Comments on ERO Notice 019…

Comments on ERO Notice 019-6928

The following are concerns and shortcomings of these proposed rule changes that the Lanark & District Fish & Game Conservation Club are very concerned with:

· This legislation would loosen controls on the aggregate extraction industry, and would eliminate
the opportunity for public input and scrutiny.

· With the expansion of the existing "permit-by-rule framework" already used in some industries, the
aggregate industry would self-register for a permit to initiate a project through the Environmental
Activity and Sector Registry (EASR), and would be allowed to start work immediately, without
ministry review or public consultation.

· Any activity could proceed either by meeting a set out list of criteria (rule based EASR) OR by
providing a technical assessment of the project by a qualified person (assessed EASR), to
demonstrate that the activities of the project would meet standards for environmental outcomes
set out by the province.

· Less frequent inspections - While the Ministries would maintain the authority to "inspect facilities"
and "ensure compliance with regulatory requirements", we currently see dramatically reduced
levels of staffing in the MNRF and MECP; we observe that already existing requirements for
monitoring pit operations and inspecting sites are not being fulfilled; shortening the timeline
between the issuance of a permit and beginning site work would put even greater pressure on
inspectors.

· Inappropriate criteria - A proposed aggregate project would be required to meet a minimal set of
criteria, which are geared for the flat agricultural land of southern Ontario; criteria do not address
the environmentally complex areas of waterways, forests and wetlands of Lanark Highlands, and
similar areas.

· Industry bias - Applications are supported, if at all, only with technical reports by a "qualified
person", hired by the proponent to provide the desired information for approval.

· No public input – With the period for public consultation dropped from the application process, the
“qualified person’s” assessment would not be subject to scrutiny by landowners, interested citizens,
or local levels of government.

· Removing Public Input - Removing public input, especial local individuals and local organizations ie
fish & game clubs, has the potential to harm waterways, aquatic life and our natural environment
or species at risk. Local individuals and organizations often have knowledge that a qualified
person, usually not from the immediate area, does not have and without their input does not
become aware of.

· Unlimited water taking - Ontario proposes removing the current limit of 400,000 litres of
groundwater per day.

· Sidelining Conservation Authorities - In this situation where assessment and oversight are needed
more than ever, the Conservation Authorities' staff at the local level continue to be prohibited from
any oversight of water resources and wetlands impacted by the aggregate extraction industry.

· Rushed process - The shortcuts proposed do not offer time for people to fully investigate an
application, limiting the rights of citizens. The existing review process for an application can last up
to two years; local citizens, indigenous people, ministries and lower tier levels of government can
scrutinize proposals and offer input. This would no longer happen.
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