I support the inclusion of…

I support the inclusion of low-profile leaching chambers into the OBC.

I do not support the inclusion of CTD systems as they have been proposed.
The text in 8.7.9.1.(4)(b) proposes to require an additional sand layer of 300 mm below CTD systems. This is contrary to all CTD BMEC authorizations, which means contradictory to the manner in which these systems have been designed and installed for many years in Ontario. Has the proposer provided any technical support for this new requirement? Independent third-party testing of all BMEC-authorized CTD systems has proven that the treatment of TSS and BOD5 is well within required parameters with the use of 300 mm of sand below the proprietary media.

Installation of CTD system with an additional 300 mm of sand doubles the amount of sand required below the manufactured media. Our calculations indicate that this will result in an increase of more than 40% in the cost of material, including delivery-related costs, compared to how a BMEC-authorized CTD system is installed today. Labor costs will be impacted as well. We submit that the proponent’s claim that “No cost impact is expected” is unfounded on its face.
The proposed language in 8.7.9.1.(4)(d) is a significant change in the manner in which CTD systems are designed and installed under their BMEC authorizations. Under existing Code language, Type A treatment units need a 600 mm vertical separation over only the stone bed area (Q/B), and the rest of the QT/400 area is not required to provide any vertical separation. As proposed, the Code will require CTD systems to have this 600 mm over the entire basal area (QT/400). This is problematical in a number of ways: it does not mate with the manner in which CTD systems are designed and installed under their BMEC authorizations; it will be very difficult to achieve on many sites; and if available for design on a given site will require a significant amount of additional imported material – which results in significantly increased costs to the property owner.