Sewage Treatment: Not Good Enough

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Big, blue and beautiful, the Great Lakes are our unmistakeable signposts of home on any map of the world. They are our natural heritage, our playground and the source of much of our drinking water. When Ontario kids get their first chance to swim in a lake, there is a good likelihood it will be in one of the Great Lakes. Sadly, the Great Lakes are also blighted by areas where water quality has been degraded for generations.

However, we could achieve real – even dramatic – improvements in the water quality of our Great Lakes by cleaning up our municipal wastewater effluents. It has been done before. The Americans were able to achieve remarkable clean-ups of their lakes and rivers in the 1980s and 1990s by strengthening their Clean Water Act and by setting clear standards for municipal wastewater. In Ontario we already have communities such as Guelph showing great potential to produce very high quality wastewater effluent (see Success Story: Guelph Optimizes its Sewage Treatment). So the precedents and technology are available, ready for us to apply, and we have the ability to restore our Great Lakes to truly “great” status, in our generation.

Municipal wastewater effluents – even treated effluents – place very heavy burdens on our lakes and rivers. They are key contributing pressures to water quality deterioration, along with other pressures, such as agricultural and urban run-off and industrial discharges. Our beaches are often closed due to high bacterial levels; fish and other aquatic organisms suffer acute and chronic toxicity from ammonia or residual chlorine; and excessive nutrients produce soupy algal growth, fouling our shorelines. These and other kinds of chronic habitat degradation are, to a considerable degree, consequences of the pollutants found in municipal wastewater discharges. Harmful effects can often be observed for 10 to 20 kilometres downstream from a municipal effluent discharge, and some parts of ecosystems may not recover for 20 to100 kilometres.

All waterways are vulnerable to deterioration from municipal wastewater, but the most densely populated parts of the Great Lakes basin – Lake Ontario, Lake Erie and the Ottawa River – receive the lion’s share (about 85 per cent) of Ontario’s effluent. Environment Canada has estimated that 15 per cent of river and lake areas in the Great Lakes basin have been damaged by effluents from municipal wastewater treatment plants. As in the case of Ottawa (see Ottawa’s Overflow Woes), sewer overflows and sewage spills are often to blame, but aging, inadequate treatment capacity is also a problem at many locations.

Long-standing concerns of the ECO

Past annual reports of the ECO have repeatedly highlighted Ontario’s chronic problems with sewage. Our 2002/2003 Annual Report outlined the environmental impacts, and critiqued the scanty information available to Ontarians on the performance of their sewage systems. The Ministry of the Environment (MOE), which regulates wastewater effluents, has not published an overview of basic performance parameters, such as pollution loadings and overall compliance rates, since 1993.

The ECO revisited this issue in subsequent years and asked the ministry for updates. MOE responded in 2004, 2005 and again in 2006, that it was deferring important monitoring and reporting work, pending the development of a national strategy under the umbrella of the Canadian Council of Ministers of the Environment (CCME) to manage municipal wastewater effluent.

What the new CCME strategy will - and won’t – do

The CCME Strategy and accompanying new Fisheries Act regulations will set minimum effluent standards, achievable through normal secondary wastewater treatment. Individual provinces and territories are free to set stronger standards if they choose.

The CCME Strategy was slow in coming, but in February 2009 it was finally signed by the Environment Ministers of most provinces, including Ontario. Some parts of this non-binding strategy will be given the weight of law, as the federal government plans to finalize regulations under the federal Fisheries Act to harmonize effluent standards for a short list of conventional pollutants. Draft federal Wastewater Systems Effluent Regulations were released in March 2010. Implementing other parts of the strategy will be left to each province, including sections dealing with sewer overflows and managing other problematic pollutants in effluents.

