Comment
I urge that the Premier not proceed with the proposed amendments to existing water protections under provincial law. I am deeply concerned with the potential environmental impacts.
Ontario’s proposal to remove the protective limits for groundwater-taking and to allow a tremendous increase in litres of groundwater-taking per day without permit, while restricting public consultation and removing the requirement to notify conservation authorities, puts the ecosystem, human health, and municipal infrastructure at risk.
Regulatory frameworks such as the Clean Water Act and the Ontario Water Resources Act were designed to manage and protect our shared water resources, ecosystems, and health.
Key regulatory tools that currently protect our water include:
- Requirement of permits – including application and approval processes – for extracting more than 50,000 litres of groundwater per day;
- Public consultation that allows local communities to have a say in decisions that may impact them; and
- Requirements for industry to notify local conservation authorities of water-taking practices in order to facilitate collaborative management of water resources and municipal infrastructure, including consideration of drought and flood risks and conditions.
Allowing exemptions which increase the current water-taking limits for construction activities will have significant cumulative impacts, particularly if there are multiple water-taking activities on site.
Dewatering activities on very large construction sites could result in a significant discharge of water into the surrounding watershed. Removing the requirement to inform Conservation Authorities about water-taking, limits their ability to protect drinking water sources. It also impedes their ability to effectively carry out flood and drought forecasts which are critical for managing watersheds amidst changing climate conditions across seasons and years.
Overall, the proposed changes would result in an unacceptable reduction in government oversight of construction activities and their cumulative impact on freshwater systems, our most precious resource for drinking water. This oversight would be offloaded to private Licensed Engineer Practitioners (LEPs) hired by construction companies to oversee the design and eligibility requirements of applicants’ projects. This situation presents a clear conflict of interest and opens up the door for the system to be exploited.
I'm concerned that this proposal could have serious implications to watershed sustainability. Do not proceed with this proposal.
Thank You,
Submitted October 28, 2023 12:10 PM
Comment on
Streamlining permissions for water takings for construction site dewatering activities and foundation drains
ERO number
019-6853
Comment ID
93940
Commenting on behalf of
Comment status