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A summary of comments specifically noted in the attached table are as follows:

1. Proposed New “Core Watershed-Based Resource Management Strategy.”
These are significant environmental studies that are proposed to be conducted by CAs for each subwatershed. Many CAs would not have the capacity to lead these studies from both a workload or staff expertise perspective. Engaging consultants to undertake this work will be a time-consuming and costly process. Further, there is currently no budget allocated at any level of government to conduct the studies as proposed.

2. Definitions needed:
o Hazard Lands needs to be defined in this document. Our understanding is that hazard areas include flooding, erosion and natural heritage (wetland) hazards. The Provincial document “Protecting People and Property: Ontario’s Flooding Strategy” (March 9, 2020) states floodplain updates are the role and responsibility of the municipality and that the municipality may choose to request the CA to complete this work. As a result, clarification throughout the document to separate flood hazards from other hazards is required.
o Similarly, common definitions in the PPS, Planning Act, CA Act, etc. are needed as it relates to “development” or “wetlands”, etc. It can be inconsistent at times depending on the perspective taken and may need legal advice to interpret.

3. Municipal Support for Provincial Water Quantity and Groundwater Monitoring:
The proposal for CAs to lead the provincial monitoring network is greatly supported. This information would fill a critical data gap to conduct better floodplain mapping updates and monitor changes to the natural environment.

4. Missing Nutrient Management Strategy:
This topic is not discussed under mandatory or non-mandatory programs. It would be beneficial for CAs to lead nutrient management initiatives from a watershed perspective to address mitigation of rural and urban sources of phosphorus and nitrates, all to support the health of watercourses and the Great Lakes.

5. Unclear Intent of Community Advisory Boards:
The purpose, role, and subject matter of the community advisory boards needs to be clarified. Generally, it is not desired to add another layer of review to CA processes. The CA advisory boards may be redundant with Municipal Advisory Committees.

6. Short Timelines for MOUs:
Completing the mandatory services MOU by the end of 2021 is unrealistic for most municipalities and CAs. Rather than have a process to extend the deadline, it would be preferred to extend the date to mid-2022 or 2023 for both mandatory and non-mandatory services as these are linked.