This comment is with respect…

This comment is with respect to the requirement for municipalities to provide a Letter of Credit (LOC) to Department of Fisheries (DFO) to guarantee proper construction/maintenance of a drain.

Firstly, our very small Township (pop 1976) has upwards of 350 municipal drains throughout the Township. In 2018 the Township had to produce a LOC of close to $100,000. Again this past month, the Township has had to produce another LOC in the amount of $114,240. As a responsible level of government, a municipality should not have to provide this additional level of security in the form of a letter of credit to an upper level of government (DFO) in order to guarantee proper construction and maintenance of the drain especially when there are other methods to guarantee this - such as withholding the drainage grant via OMAFRA. The municipality, being a responsible level of government, already engages the services of a professional engineer to oversee the construction/maintenance of a drain and as well the municipality oversees this work. If there is an issue with the drain – the municipality will correct it or the grant is with held. There is no additional security in the form of a LOC required.

Plus, the cost of a letter of credit is $250 each + 3/4% interest charges per year. This is a significant cost to a small Township and can be onerous. If municipalities are considered "a responsible level of government", we should be treated as such.

If you have any questions, please do not hesitate to contact me.