In Annex 3: Wastewater and…

ERO number

019-0198

Comment ID

33505

Commenting on behalf of

City of Kitchener

Comment status

Comment approved More about comment statuses

Comment

In Annex 3: Wastewater and Stormwater, Result 2 section (p) it refers to certification and alternatives for both public and private sectors.
As a public sector representative, we have robust training programs for winter maintenance staff which is supported by the Ontario Good Roads Association. We have previously participated in certification through Smart About Salt and found the course content not specific enough to a municipal environment and very costly. Due to the number of staff involved in winter operations, the requirement for certification by a third party such as Smart About Salt would incur a financial burden on Municipalities without demonstrating a significant benefit. I would suggest within the context of this statement "certification and alternatives" be removed. While it may be an outcome from promoting salt application best management practices, it is stating a requirement without first following the initial statement of "Working with municipalities, conservation authorities, private sector and other partners".