The Government of Canada is committed to providing safe, clean drinking water in all First Nations communities, and to ensuring that wastewater services in all First Nations communities meet acceptable effluent quality standards. As part of this commitment, the Government announced the First Nations Water and Wastewater Action Plan (FNWWAP). The plan funds the construction and renovation of water and wastewater facilities, operator training, and public health activities related to water and wastewater on reserves. It also provided for a national, independent assessment – The National Assessment of First Nations Water and Wastewater Systems – which will inform the Government’s future, long-term investment strategy. This assessment was also recommended by the Senate Standing Committee on Aboriginal Peoples.

The purpose of the National Assessment is to define the current deficiencies and the operational needs of water and wastewater systems, identify the long-term water and wastewater needs of each community and recommend sustainable, long-term infrastructure development strategies.

The objectives of the National Assessment are to:

• Identify which upgrades will be required for existing public systems to meet INAC’s Level of Service Standards; INAC’s Protocol for Safe Drinking Water in First Nations Communities; INAC’s Protocol for Wastewater Treatment and Disposal in First Nations Communities; and applicable provincial regulations, codes, and standards
  
  
• Complete the Annual Inspection, Risk Assessment and Asset Condition Reporting Systems (ACRS) assessment for water and wastewater assets
  
  
• Conduct an overall community serviceability assessment of private, on-site communal and/or central systems
  
  
• Prepare Class “D” cost estimates for each of the communities visited. Class “D” estimates are preliminary, and are based on available site information. They indicate the approximate magnitude of the cost of the recommended actions, and they may be used to develop long-term capital plans. In addition, these estimates may be used in preliminary discussions of proposed capital projects.

This assessment involved collecting background data and information about each community, undertaking a site visit, and preparing individual community reports for each participating First Nation. Neegan Burnside and its sub-consultants conducted an assessment for each of the eight regions. This report summarizes the findings for the Ontario region.

1.1 Site Visits

Neegan Burnside Ltd. and its sub-consultants, R.J. Burnside & Associates Limited, XCG Consultants Ltd., and KGS Group, made site visits in the Ontario region during September and October, 2009, and during May through September, 2010. Each visit included at least two team members. In addition to the consultant staff, additional participants including the Circuit Rider Trainer (CRT), INAC Representative, Environmental Health Officer (EHO) from Health Canada and Tribal Council Representative were invited to attend the site visits. Each community report identifies the additional participants who were able to attend.

After confirming the various components that the First Nation uses to provide water and wastewater services to the community (i.e. number and types of systems, piping, individual systems, etc.) along with population and future servicing needs (planned development and population growth), an assessment was carried out of the water and wastewater systems, as well as 5% of the individual systems.

1.2 Reporting

Individual community reports have been prepared for each First Nation. In cases where the First Nation consists of multiple communities that are located in geographically distinct areas, a separate report was prepared for each community. In the Ontario Region, 120 of 121 First Nations (99%) with water/wastewater assets participated in the study, which resulted in the preparation of 122 individual community reports. Figure 1.1 indicates the location of each First Nation visited as a part of this study.

The reports include an assessment of existing communal and individual systems, identification of required upgrades to meet departmental, federal and provincial protocols and guidelines, and an assessment of existing servicing of the community along with projections of population and water and wastewater flows for future servicing for the 10 year period. Each report includes the projected costs for the recommendations to meet departmental protocol, federal and provincial guidelines, and an evaluation of servicing alternatives along with life cycle costing for each feasible alternative.

The appendices of each report also include an annual water inspection, a risk evaluation, and an Asset Condition and Reporting System inspection for each system.

Figure 1.1 - Ontario First Nations Visited

Detailed description of Figure 1.1

The Ontario region includes 121 First Nations with water and wastewater assets. 120 of these First Nations participated in the National Assessment. There are 158 water systems (146 First Nation systems and 12 Municipal Type Agreements) and 77 wastewater systems (71 First Nation systems and 6 Municipal Type Agreements).

A water or wastewater system considered a First Nation system, consists of INAC-funded assets, and serves five or more residences or public facilities. A Municipal Type Agreement (MTA), on the other hand, is when First Nations are supplied with treated water from or send their wastewater to a nearby municipality or neighbouring First Nation or corporate entity as outlined in a formal agreement between the two parties.

The First Nation community population ranges from 23 to 11,449 people, and household sizes range from 1.5 to 7.2 people per unit (ppu). The total number of dwellings is 23,732 and the average household size in the Ontario region is 3.9 ppu.

2.1 Water Servicing

There are a total of 158 water systems serving 115 First Nations. The remaining five First Nations are serviced solely by individual water supplies.

For water treatment, the 158 systems include:

• 12 systems that receive their water supply through a Municipal Type Agreement (MTA)
• 39 groundwater systems
• 13 GUDI (groundwater under the direct influence of surface water) systems
• 94 surface water systems.

For water distribution, the 158 systems include:

• 3 distribution systems that are maintained through a Municipal Type Agreement (MTA)
• 155 distribution systems that are maintained by the First Nation.

The following summarizes the level of service being provided to the homes within the Ontario region:

• 69% of the homes (16,354) are piped
• 9% of the homes (2,078) are on truck delivery
• 19% of the homes (4,468) are serviced by individual wells
• 3% of the homes (832) are reported to have no water service.

For the purposes of the assessment, homes without water service are typically those without plumbing within the house.

Table 2.1, below, provides an overview of the water systems by system classification, source type, treatment type and storage type.

In general, the treatment system classification reflects the complexity of the treatment process. Treatment systems labeled as “Small System” and “None” typically represent systems with either disinfection only or no treatment. The distribution classification reflects the population of the community being serviced. The classification follows Ontario’s regulations.

