Hello Mr. McCann,…

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013-0551

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2184

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Hello Mr. McCann,

There is an incredible opportunity to set in motion adaptation strategies at scale to help address the damaging effects of climate change. We strongly encourage the Government of Ontario to help develop the green infrastructure industry in all its manifestations and achieve the goals set out by triple bottom line accounting. We believe rain gardens as per Low Impact Development have a key role to play in urban areas in particular and we are encouraged by the gains made by green roofs in the area of stormwater management.

We have joined the chorus set out by GIO Coalition:

The Green Infrastructure Ontario (GIO) Coalition strongly supports the province’s leadership in integrating green infrastructure into its new regulation for municipal asset management planning.

as per their suggestions:

1) Define “green infrastructure”: To ensure clarity around the definition of green infrastructure and alignment to policy statements under section 3(1) of the Planning Act, we recommend including a direct reference to or inclusion of the Provincial Policy Statement (2014) definition of green infrastructure: “Green infrastructure: means natural and human made elements that provide ecological and hydrological functions and processes. Green infrastructure can include components such as natural heritage features and systems, parklands, stormwater management systems, street trees, urban forests, natural channels, permeable surfaces, and green roofs.”

2) Revise the definition of “infrastructure assets” to ensure green infrastructure assets are not required to be tangible capital assets: We suggest broadening the definition of “infrastructure assets” beyond tangible capital assets (TCAs) to avoid a potential contradiction between the regulation and Public Sector Accounting Board guidance. The draft definition of “infrastructure assets” in the proposed regulation could be interpreted to only include TCAs. The term TCA does not include green infrastructure assets, according to the current guidance from the Public Sector Accounting Board. Not all infrastructure assets owned by a municipality are TCAs, and assets do not need to be TCAs to benefit from inclusion in asset management planning. We propose an alternate definition below for your consideration:

“Infrastructure Assets” are built and natural assets that are directly owned by a municipality or consolidated on the financial statements of a municipality, including tangible capital assets, and may include green infrastructure, but do not include assets that are managed by a joint municipal water board.

3) Set a timeframe to require green infrastructure’s integration to asset management plans: Require green infrastructure be integrated in to asset management plans following a five year phase in period. This would provide time to develop guidance documents and establish the various training, accounting and regulatory elements needed to implement green infrastructure asset management across the province.

Let's make our province great again:)

Truly,

Marc Yamaguchi

http://www.raingardensunited.com/

[Original Comment ID: 210167]