For the Proposed regulatory…

ERO number

019-6853

Comment ID

93755

Commenting on behalf of

Groundwater Environmental Management Services Inc. (GEMS)

Comment status

Comment approved More about comment statuses

Comment

For the Proposed regulatory amendments to O. Reg. 63/16 under the Environmental Protection Act
1. What defines “more complex water taking” that will be subject to the ministry review? How is that triggered? Will there be a review period?
2. Is there a new proposed upper water-taking limit? Or will short-term PTTW applications for construction dewatering become obsolete?
3. Is there a timeline limit for short-term construction dewatering? Especially for multi-phase projects that can go on for years/decades?

For Proposed regulatory amendments to O. Reg. 387/04 under the Ontario Water Resources Act
1. Will the MECP require a HydroG report for foundation drainage under 379,000 L/day?
2. Similar to the EASR, are there "more complex foundation drainage water taking" that would trigger an MECP review?

For Seeking feedback on municipal sewer-use bylaws
We work closely with developers and municipalities and have encountered this issue on several developments. We would be happy to provide feedback. We have been informed by several municipalities that they are not going to change their sewer use by-law, which is the by-law that dictates what can be received by sewers and if long-term filtration is required.
1. Is completing an analysis on the sewer outlet being proposed to determine the relevant criteria?
2. Is completing ongoing annual testing of the foundation drainage to the sewer being proposed?
3. What is proposed if the foundation drainage doesn't meet the criteria years after the building is completed? It may not be feasible to implement filtration once the building is completed.

For the comment: Furthermore, Ontario is proposing to remove the current requirements to notify the local conservation authority of the water taking to align with changes to the Conservation Authorities Act.
1. Are there any circumstances where we do need to notify the CA?

Overall
1. Is there a proposed timeline for when these proposed changes will be implemented?
2. For an issued EASR or PTTW, does the owner remain responsible for implementing the recommended monitoring and mitigation in the supporting reports?