Ontario has recently modified the licensing of systems and the certification of operators. First Nation water systems have been evaluated as “year round municipal residential” systems. Ontario recognizes three classes of sub-system: Distribution, Distribution and Supply, and Water Treatment, each of which may be Class I,II,III or IV, and the province requires operators to be certified to the appropriate subsystem and class. The mapping of the existing treatment and distribution certifications to the three categories in the updated Ontario system is outside of the scope of this project.

Table 2.1 - Water Overview

System Classification	No.	% of Total
None	3	2%
Small System	24	15%
Level I	45	28%
Level II	62	39%
Level III	12	8%
MTA	12	8%

Source Type	No.	% of Total
Groundwater	39	25%
Surface Water	94	59%
Groundwater GUDI	13	8%
MTA	12	8%

Storage	No.	% of Total
None	47	30%
Elevated	14	9%
Standpipe	7	4%
Grade level	10	6%
Underground	80	51%

Treatment Type	No.	% of Total
None - Direct Use	4	2%
Disinfection Only	28	18%
Greensand Filtration	6	4%
Slow Sand	19	12%
Conventional	46	29%
Membrane Filtration	43	27%
MTA	12	8%

2.2 Wastewater Servicing

There are a total of 77 wastewater systems serving 67 First Nations. The remaining 53 First Nations are serviced solely by individual wastewater systems.

For wastewater treatment, the 77 systems include:

• 6 systems are provided treatment through a Municipal Type Agreement (MTA)
• 71 First Nation wastewater treatment systems, consisting of 38 systems that use either facultative or aerated lagoons, 27 systems that use a mechanical plant, 4 communal septic systems and 2 other treatment type systems.

For wastewater collection, the 77 systems include:

• 2 wastewater collection systems that are maintained through a Municipal Type Agreement (MTA)
• 75 wastewater collection systems that are maintained by the First Nation.

The following is a summary of the level of service being provided to the homes within the Ontario region:

• 35% of the homes (8,230) are piped
• 5% of the homes (1,276) are on truck haul
• 57% of the homes (13,537) are serviced by individual wastewater systems
• 3% of the homes (689) are reported to have no service.

The following table provides an overview of the wastewater systems by system classification and treatment type:

Table 2.2 - Wastewater Overview

System Classification	No.	% of Total
Small System	7	9%
Level I	46	60%
Level II	17	22%
Level III	1	1%
MTA	6	8%

Treatment Type	No.	% of Total
Aerated Lagoon	1	1%
Facultative Lagoon	37	48%
Mechanical Treatment	27	35%
MTA	6	8%
Other	2	3%
Septic System	4	5%

3.1 Per Capita Consumption and Plant Capacity

For communal water systems, the average per capita demand ranges from 31 L/p/d to 778 L/p/d, with an average per capita demand of approximately 298 L/p/d.[Note 1]

Historical flow records are not available for approximately 50% of the First Nations with communal water systems, including five of the 12 systems serviced by a Municipal Type Agreement. For these First Nations, an average per capita flow rate of 275 to 325 L/p/d was used to evaluate the water systems.

The distribution of per capita flow is outlined in Table 3.1.

Table 3.1 - Range of Per Capita Water Usage Rates

	No. of systems 2009
Less than 250 L/c/d	40
250 L/c/d to 375 L/c/d	101
Greater than 375 L/c/d	17

There is no historical wastewater flow data available for most of these systems. Therefore, to evaluate the ability of the existing infrastructure to meet the current and projected needs, an average daily flow was calculated based on the actual or assumed per capita water consumption, plus an infiltration allowance of 90 L/c/d for piped servicing.

The following figure provides a summary of the treatment capacity for the water and wastewater systems:

• over capacity: the existing system is unable to meet the current needs
• at capacity: the existing system is able to meet the current needs
• available capacity: the existing system has sufficient capacity to meet more than the current needs
• not enough data: insufficient data to determine the actual system capacity.

Figure 3.1 - Water and Wastewater Treatment Capacities

Detailed description of Figure 3.1

The data shows that 32 water systems and 20 wastewater systems are operating at or beyond their estimated capacities. Two of these water systems have per capita demands in excess of 450 L/c/d.

3.2 Distribution and Collection

The household size for the 120 First Nations ranges from 1.5 to 7.2 people per unit (ppu), with an average of 3.9 ppu.[Note 2] The total number of piped connections in the region is 16,354 for water and 8,230 for wastewater. The average length per connection of watermain in the region is approximately 52 m. The average length per connection of sewermain in the region is approximately 30 m.

As the table and the figures below illustrate, there is no strong correlation between the size of the community and the length of pipe per connection. The length of the watermain per connection is greater than the length of the sanitary main per connection. This difference is likely because some communities provide water service only, so the homes are farther apart to allow for the installation of private septic systems. In some cases, the data provided for watermains includes dedicated transmission main lengths (no service connections) and non-distribution mains (i.e. intake pipes, raw water pipes). As a result, the average length per connection is inflated, particularly for smaller communities where the additional pipe length is spread over a smaller number of connections. The tables and figures include only those communities for which suitable data was available.

The table below indicates the number of water and wastewater systems that have pipe lengths above and below 30 m/connection. It should be noted that this information was not available for all of the systems.

Table 3.2 - Average Water Distribution and Wastewater Collection Pipe Lengths

	Watermain	Sewer
Average m/connection	52	30
No. of systems with pipe lengths above 30 m/connection	113	34
No. of systems with pipe lengths below 30 m/connection	22	29

Figure 3.2 - Water Distribution: Average Pipe Length per Connection

Detailed description of Figure 3.2

Figure 3.3 - Wastewater Collection: Average Pipe Length per Connection

Detailed description of Figure 3.3

3.3 Water Risk Evaluation

A risk assessment has been completed for each water system according to the INAC Risk Level Evaluation Guidelines. Each facility is ranked in risk according to the following categories: Water Source, Design, Operation (and Maintenance), Reporting and Operators. The risk levels of all five categories are then used to determine the overall risk for the system.

