Peel Community Climate Change Flood Resiliency Strategies - Date Revised: February 21, 2019
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Peel Community Climate Change Flood Resiliency Strategies Date Revised: February 21, 2019 1
Flood Resiliency Strategy Context: The Peel Community Climate Change Steering Committee (PCCCSC) identified flood resiliency as 1 of 3 priorities that could be addressed by partner organizations (Peel, Brampton, Mississauga, Caledon, CVC and TRCA). The following strategy was approved by the Peel (PCCCSC) on December 19, 2017. Purpose: Work together to improve flood resiliency in light of current and future extreme weather events. Build upon the Region of Peel Water and Natural Heritage Vulnerability assessments by optimizing policies, programs, and practices, and increasing alignment amongst partners Strategy Lead: Christine Zimmer (CVC) Technical Advisory in the development of the Approved 2017 Workplan • Peel: Christine Tu (formerly at TRCA during Strategy development), Andrew Farr, Imran Motala, Italia Ponce, Steve Ganesh, Sally Rook, Syeda Banuri, Learie Miller, Gail Anderson, Mark Pajot, Sam Paquette • Mississauga: Paul Mitcham, Helen Noehammer; Michael Cleland; Julius Lindsay , Tim Lindsay, Muneef Ahmed • Caledon: Shannon Carto, Katelyn McFadyen, Ryan Grodecki , Geoff Hebbert • Brampton: Michael Heralall • TRCA: Nick Lorrain, Sonya Meek, Sameer Dhalla, Rebecca Elliot, Tim Van Seters, Meaghan Eastwood, Dilnesaw Chekol • CVC: Tim Mereu, Jeff Payne, Roger Tharakan, Alex Lenarduzzi, Gayle SooChan, Lisa Brusse, John Sinnige, Loveleen Clayton, Jeff Wong, Maureen Pogue, Lisa Brusse, Alex Pluchik, Cassie Schembri 2
ToCP: Adapt effects of Climate Change Strategy: Urban and Riverine Flood Resiliency Strategy within Peel Key Question(s) Responses Description Describe the strategy and its purpose in a The purpose of the Flood Resiliency Strategy is to improve flood resiliency for urban and sentence or two riverine flooding in light of current and future extreme weather events. The strategy builds on the Peel Climate Change Vulnerability Assessments. Improvements will be achieved through the optimization and coordination of consistent approaches, optimizing policies, programs, and practices by partners to reduce risks. Rationale Why do we believe that it will have an The 2017 Peel Water Vulnerability Assessment found: impact on our key outcome and metric? • Climate change is likely to lead to increased severity and frequency of extreme rainfall events. These events are difficult to predict in advance, posing challenges to warning systems and emergency response. These two critical factors are the responsibility of different partner agencies so increased alignment amongst the agencies will aid in overcoming this challenge. • Recent extreme rainfall events within Peel Region have highlighted the wide range of risks to public infrastructure and services, natural environment, and human health and well-being. Critical interdependencies (stormwater, water, wastewater, EMS, public health, etc.) highlight the need to respect the different roles partners have in building flood resiliency. Processes can be strategically aligned to maximize return on investment and reduce overall risk. • One of the first steps to adaptation is addressing current vulnerabilities that otherwise will be exacerbated by climate change. Benchmarking our current risk and level of service will allow reductions in vulnerability to be measured. This information can help determine where to focus collective adaptation efforts in the future, if needed. • Vulnerability Studies recommend 5 key component which form the basis of the 3
FRS (for the purposes of the strategy, recommendations 3 and 4 have been combined): 1. Building capacity and resiliency through “in the ground action using SNAP” and “prioritization of high risk areas through mapping and Tools” 2. Land-use compatibility in flood-prone areas through planning policies 3 and 4. Multi-stage early emergency warning systems; Post-event forensic investigation to understand the direct/indirect costs and risks associated with flooding 5. Framework for action on resiliency to ensure level of service is maintained to meet an acceptable levels of risk Scale At what scale (number of staff, citizens, e.g.) This Strategy consists of two components: will the strategy be implemented? 1. Enhance the coordination of currently planned programs (2018-2022) by highlighting current Peel-wide partner initiatives that align with the goals of the PCCP Flood Resiliency Strategy. This information will serve to inform the Flood Resiliency Strategy Pilot. 