The City of Port Colborne is pleased to have had the opportunity to review the proposed linear infrastructure ECAs and the draft design criteria for sanitary and stormwater systems. We believe that the new approvals process will be beneficial to the City's operations and will bring consistency and clarity to not only the City's construction projects, but to developer's projects.
We do request that the Ministry consider issuing the ECAs in a staggered manner, similar to how the drinking water licensing requirements were rolled out. While it is true that there are a few less requirements to transition to sani and storm ECAs, there is still a financial impact with many of the reports and studies required under the ECAs and with the pandemic, many municipalities are dealing with budget shortfalls and cost cutting measures, so a staggered implementation will permit municipalities to budget for the implementation costs.
Additionally, municipalities where there are more than one level of government and/or more than one operating authority involved in the operation and maintenance of the collection system and/or stormwater management system will require extra coordination and would benefit from having a staggered approvals process that ensured the upper tier system received their approval first.
Submitted August 17, 2020 12:48 PM