Response to Sanitary Sewerage Servicing

The London Region Manufacturing Council (LRMC) wishes to once again thank the E&T Committee for inviting our input on this important matter as it relates directly to the future growth and prosperity of the London manufacturing sector.

Date: June 22, 2004

To: Chair and Members, Environment and Transportation Committee, City of London

From: London Region Manufacturing Council (LRMC)

Subject: Response to Sanitary Sewerage Servicing Strategy for the Area Served by the Greenway Pollution Control Centre

The London Region Manufacturing Council (LRMC) wishes to once again thank the E&T Committee for inviting our input on this important matter as it relates directly to the future growth and prosperity of the London manufacturing sector.

The manufacturing sector creates wealth in London through industrial investment and the export of products outside our region. As a result, it is important that the growth and attraction of manufacturing facilities in London be as competitive and unobstructed as possible in relation to surrounding communities.

After reviewing the contents of the position paper identified above, and after significant discussions over these issues, the LRMC herewith offers the following opinions:

1. Sanitary Sewer Surcharges and Usage Costs

The LRMC strongly recommends that the City of London maintain competitive sanitary sewer surcharges and other usage charges with neighbouring communities. Significant increases to sewer surcharges will pose financial burdens for high volume industrial users of the sanitary sewer infrastructure. In particular, food processing, a key industrial sector within the city would be negatively impacted. Substantial increases in London sanitary sewer use rates could threaten existing industrial investments as well as provide a disincentive for future expansion and new investment decisions.

To this end, the LRMC supports the position that the timing for the construction of new sanitary sewerage works be managed to maximize the usage of existing infrastructure and delay new investment until the need is clearly established.

2. Allocation of Remaining Capacity

The LRMC does not support any recommendations that will in any way constrain the growth of existing industry or jeopardize attraction of new investment to the city. Although the LRMC supports the position of maximizing the usage of existing infrastructure, at that point in time when there is any indication that growth could be impeded, investment in new sewerage facilities and infrastructure should be expedited.

If an allocation policy is to be implemented, the City should survey the needs of the industrial, commercial, and residential sectors on an annual basis to quantify short to mid-term needs. City of London Environmental and Engineering Services should clearly communicate on a regular basis the status of remaining capacity. This will ensure that the City of London environment and planning administrations trigger the appropriate investment in sewerage facilities in a timely manner.

3. Extension of Remaining Capacity

Environmental and Engineering Services should investigate methods of delaying investment in new sewerage facilities and infrastructure without constraining growth and attraction of industry. In review of the documentation provided to the LRMC, it is evident that flows to the Greenway Pollution Control Centre (GPCC) increase during wet weather and during the spring melt. This implies storm water represents a significant portion of the total flow to GPCC. As such, the LRMC recommends that as the City embarks to upgrade the existing sanitary sewer infrastructure, that every opportunity be explored to separate sanitary and storm water flows, and direct only sanitary sewerage to the treatment facility. This will have the net effect of increasing the available remaining capacity of GPCC.

4. True Cost Benefit of Delaying Investment

The LRMC supports the efficient use of capital funds. Delaying investment of sewerage facilities and infrastructure is a prudent financial decision provided that it does not result in illogical planning decisions or the investment in other costly infrastructure to compensate for lack of sewerage capacity. As an example, growth of the industrial sector in the SW corner of the city may be prohibited as a result of delays in construction of the Southside Pollution Control Plant (PCP), forcing growth to the NE part of the city. This in turn may result in further investment in transportation routes into the NE which otherwise may have been avoided had industrial growth occurred unimpeded in close proximity to the Highway 401. In summary, the financial benefit of delaying the investment in sewerage facilities must include the cost implications with respect to all aspects of municipal infrastructure.

In conclusion, London must remain cost competitive with neighbouring communities, and avoid establishing any barriers to the growth and attraction of industry. Failing to do so will encourage industrial investment outside of London which will still benefit from London's skill and labour pool without contributing to London tax base or infrastructure. The LRMC recommends that no steps be taken that would jeopardize London’s growing reputation as a successful location for industrial investment.

Dave Gardner, P.Eng.
Chair, London Region Manufacturing Council (LRMC)