On behalf of the 47 undersigned organizations, we are providing these comments on the two draft binational strategies under Annex 3 – Binational Strategy for PCB Risk Management (February 2017, hereafter “PCB Strategy”), and Binational Strategy for HBCD Risk Management (March 2017, hereafter “HBCD Strategy”). We are offering several general observations and recommendations to the Parties for both chemical of mutual concern (CMC) strategies together. Then for each strategy document, we offer specific observations and/or recommendations for individual sections.
The undersigned applaud the Ontario Ministry of Environment and Climate Change (MOECC) for its initiative in developing runoff volume control targets to reduce urban stormwater runoff and associated water pollution. We look forward to working with the Ministry on both the development and implementation of a Low Impact Development Stormwater Management Guidance Manual (which the above-noted Registry notice indicates will be drafted and consulted upon at a later date) and the further evolution of rainwater management policy and practice (both urban and rural) in Ontario. Our comments are directed only at the consultant reports attached to the Registry notice.