Key comments are summarized below. Detailed comments are included in the attached document.
• Provide clearer direction for when an area-based management strategy is initiated. Clearer direction could include triggers, criteria and processes that would require the PTTW director to consider an area-based strategy.
• Links to existing water management programs such as source water protection, municipal water supply planning, subwatershed studies, and the low water response program need to be recognized early on in the process when developing an area-based management strategy. Data and knowledge from these programs, where available, should form a basis for development of an area-based strategy as well as improve proactive water management in areas of constraint or increased growth pressures.
• The guidance should include a detailed engagement strategy (or a process to develop one) for engagement and collaboration with local agencies, e.g., conservation authorities, municipalities, indigenous communities etc., to take advantage of local knowledge and expertise, minimize duplication of effort and cost, and share resources/capacities. Ministry could delegate establishment of strategy or components of it to a local agency.
• The current draft guidance limits priorities of water use to existing conflicts and established water takers. The Ministry is encouraged to enhance the concept of priority of use by using it in conjunction with area-based management to proactively avoid conflicts and constraints.
Submitted January 22, 2021 4:27 PM