Dear Sirs, I do not support…

Dear Sirs,

I do not support the regulatory changes proposed. Surely, there are ways to improve efficiency without removing oversight and review prior to approval.

Improper management of wastewater and stormwater has the potential to cause serious impacts to human and environmental health.

With appropriate regulation and monitoring, stormwater can fulfill public needs, social equity and enhance food security; a lack of proper management results in financial, environmental, and societal costs in terms of human health, mortality, and morbidity.

We support expanding on the exemptions in Ontario Regulation 525/98 for low impact development (LID) works, limited to infiltration trenches, swales, permeable pavements and rain gardens, if it means it’s easier for people to help manage stormwater.
However at Lake Simcoe, polluted stormwater is the #1 source of phosphorus for the lake, and that’s a big problem. With municipalities forced to swallow ever more costs we are doubtful that stormwater management inspection and maintenance is going to remain a spending priority. Thus we would feel much more comfortable with changes that do not reduce oversight.
The https://ero.ontario.ca/notice/019-6928 Proposal reads: Owners of stormwater management works that are eligible to self-register on the EASR would need to meet rigorous requirements and follow existing ministry standards, guidance, and limits. If the works are a significant drinking water threat, the LEP would be required to consider additional management measures.

“Considering” does not protect the environment. This should be reworded to: “If the works are a significant drinking water threat the LEP would be required to add management measures.”

The https://ero.ontario.ca/notice/019-6928 Proposal reads: If this proposal is implemented, the ministry will continue to audit the registry and inspect these stormwater management works as needed to enforce compliance with the rules in our new regulation.

I do not believe that the MoECP has adequate staff to do this. There are a number of things that have been deregulated in Ontario, with MoECP taking up the slack, but we also know that staff have been slashed or left for reasons of conscience. Is adequate staffing in place to undertake audits?

The https://ero.ontario.ca/notice/019-6928 Proposal reads: The proposed changes will reduce regulatory burden while ensuring that human health and the environment are protected.

What is the evidence for that statement? Without adequate staffing at MoECP, which is currently a problem, MoECP will not be able to manage the volume of oversight needed to protect the environment.

QUESTIONS

Is adequate staffing in place to undertake audits?
The proposed changes will reduce regulatory burden while ensuring that human health and the environment are protected. What is the evidence for that statement?

Thank you for considering my comments.