Dear Sirs, I do not support…

Dear Sirs,

I do not support the regulatory changes proposed. Surely, there are ways to improve efficiency without removing oversight and review prior to approval.

Regulatory frameworks such as the Clean Water Act and the Ontario Water Resources Act were designed to manage and protect our shared water resources, ecosystems, and health.

Key regulatory tools that currently protect our water include:

Requirement of permits – including application and approval processes – for extracting more than 50,000 litres of groundwater per day;

Public consultation that allows local communities to have a say in decisions that may impact them; and

Requirements for industry to notify local conservation authorities of water-taking practices in order to facilitate collaborative management of water resources and municipal infrastructure, including consideration of drought and flood risks and conditions.

Ontario’s proposal to remove the limit for groundwater-taking and to allow up to 379,000 litres of groundwater-taking per day without permit, while restricting public consultation and removing the requirement to notify conservation authorities, puts the ecosystem, human health, and municipal infrastructure at risk.

In cases where dewatering will bring water, known to contain parameters that do not meet Ontario’s water quality standards, up to the surface to be released back to the environment, this proposal is a disaster. We know this for example to be the case for the proposed Bradford Bypass. The developer / builder should be on the hook for any costs associated with keeping water clean, or, in this case making the water they are taking out of the ground clean before releasing it to the environment. They are however for-profit companies and any extra work they do to clean up the environment comes off the bottom line - this is why regulation is imperative. As you well know, it will not happen as a random act of charity.
Interestingly, one of our members found a 2020 request from developers that says, “...we would recommend removal of the EASR process completely for construction site and road construction up to 400,000L/day”. Neat. Unfortunately, this government has a bad habit of doing what developers want, creating massive problems, wasting everyone’s time and money, and making bad decisions. Please do not do so this time.

I look forward to hearing the Ministry’s response to these comments.