OFA outlined key concerns and recommendations regarding the Ministry of Environment, Conservation and Park’s proposed changes to the Technical Rules under the Clean Water Act. For sections 15.1(4) and 55.1, OFA recommended that Source Protection Committees be required to consult directly with stakeholders prior to making changes. Potentially impacted landowners must be both informed and consulted by the Source Protection Committee directly, have input into these changes and be provided with some form of complaint and appeal process. OFA opposed section 62.1 revisions that may extend setbacks beyond those based on defensible science that includes calculations of time of travel from hydrological studies. OFA also noted concerns with the proposed amendments to the Tables of Drinking Water Threats. OFA recommended broader consultation prior to making any amendments to the Road Salt provisions to assess the potential threat to municipal drinking water sources and the impact to landowners. OFA requested further clarity regarding the proposed definition of “Storm Water Infiltration Facility”. OFA also requested a clear statement that the “Wastewater Treatment Facilities and Associated Parts” section is specific to human waste. OFA opposed the changes regarding the Handling and Storage of Commercial Fertilizer as proposed. In addition, OFA stated that the proposed amendments to the Technical Rules: Assessment Report under the Clean Water Act absolutely cannot be enacted without financial support for both capital and ongoing operating costs that farmers may incur for protecting municipal drinking water sources. OFA recommended that the Ministry directly engage the agricultural community to understand the potential for unintended consequences of this proposal and work to mitigate these impacts.
Submissions & Correspondence
OFA submission regarding proposed amendments to the technical rules under the Clean Water Act
Updated: November 11, 2020