Proposal ero.ontario.ca…

Proposal ero.ontario.ca/notice/019-6951 says Ministry staff should eliminate their oversight and reduce environmental protection requirements so housing can be built faster. I don't agree that environmental protection is the reason we lack affordable housing.

In any case, I don't want protections lessened, and I especially don't want Ministry staff to step back from a thorough, conscientious review of proposals for waste management systems, stormwater management, and water-taking for construction sites, dewatering and foundation activities.

Under both the "Assessed EASR" and "permit-by-rule" regimes, proposals will never be even glanced at by trained Ministry staff, except if selected for (infrequent) audits. This is too much of a risk for our environment.

Instead of submitting a detailed application to Ministry staff, and having Ministry staff identify all aspects of the proposal that might impact the environment, identify best management practices within the sector, look at how potential impacts could be lessened and avoided, then prepare a technical discussion paper that summarizes staff's investigations and proposes eligibility and operating criteria and post this discussion paper on the Environmental Registry for comments from stakeholders and the public, instead of this thorough and transparent process, the Ministry proposes that applicants simply hire a "qualified person" to prepare "technical assessments" and post these on the Environmental Activity and Sector Registry (EASR), then immediately get to work.

There will be no Ministry review of these registrations, although there may be audits from time to time. In 2007 the Auditor General found over half the registrations were missing information, and "a significant level of non-compliance [with regulations] in every sector of the hazardous waste industry."

For Assessed EASRs, someone should check that the "qualified person" is truly qualified to do that particular assessment. Who will check that the "technical assessment" was thorough and appropriate for the particular project? Who will check that it wasn't just a boiler plate "technical assessment" slapped on a project without regard for the project's special circumstances?

Even more concerning is the fact the permits filed on the Environmental Activity and Sector Registry EASR are not open to public review or challenge.
This is not acceptable.
There must be checks and oversight of potentially harmful actions.

The Ministry of the Environment should live up to its name and put our environment first, instead of seeking to compromise environmental protection to meet other goals.

I remember the fiasco which happened with Varnicolor Chemical in Elmira in the 1960s and 1970s, where the company owner disposed of barrels of toxic solvents he found on the property by burying them underground, out of site. Would Assessed EASR, a system that permits a company owner to hire a "qualified person" of their own choosing to prepare a "technical assessment" that no one ever looks at before work commenced, would such a system have prevented the soil and water contamination that is taking decades to clean up? I don't think so.

I am especially appalled that the Ministry suggests that "aggregate operations, including stormwater and aggregate wash water, would be good candidates" for this streamlined Assessed EASR process.

I remember the hour I spent at Wilmot Council in May, listening to resident after resident talking about the health problems they faced living next door to aggregate operations.
How could one "qualified person" working in isolation on one aggregate application ever see the bigger picture?
How can we be assured that our health concerns are even being considered by the "qualified person" employed to create an Assessed EASR for an aggregate operation?
We can't.

These proposals are dangerous to human, flora and fauna health. Please don't implement them.