I am concerned about all…

I am concerned about all these proposals which remove potentially harmful environmental actions from public servant oversight and from public view and intervention. The risks are too high.

I am especially alarmed about the proposal to automatically approve all applications to transport what are called "low risk" wastes, using the argument that "Ontario recognizes that assessed EASRs, which require technical assessments by qualified persons (QPs), may be too costly for some sectors."

If this proposal is approved, all anyone who wants to transport or temporarily store hazardous waste, biomedical waste, asbestos waste, PCBs, liquid industrial waste, needs to do is sign up on the Environmental Activity and Sector Registry EASR, and say you'll follow the rules. Ministry staff may or may not check up on you... ever.

The Ministry justifies this by saying transporting asbestos, biomedical, PCB, liquid industrial waste is "low risk". The Canadian Environmental Law Association -- and common sense -- disagree. (CELA opinion can be found here: https://cela.ca/action-alert-environment-ministry-proposes-to-exempt-ha… )

Accidents transporting hazardous, asbestos, biomedical waste etc may be arguably low risk because they are rare, but when they happen the impacts are tremendous, as this 2017 news story shows: https://www.cp24.com/news/stretch-of-hwy-401-reopens-32-hours-after-dea…

And there are just too many accounts of trucks being forced off the road, when spot check vehicle inspections are done. In a two-day inspection blitz at the Vineland Truck Inspection Station in March 2023, 65 transport trucks were found to have serious problems. 24 were immediately yanked off the road "for significant safety concerns," three sets of license plates were seized and 95 tickets were issued for improper brakes, improper tires, insecure loads, careless or distracted driving. https://www.insauga.com/niagara-mto-and-hamilton-police-yank-24-transpo…

Yet ero.ontario.ca/notice/019-6963 proposes that we should authorize instant licenses for trucks like these as long as they are carrying asbestos, biomedical, PCB or liquid industrial wastes. This is outrageous!

Please rethink this idea.