Comment re: ERO #019-6928 In…

Comment re: ERO #019-6928

In the Ontario governments stated objective to create smarter and more efficient environmental permissions processes to support infrastructure development and help protect human health and the environment, the aggregate extraction industry SHOULD NOT be considered an eligible industry, like mining, for EASR permitting as is proposed in this new regulation under the Environmental Protection Act, to allow private owners of certain stormwater management works to self-register on the Environmental Activity and Sector Registry (EASR).

The fundamental purpose of our Environmental Protection Act (EPA) is to provide for the protection and conservation of the natural environment. Our fundamental rights are clearly outlined in the Preamble of our provincial Environmental Bill of Rights (EBOR), including our right to the primary democratic tool of public consultation as defined in Part II of this Bill:

“3 (1) This Part sets out minimum levels of public participation that must be met before the Government of Ontario makes decisions on certain kinds of environmentally significant proposals for policies, Acts, regulations and instruments. 1993, c. 28, s. 3 (1).”

As such proposed stormwater management works, especially if required in aggregate extraction operations, could have profound effects on the local water systems, balance of normal seasonal water flows, distribution of surface and ground water systems and impacts on communicating aquifers, including the introduction of pollutants, public consultation is a right for any effected citizen and must be included as a major input in the evaluation of such stormwater management works. This public consultation should include adjacent businesses, farms, and residential properties especially those dependent on well systems, as well as, the input of expert hydrogeological advice, and of local tiers of government representing effected businesses, farms and residents.

Ontario’s Conservation Authorities mandate includes overseeing and ensuring maintenance of our natural water systems, therefore, they MUST be involved in planning and oversight of stormwater management on such privately owned sites. Conservation Authority overview, input and commenting is necessary and important where such stormwater management works could interfere with local rivers, creeks, streams, watercourses, wetlands, flood or erosion control, as well as, where consideration of potential for pollution through such proposed stormwater management works could occur. The inclusion of Ontario’s Conservation Authorities review must be restored and considered a valued input in good land and water system stewardship with regard to such proposed stormwater management works.