Value of a made-in-Ontario management system standard for municipal wastewater and stormwater utilities

This paper builds on previous research to address the question of whether there is practical value for a made-in-Ontario municipal management system standard (MSS) for wastewater and stormwater related activities, in addition to the Drinking Water Quality Management System Standard (DWQMS) that is already statutorily required. This research specifically addressed the questions: is there value in a mandatory or voluntary MSS; are there neutral, positive, or negative effects of having an MSS; and what standard is more adequate? Through a focus group method, this research finds evidence in support of and wide recognition of the practical value an MSS in assisting municipalities in meeting their environmental objectives, addressing property damage risks, providing an additional mechanism of public accountability, and improving alignment with the legal structure. It was also apparent that there is no political appetite in the provincial government to embark on a mandated MSS, so the preferred option at this time appears to be a provincially endorsed, voluntary, sector-specific standard for wastewater and for stormwater, which could constitute a catalyst to boost voluntary uptake ofMSS by small to medium municipalities (as is already occurring with large municipalities). This standard could be based on a customized variation of the ISO 14001 and DWQMS.


INTRODUCTION
In a broader context, the expectation of modern society is that governments would ensure the provision of safe drinking water, the collection and treatment of wastewater, as well as the collection and treatment of stormwater runoff.   The focus group method was undertaken with a view to addressing the following research sub-questions: (1) Is there value in creating a provincially mandated municipal wastewater environmental MSS and a stormwater environmental MSS? • provincial government regulators from the MECP directly involved with all municipal water, wastewater, and stormwater systems (four participants); • large municipalities (1þ million residents) with EMS systems in place or in the process of being implemented (three participants); • medium to small municipalities, including representation of the Ontario Clean Water Agency (OCWA) (three participants); • international private sector regulators and registrars, with representation of the CSA Group, including the two registrars designated to conduct DWQMS external audits for all municipal water systems in Ontario (three participants); and • a consultant with ample experience in ISO management systems and with the operation and compliance of municipal water systems (one participant).
One challenge was to ensure meaningful representation of small municipalities (i.e. there are 444 municipalities in Ontario, who own and/or operate 630 licensed drinking water systems with a similar distribution for wastewater systems). A total of 10 municipalities cover 75% of the population in Ontario, most of these 10 municipalities are located in what is referred to as the Greater Golden Horseshoe (see Figure 1). So, to address this challenge, the focus group included three senior officials from the OCWA.
OCWA manages and operates 180 municipal, non-municipal and First Nation water and wastewater systems across The points for which there appeared to be consensus were summarized and noted at the half-way point in the focus group session, and an opportunity was provided for focus group participants to confirm their veracity, to corroborate, elaborate, or disagree, after which the remaining questions were discussed.
When the focus group session concluded, the author reviewed and consolidated the notes taken by the two recorders. The summary of transcripts was shared with each individual participant to obtain their feedback. All participants were given the opportunity to review the summary to clarify, comment, or confirm their insights. Based on the revised transcripts, all recorded discussions were reviewed and classified. The confirmed transcripts of the 14 participants were coded and then analyzed. A draft report of the conclusions was prepared and provided to participants for comment. Although consensus was not sought by the author, there was a certain degree of agreement expressed by the focus group participants. By reviewing the transcripts, a coding framework with topics based on the key research question, and sub-questions and categories was developed. The term consensus in this study means overall agreement on a topic by the majority of participants while having no one expressing opposing views.

RESULTS AND DISCUSSION
The participants appeared to have a common understanding that the governance structure for the wastewater and stormwater sector relies on a provincial regulatory framework but also on proactive action by municipalities in adopting best management practices (BMPs) derived from non-state actors that have developed useful tools such as non-state MSSs and protocols (e.g. ISO and Canadian Standard Association (CSA) Group standards, FCM  Protocols). The data from the focus group generated the following topics: (1) Perceptions of the effects of EMS on managing municipal wastewater and stormwater systems (positive, negative, and neutral); (2) Role of the provincial government in adopting standards for EMS (legislated/ mandatory versus voluntary adoption of EMS); (3) Role of municipalities in adopting non-state standards for EMS (peer-to-peer support and lessons learned); (4) Role of non-state actors supplementing state-based regulations (risk assessment and standards development processes); and (5) Drivers for EMS in the municipal wastewater sector (motivators and barriers). The focus group's municipal representatives identified the EMS as a management tool for the risk assessment process: 'We are identifying areas that we inaccurately predicted were low risk that in fact turned out to be higher risk'  This topic became one of the most debated points by the focus group participants during the second half of the session. As one municipal representative put it, 'before thinking about making EMS a provincial requirement, we need to define what problem we are trying to solve, and how solving the problem will benefit the province' (Fp7).
A provincial regulator also pointed out that: ] phasing in a new requirement such as an EMS is relatively straightforward, we did that with the DWQMS. But what is more challenging is getting to the stage where you are ready for making it a requirement (Fp1).' There was agreement that the three problems noted abovemanagement of the system, the infrastructure design principles, and investing in increasing capacityneed to be addressed, but there was no agreement as to which to look into first. There was a general understanding that MSS and design standards would assist in achieving the ultimate goal: to improve the levels of service to citizens and the community by reducing floods, spills and CSOs, flooding of people's basement, inflow/infiltration, and environmental degradation. Having management standards and adequate design standards would certainly help to achieve this objective. However, in terms of economic resources the question is where to spend tax-payer money: e.g. on an MSS or on increasing infrastructure capacity.
Another important driver noted was that the existing wastewater and stormwater regulations are very old, with the regulatory framework for the stormwater sector being particularly out of date. Specifically, it was pointed out that: It was also apparent that there is no political appetite in the provincial government to embark on a mandated MSS, so the preferred option at this time appears to take the form of a provincially endorsed, voluntary sector-specific standard for wastewater and also for stormwater, which could constitute a catalyst to boost voluntary uptake of MSSs by small to medium municipalities (as is already occurring with large municipalities).

