ERO 019-6928 Streamlining…

ERO 019-6928 Streamlining environmental permissions for stormwater management under the EASR
This document begins with “What we’re proposing” and goes on to propose a number of contradictory suggestions. Following motherhood statements about ensuring that Ontario will have clean water for drinking, manufacturing and recreation we are told that some storm water systems will be allowed to self-register rather than going through a ministry regulated approval process, some storm water management systems will be exempt from approval requirements and some source water protection plans will be able to make amendments to their plans without following usual practices.
These changes would help companies develop projects faster, in line with the goals of Bill 23, but they clearly are not designed with protections of Ontario’s water as a top priority.
Perhaps worse than this it is suggested that proponents can save up to a year, avoiding the wait for ministry review, by dropping the requirement for Environmental Compliance Approval. Rather than having to comply with an approvals process deigned to protect the water we all need the change would allow for activity to start as soon as self-registration on the EASR is completed. If the goal is to eliminate the delay of up to a year it would make more sense to leave the ECA requirement in place and increase ministry staffing to speed up the process without abandoning independent oversight in favour of self-regulation.
In the section “Protecting the Environment” there is too much faith placed in the owners of storm water management systems. For EASR registration these systems must be privately owned, meaning that seeking to maximize profit will be the prime motivator for the company seeking approval. Nonetheless, the plan is to turn over key decisions to the employees of the applicant. The proponent will determine whether the activity is a significant drinking water threat. It can be foreseen that the additional design and monitoring costs that would result from such a determination could create pressure for company employees to hold off on calling the project a threat to drinking water. Too many potential threats to human health come from the temptations of self-regulation.

In the final paragraph of 019-6928 we are assured that “The proposal would allow businesses to begin operations and infrastructure projects faster, which is beneficial for the community.” At last, we have a succinct summary of exactly what this proposal is all about – making things happen more quickly for developers with few holdups caused by regulation enforcement designed to protect us and our environment. It is a very poor day in Ontario’s planning history when this passes for wise counsel. When faster approvals is the primary consideration we can all expect to see a degradation in the environment we must all live in.