Please see attached document…

Please see attached document for detailed comments. A summary of the comments is provided here:

- need for clarity on mandatory or voluntary nature of amendments, who will fund and undertake the work required
- need for updating CWA to be able to address activities that impact vulnerability
- need for clarification why vulnerability scores for SGRAs have been removed
- need for support/funding for SPA staff to support Climate Impact Assessments
- support for changes to rules around application of road salt, but concerned lack of provincial funding will lead to inconsistencies of calculations across the watershed
- support for changes around definition of ICA but concerned about level of evidence needed for "contributing to Issue"
- concern with proposed change to local threat rules, as it unnecessarily restricts activities from being able to be considered
- concern with proposed changes around condition sites, as it results in greater level of effort needed to provide evidence of migration towards well/intake
- concern with no lower limit for snow storage
- concern with limited additional support for identifying handling and storage of DNAPLs
- concern with waste oil sites not being able to be address under CWA
- need to address PFOA and PFOs under CWA framework
- need to remove area of application restriction for pesticide application