March 15, 2024 Dear Sir…

March 15, 2024

Dear Sir/Madam:

RE: Engineering Department Comments on the ERO-019-7891, March 12,2024

Thank you for opportunity to comment on the proposed modifications/changes to the MCEA Document. Please find below comments from the various groups within the Engineering Department - City of Markham:
1- Clarifications on the transition period should be provided by MECP for current EA projects.
2- For completed EAs that municipalities are moving forward with detail design, if there are changes to the preferred alternatives, what is the process. I assume there won’t be an amendment requirement, but we need clarification on this.
3- The majority if not all our projects are proposed to be exempt from EA, I agree with MEA comment that municipalities need to have an established and consistent guideline to deal with environmental considerations and environmental agencies requirements.
4- Will the municipality be responsible for establishing and formalizing a process for evaluating the environmental impacts of infrastructure projects under the proposed regulations?
5- Since some municipal infrastructure, like roads, parking lots, and bridge reconstruction, would not be regulated under the EA Act under this proposal, how will dispute resolution be managed without a Part II order request? Does the City Council have the authority to make a final decision to approve an environmental assessment study?
6- In addition to the many efficiencies introduced in the new proposed MPAP Reg, we strongly support exempting the many projects listed in proposal from the MOAO and the Schedule B projects from the EA Act.
7- What happens if a project requires more than the proposed 120 days + 30 days pauses for evaluating options, establish mitigations and select the preferred design? What is the timeline for the Ministry to provide additional guidance on the proposed assessment process?
8- More clarifications is required regarding the diversion of “channel” from one catchment and receiving water course to another.
9- Clarification is required regarding the term “active” chemical or biological treatment used in the document.
10- Recharging groundwater is usually required as part of the water balance plan in most subdivisions and land development. If this recharge is considered artificial, then a threshold to “artificially recharge” surface water to the groundwater. We recommend a threshold larger than 100,000 l/d.

Thank you,
Soran Sito, Manager, Environmental Engineering
Engineering Department, City of Markham
101 Town Centre Boulevard Markham, Ontario L3R 9W3
Tel: (905) 477-7000 Fax: (905) 479-7773