Firstly, I am glad to see the the consultation with First Nations is now back to the Ministry rather than the applicant, the Federal adoption of UNDRIP would have made this an issue.
Secondly, the science is not the applicants but the Ministry's but am not sure how this can be done in a Ministry under funded and under staffed especially with the Conservation Authorities and their expertise hobbled so badly.
Also, the priorities of use ought to be moved up to earlier in the process to save wasting time in the face of water use conflicts.
What happened to transparency of data that was in the proposal but appears to have vanished now? This is crucial for an informed and democratic process and informed oversight!
Some of this is just wrong headed however. The length of permits from 5 to 10 years is irresponsible and dangerous. Circumstances change especially in this time of rapid, unchecked climate change!
The reduction of time on the ERO is way too short to get word out and get research together in order to make proper responses. The 90 days is much better!
How are environmental needs established and monitored? Will they actually be considered at all by governments that disregard environmental considerations?
The impacts of planned municipal use does not allow municipalities to plan ahead for future needs. Wells that have already been approved is too restrictive for a community that needs new wells and must get approvals before those wells are considered. Planning requires some degree of certainty as the growing demands for water come from so many sources.
Some positives here and some get back to the drawing board on crucial segments!
Submitted December 15, 2020 3:43 PM