Each of the five risk categories, as well as the overall risk level of the entire system, is ranked numerically from 1 to 10. Low, medium and high risks are defined as follows:

• Low Risk (1.0 to 4.0): These are systems that operate with minor deficiencies. Low-risk systems usually meet the water quality parameters that are specified by the appropriate Canadian Guidelines for drinking water (in particular, the Guidelines for Canadian Drinking Water Quality (GCDWQ).
• Medium Risk (4.1 to 7.0): These are systems with deficiencies, which — individually or combined—pose a medium risk to the quality of water and to human health. These systems do not generally require immediate action, but the deficiencies should be corrected to avoid future problems.
• High Risk (7.1 to 10.0): These are systems with major deficiencies, which— individually or combined—pose a high risk to the quality of water. These deficiencies may lead to potential health and safety or environmental concerns. They could also result in water quality advisories against drinking the water (such as, but not limited to, boil water advisories), repetitive non-compliance with guidelines, and inadequate water supplies. Once systems are classified under this category, regions and First Nations must take immediate corrective action to minimize or eliminate deficiencies.

Regional Risk Summary:

Of the 158 water systems inspected:

• 72 are categorized as high overall risk
• 61 are categorized as medium overall risk
• 25 are categorized as low overall risk.

The 25 Low-risk systems include 7 groundwater systems, 7 Municipal Type Agreement (MTA) systems, and 11 surface water systems.

Appendix E.1 provides a table summarizing the correlation between component risk and overall risk. In general, MTA systems are more likely to have a lower overall risk, whereas groundwater under the influence of surface water (GUDI) systems and surface water systems are more likely to be higher risk.

Figure 3.4 provides a geographical representation of the final risk for the water systems that were inspected.

Figure 3.4 - Ontario Water System Risk

Detailed description of Figure 3.4

3.3.1 Overall System Risk by Source

The following table summarizes the overall system risk by water source. In general, it is assumed that MTA systems have a lower overall risk than other systems because they operate in accordance with provincial legislation. In the Ontario region, 54% of the GUDI systems, 48% of the surface water systems, 46% of the groundwater systems and 17% of the MTA systems were high risk systems. 58% of the MTA systems, 18% of the groundwater systems, 12% of the surface water systems, and none of the GUDI systems have a low overall risk.

Table 3.3 - Summary of Overall Risk Levels by Water Source

Overall Risk Level	Groundwater	GUDI	Surface Water	MTA	Total
High	18	7	45	2	72
Medium	14	6	38	3	61
Low	7	0	11	7	25
Total	39	13	94	12	158

3.3.2 Overall System Risk by Treatment Classification

The following table summarizes the overall system risk by the classification level of the treatment system. System classification is based on a number of factors. Systems with no treatment and small systems are more likely to have higher overall risk scores than more complicated systems.

Table 3.4 - Summary of Overall Risk Levels by Treatment System Classification

Overall Risk Level	None	Small System	Level I	Level II	Level III	MTA	Total
High	3	20	20	23	4	2	72
Medium	0	1	21	31	5	3	61
Low	0	3	4	8	3	7	25
Total	3	24	45	62	12	12	158

Figure 3.5 - Risk Profile Based on Water Treatment System Classification

Detailed description of Figure 3.5

3.3.3 Overall Risk by Number of Connections

For the Ontario region, systems serving more than 100 connections have a fairly even distribution of high-, medium- and low-risk systems. Systems serving less than 100 connections are more likely to have a high- or medium-overall risk. The most likely reason for the higher risk rating for smaller systems includes:

• inadequate treatment for the source water
• untrained operators
• no backup operators
• poor reporting practices.

The above factors seem to be more prevalent in smaller systems.

3.3.4 Component Risks: Water

The overall risk is comprised of five component risks: water source, design, operation, reporting and operator. Each of these component risk factors is discussed below.

Figure 3.6 - Water: Risk Profile Based on Risk Components

Detailed description of Figure 3.6

	Source	Design	Operation	Reporting	Operator
Risk	7.5	5.4	6.9	7.0	3.1
Minimum	1.0	1.0	1.0	1.0	1.0
Maximum	10.0	10.0	10.0	10.0	10.0
Std. Dev.	2.3	2.7	2.4	3.3	2.6

3.3.5 Component Risk - Water: Source

The risk associated with the source has a mean score of 7.5. The mean source risk score by type of source is:

• groundwater at 6.2
• groundwater under the direct influence of surface water (GUDI) at 9.5
• surface water at 8.6
• Municipal Type Agreement (MTA) at 1.9.

The data indicates that systems that rely on surface water or groundwater under the direct influence of surface water (GUDI) water typically have a higher component risk score than systems that rely on groundwater. The risk formula automatically assigns a higher base risk to these types of systems.

The following figure identifies the drivers that contribute to source risk scores.

Figure 3.7 - Source Risk Drivers

Detailed description of Figure 3.7

3.3.6 Component Risk - Water: Design

The risk associated with the design has a mean score of 5.4. The mean design risk score by type of source is:

• groundwater at 5.3
• groundwater under the direct influence of surface water (GUDI) at 7.2
• surface water at 5.5
• Municipal Type Agreement (MTA) at 3.2.

The higher design risk for the GUDI sources is associated with the relatively recent requirement for GUDI sources to meet treatment levels equivalent to those required for surface water. If the system was developed prior to this change, as a groundwater source, rather than GUDI, then it would not provide the required level of treatment. Of the 13 GUDI systems, 1 has direct use of raw water, 2 are equipped with disinfection only, and 2 additional systems do not have adequate filtration. The remaining systems use cartridge, granular media or membrane filtration, and their effectiveness varies.

As part of the multi-barrier approach to water treatment, chlorination is now required for all water systems. Typically, a groundwater system has an increased design risk if it does not have a disinfection system in place, or if there is insufficient contact time to ensure that the chlorination process is adequate.

