OFA comments on the proposed changes to the environmental permissions for stormwater management under the Environmental Activity and Sector Registry. OFA is in favour of the intent of creating more efficient environmental permissions processes. However, OFA is concerned that this proposal requires further considerations with regards to the significant unintended consequences to neighbouring agricultural properties, and the potential to negatively impact our food safety, security and health of our livestock.
Our topline feedback is summarized below:
- While the proposed changes are intended to “reduce regulatory burden while ensuring human health and the environment are protected”, we believe that protecting the health and safety of the food grown in Ontario has been overlooked,
- We believe that any regulation, registry or program put in place must prohibit any negative impact to neighbouring properties, in addition to ensuring “that the works do not pose a negative environmental impact” that is already included;
- Nearby receptors must be amended to also include agricultural lands and activities;
- Inclusion of consideration of discharges to municipal drains;
- Detail a process for negatively impacted nearby receptors to escalate their concerns / complaints if they are not appropriately addressed by the owner of the works;
- A review of the “Effluents” section to consider and ensure that the safety of our food and health of our livestock are given appropriate consideration;
- Stormwater run-off analysis to include the potential impact to agricultural lands and activities; and
- The Spill Contingency Plan (SPC) to be expanded to include all nearby wells and intakes, including private systems and sources that may be used for agricultural purposes.
OFA looks forward to working with the provincial government to protect Ontario’s farmlands as well as support infrastructure development and help protect human health and the environment.