CELA submission - with endorsements - permit-by-rule expanding and streamlining proposal - 30October

The Proposals The Ministry is proposing to expand the use of its permit-by-rule framework to the following activities: ● Waste Management Systems ● Stormwater Management ● Water-taking for construction site dewatering activities and foundation drains In addition to expanding the list of eligible activities under the permit-by rule approach, the Ministry is also seeking feedback on whether it shoul. [...] As the Environmental Commissioner of Ontario (ECO) has previously stated in the 2017 Annual Report “the reason the MOECC introduced the EASR in the first place was to enable the ministry to focus more resources on the higher-risk activities that pose the greatest threat to the environment; now it needs to do just that. [...] The language in the regulation is not clear in determining which construction sites will be included; if the site is for housing construction, and a new sub-division is being built, will the roads to get to the sub-division be included? Will the current "short-term" regulations of 7, or 30 days be included in the proposal? Under the current draft, the prescribed criteria for timeframe of construct. [...] Moreover, it raises concerns about the efficacy of the oversight from the Ministry of the Environment, Conservation and Parks (MECP), particularly when the management of such significant environmental matters is left to a self-approval mechanism, questioning how the MECP would remain informed and ensure accountability regarding the aquifer’s condition and safety. [...] Collectively, the recommendations are summarized as follows: With respect to the proposal “Streamlining environmental permissions for waste management systems under the Environmental Activity and Sector Registry” (ERO number 019-6963): Recommendation 1: CELA recommends that the Ministry not adopt the proposal to extend the permit-by rule framework to the proposed waste management systems.