There are several key drivers of the region’s design risk scores, including:

• failure to meet the Guidelines for Canadian Drinking Water Quality (GCDWQ)
• exceeding the GCDWQ Maximum Acceptable Concentration (MAC) for bacteria
• no disinfection system in place or a disinfection system that is not being used
• no appropriate treatment in place to meet INAC’s Protocol requirements
• problems with system reliability
• systems approaching or exceeding design capacity
• inappropriate waste management.

Figure 3.8 - Design Risk Drivers

Detailed description of Figure 3.8

It should be noted that the design risk drivers in red result in the entire water system being given a high risk score, regardless of all of the other component risk scores.

3.3.7 Component Risk - Water: Operation

The risk associated with operation has a mean score of 6.9. The mean operation risk score by type of source is:

• groundwater at 7.2
• groundwater under the direct influence of surface water (GUDI) at 7.3
• surface water at 7.0
• Municipal Type Agreement (MTA) at 5.3.

Areas that increased risk include operators not maintaining records, operators not having or not using approved Operation & Maintenance manuals, and operators not scheduling and performing maintenance activities. Increased effort focused on these areas would result in lowering both the component and overall risk scores.

There are several key drivers of the region’s operation risk scores, including:

• failure to meet the Guidelines for Canadian Drinking Water Quality (GCDWQ)
• exceeding the GCDWQ Maximum Acceptable Concentration (MAC) for bacteria
• maintenance logs being inadequately maintained
• lack of general system maintenance
• Emergency Response Plan not in place or not in use
• no Operation & Maintenance manual or Operation & Maintenance manual not being used.

Figure 3.9 - Operations Risk Drivers

Detailed description of Figure 3.9

Figure 3.10 - Summary of Findings: Water Systems Operational Practices

Detailed description of Figure 3.10

One or more major components are not working for 41% of the systems. Although the operators for 70% of the systems practice line flushing and 88% hydrant flushing, most do not regularly swab watermains, clean reservoirs or test fire pumps. Records of system maintenance and repairs were available for only 42% of the systems.

3.3.8 Component Risk - Water: Reporting

The risk associated with reporting has a mean score of 7.0. The mean reporting risk score by type of source is:

• groundwater at 7.7
• groundwater under the direct influence of surface water (GUDI) at 7.6
• surface water at 6.8
• Municipal Type Agreement (MTA) at 5.9.

Poor record keeping and reporting are significant drivers of reporting risk for all systems (70%), as is inconsistent record keeping (59%). For systems with a Supervisory Control and Data Acquisition (SCADA) system in place, an additional driver is that the instruments are not being calibrated to ensure that the information being recorded is accurate (24%).

An important consideration is that the systems were evaluated based on the requirements for monitoring and reporting as set out in INAC’s Protocol. Generally, monitoring and reporting being undertaken by the operators does not meet these requirements. Operator awareness and training could have a significant impact on these risk scores.

Figure 3.11 - Reporting Risk Drivers

Detailed description of Figure 3.11

3.3.9 Component Risk - Water: Operator

The risk associated with the operator has a mean score of 3.1. It should be noted that a more complicated system (based on treatment classification) requires an operator with a higher level of training. Operator Risk is higher for the more complicated systems, because systems with higher classifications appear less likely to have suitably certified staff. The mean operator risk score by type of source is:

• groundwater at 2.7
• groundwater under the direct influence of surface water (GUDI) at 2.7
• surface water at 3.4
• Municipal Type Agreement (MTA) at 2.3.

The extent to which existing systems have fully certified primary and backup operators is presented in Table 3.5. Of the 143 systems that require a certified operator for the water treatment system, 55% did not have a fully certified primary operator and 87% did not have a fully certified backup operator. Of the 150 systems that require a certified operator for the distribution system, 59% did not have a fully certified primary operator and 78% did not have a fully certified backup operator.

Table 3.5 - Water: Operator Status for Ontario Region

	Primary Operator		Backup Operator
	Treatment	Distribution	Treatment	Distribution
No. of Systems Currently Without an Operator	3	4	17	18
No. of Systems with Operator with No Certification	55	75	79	87
No. of Systems with Operator Certified but not to the Required Level of the System	20	9	29	12
No. of Systems with Operator with Adequate Certification	65	62	18	33
No. of Systems Not Requiring Operators with Certification	15	8	15	8
Total No. of Systems	158	158	158	158

Those factors which frequently contribute to increased operator risk are identified in Figure 3.12. A lack of certification, lack of training and the lack of primary or backup operator are common drivers that increase operator risk.

Figure 3.12 - Operator Risk Drivers

Detailed description of Figure 3.12

3.4 Wastewater Risk Evaluation

A risk assessment was completed for each wastewater system according to INAC’s Risk Level Evaluation Guidelines. The risk of each wastewater facility is ranked according to the following categories: effluent receiver, design, operation and maintenance, reporting, and operator. The overall risk score is a weighted average of the component risk scores.

Each of the five risk categories is ranked numerically from 1 to 10, as is the overall risk level of the entire system. A risk ranking of 1.0 to 4.0 represents a low risk, a risk ranking of 4.1 to 7.0 represents a medium risk, and a risk of 7.1 to 10.0 represents a high risk.

Of the 77 wastewater systems inspected:

• 28 are categorized as high overall risk
• 38 are categorized as medium overall risk
• 11 are categorized as low risk.

Appendix E.2 provides a table that summarizes the correlation between the component risk and the overall risk.

Figure 3.13 provides a geographical representation of the final risk for the wastewater systems that were inspected.

3.4.1 Overall System Risk by Treatment Classification

Figure 3.14 demonstrates the correlation between the mean overall system risk and the classification level of the treatment system. For MTA systems, it was assumed that the municipality operates their system in accordance with provincial legislation, which contributes to a lower overall risk for these systems.

