OFA provided feedback on ERO # 025-0600. This consultation addresses proposed regulatory changes under the Environmental Protection Act, that would enable proponents such as utility companies to self-register their stormwater management and spill control works through the Environmental Activity and Sector Registry (EASR).

OFA recommends that stormwater management (SWM) reports be prepared and certified by a Professional Engineer (P.Eng.) to ensure technical integrity and accountability. Poorly designed or maintained systems can flood neighbouring farmland, and farmers should not be forced into court to protect their livelihoods. SWM designs must calculate runoff increases from impervious surfaces and grading changes, assess both pre- and post-development conditions, and demonstrate capacity to manage added volumes without harming downstream landowners. The definition of a “spill” should include flooding onto neighbouring property, with contingency plans addressing neighbour impacts and mitigation. A formal complaint resolution process is also needed, allowing neighbours to escalate concerns to an independent authority such as MECP with enforcement powers. OFA supports restrictions on SWM works in source protection areas and enhanced protections for discharges to the natural environment.