Sanjay Coelho…

Sanjay Coelho
Senior Policy Analyst
Ministry of the Environment and Climate Change
Climate Change and Environmental Policy Division
Land and Water Policy Branch
40 St. Clair Avenue West
Floor 10
Toronto Ontario
M4V 1M2
POSTED DIRECTLY TO EBR COMMENT WEBPAGE

Re:EBR Registry Number 013-0299 Excess Soil Management Regulatory Proposal

Staff from the Hydrogeology and Source Water Section of the Region of Waterloo provide the following comments on the current EBR proposal listed above. We see this proposal as an important opportunity to better align the Environmental Protection Act legislation with the Clean Water Act.

We ask for the following minor amendments to Regulation 153, in addition to those listed in the EBR proposal.

Requested Additions to Regulation 153, Definitions

Add: “source water protection vulnerable area” means vulnerable areas as defined by the Ontario Clean Water Act

Requested Additions to Regulation 153, Table 1 of Schedule D

A new subsection be added to 4 (Records Review) (c) to include the subheading “Source Water Protection Vulnerable Areas and Drinking Water Intakes”. Minimum requirements: Describe any source water protection vulnerable areas (per Clean Water Act) in the phase one study area, and the associated drinking water wells or intakes.

A new requirement be added to 6 (Site Reconnaissance) (b) to include the minimum requirements: Provide a listing and general description of any Risk Management Plans registered to the phase one property under the local Source Protection Plan per the Clean Water Act.

A new requirement be added to 7 (Review and Evaluation of Information) (iv) to include the minimum requirements: Identify and locate any source water protection vulnerable areas (per Clean Water Act) located in whole or in part on the phase 1 study area.

Requested Additions to Regulation 153, Table 1 of Schedule E

A new requirement be added to 3 (Background Information) (i): to include the minimum requirement to provide a description of “any source water protection vulnerable areas within the phase one study area, and the associated drinking water wells or intakes”.

A new requirement be added to 6 (Review and Evaluation) (i) (Geology), where the Phase Two property is located within a source water protection vulnerable area, to include the minimum requirement: for each described aquifer and aquitard, indicate the stratigraphic relationship between the aquifer or aquitard and the drinking water source aquifer and/ or intake as described in the local Source Protection Plan per the Clean Water Act.

Sincerely,

[Original Comment ID: 209845]