Overview of the quality and completeness of wastewater ECA applications Sanja Jankovic, Application Assessment Unit Client Services and Permissions Branch, MOECC November 29, 2017
Overview Background Approval Process Application Assessment Unit Driving High Quality (ECA) Submissions Overview of Screening Results 2
Background In 2015, the Ontario Fall Economic Statement identified a commitment to further improve the ECA process by implementing a one-year service standard for higher-risk ECA applications received after 2017. As part of the Modernization of Approvals initiative, the ministry introduced efficiencies by providing additional guidance and introducing more efficient business processes. Ontario Regulation 255/11 Applications for Environmental Compliance Approvals, prescribes minimum application requirements for ECAs. The Checklist for Technical Requirements for a Complete Environmental Compliance Approval Submission (Checklist) was made available to the public in February 2013.
Approval Process CSPB Application Assessment/ Screening Important EAPB Technical Review Signing Director Decision Application Review Unit/Technical Review 4
Application Assessment Unit (AAU) Performs an upfront assessment of each ECA application against legislative and ministry requirements. Performs fee assessment in accordance with Minister s Requirement for Fees for ECAs. Returns incomplete application submissions to applicants early in the review process. Sends the acknowledgment letters to applicants/consultants requesting additional information/fees. Posts project proposals on the Environmental Registry (if proposals are subject to EBR) once the application has been deemed complete. 5
Driving High Quality (ECA) Submissions New Implemented internal processes and tools to support approvals program efficiencies to meet timelines. More in-depth assessment upfront so incomplete application submissions are returned early in the screening process. More efficient and responsive communications between Ministry and applicants i.e. fewer correspondences and information request letters. Strictly enforcing the deadline to provide additional information. If the response is not provided within the two weeks, the application is returned. Applications only move from AAU to technical review when deemed complete. 6
The Checklist To assist proponents in the preparation of complete submissions, the Checklist for Technical Requirements for a Complete Environmental Compliance Approval Submission (Checklist) was developed. Businesses may use this Checklist as an additional reference on the information that is required in a complete application. The Checklist was made available to the public on February 2013 and can be found on the ministry s website. 7
Overview of Screening Results Waste Water Applications Month # Sewage applications acknowledged by AAU Transfer of Review Files Sewage Files Screened for Completeness A=B+C+D Complete B Info Requested C Returned (Red Flag) January 203 52 119 28 (24%) 87 (73%) 4 (3%) February 159 54 88 18 (20%) 67 (76%) 3 (3%) March 173 52 104 16 (15%) 77 (74%) 11 (11%) April 191 79 104 24 (23%) 78 (75%) 2 (2%) May 187 70 114 34 (30%) 77 (68%) 3 (3%) June 161 60 94 18 (19%) 74 (79%) 2 (2%) July 108 35 66 17 (26%) 47 (71%) 2 (3%) August 149 40 91 17 (19%) 71 (78%) 3 (3%) September 127 44 76 24 (32%) 50 (66%) 2 (3%) October 118 39 67 19 (28%) 45 (67%) 3 (4%) November 122 25 87 24 (28%) 59 (68%) 4 (5%) December 117 33 73 13 (18%) 54 (74%) 6 (8%) Total 1815 583 1083 252 (23%) 786 (73%) 45 (4%) D 8 Note: Screening not conducted for Transfers of Review, minor administrative amendments, revocations, reports submitted in compliance with conditions of the approvals
100 90 Overview of Screening Results Waste Water Applications 87 Returned 4% Number of Submissions 80 70 60 50 40 30 20 10 0 67 28 18 4 3 77 78 77 74 71 59 47 50 45 34 24 24 24 16 18 17 17 19 11 2 3 2 2 3 2 3 4 54 13 6 Info/Fee requested 73% Complete 23% Note: Screening not conducted for Transfers of Review, minor administrative amendments, revocations, reports submitted in compliance with conditions of the approvals 9
Red Flag Items Waste Water Applications Eng. Drawings/Site Plans Missing 23 ECA Form Missing 2% Fee Not Submitted 14 SWM Report Missing 9 Sewage Treatment Plant Report Missing Subsurface Sewage Disposal Report Missing 4 5 Fee Not Submitted 22% Technical Design Report Missing 40% Missing Oil/Grit Design Brief Industrial Wastewater Treatment Report Missing 3 4 Eng. Drawings/Site Plans Missing 36% ECA Form Missing 1 0 5 10 15 20 25 Number of Times Red Flag Items were Found 10
