ERO 019-6963 Waste…

ERO 019-6963 Waste Management Systems EASR Proposals
This proposal sets out guidelines for allowing a number of waste streams in Ontario to move from the existing framework of ministry review and approvals to a self-register system under the EASR. The existing system’s notifications to the public, opportunity for public input, review by ministry staff before approval with conditions specific to the location being applied for would all be replaced by a streamlined EASR model. This would allow for online application with automatic approval if predetermined conditions, not specific to any particular application, are met.
The present opportunity to comment to the ERO is puzzling; the public is being asked to comment on changes that will eliminate their right to comment in the future. I hope their outrage is loud and clear.
A change of this sort would allow applicants to get to work in a shorter period of time. The time presently devoted to consultation with the public and review by ministry staff before approval would be eliminated. “Red tape” would be greatly reduced. (There another way to speed up the process – increase ministry staffing to the point where the review process is not a bottleneck.)
Focusing on speedy approval above all else is of course right in line with the government philosophy which created Bill 23 (More Homes Built Faster). That revolutionary piece of legislation virtually destroyed the traditional role of Conservation Authorities, opened the Green Belt to development, forced municipalities to expand whether or not they wanted to and allowed severances from parcels of land in prime agricultural areas.
The public outcry to the flaws in Bill 23 was so great that the government retreated, restoring the Green Belt lands, cancelling the severances on agricultural land as well as the plan to force municipalities to expand. Perhaps we will now sensibly build houses where they are needed rather than where it is easiest for developers. Hopefully we’ll also see the neutering of Conservation Authorities reversed as well.
019-6963 shares a lot with the motivating spirit of Bill 23, favoring speed over careful planning. When I read that we are perhaps going to a provincial system that would allow things like asbestos, hazardous waste and liquid industrial waste to come under an EASR system with automatic online registration I do not feel confident that our environment would be protected under the new system. Without proper oversight during and after the approvals process these waste streams can all too easily create situations where an environmental catastrophe results.
We all know that environmental mistakes can be very costly, difficult or impossible to clean up. The negative effects can last for generations or perhaps forever. A township in Rideau lakes recently found itself in this situation. An old landfill has leaked chemicals into the water table leaving a number of homes with no usable drinking water. The municipality has been forced to purchase the homes and the residents must relocate, in many cases abandoning their “dream home”.
As more companies ask for approval of aggregate extraction well below the water table a new environmental threat emerges in many places across the province. As part of their Site Plans these operations detail plans to import and store onsite large quantities of material to be recycled. Used asphalt, cement and metals will accumulate at aggregate extraction sites until the quantities are large enough to make commercial recycling feasible. In many cases they will be leaching toxic substances as they are exposed to rainwater and surface water. Particularly in operations below the water table this is a recipe for disaster and a threat to the water table. It is a situation that needs more regulation and more oversight, not less.

If the province creates a system in which proponents can get to work faster at the expense of properly protecting our environment the long-term price to be paid by Ontarians could be huge. We are living in a time when it is more important than ever to ensure that we are not causing permanent damage to the world around us. It does not make sense to continue an ill-advised focus on speedy approvals above all other considerations.