Minor Improvements The scope…

Minor Improvements
The scope of projects that fall within the criteria for minor improvements are so limiting that it is anticipated that this Drainage Act amendment is not going to prove to be very useful. There are very few projects that would fit the criteria to not change how future maintenance costs are allocated other than secondary culverts. Most culvert reports that are initiated for extensions are because the existing report does not contain cost sharing provisions and the other portion of the culvert requires replacement as well, so that eliminates that report type from being able to use the minor improvement process. In addition, the wait time for a Request for Review from DFO exceeds 90 days, so any reports on any kind of sensitive drain or drain type other than F will not fit this condensed timeline.
Our drainage engineering firms are limited in terms of staff that pushing shorter timelines for them to complete reports isn’t ultimately helping the process. In fact, these minor improvements with shorter timelines to be completed would take precedence over the projects we already the engineers appointed to complete under other sections of the Act.
The proposed changes under this minor improvement serve such a small scope of works that there are other ideas for Drainage Act amendments that I think would serve a much better purpose to the drainage community. For example, adding the option of the CA to waive the requirement under Section 78(2) would drastically improve our project timing. At this point the CA will often provide comments within a week stating they don’t have any concern under this section, yet we have no mechanism to bypass the 30 day waiting period. This would apply on almost every single Section 78 project and not once in my career have I ever had a CA make a request using this section. A change such as this would have a notable improvement to project timing across the province if the CA responds in a reasonable amount of time.