I am generally in favour of…

Commentaire

I am generally in favour of simplifying the approvals process but what is currently proposed does not adequately protect the environment nor does it adequately protect downstream groundwater users. There are improvements that could be made without sacrificing the goal of streamlining the approval process. To-date, licensed engineers and professional hydrogeologists have been required to address the above two issues for large scale wastewater systems. The training and qualifications for designers with a BCIN do not address the above issues adequately should this carve out to the OWRA proceed as written.
The broad assumptions in the proposed OWRA changes (and reflected the OBC changes) are flawed. Designers could apply the regulations in unintended ways and CBOs could approve inadequately designed systems.

Please also consider my comment on ERO #025-0899 as forming part of my comment on this ERO posting.