I am providing a single set…

I am providing a single set of comments in response to the policy and regulation proposals in the following postings on the Environmental Registry of Ontario: ERO #019-6951, ERO #019-6853, ERO #019-6963, and ERO #019-6928 ("ERO Proposals"), as these proposals are intended to implement a single package of regulatory changes.

The ERO Proposals apply to:

• certain waste management systems that involve asbestos waste, biomedical waste, treated biomedical waste, hazardous waste, liquid industrial waste, and treated waste that can not be disposed of by land;

• stormwater management; and

• water-taking for construction sites dewatering activities and foundation drains.
I am extremely concerned that the ERO Proposals would result in a lack of Government oversight and public scrutiny in relation to the above noted activities.

In particular, the ERO Proposals would have the result that there will no longer be prior, detailed reviews by Ministry of Environment staff to assess the potential environmental impacts from the above noted-activities.

Equally concerning is that the ERO Proposals would have the result that the Environmental Bill of Rights, 1993 (and, in particular, public participation and appeal rights of this Act) would no longer apply to the above-noted activities.
In summary, the ERO Proposals would lead to a regulatory regime whereby the above-noted activities would no longer be subject to either government or public scrutiny before commencing operation in Ontario.

Rather, the Ontario government would merely have the specified activities self-registered under a public registry.

We are all only too aware of what happened in the 2000 Walkerton e coli outbreak that resulted from lack of regulatory rigor in inspecting and enforcing public health and environmental regulations.

The Walkerton comparison is apt as,

• the ERO Proposals apply to management systems that transport and store waste (in particular, asbestos waste, hazardous waste, and biomedical waste) which have the potential to cause serious harm to our health and the natural environment,

• improper management of wastewater and stormwater has the potential to cause serious impacts to freshwater systems and safe drinking water, and

• removing the requirement to inform Conservation Authorities about water-taking limits their ability to protect drinking water sources.
An additional concern with the ERO Proposals is that they would allow, without prior government regulatory review, up to 379,000 litres of groundwater-taking per day without a permit, an amount which has the potential to threaten aquifers, impacts wells, and strains municipal infrastructure.

I strongly oppose the ERO Proposals and would request that they not be implemented.