Comment
I am opposed to streamlining environmental permissions for stormwater management under the Environmental Activity and Sector Registry, because we are in a time of climate change and facing an increasing number of extreme storms.
The risks are too high. Improper management of wastewater and stormwater has the potential to cause serious impacts to human and environmental health. The Walkerton tragedy, an e. coli outbreak which sickened 2300 Walkerton residents and killed 7, showed how important it is to have a multi-barrier approach.
The Clean Water Act, legislation which grew out of the Walkerton calamity, takes such an approach. But this proposal 019-6928 would remove the multiple barriers which protect our drinking water and our natural environment. It will remove Ministry oversight of what the Ministry deems "low risk" stormwater management works such as privately owned multi-residential units discharging to combined sewers or the natural environment.
If 019-6928 is approved, as long as the builder/developer hires a Licensed Engineering Practitioner (LEP) to assess whether stormwater runoff might affect drinking water quality, they can self-register on the Environmental Activity and Sector Registry EASR and get straight to work building new commercial, institutional, light industrial and multi-residential developments.
Of course, if the LEP makes a mistake in calculating the risk, or an error in designing their stormwater management system, or more likely, fails to consider that climate change could bring larger or more frequent storms than ever experienced in the past, the untreated runoff will flow directly into our lakes and rivers. This is a huge risk to human, animal and plant health.
This is too great a risk.
Our changing climate makes it more important than ever that Ministry staff oversee stormwater management projects. Now is not the time to let potentially polluting stormwater management systems slip through the cracks.
I am opposed to streamlining environmental permissions for stormwater management under the Environmental Activity and Sector Registry.
The risks are too high. Improper management of wastewater and stormwater has the potential to cause serious impacts to human and environmental health.
The Walkerton tragedy, an e. coli outbreak which sickened 2300 Walkerton residents and killed 7, showed how important it is to have a multi-barrier approach. The Clean Water Act, legislation which grew out of the Walkerton calamity, takes such an approach.
But this proposal 019-6928 would remove the multiple barriers which protect our drinking water and our natural environment. It will remove Ministry oversight of what the Ministry deems "low risk" stormwater management works such as privately owned multi-residential units discharging to combined sewers or the natural environment.
If 019-6928 is approved, as long as the builder/developer hires a Licensed Engineering Practitioner (LEP) to assess whether stormwater runoff might affect drinking water quality, they can self-register on the Environmental Activity and Sector Registry EASR and get straight to work building new commercial, institutional, light industrial and multi-residential developments.
Of course, if the LEP makes a mistake in calculating the risk, or an error in designing their stormwater management system, or more likely, fails to consider that climate change could bring larger or more frequent storms than ever experienced in the past, the untreated runoff will flow directly into our lakes and rivers. This is a huge risk to human, animal and plant health.
This is too great a risk.
Our changing climate makes it more important than ever that Ministry staff oversee stormwater management projects. Now is not the time to let potentially polluting stormwater management systems slip through the cracks.
Submitted October 27, 2023 10:28 PM
Comment on
Streamlining environmental permissions for stormwater management under the Environmental Activity and Sector Registry
ERO number
019-6928
Comment ID
93913
Commenting on behalf of
Comment status