SCOPE FOR MUNICIPAL WASTEWATER AND STORMWATER MSS
This section considers the basis for selecting the appropriate MSS for the municipal drinking water, wastewater, and stormwater sectors, followed by a discussion of the appropriate scope of the management standard for municipal wastewater and stormwater.
Based on the risks and hazards associated with the provision of water/wastewater/stormwater services can be grouped as follows: • Risks to human health, i.e. waterborne disease.
• Environmental risks, such as contamination of soil, rivers and lakes, e.g. combined sewer overflow (CSO) (from combined sewer systems (CSS)) or sewer system overflows (SSO) (from separate sewer systems (SSS)). (Combined sewer overflow (CSO) refers to a discharge to the environment from a combined sewer system that usually occurs as a result of a rainfall event when the capacity of sewers are exceeded (MECP ); combined sewer system (CSS) refers to a collection system that contains sanitary sewers and stormwater sewers within the same sewer collection system (adapted from MECP ); sewer system overflow (SSO) refers to an overflow when additional flows enter the sewer system due to rainwater, groundwater rise or emergency situations (blockage such as grease build-up, tree roots in pipes, or accumulation of 'unflushables') over-  A QMS is designed to ensure that a product is manufactured at the same level of quality regardless of where it is manufactured. Manufacturing a beverage like drinking water requires a QMS/HACCP approach to ensure it is delivered (output) with the same level of quality regardless of the water source used (lake, river or wells). This is controlled through strict standards for design, as well as manufacturing (or construction of the infrastructure that will distribute water). In the drinking water context, the MECP accomplished an effective DWQMS with the support of regulated design standards and source water protection to ensure continual water pressure, testing, and disinfection.
In contrast, an EMS standard is intended to ensure that there are procedures in place to reduce impacts on the environment, including addressing the impacts of the broader infrastructure in both design capacity and performance. Figure 4 illustrates the EMS approach with uncontrolled inputs and outputs. The objective here is to minimize undesired outputs considering the uncertainty of multiple inputs to the system.   The scope of the MSS was also discussed with the focus group participants. While it was acknowledged that the DWQMS is a standard that covered planning, design, construction, commissioning, and operations, it was noted that such a wide scope for a wastewater and stormwater management standard would be too onerous and close to impossible to implement without designated funding a strong legislative authority. Focus group participants noted that the practical approach for a voluntary MSS would be one that brings awareness to the planning, design, and construction, but focuses on the operational processes inherent in the collection and treatment.
The operational processes and business support processes align with many elements of the DWQMS such as the annual planning, management review, audit, continuous improvement, sampling, and document control. Moreover, many municipalities have already expanded some of those business processes from their drinking water operations to their wastewater operations. On the other hand, high-level In Ontario, such high-level aspects follow established and legislated protocols under the Planning Act, the Drainage Act, and the Environmental Protection Act.

CONCLUSIONS
This study found widespread support among the state and non-state focus group participants for selecting the QMS as the best approach to address water quality objectives; and the EMS as the more adequate approach that could have positive environmental and regulatory effects on wastewater and stormwater sectors. The concept of 'standardization of operations' was generally acknowledged as one of the primary benefits of the new array of regulations for drinking water. An EMS-based approach was also noted as a safety net in the event of environmental risks being underestimated and as an enabler for consistent compliance with regulatory requirements and making municipalities more efficient (in removing cobwebs).
There was also consensus that an EMS approach would best be achieved through a provincially regulated requirement.
There was consensus that medium to large municipalities would likely have the resources to develop and implement EMS, but that there would be significant implementation challenges for small to medium municipalities (i.e. lack of resources for development and operationalization, complexity, and capacity). A scalable, adaptable, and risk-based approach for gradual implementation was seen as preferable.
There appeared to be general agreement that addressing wastewater and stormwater environmental management in a single standard would be complex since for the most part risks are different and have different drivers. It was also apparent that there is no political appetite in the provincial government to embark on a mandated MSS for wastewater and stormwater, so the preferred option at this time appears to take the form of a provincially endorsed, voluntary sectorspecific standard for wastewater and also for stormwater, which could constitute a catalyst to boost voluntary uptake of MSSs by small to medium municipalities (as is already occurring with large municipalities). This standard could be based on a customized variation of the ISO 14001, the DWQMS and other standards, and its scope should cover the operational processes and support businesses processes but does not include the planning, design and construction, which would make it less feasible for municipalities to implement and adopt. Figure 2 illustrates the typical components in scope and out of scope for a typical wastewater and stormwater system.

DATA AVAILABILITY STATEMENT
Data cannot be made publicly available; readers should contact the corresponding author for details.