HIEA would like to make the…

HIEA would like to make the following comments on the proposed guidance document:

• HIEA supports updating the tools and resources used by environmental officers to help determine the level of intervention required.
• HIEA agrees that updating the “compliance history” and “environmental/human health” components of the informed judgement matrix will better reflect modern regulator objectives and environmental risk principles and will allow the Ministry to better address non-compliance activities.
• The Informed Judgement framework requires strict operating policies and internal operational auditing to ensure that the tool is being applied consistently across the regulated community. As a modern regulator, MECP must ensure that operational policies and results from operational audits are transparent and made available to the regulated community and public.
• By proposing that the municipalities will administer “nuisance” noise and odour complaints to non-regulated facilities, MECP may create confusion and frustration, especially if not properly implemented and communicated.
• Municipalities must be supported in taking on the nuisance complaints from MECP as these account for a significant portion of the current MECP workload.
• The framework must promote and maintain consistency for all regulated entities across the province, and within regional jurisdictions.
• Environmental Monetary Penalties need to be consistently applied across Ontario’s regulated community. Currently there is considerable regional variability in the use of this penalty across the regulated community. HIEA supports the consistent application of this tool.