Phase-in of the new rules under the Fisheries Act will be very leisurely; wastewater systems posing a “high risk” will be required to comply within 10 years, while “medium” or “low” risk systems will be given 20 to 30 years. For some parts of Canada, where both small and large communities still rely on primary treatment, the new standards will at least set a badly needed minimum, and will trigger upgrades in the fullness of time. In 2004, almost a quarter of the Canadian population connected to sewers were still relying on primary sewage treatment. A further three per cent had no wastewater treatment at all. By contrast, in the United States, secondary treatment has been the minimum acceptable technology for 38 years, since the enactment of the Clean Water Act in 1972.

Status Quo for Ontario?

It is very doubtful whether the set of new national standards will serve as a force for change in Ontario. As seen in the table below, many of Ontario’s municipal wastewater plants have already been operating for 25 years under effluent guidelines that are identical or remarkably similar to the proposed new national standards.

Comparison of municipal wastewater effluent standards (after secondary treatment)

Parameter MOE effluent guidelines

(since 1983)

Proposed Fisheries Act regulations

(January 2010)

U.S. EPA requirements

(since 1977)

Biochemical oxygen demand (BOD5) (mg/L) averaged over 5 days < 25 < 25 25
Total suspended solids (TSS) (mg/L) < 25 < 25 30
Phosphorus (mg/L) 1
E. coli < 200 counts/100mL
Total residual chlorine (mg/L) < 0.02
Un-ionized ammonia (mg/L) < 1.25
pH 6-9
Removal requirements 85% BOD5 & TSS

The new national standards set no limit at all on phosphorus. However, many Ontario wastewater treatment plants have long operated under phosphorus limits, reflecting in part Ontario’s commitments under the 1983 bi-national Great Lakes Water Quality Agreement. In April 2010, MOE advised ECO that the new national standards will not be game changing:

Ontario is well-positioned to meet the requirements of the federal regulation for treatment facilities…It is anticipated that a manageable number of small systems in Ontario may have difficulty complying for various reasons, however, they would have 20-30 years to improve their situation…. It must also be noted that through MOE’s issuance of certificates of approval, many plants in Ontario go beyond the CCME requirements.

Ontario still has eight primary treatment plants (including Cornwall, Owen Sound and Brockville), serving about 140,000 people in total; however, MOE is confident that funding is in place to upgrade all these plants by 2015. Overall, this sounds like reassuring news. Ontario’s wastewater plants tend to be in better shape than many in other provinces. But it does not answer a core question: is there a need for Ontario’s municipal wastewater facilities to go beyond CCME’s standards? To answer this question, we need information in three key areas.

Question #1: What are Great Lakes trends telling us?

We do have some relevant indicators, and they are troubling. The 2009 binational State of the Great Lakes report describes the phosphorus situation as “poor” in nearshore areas of Lake Ontario, Lake Erie and Lake Huron, and calls for target phosphorus loads for major municipal sewage treatment plants. High phosphorus levels are contributing to increased algal fouling of shorelines over wide areas of eastern Lake Erie, areas of Lake Ontario and patches around Lake Huron. The quality of beaches in Ontario is “poor” and “deteriorating” over time not just for Lake Erie, but also for Lake Ontario. For 2006-07, only a quarter of beaches on our side of Lake Ontario were clean enough for swimming over 95 per cent of the beach season. Beaches on the U.S. side of the lake were much cleaner.

Question #2: What are pollution loading trends telling us?

We need to know the impacts of Ontario’s population growth on wastewater loadings, (i.e., the total amount of pollutants discharged per year). Between 1991 and 2007, Ontario’s population increased by 26 per cent. Projections anticipate the population will grow by a further 38 per cent between 2008 to 2036, adding another 4.9 million people. Simple arithmetic dictates that as wastewater volumes increase with population, the effluent concentrations of key pollutants should be steadily ratcheted downward, to avoid increasing overall loadings to our waterways.

Is MOE tightening pollutant concentration limits to levels low enough to keep overall loadings from growing? The evidence suggests not. MOE’s effluent guidelines have remained the same since 1981 (see table), and there is no formal review mechanism to tighten the guidelines. MOE can and does set more stringent effluent limits for specific plants on a case-by-case basis, and some plants are meeting very tough limits. But it seems, with the notable exception of Lake Simcoe (see A Watershed Moment? Ontario introduces the Lake Simcoe Protection Plan), that the ministry has not been regulating, calculating, reporting or even thinking in terms of overall loadings of pollutants to waterways since the early 1990s. It is frankly surprising for MOE, entrusted with the quality of our waterways, to be in the dark on such a fundamental parameter.

