Hon. David Piccini, Minister…

Hon. David Piccini, Minister of Environment, Conservation and Parks
Ministry of Environment, Conservation and Parks
5
th Floor, 777 Bay Street
Toronto, Ontario
M7A 2J3
Delivered via email: minister.mecp@ontario.ca,
permissions.modernization@ontario.ca
September 18, 2023
Re: Request for Public Comment Periods to be Extended for ERO Numbers 019-6928, 019-
6853, 019-6963, and 019-6951 to a Minimum of 145 Days
Dear Hon. David Piccini, Minister of the Environment, Conservation and Parks,
Transition to Less Waste (TTLW) is an Ontario based non-profit that seeks to protect and
improve the environment within the province. Our organization promotes key concepts from
the international Transition Movement including the reduction of waste-to-disposal, prudent
use of finite resources, and protection and improvement of land, air and water resources. We
believe that it is in the public interest to safeguard and enhance Ontario’s environment.
Our organization is asking for you to please use your discretion as the Minister of
Environment, Conservation and Parks (MECP) to extend the time period allotted for
comments on the concurrently posted ERO proposals numbered 019-6928, 019-6853, 019-
6963 and 019-6951 from 60 days, to a minimum of 145 days.
These proposals were presented on the Environmental Registry of Ontario (ERO) website on
August 31, 2023 under the umbrella of the MECP’s “Environmental Permissions Modernization”
package. We believe that the proposals, if implemented, have the potential to cause significant
effects on the environment. The proposals have been posted concurrently, with comment
periods all ending only 60 days later, on October 30, 2023.
The proposals were posted on the ERO as regulation and policy notice types from the
Province’s MECP under the following headings:
• Streamlining environmental permissions for stormwater management under the
Environmental Activity and Sector Registry
• Streamlining permissions for water takings for construction site dewatering activities
and foundation drains
TTLW Comment Period Extension Requests for ERO Numbers 019-6928, 019-6853, 019-
6963, and 019-6951
2
• Streamlining environmental permissions for waste management systems under the
Environmental Activity and Sector Registry
• Exploring changes to streaming the permit-by-rule framework
TTLW believes additional review time will allow more stakeholders and interested persons to
provide meaningful comments for the Ministry’s consideration. With the volume of materials
involved in a complete review of the proposals and associated acts, regulations, and policies, 60
days is not a realistic time period within which the public and other interested stakeholders,
could most effectively comment.
The public has shown through recent comment periods on issues involving Ontario’s
environment, and environmentally sensitive land uses, that there is a keen interest in
participating in decision making. There is deep concern among Ontario residents, regarding the
specific topics of waste transportation and disposal, self-reporting of compliance for
corporations, urban sprawl, and protection of natural systems; all topics encompassed within
the four proposals.
Protecting surface and groundwater resources that are the source of drinking water for all of
Ontario’s residents, is of the utmost importance; and has been a top issue of public concern in
the years following the devastating Walkerton tainted drinking water tragedy. Any proposals
involving alteration of Source Protection Plan processes will be of strong interest. Ontario’s
residents have demonstrated through tens of thousands of recent comments to the province,
and MECP, that they are engaged and interested stakeholders.
Providing a minimum of 145 days to comment would allow for enhancement of public
participation on these complex proposals that if implemented, would have the potential to
impact the entire Province of Ontario.
Sincerely,
Michael Farlow,
President, Transition to Less Waste (TTLW), on behalf of Transition to Less Waste
The comments contained in this letter represent the opinions held by the non-profit organization
Transition to Less Waste (TTLW). They are provided in response to ERO proposal numbers 019-
6928, 019-6853, 019-6963, and 019-6951, and related matters we believe may impact the
environment and public well-being in Ontario.