The Board of Directors for…

The Board of Directors for the Mississippi Valley Conservation Authority recommend that Schedule 2 not be removed from Bill 108 and deferred for further consideration for the following reasons:

1) There is a fundamental misunderstanding in the legislation and proposed regulatory changes on how watershed planning supports flood management and the need for comprehensive coordinated action by municipalities through their CA, as is done between Canada and the USA via the IJC.

2) The proposed changes in definitions could undermine the rigor and effectiveness of the regulatory tools.

3) The proposed introduction of exceptions adds potential for disputes and referrals to the regulations committee, and overall confusion on what is and isn't permitted.

4) The funding model proposed undermines the ability to undertake the type of studies, analysis, and planning required to mitigate and respond to not only flooding but also drought conditions, which is at increased risk under climate change, and per comment 1.

Additional comments are made in the letter.