Overview of Items Requested by Major Categories Waste Water Applications Administrative Items 924 Site Plan 10% Fee 195 ECA Form 334 Technical 19% Administrative Items 45% Technical 377 Note: Site Plan 205 0 200 400 600 800 1000 Number of Times Items in Each Category were Requested Data represent the number of times item was requested. Therefore multiple items could be requested for the same file. ECA Form 16% The total number of items is greater than the number of DCAT files processed. Fee 10% 11
Missing Administrative Items and Incorrect Fees Waste Water Applications Electronic Copy EBR Abstract Fees Proof of Legal Name 102 195 278 358 Info Confirmation 6% Name Change Documentation 3% EAA Requirements 6% Other Documentation 2% Info Confirmation EAA Requirements 66 61 Proof of Legal Name 9% Electronic Copy 32% Name Change Documentation Other Documentation 25 34 Fees 17% Note: 0 100 200 300 400 Number of Times Items were Requested EBR Abstract 25% Data is based on the number of administrative items requested in the Acknowledgment Letters, not directly related to the ECA form or other categories. 12
Missing ECA Application Form Items Waste Water Applications Applicant Signature 88 NEPDA/ORM Permits 3% Other Documentation 6% Operating authority 63 Missing/Incomplete Form 7% Technical contact signature 55 Land owner consent Statement of the municipality 33 42 Statement of the municipality 10% Applicant Signature 26% Missing/Incomplete Form 24 Land owner consent 13% Operating authority 19% Other Documentation 19 NEPDA/ORM Permits 10 Technical contact signature 16% 0 20 40 60 80 100 Number of Times Items were Requested 13
Missing Engineering Drawings or Map Items Waste Water Applications Eng. Drawings Not Stamped by P.Eng 131 Site Zoning Plan missing 2% North Arrow 2% Not Legible 20 Scale 6% Fully labelled 18 Other items 7% Other items 14 Fully labelled 9% Scale Site Zoning Plan missing 5 12 Not Legible 10% Eng. Drawings Not Stamped by P.Eng 64% North Arrow 5 0 50 100 150 Number of Times Items were Requested 14
Missing Technical Items Waste Water Applications Conservation Authority Clearance Sewer Design Sheets 73 128 General Info Confirmation 2% Subsurface Disposal Items 4% Sewage Pumping Station Report Items 1% SWM Report Items 69 Wastewater Treatment Items 4% Completed Pipe Data Form 43 Oil/Grit Separator Documentation 5% Oil/Grit Separator Documentation Wastewater Treatment Items 16 20 Completed Pipe Data Form 12% Conservation Authority Clearance 34% Subsurface Disposal Items General Info Confirmation Sewage Pumping Station Report Items 5 8 15 SWM Report Items 18% Sewer Design Sheets 20% 0 50 100 150 Number of Times Items were Requested 15
Selected Consultants Report Cards Technical Contact Number of Submissions Percentage Completed Percentage Info Requested Percentage Returned Consultant A 49 29% 67% 4% Consultant B 47 23% 77% 0% Consultant C 34 24% 76% 0% Consultant E 32 6% 91% 3% Consultant D 32 25% 69% 6% Consultant F 31 26% 71% 3% Consultant G 30 20% 77% 3% Consultant H 28 21% 71% 7% Consultant I 27 19% 81% 0% Consultant K 24 50% 50% 0% Consultant J 24 17% 83% 0% Consultant M 21 24% 76% 0% Consultant L 21 19% 81% 0% Consultant O 20 30% 65% 5% Consultant N 20 30% 70% 0% 16
Selected Consultants Comparison of the Quality of Applications 60 50 2 Returned Number of Submissions 40 30 20 10 0 1 2 1 12 12 13 3 3 3 1 12 13 14 16 17 6 6 6 5 4 12 12 1 2 23 22 20 20 4 5 6 6 1 22 8 1 2 26 22 29 8 8 2 36 11 33 14 Info Requested Completed 17
Selected Consultants Missing Information Requested from Top Consultants 90 Number of Times Items were Requested in Each Category 80 70 60 50 40 30 20 10 0 5 6 3 19 3 6 4 4 9 9 4 2 2 6 8 4 3 1 2 4 3 4 3 3 19 19 13 12 5 2 7 3 11 9 4 2 18 3 2 4 1 7 6 7 7 6 3 3 26 24 6 7 6 10 12 11 6 4 30 31 2 3 9 4 20 7 8 13 14 11 13 10 24 22 12 18 8 27 17 10 7 36 21 11 8 43 Eng. Drawings/Site Plans Technical ECA Form Fee Administrative Items 18
Summary Approximately 75% of applications received by the ministry were found to be missing technical or administrative information. The ministry implemented changes to improve program efficiencies and meet one-year service standard. Applications only move from application assessment to technical review when deemed complete. Please note that additional technical information may be requested at the detailed technical review stage. We continue to analyze the quality and completeness of ECA application submissions and will provide feedback to consultants. We continue to work with proponents and consultants to improve on the quality of ECA submissions. If you would like to know results of our screening of your ECA submissions, please contact: Sanja Jankovic at sanja.jankovic@ontario.ca
QUESTIONS? Sanja Jankovic Supervisor, Application Assessment Unit Client Services and Permissions Branch Sanja.Jankovic@ontario.ca (416) 314-7969 20