Greetings: While there is…

Greetings:
While there is benefit to reducing administrative requirements, the current system of limiting EASR's to a maximum allowable taking of 400,000 L/day should provide a good balance between professionals writing a report and making professional judgements of monitoirng requirements without direct ministry review, vs. the need for direct ministry review.

Water takings greater than 400,000 L/day can have increasingly large and sometimes unforeseen zones of influence, affecting areas more than a kilometer from the construction site. Professional judgement may not envision this fully, and, other groundwater users 500 meters or more from a construction site may not realize what is impacting their groundwater resources, where it is, or be able to find out more information, easily. That is one reason where / why ministry oversight is necessary to ensure that professionals are making sound judgement, and not cutting corners for economic benefit of the client or their organization.

In addition, a full PTTW review triggers notifications to conservation authorities, indigenous groups, and other interested / affected parties, and a poor review or lack of consultation can have unfortunate and costly impacts and / or result in significant or even irreparable damage to ecosystems, or create unnecessary tensions with landowners and special interest groups who may be affected by such a project. Given that construction dewatering can go on for years, as authorized by an EASR, this is important to consider, that, the professionals who prepared the hydrogeological assessment may have moved on and it may be difficult for affected landowners or special interest groups to reach a responsible party.