I am writing to strongly…

I am writing to strongly oppose this proposed regulation.

This proposal is being described as “streamlining,” but in reality it removes important public safeguards for communities that may be directly affected by major waste-site changes. Service area and fill rate are not minor administrative details. They determine where waste can come from, how much waste can be accepted, how many trucks may enter a community, how quickly a landfill or dump may fill, and what level of environmental, health, infrastructure, and emergency-response risk a host community may face.

The current Environmental Screening Process exists for a reason. It requires potential environmental effects to be identified and assessed, mitigation measures to be considered, and Indigenous communities, municipalities, and interested members of the public to be engaged before changes proceed. Removing that process weakens transparency and public trust.

I am especially concerned that the proposal would also remove the requirement for these ECA amendment applications to be posted on the Environmental Registry of Ontario and would remove related third-party appeal rights under the Environmental Bill of Rights. That means residents may lose the ability to even know about a major change before it is approved, and may also lose meaningful appeal rights afterward. That is not acceptable.

Dresden, Ontario is a clear example of why this matters. Our community has already experienced the fear, confusion, and loss of trust that happens when a waste site proposal raises serious questions about truck traffic, dust, odour, groundwater, surface water, wells, nearby homes, nearby schools, agricultural land, road safety, emergency response, and long-term liability. Communities should not have to fight after the fact for basic information about projects that could affect their health, water, roads, property, and quality of life.

An ECA review alone is not a substitute for public environmental assessment, public notice, public comment, and appeal rights. Adjacent landowner notification is not enough. Waste-site impacts do not stop at the fence line. A change in service area or fill rate can affect an entire town, surrounding farms, neighbouring municipalities, watersheds, Indigenous rights and interests, and public infrastructure.

If Ontario wants to maintain public confidence, then decisions about waste capacity must be transparent, evidence-based, and open to public scrutiny. Reducing costs and timelines for operators should not come at the expense of environmental protection, Indigenous consultation, municipal input, or community rights.

I respectfully request that the Ministry:

1. Withdraw this proposal in its current form.

2. Keep the Environmental Screening Process requirement for service-area and fill-rate changes, especially where the proposed change would materially increase waste volume, expand the geographic source of waste, increase truck traffic, or affect communities, waterways, wells, agricultural land, or sensitive environmental areas.

3. Keep ERO posting requirements for ECA amendment applications involving service-area and fill-rate changes.

4. Keep Environmental Bill of Rights appeal rights for affected residents, municipalities, Indigenous communities, and public-interest participants.

5. Require full public disclosure of supporting studies, including traffic, hydrogeology, surface water, stormwater, leachate, odour, dust, noise, air emissions, fire risk, emergency response, financial assurance, site history, and cumulative-impact assessments.

6. Require meaningful municipal input and clear consideration of local land-use planning, infrastructure burden, road safety, and community compatibility.

7. Ensure that Indigenous consultation is not narrowed, rushed, or treated as a box-checking exercise.

8. Include protections so that existing or active waste-site proposals cannot use any new regulation to avoid public review, ERO posting, appeal rights, or community scrutiny.

Ontario should not weaken public oversight over waste facilities. Waste decisions have long-term consequences. Once groundwater, surface water, soil, roads, public trust, or community safety are damaged, the harm may not be easily repaired.

For these reasons, I strongly oppose ERO 026-0414 and ask the Ministry to maintain strong environmental assessment, public notice, public participation, and appeal rights for waste disposal site service area and fill rate changes.