ERO 019-6853 Streamlining…

ERO 019-6853 Streamlining permissions for water taking for construction site dewatering activities and foundation drains.
This proposal describes amendments that “will ensure appropriate environmental protections are in place while reducing regulatory burden for construction and infrastructure projects.” Things begin to unravel immediately when the first suggestion provided is to remove the existing requirement of taking no more than 400,000 litres of ground water per day at any work site. To suggest that environmental protection is served by allowing water taking without limit is ludicrous, yet that is clearly what is intended. “This would allow someone to self-register on the EASR for the taking of any quantity of ground or storm water”.
It appears that the only intent here is to make it easier for companies to go ahead with construction with no pesky oversight. This is reinforced by the additional suggestion that existing requirements to notify the local Conservation Authority of water taking would also be removed. This would be consistent with the government’s assault on Conservation Authorities through Bill 23, but it has nothing to do with good planning or proper oversight. Somehow the authors can feel comfortable adding that “Removing the volumetric limit is not expected to change the effect of this type of taking on the environment.” It is impossible to believe that water taking without limit, instantly approved through self-registration, could have no effect on the environment.
This section concludes by listing five points of regulatory compliance that will remain in force even with these changes. The problem with these assurances is of course that the ministry is already unable to come anywhere near meeting its oversight responsibilities. Anyone who has tried to report environmental infractions has had the experience of finding it almost impossible to get action, to see a ministry staff member make an inspection. Violators often go for years without being made to be compliant.
I believe that the real motivation behind the proposed changes is apparent when we get to the section titled “Reducing time and costs while protecting the environment” which attempts to persuade the reader that Bill 23 (More Homes Built Faster) grew out of “what matters most to Ontario communities”. The Bill was written in consultation with representatives of the Ontario Home Builders Association and The Ontario Sand and Gravel Association. They got what they wanted, although some of their key requests have since been rolled back in response to public outcry, but no other consultation was done. Municipal governments, citizen groups and the general population had no input. Making “faster” the crucial determinant of policy development is nothing but poor planning and everything proposed to support Bill 23 needs to be re-examined. We need more housing but the questions of housing type, location and cost need to be part of the planning process from the start. The government’s announcement that 1.5 million houses are needed is said to come out of the Housing Affordability Task Force Report, but the figure of 1.5 million houses is not supported anywhere in that Report.
ERO proposals are made under the Environmental Protection Act. The guiding principle for all ERO proposals should be to protect the environment, not to create frameworks to support poorly planned construction, done for the wrong reasons to benefit a small number of industries rather than the Ontario population.