This Comment addresses each…

This Comment addresses each of the three proposed points of the Proposal.
In response to point one of the Proposal our perspective is that ‘rigorous’ requirements for registration of stormwater management works are in the province's best interest. This is for three reasons: (i) Self-regulation is not as effective as the current regulation process (ii) Concurrent and cumulative risks posed by less scrutiny of an already overburdened stormwater management system is not in line with the values and principles outlined in Ontario’s Environmental Bill of Rights, it does not serve to drive industry innovation toward sustainability goals, and does not adhere to the precautionary principle. (iii) The damages from flooding are unpredictable and stripping regulations will be costly.
In response to point two of the Proposal, we urge the following two factors to be considered. First, further clarification around the scope of the new LID exemptions with a particular focus on the cumulative effect that multiple LIDs in one region can cause. Second, postponing the exemptions regarding roadway and railway drainage works until a more comprehensive definition of the exemptions are provided to the public.
In response to point three of the Proposal we are of the opinion that the government’s proposed amendments to O. Reg.. 287/07: (i) contravene the purpose of the Clean Water Act, 2006; (ii) problematically disposes of public participation and notice to changes in source water protection plans and; (iii) creates unacceptable dilution of current procedure, putting Ontarians at a higher risk of being exposed to contaminated drinking water.