Comment
The proposal for Waste management systems is expanding the permit-by-rule process to include high-risk activities that pose serious threats to human health and the environment.
The proposal would expand permit-by-rule to cover the transportation of:
• Asbestos Waste
• Biomedical Waste
• Treated Biomedical Waste
• Liquid Industrial Waste
• Hazardous Waste
• PCB Waste
• Naturally Occurring Radioactive Materials (NORM)
Impacts and concerns related to Permit-by Rule:
1. The above have Environmental and Human Health risks.
2. The proposal eliminates important participation rights (Public Participation and appeal Rights) under the Environmental Bill for Rights, 1993 (EBR). Loss of 30-day comment period and Appeal Rights
3. The cumulative effect of several "Low-risk facilities" in an area may not be assessed adequately on impacts to the surrounding environment and now fall under high risk.
4. Removal of financial assurance requirements will result in a liability to the Municipality for environmental spills or cleanup from haulers transporting liquid industrial, hazardous, and biomedical wastes.
Submitted October 30, 2023 4:11 PM
Comment on
Streamlining environmental permissions for waste management systems under the Environmental Activity and Sector Registry
ERO number
019-6963
Comment ID
94184
Commenting on behalf of
Comment status