3) Oftentimes SWMP are…

3) Oftentimes SWMP are owned privately (private sites/unassumed subdivisions) and need to be cleaned out. Owners of private ponds aren't defined as infrastructure related under O. reg 406/19 but should be able to reuse similarly on ROWs of an asphalt road within the contiguous subdivision at minimum and on other road projects both private and infrastructure related (public) preferably.

4) Why is less testing being permitted only on infrastructure related (public) projects. Why only if identified in the planning documents prior to construction starting? It would be hard to get timing right.

7) Municipalities should consult with local Geotechnical Engineers for creation of local exceedances mapping and thresholds.

It appears that these changes are mostly being proposed to ease the workload and financial burden on municipalities when private industry deals with similar costs and burdens that are passed along to the homeowners. Municipal (infrastructure related) aren't less contaminated generally than private projects.

Additional recommendations per the attached file.