2. Develop of a Flood Resiliency Strategy for the Town of Caledon as a pilot which can be expanded across the partnership. It will inform flood resiliency initiatives in new developments (greenfield) and existing urban areas. Resources What people, time, money, and technology Staffing needs: Required will be needed to implement it? Estimate Strategy Lead: Christine Zimmer specific numbers required for each; if In keeping with the vulnerability recommendations, the following components form the basis appropriate, specify which resources will be of the FRS. A lead or co-lead has been assigned to each component. Advisory teams can reallocated and which are new. ensure case studies findings inform broad Peel-wide application to meet the Strategy Goals. 1. Building capacity and resiliency through “in the ground action through SNAP” and “prioritization of high risk areas” • SNAP o Recommended Co-Leads: Sonja Meek (TRCA) and Andrew Kett (CVC) o Advisory team: Jose Torcal (TRCA), Karen Bannister (CVC) Katelyn McFadyen 4
(Caledon), Johanne Manente (Peel), TBD (Brampton), Mississauga (TBD) • Mapping Partner Initiatives o Recommended Co-Leads: Amna Tariq (CVC) and Shahir Alam (Peel) o Advisory team: Muneef Ahmed (Mississauga), Michael Heralall (Brampton), Geoff Hebbert (Caledon,) Samantha Paquette (Peel), Syeda Banuri (Peel), Katie MacDonnell (CVC), Kamal Paudel (CVC), Tim Mereu (CVC), Alex Pluchik (CVC), Sameer Dhalla (TRCA), Rebecca Elliot (TRCA), Ryan Grodecki (Caledon), Tim Van Seters (TRCA), Sonya Meek (TRCA), Cassie Schembri (CVC), and Meaghan Eastwood (TRCA) • Prioritizing high risk areas and management strategies o Recommended Co-Leads: Geoff Hebert (Caledon) and Christine Zimmer (CVC) o Advisory team: Muneef Ahmed (Mississauga), Greg Frew (Mississauga), Luis Lasso (Peel), Miriam Polga (Peel), Mark Head (Peel), Syeda Banuri (Peel), Michael Hoy (Brampton), TBD (Brampton), Katelyn McFadyen (Caledon), Geoff Hebbert (Caledon), Sameer Dhalla (TRCA), Nick Lorraine (TRCA) , Meaghan Eastwood (TRCA), Michelle Sawka (TRCA), Neelam Gupta (CVC), Tim Mereu (CVC), Amna Tariq (CVC), Sakshi Saini (CVC), Katie MacDonnell (CVC), Tatiana Koveshnikova (CVC), Kamal Paudel (CVC), Scott Sampson (CVC) 2. Land-use compatibility in flood-prone areas through planning policies • Integration of flood resiliency into planning policies and processes o Recommended Co-Leads: Gail Anderson (Peel), Katelyn McFadyen (Caledon) and Meg Olson (CVC) o Advisory team: Planning Technical Advisory Committee – Sylvia Kirkwood (Town of Caledon), Bailey Loverock (Town of Caledon), Marie Miller (Caledon), Mark Head (Caledon), Eniber Cabrera (City of Mississauga), David Waters (City of Brampton), David Burnett (TRCA), Joshua Campbell (CVC), Hailey Ashworth (CVC) • Risk Management Framework 5
3. Multi-stage early emergency warning systems and post-event forensic investigation to understand the direct/indirect costs and risks associated with flooding • Emergency management o Recommended Co-Leads: Christine Zimmer (CVC) and Teresa Burgess-Ogilvie (Mississauga) o Advisory team: John Sinnige (CVC), Rebecca Elliott (TRCA), Meg Olson (CVC) Hailey Ashworth (CVC) Katie MacDonnell (CVC), Andrew Cooper (Peel), Alain Normand (Brampton), Mark Wallace (Caledon) 4. Framework for action on resiliency to maintain a level of service and acceptable level of risk • Monitoring strategy o Recommended Co-Leads: Jennifer Dougherty (CVC) and Tim Van Seters (TRCA) o Advisory team: Syeda Banuri (Peel), Sam Paquette (Peel), John Antoszek (MOECC), Geoff Hebbert (Caledon), TBD (Brampton) and other members of STEP advisory Committee, Meaghan Kline (CVC), Katie MacDonnell (CVC) Definition of What would success look like for this specific • Completion of all short term products for 2018 identified below (see Milestone Success strategy? Section). • Visual products to help prioritize partnership efforts (mapping completed 2018) • Clear, consistent, and partnership-wide understanding of flood risk (Flood risk meeting 2018) • Completion of a comprehensive list of flood risk reduction activities (policy, management, emergency planning, enforcement, maintenance) complete with approximate costs (return on investment data) for effective decision-making and cost savings. (Q1 2022) • A list of barriers and gaps needed to address coordinated emergency management strategy. (Q2 2019) 6
