These changes to stormwater…

These changes to stormwater management are based on the false premise that building homes more and faster is the answer to our clear housing shortage. I would argue that the housing shortage is not a building crisis but a societal crisis requiring changes to senior, student, immigrant and young family needs for housing rather than just new houses.
Regardless of this perspective, which by itself tips the "Risk Balance Approach" of the government to a no change approach, there are specific aspects of this proposal that also tip this proposal into the too risky zone. These aspects include the elimination of "duplication requirements" when history has shown us these "cross-checks" are a critical component of any effective working process, the delegation of assessments to "licensed engineering practitioners" devolving the level of assessment expertise involved and proponents being required to self-identify "whether the activity is a significant drinking water threat". Unusually, this particular proposal also puts at risk the positive aspects of Stormwater Management, which if properly applied can be of significant benefit to the community.
I would ask the Ministry to maintain a status quo approach that has been working well at maintaining a Risk Balance, effective at protecting both the economy and the environment.