At one time, the ministry did recognize the importance of loadings. In 1993, MOE last reported five-year province-wide trends for wastewater flows and loadings of two key indicator pollutants: biological oxygen demand (BOD) and suspended solids. The trends were steadily upwards. Since 1993, given population growth and the lack of tighter standards, the trends have probably continued inexorably upwards, but the ministry has not been crunching the numbers to find out. Other regulatory agencies see a need for this work. For example, in the 2009 State of the Great Lakes Report, Environment Canada and the U.S. EPA noted that loadings are a necessary indicator of Great Lakes health, and recommended a push on preparing trend analyses and making them public.

Question #3: What is MOE already planning to do?

The ministry has no published strategy for discussion. However, MOE seems to have two areas of focus:

  • funding support for upgrades at selected wastewater plants; and
  • meeting the CCME strategy commitments.

Much of the recent funding has flowed through the federal-provincial Infrastructure Stimulus Fund, and priorities have evidently been driven by Great Lakes water quality concerns. Since 2007, Ontario has committed over $653 million to municipal wastewater infrastructure upgrades in the Great Lakes basin, including up to $100 million towards the upgrade of Hamilton’s wastewater treatment plant. Hamilton Harbour has long been listed as an Area of Concern on the Great Lakes, and this upgrade to tertiary treatment is part of efforts to have Hamilton “delisted.” The commitment under the to upgrade remaining primary sewage treatment plants has clearly also been an important factor in grant decisions.

To meet the CCME strategy commitments, MOE is gearing up for new effluent monitoring and public reporting requirements for wastewater facilities, proposed to take effect in 2012. The ministry is also in discussions with the federal government to harmonize the regulatory framework.

The CCME strategy also sets some targets for dealing with combined sewer overflows, but MOE believes its existing policy is already adequate. MOE has also begun a voluntary pilot project with ten municipalities, addressing bypasses and overflows from combined and sanitary sewers. The intent is to try out proposed monitoring and reporting requirements, and plans for minimizing discharges of untreated sewage. Once federal reporting rules are negotiated and finalized, the ministry also hopes to accommodate electronic data submission by all municipalities. An antiquated data management system has evidently been a long-standing drag on MOE’s ability to analyse trends in sewage bypasses, overflows and other key indicators.

ECO Comment

Based on the available evidence – deteriorating Great Lakes water quality indicators, rising population trends and MOE’s stated priorities on municipal wastewater – the ECO believes that the status quo approach to wastewater management is not adequate for today, and certainly will not be sufficient for the coming generation.

Funding approach not adequate

There are two connected problems in funding wastewater treatment: first, Ontario’s existing funding model, relying strongly on sporadic grants from senior levels of government, is not sustainable. It is very difficult for municipalities to responsibly plan, finance, manage and conserve their wastewater assets, given the temptation of rare, unpredictable, but often large grants.

Second, the absolute dollar amounts allocated are far too small. Ontario’s investment of $653 million since 2007 appears a large figure, but it pales in the context of our enormous accumulated backlog of water and sewer repairs – estimated at $18 billion. Toronto alone has a backlog of $1.3 billion in underground water and wastewater repairs, and should be spending a minimum of $254 million per year to deal with it, according to the General Manager of Toronto Water.

Full cost pricing for water and wastewater infrastructure has long been recognized as a needed reform in Ontario – a point on which industry leaders and environmental groups agree. In 2002, Ontario went as far as passing the Sustainable Water and Sewage Systems Act, requiring municipalities to prepare full-cost accounting reports and cost recovery plans for water and wastewater. Unfortunately, this law has never been proclaimed in force, and the government remains reluctant to take this step.