For the Ontario region, it appears that a higher plant classification is positively correlated with a higher overall risk score, and that MTA systems have the greatest likelihood of being low risk.

Figure 3.13 - Ontario Wastewater System Risk

Detailed description of Figure 3.13

Figure 3.14 - Risk Profile Based on Wastewater Treatment System Classification

Detailed description of Figure 3.14

3.4.2 Overall System Risk by Number of Connections

For the Ontario region systems with less than 100 connections are more likely to be medium or high risk than systems with 100 or more connections.

3.4.3 Component Risks: Wastewater

The overall risk is comprised of five component risks: effluent receiver, design, operation, reporting and operators. Each of these component risk factors is discussed below.

Figure 3.15 - Wastewater: Risk Profile Based on Risk Components

Detailed description of Figure 3.15

	Effluent	Design	Operation	Reporting	Operator
Risk	6.7	4.7	7.4	7.1	5.1
Minimum	1.0	1.0	2.0	1.0	1.0
Maximum	10.0	9.0	10.0	10.0	10.0
Std. Dev.	2.7	2.2	2.1	3.5	3.4

3.4.4 Component Risk - Wastewater: Effluent Receiver

The risk associated with the effluent receiver has a mean risk score of 6.7. The mean effluent receiver risk source by treatment type is:

• Septic Systems at 4.3
• Aerated Lagoons at 8.0
• Facultative Lagoon at 6.5
• Mechanical Treatment 8.1
• Other at 5.0
• Municipal Type Agreement (MTA) at 3.0.

There are two key drivers of this risk component:

• the receiving environment
• the extent to which the receiver is required for other human uses, such as fishing, recreation or drinking water.

Figure 3.16 - Effluent Risk Drivers

Detailed description of Figure 3.16

3.4.5 Component Risk - Wastewater: Design

The risk associated with the design has a mean score of 4.7. The design component risk has the lowest mean component score.

There are several key drivers of the design component risk scores in the region, including:

• failure to meet federal Effluent Quality Guidelines
• inappropriate treatment process
• problems with system reliability
• no design flexibility
• system at or near capacity
• inappropriate waste management
• system identified as a dangerous workplace.

Figure 3.17 - Design Risk Drivers

Detailed description of Figure 3.17

3.4.6 Component Risk - Wastewater: Operation

The risk associated with the operation has a mean score of 7.4. All of the wastewater systems have a medium- or high-risk score. As a result, operation is identified as an area of opportunity for increased risk-mitigation efforts.

There are several key drivers of the operation risk in the region, including:

• failure to meet federal Effluent Guidelines
• inadequate maintenance logs
• general maintenance not being performed adequately
• Emergency Response Plans not in place or not being used
• Operation & Maintenance manuals not available or not in use.

Figure 3.18 - Operation Risk Drivers

Detailed description of Figure 3.18

3.4.7 Component Risk - Wastewater: Reporting

The risk associated with reporting has a mean score of 7.1. The reporting risk component assesses whether operators maintain effluent-testing and system-monitoring records. Poor record keeping is a significant factor in raising the overall risk ranking for many communities in this region.

There are several key drivers of the reporting risk in the region, including:

• inconsistent record keeping
• poor records for key parameters.

Figure 3.19 - Reporting Risk Drivers

Detailed description of Figure 3.19

3.4.8 Component Risk - Wastewater: Operator

The risk associated with the operator has a mean score of 5.1. Operator risk is determined by whether or not the operators have adequate certification.

The extent to which existing wastewater systems have fully certified primary and backup operators is presented in Table 3.6. Of the 71 systems which require a certified operator for the wastewater treatment system, 75% did not have a fully certified primary operator and 93% did not have a fully certified backup operator. Of the 71 systems which require a certified operator for the collection system, 73% did not have a fully certified primary operator and 93% did not have a fully certified backup operator.

Table 3.6 - Wastewater: Operator Status for Ontario Region

	Primary Operator		Backup Operator
	Treatment	Collection	Treatment	Collection
No. of Systems Currently Without an Operator	10	9	21	21
No. of Systems with Operator with No Certification	37	38	43	43
No. of Systems with Operator Certified but not to the Required Level of the System	6	5	2	2
No. of Systems with Operator with Adequate Certification	18	19	5	5
No. of Systems Not Requiring Operators with Certification	6	6	6	6
Total No. of Systems	77	77	77	77

Those factors which frequently contribute to increased wastewater operator risk are identified in Figure 3.20. A lack of certification, lack of training and the lack of primary or backup operator are common drivers that increase operator risk.

Figure 3.20 - Operator Risk Drivers

Detailed description of Figure 3.20

3.5 Plans

Information was collected regarding the availability of various documents, including Source Water Protection Plans (SWPP), Maintenance Management Plans (MMP), and Emergency Response Plans (ERP).

The following tables provide a summary of the percentages of First Nations that have plans in place:

Table 3.7 - Plans Summary: Water

Source	Percentage of Water Systems that have a (an)...
	Source Water Protection Plan	Maintenance Management Plan	Emergency Response Plan
Groundwater	23%	33%	21%
Groundwater GUDI	8%	23%	46%
MTA	N/A	17%	42%
Surface Water	6%	21%	21%
Overall	11%	24%	25%

Table 3.8 - Plans Summary: Wastewater

Percentage of Wastewater Systems that have a (an)…
Maintenance Management Plan	Emergency Response Plan
8%	6%

3.5.1 Source Water Protection Plans

Source water protection planning is one component of a multi-barrier approach to providing safe drinking water. Source Water Protection Plans seek to identify threats to the water source. They also establish policies and practices to prevent contamination of the water source and to ensure that the water service provider is equipped to take corrective action in the event of water contamination. Source water protection is appropriate for groundwater and surface water sources.

Only 11% of the systems reported that they had completed a Source Water Protection Plan.

