1. The UTRCA supports the…

1. The UTRCA supports the inclusion of Schedule C4 - Natural and Human-made Hazards.
a. We recommend that the applicable Conservation Authorities (CA) and their watershed boundaries also be identified on Schedule C4.
b. Will there be an option to include ‘CA Regulated Areas’ as an overlay on Schedule A3 - Land Use Designation? The overlay would provide direction to landowners that a Section 28 permit is required without looking across various schedules.

2. The ERO posting introduces the term “Natural Environment and Water Resource Areas”; however, natural hazards are identified on the Schedule C4 - Natural and Human‑made Hazards. It is unclear what is intended to be included within the “Natural Environment and Water Resource Areas,” specifically whether natural hazards are included.

3. The UTRCA encourages the inclusion of a land use designation specific to natural hazards. This designation may not be applicable to all natural hazards, but could be used where hazard areas are high risk and prohibitions apply. Inclusion of a natural hazard designation on Schedule A3 would allow for additional management and/or mitigation of the natural hazard, where required, through the zoning by‑law. This is particularly useful for areas subject to two‑zone floodplain management and Special Policy Areas.
4. It is unclear where the natural hazard policies will be located within the proposed Official Plan structure (i.e., Local Landscape and Resource Management). It is important that natural hazard policies clearly apply to all land use designations where a natural hazard is determined to be present.

5. We recommend that Secondary Plans and Site & Area-Specific Policies (SASP) be identified on a required Official Plan schedule and that SASP policies be included within a consistent section of the municipal Official Plan.

6. Please refer to the comments below related to the changes identified in the ERO posting, which are proposed in more detail across multiple ERO postings.

7. The Upper Thames River Source Protection Authority emphasizes that municipalities should be continuously integrating Source Water Protection into planning processes like official plans, zoning bylaws, development approvals, and infrastructure decisions. Policy 1.06 in the Thames-Sydenham Source Protection Plan reinforces this by requiring that: All planning decisions must conform with policies that address significant drinking water threats. This includes any activity or land use that could negatively impact municipal drinking water sources (e.g., groundwater wells or surface water intakes)