• Informed SNAP participants for effective behavioral change and support.( 2022) Strategy What metric will we use to regularly track In 2022 metric our progress toward this definition of • # of households and businesses in SNAP pilot that adopt LID measures (annually) success? • Completion of flood risk mapping (as a percentage of total length of watercourses that have floodplain mapping) • # of stormwater infrastructure improvements constructed within high priority areas (every 5 years) • % of priority areas studied through Inflow and Infiltration (I-I) Reduction and Mitigation program. (every 5 years) • % of sewers meeting the level of service in high priority areas (every 5 years) Beyond 2022 • Developing KPIs in 2019-2020, baseline monitoring 2021 • % of partner policies, programs and financial plans that integrate recommendations from the Strategy (2020+)(measured quarterly) Note: Baseline: 59% of Mississauga, 33% of Caledon, 32% of Brampton, 56% of Peel has no stormwater management Milestones / Between now and the definition of success Deliverables Roadmap (June 2019 or earlier), what are the most 1.0 Building capacity and resiliency through “in the ground action using SNAP” and important milestones that will represent “prioritization of high risk areas through mapping and tools” real progress? Who is responsible for each, and what is the deadline for each? 1.1 SNAP program • On Track- Q1 2018 (Design), Q 3 2018 (Construction): Upper Nine Stormwater Pond Retrofit - TRCA and City of Brampton retrofit a stormwater pond • On Track- Q3 2018 (Design), Q2 2019 (Construction): Glendale Public School LID Retrofit - Peel District School Board and CVC staff 7
• Completed Q1-Q2 2018: County Court Boulevard Bioswale/LID maintenance - TRCA and City of Brampton staff build capacity for LID maintenance and future applications of LID • On Track Q4 2018-Q2 2019: Develop Fletchers Creek SNAP Action Plan Report and submit for endorsement. • Q2 2019 (Design anticipated), Q3 2021 (Construction) anticipated: Haggert Ave Road Retrofit –Brampton and CVC staff, implement a LID road retrofit project • Q1-Q4 2019: Community Engagement to Build Community Leadership -TRCA, CVC, Mississauga, Brampton, Caledon (County Court SNAP and, Burnhamthorpe, Mississauga, Bolton West, Caledon). • Q1 2019 – Q4 2021: (Pending Brampton Council endorsing Fletchers Creek SNAP Action Plan) Fletchers Creek SNAP implementation fully underway and working toward four goals: reduced environmental impact of neighbours’ daily activities; empowered and knowledgeable community of neighbours who care for and are connected to nature; a healthy and diverse local landscape and; a clean and healthy creek. Specific projects to be identified when Action Plan complete at end of 2018. • Q1 2019- Q4 2022: Implement stormwater management (SWM) measures within the West Bolton SNAP neighborhood to learn lessons about its barriers, effective community capacity building, and to inform roles and responsibilities of partners. As an adaptive process, SNAP will seek opportunities to incorporate outcomes from PCCP strategy initiatives (i.e. watershed evaluation tool or risk and return on investment tool) as they become available and can contribute a neighborhood perspective to their development. 1.2 Mapping Partner Initiatives 1.2.1 Partnership Screening Mapping • Completed Q3 2018: Partnership screening mapping o Map 1: Riverine and Flood Forecasting – layers include: status of flood risk mapping and in stream monitoring and rain gauge network locations(note this map will be refined in 2021) 8
o Map 2: Partner Capital Initiatives for Flood Resiliency: Layers include: Stormwater, Sanitary and Instream Restoration Capital projects, SNAP and PPG neighbourhood boundary areas(note this map will be refined in 2021) o Map 3: Flood Resiliency Studies: Layer includes: watershed subwatershed master plans EA, other related studies (note this map will be refined in 2021) o Map 4: Draft Flood Risk Screening Map (Riverine, Urban, and Sanitary): Applying Intact Centre’s Priority Risk methodology for flood resiliency and Peel Neighborhood Information Tool or MNR Social VA tool (note this map will be refined in 2021) • Q2 2019: Create Preliminary Map #4 (Priority Flood Risk Areas) for the Town of Caledon • Q1 2020: Update Map #4 for Town of Caledon and Cooksville with RROIT results • Q4 2021: Update Mapping to reflect work done as part of partnership to define priority areas and collective impact 1.2.2 Conservation Authority Riverine Flood Risk Mapping • Completed Q4 2018: Flood Vulnerable Area (FVA) Mapping project Riverine flood risk assessment within Peel/TRCA jurisdiction (funded by NDMP) • Q3 2019: Update floodplain hazard mapping across Mississauga (CVC- NDMP funded) • Completed Q4 2018: Flood Hazard Mapping for Humber River (TRCA-Peel funded) • Q3 2020: CVC and TRCA coordination of riverine flood mapping standards. • Q1 2020: Update hydrology modelling and floodplain mapping of Mimico Creek. • Q3 2019: Update riverine flood risk mapping of Credit River watershed. 