Please see the attached PDF…

Please see the attached PDF document entitled "20190521 FINAL ERO 013-4992 Submission"; on behalf of the Ontario Society of Professional Engineers - Land Drainage Committee.

1. To maintain historical consistency, the definition of watercourse may be more appropriate if it were to follow the Common Law definition as set out in OMAFRA Fact Sheets and other publications.

2. Any policy on "enclosures" should be detailed and not simply a blanket policy. The policy must work to assist all stakeholders in moving forward with acceptable procedures and solutions.

3. Focus on “core mandate” and “developing policy” which carry out the tests of the regulation (Flooding, Erosion, Pollution, Conservation of Lands, and the integrity of dynamic beaches).
It is important that Policy be a locally derived set of values to execute the rules of the Regulation; however, the Regulation must still govern. This is demonstrated best by Conservation Authorities (CA’s) that have produced and interpret their policies with their core mandate in mind. These development proposals receive faster, more predictable and less costly approvals, while constantly ensuring the safety of the public and property.

4. There needs to be an objective of establishing consistency regarding the application of Policy by all CA’s; unfortunately, consistency does not currently exist. We believe that a more consistent set of guidelines/policies would be beneficial for the CA’s, the engineers/practitioners and each/the affected landowner/stakeholder. This would be more valuable to all stakeholders and it would better serve the environment, future planning and development.

5. In 2007, there were issues around the maintenance of municipal drains in accordance with Section 74 of the Drainage Act; consequently, it led to the creation and establishment of the DART & DAWG committees. These committees created a forum and opportunity for constructive dialogue between the CA’s and the engineers/practitioners, their work resulted in more harmony between the CA Act and the Drainage Act and were proof that each Act could work together to establish a protocol for projects under Section 4 and Section 78 of the Drainage Act. We respectfully suggest that serious consideration be given to the establishment of DART 2; this new version could be set up similar to the DART (1) committee that worked with input from all key stakeholders.