"...This would allow someone…

"...This would allow someone to self-register on the Environmental Activity and Sector Registry (EASR) ...Furthermore, Ontario is proposing to remove the current requirements to notify the local conservation authority of the water taking" -- This suggests that the registration is completely on an honour system, and there is no means to check or to enforce by the local conservation authority. This is a huge oversite. What are the ramifications for those who do not register or do not abide by the 400,000 litres limit? How will it be checked? What means or methods are given to the local authority to ensure that this is not exceeded or to confirm the affect that this has on the environment?

"Removing the volumetric limit is not expected to change the effect of this type of water taking on the environment." - This indicates that there is a possibility that these new regulations can affect the environment. The new regulations should be such that there is sufficient proof that the change will not affect the environment.

"• all registered activities will be required to be implemented in accordance with water taking and discharge reports and plans that are prepared by a qualified person, who must meet minimum professional criteria" - what is the minimum professional criteria? is this person hired by the Contractor or by a third part? Is there a pre-approved list that the contractor can hire from? Who will be reading and confirming these reports? How will the government ensure timely and thorough review of these reports?

"• all registered activities will be required to report their water taking amounts"- in what way will this be reported? to whom will it be reported? how frequently will it be reported? what support and enforcement does the reviewing body have? How will the local conservatory authority be aware of these and know whether someone is not report?

"• the ministry will retain its ability to inspect water taking activities and ensure that they are complying with all necessary legal requirements" - the ministry does not have the same qualifications and expertise as a local conservatory authority nor familiar with an area's specific needs. Although the ministry retains the ability to inspect the water taking activities, how will they be supported to inspect and confirm adherence? Surely the ministry will be overwhelmed with reports and have insufficient staffing to review and respond quickly. Further, ministry offices are not necessarily local to the construction sites and are less able to inspect site or confirm on site compliance. How will the ministry respond to breaches of legal requirements, how quickly and how effective will the enforcements be?

"The proposed amendments will support the More Homes, Built Faster: Ontario’s Housing Supply Action Plan 2022-2023, as they will enable a greater number of temporary construction site dewatering activities to register on the EASR, instead of obtaining a Permit to Take Water (PTTW)." - Why not make the PTTW application process more accessible/faster in and of itself. This will ensure the environment is protected, that water taking is within a reasonable limit, that there is sufficient staffing at local environmental authorities to administer and oversee the initiative.

"• reduce time, cost and resources that proponents spend on seeking environmental permissions from the ministry
• help tackle the housing supply crisis by streamlining the process to build infrastructure." - Building more homes faster will not help the housing crisis if we destroy the environment while doing so. Our future builds need to be sustainable and in alignment with the environment so that the new housing is a long term solution.

"• ensure adequate protection of water resources and the environment
• minimize impact on other water users" - there is nothing in this document that indicates how this will be accomplished. The government is proposing to reduce staffing and authority of local conservation offices who are familiar with the local area, and are able to confirm PTTW takings and replace with a centralized managing system at the ministry level. There has been no mention on how a centralized system will be able to handle the overload of this work nor maintain it nor enforce it. Will there be new assignments at the ministry level that will focus specifically on this to monitor use?