1.3 Prioritizing High Risk Areas and Defining Management Strategies 1.3.1 Risk and Return on Investment Tool, RROIT (CVC led) • Completed Q1 2018: - Evaluate risk reduction activities and return on investment for planned Cooksville stormwater activities (land acquisition and stormwater ponds) under climate projections • Q1 2019: Prototype Risk and Return on Investment Tool (RROIT) that quantifies public and private damages due to flooding (i.e. due to riverine, urban overland, 9
sewer and sanitary sewer back up, and erosion) under historic and climate change scenarios. • Q1 2020: Risk and Return on Investment Tool (Version 2) that utilizes updated sanitary sewer, public health, and water quality damages due to flooding. • Q1 2020: Update Cooksville Case Study RROIT Results with new modules • Q1 2020: Run RROIT in Alton and Bolton to inform Draft Town of Caledon Flood Mitigation Plan. • Q1 2021: Risk and Return on Investment Tool (Version 3) with potential liability and emergency management scenarios. • Q1 2021: RROIT application in Mayfield West. 1.3.2. Integrated Water Management (IWM) LID TTT Tool project (TRCA led) • Q1 2019: Green Infrastructure Opportunity Assessment: Model the stormwater benefits (in current and future climate) of integrating green infrastructure on to all Peel owned land assets; support SSG, as requested, to integrate results in the Climate Change Master Plan. Continued support of this project as requested after 2019. • Q1 2020: Integrate costs and tree and soil cell treatments into the LID TTT. • Q1 2021: Integrate co-benefits, and apply and one or more methods of climate change projections into the LID TTT. Pursue Opportunities to help users apply the LID TTT to practice. 1.3.3 Municipal Natural Assets Initiative Tool: Business Case for Natural Assets in the Region of Peel (CVC led) • Completed Q4 2018: Assessment and mapping of the level/value of stormwater management services provided by natural assets (wetlands, forests and other greenspace) in the Region of Peel (CVC’s and TRCA’s watersheds) • Q4 2019: Complete business case for natural assets for one rural (Caledon) and one urban (Brampton) location • Q1 2020: Complete life-cycle cost assessment of maintaining natural assets at two locations 1.3.4. Regional Stormwater Servicing Master Plan (Peel led) • Q1 2019: Regional Stormwater Infrastructure Inventory • Q2 2019: Initiate Regional Stormwater Servicing Master Plan 10
• Q3 2019: Perform Stormwater Infrastructure Conditions’ Assessment • Q2 2021: Complete Regional Servicing Master Plan 1.3.5 Level of Service and Level of Risk for Stormwater Study Guideline (CVC led) • Q4 2019: Develop a consistent approach to defining level of urban/riverine flood risk, level of service within existing urban areas • Q4 2020: Determine existing Level of flood Risk pilot areas, using existing CVC/TRCA models and Peel/Caledon studies • Q4 2021: CVC/TRCA Stormwater Management Criteria Document Update 2.0 Land-use compatibility in flood-prone areas through planning policies 2.1 Integration of Flood Resiliency into Planning Policies • Completed Q4 2018: Identify opportunities for updates to the Regional Official Plan, incorporating policies that support and enhance flood resiliency, including policy direction for the area municipal official plans. Investigate additional policy implementation mechanisms such as updates to municipal by-laws. • Completed Q4 2018: Discuss common elements of SS Bylaw development and updates as a partnership. • Q4 2019: CVC to support municipal partners in stormsewer bylaw development or updates as needed. • Q4 2019: Through partner meetings and research, identify planning policies and tools, including PCCCP screening mapping that could be implemented or evaluated to identify opportunities in the updates to support and enhance flood resiliency in Official Plans. • Q4 2020: In partnership with Caledon and Mississauga, and Peel, identify policies that need to be updated in light of Flood Mitigation Plans for Caledon and Cooksville and prioritize policies requiring an update. • 2020-2022: Create Planning Tool Chapter for the FRS that provides examples of planning tools and policies models, draft policies, bylaws, and discussion papers to support incorporation of flood resiliency in planning practice. 11
