How Waterloo, Ontario Adapted to Regulatory Changes

By Chase Mendell and Anthony Abbruscato | January 2025

In 2023, the Ministry of the Environment, Conservation and Parks (MECP) in Ontario introduced the Consolidated Linear Infrastructure Environmental Compliance Approvals regulatory framework (CLI-ECA) to modernize how the province manages municipal wastewater collections and stormwater management systems.

This change aimed to streamline processes for mu­nicipalities while maintaining high environmental stan­dards. The CLI-ECA grants municipalities and prescribed developers preauthorization on certain infrastructure projects, provided specific conditions are met.

This flexibility simplifies processes, but comes with stricter requirements for monitoring system performance, inspecting and maintaining infrastructure, and reporting overflows or spills. This balance of flexibility and account­ ability fosters an environment that encourages innovation and the adoption of advanced tools and strategies.

Waterloo Embraces Condition-Based Maintenance

Responsible for more than 260 miles of small-diameter – less than 24-in. – sanitary gravity sewers, the City of Waterloo has implemented a condition­ based maintenance program to optimize its sewer management. Traditionally, most municipalities use a time-based or rotational maintenance program that cleans all assets on a fixed schedule.

These time-based programs range from a one-year to a 12-year cycle depending on the utility with a five-year cycle being most common. These programs also sometimes include a “trouble spot” or hot spot cleaning program with shorter cycles overlayed on top. In contrast, condition­ based programs assess the health of assets before making maintenance decisions.

Transitioning to a condition-based maintenance program requires reallocat­ing resources. While th.is can sometimes stall any change, the CLI-ECA’s require­ments for documented inspections and maintenance have inspired municipali­ties to consider new approaches.

Waterloo partnered with Rapid Assess­ment Technology Services Inc. (RATS Inc.) to deploy the Sewer Line Rapid Assess­ment Tool (SL-RAT). The SL-RAT uses trans­ missive acoustics to assess pipe blockage conditions between maintenance holes. Its transmitter and receiver components are placed on adjacent maintenance holes. The transmitter sends a series of tones through the pipe and the receiver listens for the known signal. The receiver then assigns a score from O (fully obstructed) to 10 (sig­nificant excess flow capacity).

The simplicity and inspection speed of the SL-RAT make it an ideal tool for municipali­ties, like Waterloo, who are transitioning to a condition-based maintenance. The device requires no flow contact or confined space entry, enabling RATS Inc.’s two-person crew to inspect more than 2.5 miles per day.

RATS Inc., headquartered in Vaughan, Ontario, is the provider of this service across the province. Their expertise al­ lows municipalities like Waterloo to in­tegrate technology effectively into their workflows.

As Anthony Abbruscato, Partner (RATS Inc.), describes, “Our goal is to help mu­nicipalities across the province transition from a time-based sewer maintenance practice over to a condition-based one by leveraging innovative technology. By facilitating this, utility owners can fully optimize the workflow for their wastewa­ter collection systems, allowing for system resiliency through enhanced cleaning and inspection scheduling, while demonstrat­ing to the MECP (regulators) a robust sew­er operations and maintenance program under the CLI-ECA.”

Early Success and Future Goals

The full program with Waterloo will span three years, aiming to benchmark their entire gravity sewer system. In the first year alone, RATS Inc. inspected ap­proximately 110 miles of sewer lines, iden­tifying areas for targeted maintenance. Alongside acoustic inspections, RATS Inc. also facilitated a maintenance hole in­spection program. On average, an SL-RAT crew will open 30 to 50 maintenance holes per workday. By recording this additional high-level condition information, Water­ loo will gain additional insights into their system health.

The results from the first year demon­strate the program’s success. Of approxi­mately 2,800 pipes inspected, only 5 per­ cent required further maintenance. Given that cleaning gravity sewer pipes can cost upwards of $SCAD per meter, any potential reduction in cleaning yields significant di­rect and indirect cost savings.

The shift to condition-based mainte­nance also brings significant environmen­tal advantages. For instance, the program is estimated to have conserved over two million litres of flushing water. Avoiding unnecessary cleaning further reduced energy consumption associated with running flushing trucks, lowering green­ house gas emissions tied to maintenance activities. Additionally, reduced wear and tear on equipment, like cleaning trucks, not only extends their lifespan but also decreases long-term capital expenditures and operational costs. Finally, proactively addressing problematic pipes across a broader swath of the network also significantly reduces the risk of sanitary sewer overflows (SSOs) and basement backups.

Moreover, the CLI-ECA emphasis on record-keeping and regular monitoring ensures that municipalities like Waterloo maintain consistent oversight of their systems. The data collected through this pro­ gram can identify trends in system health, enabling better long-term planning, capi­tal improvement planning, and resource allocation. This proactive approach en­sures that municipalities remain resilient in the face of evolving regulatory and en­vironmental challenges.

At its core, Ontario’s CLI-ECA aims to increase flexibility while upholding high standards for system performance and environmental protection.

“The SL-RAT technology allowed Wa­terloo to enhance operational knowledge of the sanitary sewer network, meet new CLI-ECA regulatory obligations, inform on a risk-based CCTV inspection and repair program, and will allow us to optimize our operational budget to address risk,” says Leigh McDermott, director city utili­ties at the City of Waterloo.

By leveraging innovative technology like the SL-RAT, Waterloo has not only met regulatory requirements but has also achieved measurable benefits. Waterloo’s condition-based maintenance program has reduced costs, conserved water, mini­mized environmental risks, and allowed for smarter resource allocation.

Waterloo’s proactive and data-driven approach stands as a model for mu­nicipalities across Ontario, proving that modern regulations can inspire practi­cal innovations. By aligning regulatory compliance with advanced technology and sustainability goals, the City of Wa­terloo demonstrates how thoughtful ad­aptation to new frameworks can deliver lasting benefits for both communities and the environment.

Chase Mendell is the marketing and system operations manager at lnfoSense and Anthony Abbr­uscato is a partner at RATS Inc.