Some comments about this…

Some comments about this posting.

1 - It was noted that there would be no need to notify the local conservation authority regarding water takings under the proposed changes. If the MECP is no longer reviewing these permits, one wonders where the protection will be coming from for the natural environment for both dewatering and discharge where there are sensitive groundwater features such as watercourses or wetlands. The onus cannot be placed on the Qualified Person who prepares the supporting documentation for the EASR, as there are occasions where their responsibility ends after the permits are acquired. Who is going to monitor the contractor to ensure that the protocols are being followed in these cases?

2 - The posting indicates that a key objective is to reduce time, cost and resources, specifically related to housing. Some developers and contractors have been known to take short cuts and this seems to put the onus on others to manage the water takings (the QP?). Relationships between the QP and a client are not always maintained through the life of a project.

3 - The posting also noted a housing supply crisis. It is my opinion that there is no housing supply crisis, but that there is an affordable housing supply crisis.

4 - "Environmental standards and protections will remain in place and continue to be a top priority." Two of the protections that are in place are reviews by the MECP and reviews by the conservation authorities, which contradicts this claim.

5 - The posting states that more complex water taking activities will continue to be subject to ministry review, and will require ministry approval to ensure human health and the environment are protected. There are no details on what the criteria are that will require approvals or how health and the environment are to be protected.

6 - Feedback was requested on sewer use bylaws:
a) For discharges to storm sewer, manganese is often the parameter that exceeds the sewer use criteria. The value that is used is the same that is used as the aesthetic objective for drinking water, which is in place as an advisory for staining of household fixtures. It is not clear what the purpose of having this parameter at the aesthetic objective would be. Loosening this value to a more reasonable value (presumably one that is scientifically based), would alleviate the need to discharge to the sanitary sewer in many municipalities.
b) In many locations the storm sewer also requires lower than 15 mg/L of total suspended solids as a requirement for discharge. This is a very low amount, particularly given the amount of sediment and debris that enters the storm sewer during rainfall events.