Comments on ERO Notices 019…

Comments on ERO Notices 019-6951, 019-6853, 019-6928

The following are concerns and shortcomings of these proposed rule changes that I am 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.

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· 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.