I strongly disagree with…

I strongly disagree with your proposal to reduce the regulations governing the management of stormwater in Ontario. For one thing, your proposal is based on a wrong assumption; that 'activities registered on the EASR must follow rules in regulation'. If there is no third-party oversight, from the government or the public, developers can potentially set up stormwater management systems that will deliver harmful substances to the environment, or into homes, or that will not work at all in times of heavy rains. Further, leaving the oversight and inspection to a licensed engineering practitioner (LEP) will only work if such persons are employed by the government or some third-party governmental based agency, not by the development company.

I am deeply concerned by your proposal to amend Ontario Regulation 525/98 under the Ontario Water Resources Act, to exempt some stormwater management works in residential areas from approval requirements. This exemption has the potential to result in residential areas where the stormwater management facilities are inadequate or drain into natural areas without treatment; the results could be flooding of neighbourhoods and/or contamination of natural areas. The current regulations have brought us this far in our efforts to protect homes and the natural environment from damage. These kinds of damage are costs to society that reduce the prosperity and health of Ontarians.

I find most deeply disturbing, your proposal to 'amend Ontario Regulation 287/07, made under the Clean Water Act, 2006, by removing the need for, limiting, or restricting the types of policies to be included in source protection plans where a significant drinking water threat is being managed through registration on the EASR, and to allow for amendments to existing source protection plans without following the usual process.' In fact, these 'significant drinking water threats' are NOT being managed by simple registration on the EASR, and without oversight by a third party, there is no guarantee that a stormwater management system facility will not pollute local drinking water. There were rules governing drinking water in Walkerton, and without proper oversight they were not followed, and death and disease of citizens resulted. Conservation Authority policies need to stay in place and Conservation Authority oversight needs to be sustained, restored, and enhanced to support a healthy environment for Ontarians!!

• Improper management of wastewater and stormwater has the potential to cause serious impacts to human and environmental health.
• With appropriate regulation and monitoring, stormwater can fulfill public needs, social equity and enhance food security; a lack of proper management results in financial, environmental, and societal costs in terms of human health, mortality, and morbidity.