Notice to Members and Request for Feedback from Members - Ontario Regulation 903 Regarding Water Wells
Mary Jane Conboy, P.Geo.
The Environment Committee of APGO has assembled a Regulation 903 working group to address issues with the legislation and how it affects the practice of professional geoscience in Ontario.
Ontario Regulation 903 - the regulation governing water wells - was revised in August, 2003. APGO members have expressed concerns to regarding some of the changes and many members are quite concerned about the possible implications of the revised regulations. Members of the Regulation 903 working group met with the Ministry of Environment on this issue recently and will continue to work on your behalf.
Many of the concerns expressed by members involve the application of the regulation to monitoring wells. Although it is not clearly written in the regulation, monitoring wells are exempt from many aspects of the requirements in the revised regulation. Another key concern is the licensing of individuals working on wells. Issues often come down to the inherent differences between monitoring/exploration/investigation wells and water wells and how the regulation has a blanket approach to all of them.
In the broadest interpretation of the definition of "construction" many of our investigative approaches would be considered to be construction activities and following the regulation would require that only a licensed well technician perform these activities. We do not share the MOE interpretation of Reg 903. We do not support APGO members requiring dual licensure for investigative activities. Our interpretation permits us to continue the work we have been doing.
In order to represent our member’s concerns in our meetings and correspondence to the MOE we would like to hear from you. What types of activities do you or other geoscientists in your firm do on wells? Do you have staff members with a well technician's license? Notwithstanding MOE's interpretation of licensing requirements, under what circumstances do you think an APGO member should have a well technician's license? Should APGO support a requirement that anyone, including P.Geo.'s, have a well technician's licence if they are operating heavy equipment to install a well?
A letter on the O.Reg.903 issue has recently been sent to the Minister of the Environment from our President, Scott McLean, P.Geo. Members interested in reviewing this letter click here or can access it through the APGO website.
Please forward your responses and concerns about regulation 903 to: Mary Jane Conboy maryjane.conboy@ofa.on.ca |