitary sewer overflows (SSOs).
A strong regulation would include a detailed, daily administrative fine schedule for any violation of its conditions, as well as an allocation of administrative power to an appropriate governmental agency to assess and collect any fines.
A strong regulation would include improved mechanisms for the public to access compliance and monitoring records as well as revised document retention schedules.
Read our full submission here.
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