3.5.2 Maintenance Management Plans

Maintenance Management Plans are intended to improve the effectiveness of maintenance activities. They focus on planning, scheduling and documenting preventative maintenance activities, and they document unscheduled maintenance efforts. The plans represent a change from reactive to proactive thinking, and—when executed properly—they optimize maintenance spending, minimize service disruption, and extend asset life.

Only 24% water systems and 8% wastewater systems indicated that they had completed a Maintenance Management Plan.

3.5.3 Emergency Response Plans

Emergency Response Plans (ERPs) are intended to be a quick reference to assist operators and other stakeholders in managing and in responding to emergency situations. Emergency Response Plans should be in place for both water and wastewater systems. They include key contact information for those who should be notified and who may be of assistance in case of emergency (agencies, contractors, suppliers, etc.), and they provide standard communication and response protocols. Emergency Response Plans identify recommended corrective actions for “foreseeable” emergencies, and they establish methodologies for addressing unforeseen situations. They are essentially the last potential “barrier” in a multi-barrier approach to protecting the drinking water supply and the natural environment, and they provide the last opportunity to mitigate damages.

Only 25% of the water systems and 6% of the wastewater systems have an Emergency Response Plan in place.

4.1 Upgrade to Meet INAC’s Protocol: Water

In 2006, INAC began to develop a series of Protocol documents for centralised and decentralised water and wastewater systems in First Nations communities. The Protocols contain standards for the design, construction, operation, maintenance, and monitoring of these systems.

One of the objectives of this study was to review the existing water and wastewater infrastructure, and to identify the potential upgrade costs to meet INAC’s Protocols, and federal and provincial guidelines, standards and regulations. The total estimated construction cost for water system upgrades to meet the INAC Protocol is $228 million.

Table 4.1 provides a breakdown of the estimated total construction costs. A separate line item is included for engineering and contigency. Figure 4.1 provides a comparison graph of each of the categories. Note that Treatment and Storage & Pumping comprise 62% of the estimated costs.

Table 4.1 - Estimated Total Construction Costs: Water

Description	Protocol - Estimated Cost	Federal - Estimated Cost	Provincial - Estimated Cost
Building	$14,121,700	$1,514,500	$8,842,800
Distribution	$6,065,000	$1,066,000	$2,160,000
Equipment	$2,370,600	$2,300,500	$2,301,800
Additional Fire Pumps	$2,231,000	$140,000	$2,181,000
Monitoring Equipment	$2,047,200	$1,695,700	$2,047,200
Source	$5,826,350	$1,191,800	$5,790,850
Storage & Pumping	$32,985,500	$32,036,500	$32,876,500
Treatment	$109,353,600	$94,187,110	$102,798,110
Standby Power	$7,423,000	$490,000	$7,423,000
Engineering & Contingencies	$45,687,500	$33,744,050	$41,686,500
Construction Total Estimate	$228,111,450	$168,366,160	$208,107,760

There are 27 water systems that may have groundwater-under-the-direct-influence-ofsurface-water (GUDI) water supplies. Upgrade costs for these systems are estimated assuming that they will prove to be secure groundwater supplies and recommendations for GUDI studies are identified to confirm this.

If the GUDI studies indicate that these supplies should be considered to be surface water rather than groundwater, then additional upgrade requirements will be necessary for these systems to meet INAC’s Protocols. It is estimated that, depending on system capacity and site indices, an additional $1.0 to 2.5 million will be required for each system that needs to be upgraded to surface-water treatment.

Figure 4.1 - Breakdown of the Estimated Construction Costs to Meet INAC’s Protocol: Water ($ - M)

Detailed description of Figure 4.1

Treatment and Storage and Pumping comprise two of the major construction-cost categories.

Treatment costs include:

• Providing spare chemical feed equipment.
• Providing spare disinfection equipment.
• Providing secondary containment for treatment chemicals.
• Providing additional filter trains to meet Protocol.
• Providing treatment to meet Protocol.
• Providing secondary disinfection.
• Providing contact piping.
• Providing surge suppression/uninterruptible power supplies for critical electronic equipment.
• Upgrading capacity of existing water treatment plant.

Storage & Pumping costs include:

• Expanding storage for chlorine contact and/or fire protection and domestic flows.
• Providing screened reservoir vents.
• Providing secondary containment liners for onsite fuel storage.
• Retrofitting existing reservoirs to include baffling (concrete and/or curtain).
• Providing additional raw water pumping capacity.
• Providing additional highlift pumping capacity.
• Providing backwash pump.
• Upgrading fire pump systems.

Table 4.2 - Estimated Total Non- Construction Costs: Water

Description	Protocol - Estimated Cost	Federal - Estimated Cost	Provincial - Estimated Cost
Training	$1,740,000	$1,740,000	$1,740,000
GUDI Studies	$1,456,000	$0	$1,456,000
Plans/Documentation	$8,824,000	$6,739,000	$8,804,000
Studies	$1,558,000	$980,000	$1,455,000
Non-Construction Total Estimate	$13,578,000	$9,459,000	$13,455,000

Additional annual operations and maintenance costs, shown in Table 4.3, include costs that occur annually for items that are not currently being completed to meet protocols, such as calibrating monitoring equipment, additional sampling, cleaning the reservoir, and backup operator’s salary.

Table 4.3 - Estimated Additional Annual Operation & Maintenance Costs: Water

Description	Estimated Cost
Sampling	$2,503,550
Operations	$562,500
Operator	$970,000
Water O&M Total Estimated Cost	$4,036,050

The total estimated cost, including construction and non-construction costs, for water system upgrades to meet the INAC Protocol is $242 million. This excludes costs associated with potentially GUDI systems, which prove to be GUDI systems as discussed previously.

