November 7 2019 SUBJECT: ERO…

November 7 2019

SUBJECT: ERO 019-0732 Proposal for a new regulation under the Lakes and Rivers Improvement Act

I am writing to express my strong support for the proposed regulation under the Lakes and Rivers Improvement Act to implement a “one window” approach for waterpower facilities, concurrent with the proposal to exempt the sector from the duplicative requirement of a Permit to Take Water under the Ontario Water Resources Act.

The proposed movement to a “one window” approach, through the provisions of the Lakes and Rivers Improvement Act, will maintain regulatory effectiveness and increase efficiency. MNRF has shown leadership in the modernization of the regulation of dam construction and management, publishing a series of Technical Guidelines and Best Management Practices since 2011. The Ministry not only has the legislative authority but policy and procedural mechanisms in place to regulate the waterpower industry.

I note as well the regulatory provision that would enable the Minister to adopt by reference any document, including a code, formula, standard, protocol, procedure or guideline. In this regard, I would recommend that the Best Management Practices “Ontario Waterpower Development Surface Water Quality and Fish Sampling Programs” and “Small Hydro and Methyl Mercury”, commissioned by the Ontario Waterpower Association, be adopted through this provision.

Sincerely.

Paul Norris
President
Ontario Waterpower Association