RESPONSE TO ERO 019-0987 …

RESPONSE TO ERO 019-0987 “Amendment to the Record Of Site Condition (Brownfields) Regulation related to the Requirement to Sample Ground Water”
Staff at the Region of Waterloo (Water Services Division) have reviewed the proposed amendment in the context of our responsibilities to protect and manage groundwater and drinking water sources in the Region. We do not support the proposed amendment, as summarized in the points below.
KEY POINTS
1. The proposed amendment is not necessary to provide flexibility. The existing regulation already provides sufficient flexibility to the Qualified Person.
2. The proposed amendment increases the complexity of the regulation, and would add to Ontario’s regulatory burden.
3. The proposed amendment may be misconstrued as a means to reduce protection for Ontario’s bedrock aquifers, which are major water supply resources for the Region of Waterloo, Guelph, County of Wellington, and other areas.
4. The proposed amendment is worded in a manner that conflicts with other parts of the regulation, weakening the overall legal context of the regulation.
5. The proposed amendment may result in reduced protection of the public.
6. The proposed amendment is not necessary to reduce redevelopment costs.

Please see the attached document for more information.