The government’s caution on full-cost pricing is misplaced. Ontario water rates are generally low compared to the water rates assessed in many other jurisdictions, as well as compared to other household services. Indeed, a recent survey found that almost 30 per cent of Canadians don’t even know what they pay for their water. The City of Toronto has doubled its water rates over the last decade, and is still able to provide the average household with combined water, wastewater and stormwater service at a modest charge of $1.69 per day.

Effluent limits not adequate

MOE appears poised to settle for the lowest common denominator effluent standards developed by the CCME Strategy, without further public consultation. But the CCME’s target concentration limits are essentially the same limits that have been the status quo in Ontario since 1983. With southern Ontario’s ever-increasing population, allowable effluent concentrations need to be reduced over time, just to compensate for increasing flows to our waterways. In the same way, car tailpipe emissions have had to improve over time to compensate for soaring vehicle numbers.

MOE internal capacity not adequate

It does not appear that MOE currently has the capacity or the data to be proactive on municipal wastewater issues. To start with, the ministry should restore its capacity to measure, track and publicly report on loadings. Pollution loadings are an excellent measure of cumulative impacts on a water body, and the ministry has committed itself to consider cumulative effects. So far, MOE has applied a loadings approach only to Lake Simcoe, setting a loading target of 44 tonnes of phosphorus per year. That approach should be expanded to the Great Lakes.

The ministry also needs to rebuild its internal technical expertise, to experiment with new approaches, and to provide support, guidance and direction to municipalities. For example, municipalities that are looking to optimize their facilities should be able to turn to MOE for advice and input (see Success Story: Guelph Optimizes its Sewage Treatment). On broader policy issues, such as the pros and cons of decentralized wastewater treatment, the ministry should be able to provide a context for and lead the policy debate (see When Bigger Isn’t Better: Decentralized Wastewater Treatment Systems).

Transparency not adequate

For some sectors, MOE has wisely published performance data and trends over time, shining a light on both leaders and laggards. For example, MOE applies this approach admirably to Ontario’s drinking water facilities, and also in the new Toxics Reduction Act (see Moving From End-of-Pipe to Front-End Toxics Reduction in Ontario). But the public is left in the dark on the performance of municipal wastewater facilities, so much so that an environmental group, Ecojustice Canada, has seen the need to issue periodic assessments of Ontario sewage discharges, analysing data it requests from the ministry. MOE should greatly strengthen transparency and public engagement on broader wastewater policies as well.

Opportunities for MOE

MOE has a special opportunity to build on the minimum floor set by the CCME strategy and minimum treatment levels. Both our water quality and population trends are compelling arguments for the ministry to take immediate action to assess and strengthen the control of municipal wastewater treatment. Experience and extensive documentation in the United States show what can be accomplished: over a 28 year period, tougher municipal wastewater standards led to a 23 per cent decline in loadings of BOD to that nation’s waterways, despite a significant 35 per cent increase in the population served. Many U.S. river basins and urban waterways showed tremendously improved water quality and fisheries as a result.

To do the job properly, MOE will need to tackle some challenging issues, including: requiring full-cost pricing; setting effluent limits that reflect loadings; rebuilding its own internal capacity to assess wastewater treatment and support municipal efforts; and engaging the interest of the general public in water quality issues in general and the current state of wastewater treatment in particular. Perhaps this last point is where the ministry needs to begin. If the recent experience of the City of Ottawa is any guide, Ontarians have already decided it is time to put some real money on the table for swimmable, fishable, drinkable waterways.

Recommendation 5:

The ECO recommends that the Ministry of Environment monitor and publish annual reports on the quality of municipal wastewater discharges to Ontario waterways, providing both concentrations and loadings of key pollutants.

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This is an article from the 2009/10 Annual Report to the Legislature from the Environmental Commissioner of Ontario.

Citing This Article:
Environmental Commissioner of Ontario. 2010. "Sewage Treatment: Not Good Enough." Redefining Conservation, ECO Annual Report, 2009/10. Toronto, ON : Environmental Commissioner of Ontario. 80.