4.2 Upgrade to Meet Protocol: Wastewater

The total estimated construction cost for wastewater system upgrades to meet INAC Protocol is $64 million. Below is a list of specific needs of the systems, the number of systems impacted by upgrades,and the total cost of each need.

Upgrading treatment and providing standby power will account for over 68% of the cost of meeting INAC Protocol. Providing standby power is a widespread necessity, but the upgrades cost less than upgrading treatment.

Table 4.4 - Estimated Total Construction and Related Costs: Wastewater

Description	Protocol - Estimated Cost	Federal - Estimated Cost	Provincial - Estimated Cost
Building	$1,743,000	$185,000	$1,358,000
Collection System	$1,835,500	$1,792,500	$1,821,500
Equipment	$1,232,000	$1,227,000	$1,227,000
Monitoring Equipment	$1,208,000	$165,500	$1,189,000
Pumping Stations	$1,663,000	$1,533,000	$1,663,000
Treatment	$31,713,500	$31,058,000	$31,333,500
Standby Power	$11,582,000	$11,455,000	$11,880,500
Engineering & Contingencies	$12,752,150	$11,849,450	$12,620,350
Construction Total Estimate	$63,729,150	$59,265,450	$63,092,850

Figure 4.2 - Breakdown of the Estimated Construction Costs to Meet Protocol: Wastewater ($ - M)

Detailed description of Figure 4.2

Treatment and Standby Power comprise two of the major construction-cost categories.

Treatment costs include:

• General upgrades to existing infrastructure.
• Expanding existing system to meet current capacity.
• Providing redundant chemical feed equipment.
• Providing additional sewage pumps.
• Providing fence for security.
• Providing treatment for sludge wastes.
• Providing disinfection (UV or chlorine).

Standby Power costs include:

• Providing standby power for sewage pumping stations.
• Providing standby power for sewage treatment plant.

Table 4.5 - Estimated Total Non-Construction and Related Costs: Wastewater

Description	Protocol - Estimated Cost	Federal - Estimated Cost	Provincial - Estimated Cost
Training	$745,000	$745,000	$745,000
Plans/Documentation	$2,412,500	$1,559,500	$2,382,500
Studies	$90,000	$70,000	$70,000
Non-Construction Total Estimate	$3,247,500	$2,374,500	$3,197,500

Additional annual operations and maintenance costs, as shown in Table 4.6, include costs that occur annually, for items that are not currently being completed to meet protocols, such as calibrating monitoring equipment, additional sampling, and backup operator’s salary.

Table 4.6 - Estimated Additional Annual Operation & Maintenance Costs: Wastewater

Description	Estimated Cost
Sampling	$316,400
Operations	$204,000
Operator	$935,000
Wastewater O&M Total Estimated Cost	$1,455,400

The total estimated cost, including construction and non-construction costs, for wastewater system upgrades is $67 million.

4.3 Upgrade Cost Summary

Table 4.7 provides a summary of the upgrade costs for systems to meet INAC’s Protocol, and federal and provincial guidelines and standards.

Table 4.7 - Summary and Comparison of Upgrade Costs

	Total Estimated Cost
	Water	Wastewater
Upgrade to meet Protocol	$241,689,450	$66,976,650
Upgrade to meet Federal Guidelines	$177,825,160	$61,639,950
Upgrade to meet Provincial Guidelines	$221,562,760	$66,290,350

The following tables present a breakdown of the estimated upgrade costs to meet INAC Protocols by overall risk level.

Table 4.8 - Breakdown of Protocol Estimated Costs by Risk Level: Water

Risk Level	Short Term	Long Term	Total
High	$130,350,702	$0	$130,350,702
Medium	$99,987,349	$12,331	$99,999,680
Low	$11,289,744	$49,324	$11,339,068
Total	$241,627,795	$61,655	$241,689,450

Table 4.9 - Breakdown of Protocol Estimated Costs by Risk Level: Wastewater

Risk Level	Short Term	Long Term	Total
High	$28,969,135	$80,286	$29,049,421
Medium	$35,413,034	$0	$35,413,034
Low	$2,514,195	$0	$2,514,195
Total	$66,896,364	$80,286	$66,976,650

4.4 Asset Condition and Reporting System Needs

Asset Condition and Reporting System (ACRS) inspections were completed for all water- and wastewater-related assets. The following table summarizes the ACRS needs identified. For the purposes of this assessment, ACRS needs were limited to required repairs of existing facilities, and did not include any upgrade costs, in order to avoid duplication with the Upgrade to Protocol needs identified. The following two tables (Tables 4.10 and 4.11) provide a summary of the O&M repairs required broken down by asset for both water and wastewater, respectively.

Table 4.10 - Asset Condition and Reporting System Identified Operation & Maintenance Costs: Water

Asset Code	Description	Estimated Cost
A5A	Buildings	$636,750
B1B	Watermains	$1,058,100
B1C/B1D	Treatment	$2,336,950
B1E	Reservoirs	$212,770
B1G	Standpipe/Truckfill	$18,000
B1F	Community Wells	$205,600
B1I	Low Lift Pumping	$789,400
B1H	High Lift Pumping	$251,650
E4A	Trucks	$59,000
B1Z	Other	$28,750
	Water ACRS Total Estimated Cost	$5,596,970

Table 4.11 - Asset Condition and Reporting System Identified Operation & Maintenance Costs: Wastewater

Asset Code	Description	Estimated Cost
A5B	Buildings	$101,075
B2A	Sewers	$1,091,600
B2H/B2J	Lift Stations & Forcemains	$1,071,310
B2C/B2D	Treatment	$921,850
B2E/B2I	Lagoons	$1,530,550
B2F	Septic Systems	$6,700
E3A	Trucks	$10,200
	Wastewater ACRS Total Estimated Cost	$4,733,285

4.5 Community Servicing

An analysis was completed to evaluate future servicing alternatives for a 10-year design period. The analysis considers a variety of alternatives, including expanding existing systems, developing new systems, establishing local Municipal Type Agreements (if applicable), and using individual systems.

A theoretical operation and maintenance cost has been developed for each alternative, along with a 30-year life-cycle cost. The cost of the upgrades that are necessary for systems to meet INAC Protocol is included in the new servicing cost, if appropriate (i.e. for new servicing alternatives that include continued use of the existing system).

A summary of the capital cost along with the estimated total O&M cost for the recommended servicing alternatives is shown below.

Table 4.12 - Future Servicing Costs

	Total Estimated Cost		Cost Per Connection
	Water	Wastewater	Water	Wastewater
Future Servicing Cost	$700,000,000	$440,000,000	$21,800	$13,600
Annual O&M to service future growth	$51,100,000	$42,200,000	$1,600	$1,300

The majority of communities in the Ontario region are at least partially serviced by a piped water system, and slightly more than half are at least partially serviced by a piped collection system.

The evaluation of future servicing included continuing to service the existing population with the same level of service that was currently in place and then evaluating the options for providing service to the future 10 year growth for the community. Existing servicing includes piped, trucked and individual servicing. In some cases, where future servicing resulted in the ability to provide a higher level of service to some or all of the existing homes this was also considered in the overall servicing strategy.

Predominantly, it was found that the life cycle costs for extending piped water and wastewater servicing for the future growth was the most cost effective solution. This assumes that future homes would be constructed in a compact subdivision type setting adjacent to the existing serviced area. This however will need to be confirmed through detailed studies for each community. It is realized that some residents may choose to continue to build homes in outlying areas where individual wells or truck haul servicing may be more appropriate.

All but one of the 121 First Nations with water/wastewater assets in the Ontario Region were visited during the completion of this project. Of the 120 First Nations visited, 103 are serviced by community water systems, 12 are serviced by Municipal Type Agreements with neighbouring municipalities, and 5 are serviced by individual water systems. Surface water community systems are the most common (59%). All but two of the community systems include piped distribution for at least part of the community, and 69% of the overall homes are provided with piped service.

There are a total of 77 wastewater systems serving 67 First Nations. The remaining 54 First Nations are serviced solely by individual wastewater systems. 6 out of the 77 community wastewater systems are serviced by Municipal Type Agreements with neighbouring municipalities. Lagoons are the most common (49%) wastewater system. Regionally, 35% of the homes have piped collection and 57% of the homes are serviced by individual septics.

There are 72 water systems and 28 wastewater systems in the Ontario region identified as high-risk systems. While there are multiple factors contributing to risk, design and operational concerns are given the most weight, particularly when the concern is related to the protection of public health or the environment. The high risk systems in the region typically require system upgrades or improved operational procedures to meet the guidelines for treated water quality or sewage effluent quality.

The total estimated construction cost to bring the region into compliance with INAC’s Protocol for Safe Drinking Water in First Nations Communities is $228 million. An additional $13.6 million is required to address non-construction costs. This estimate excludes the costs associated with upgrading sites that may prove to have groundwater under the direct influence of surface-water (GUDI) sources.

The total estimated construction cost to bring the region into compliance with INAC’s Protocol for Wastewater Treatment and Disposal in First Nations Communities is $63.7 million. An additional $3.2 million is required to address non-construction costs.

In Ontario, since the Walkerton Incident in May 2000, there have been sweeping regulatory changes that affect the design, approval and operation of provincial water systems. All municipal systems have a legislated minimum level of treatment. Similarly, the Ontario Ministry of Environment Design Guidelines and INAC Protocol include increased focus on the redundancy of equipment to ensure the necessary processes are in place. According to the Ontario Ministry of the Environment’s Design Guidelines for Drinking Water Systems,

“The design of water treatment plants should be based on the premise that failure of any single component must not prevent the drinking-water system from satisfying all applicable regulatory requirements and other site specific treated water quality and quantity criteria, while operating at design flows.”

Very few First Nation systems in Ontario have been designed to this level of redundancy. A number of First Nation systems have received disinfection upgrades, including the addition of chlorination systems equipped with auto-switchover and alarm capabilities. In many instances, however, this equipment was not fully functional at the time of the site visits.

Based on the data collected, a significant area to reduce risk would be to ensure that all systems are operated and maintained by trained/certified operators and that monitoring and record keeping is completed in accordance with the INAC’s Protocol.

There are a significant number of surface water treatment systems in the province that require operators with higher certification levels. A number of remote (winter road only) northern communities have surface water treatment plants. The remote nature of these communities makes it more difficult for the operators to obtain the required training and to maintain appropriate supplies on hand. A number of these facilities operate under the Safe Water Operations Program (SWOP), with direct third-party oversight, which generally results in improved operations and record keeping.

The Province of Ontario has recently introduced changes in the system and operator classification. As such, operators with existing certifications may no longer be fully consistent with these changes. In addition, Ontario has introduced the concept of Overall Responsible Operator and Operator in Charge, and now requires operating authorities to be accredited, a process which includes the preparation of financial plans and the development of drinking water quality management plans.

Another area that INAC, Health Canada and Band Councils need to address is the lack of planning tools, including Source Water Protection Plans (SWPPs), Operation & Maintenance (O & M) Manuals, and to a much lesser extent Emergency Response Plans (ERPs).

The comments received from individual First Nations voice a general feeling among the First Nation communities that current Operation & Maintenance budgets are often insufficient to retain operators, to provide ongoing component replacement, and to perform all of the monitoring and recording requirements. Many site inspectors saw missing equipment or equipment in disrepair and were informed that repairs have not been completed because of a lack of funding.

Wastewater sampling prior to effluent discharge appears to be another area that INAC, Health Canada and Band Councils could address in order to reduce the overall risk significantly. Sampling, testing and recording the effluent quality and volumes prior to and during discharge would reduce the reporting risk for these systems.