2.2 Risk Management Framework • Completed Q3 2018: Complete “Caledon Case Study: Feasibility Assessment of Standards and Systems for Quality and Risk Management Framework (RMF) for Stormwater Infrastructure in light of existing and Future Climate Change Impacts”. To support the implementation of a RMF and understand what best practices municipalities are doing nationally, PCCP (CVC) was awarded a grant by Standards Council of Canada. The grant provides funds to write a seed document “Stormwater Quality Management Standard (SW QMS) in light of climate change in Canada” to help inform potential national standards and showcase PCCP leadership. • Q3 2018: Identify barriers to tracking, documenting, inspecting, monitoring and maintaining SWM to meet ECA permits • Q4 2019: Complete review of ECA process recommendations in light of the Risk Management Framework. • Q4 2022: Complete Caledon Case Study using RMF (ongoing from Q3 2018-2022) 3.0 Multi-stage early emergency warning systems; Post-event forensic investigation to understand the direct/indirect costs and risks associated with flooding 3.1 Emergency Management (EM) 3.1.1 Coordinated EM Strategy (2020-2022) • Completed Q4 2018: Workshop with emergency management teams to discuss lessons learned from recent extreme events to identify gaps and identify partnership solutions (i.e. evacuation plans for schools in floodplain, inundation mapping for various storm events to identify vulnerable areas) • Q1 2019: Create a list of barriers and gaps needed to address coordinated emergency management strategy. • Q3 2019: Prioritize gaps and barriers through meetings with project partners and identify areas for EM integration with planning, public works and Conservation Authority initiatives. • Q1 2020: Develop a scope of work with budget estimate needed to enhance 12
coordinated emergency management based on prioritized needs • Q4 2020: Based on lessons learned from research, event debriefings, and risk framework, and current partner post-event reporting, develop a Post-Event Forensic Partner Process for continual improvement of EM. • Q4 2021: Complete a Chapter on Enhanced Coordinated Emergency Management that includes: vulnerable area maps, lessons learned from past extreme events, solutions and tools to address barriers/gaps, forensic audit protocols post events for continual improvement 3.1.2 Emergency Preparedness Marketing Campaign in High Risk Areas • Q3 2019: Study existing EM public outreach and market research from partners, and identify high risk areas to focus targeted campaign • Q4 2019: Estimate budget for market campaign with draft RFP for high risk areas in Cooksville. • Q1 2020: Work with partners to incorporated planned scope of work into budgeting cycles for 2021. • Q4 2020: Finalize RFP for market campaign research, including evaluation options, and conclude RFP for work. • Q2 2021: Launch marketing campaign for flood preparedness in identified high risk areas in Cooksville. • Q4 2022: Continue messaging; evaluate program reach and uptake to recommend improvements in final Flood Resiliency Strategy. 4.0 Framework for action on resiliency to ensure level of service is maintained to meet an acceptable levels of risk 4.1 Monitoring Strategy 4.1.1 Performance, Compliance and Inspection Monitoring of SWM Site Monitoring Region of Peel-led monitoring projects • Ongoing: Inspection and monitoring program of 3 Peel owned SWM ponds to be shared with partners to inform discussions for the development of template 13
protocols • Ongoing: Region of Peel creating documentation, tracking, compliance inspection/monitoring for LID road-right of way projects which can be shared with partners to support operations and maintenance programs • Ongoing: Region of Peel’s Environmental Control group will conduct pre- construction monitoring to help inform designs of future SWM/LID roadway projects. This information can be shared with partners to help support their programs. • Ongoing: Characterization of I-I generation across the Region via flow monitoring TRCA-led monitoring projects • Completed Q2 2018: Brampton County Court LID Performance monitoring Report CVC-led monitoring projects • Ongoing (2018-2022): Mississauga Road LID performance monitoring as part of ECA requirements • Completed Q3 2018: Brampton Drinkwater SWM Pond Monitoring Technical Memo • Completed Q3 2018: CWWF Caledon Pond Monitoring Plan finalized and monitoring initiated, and 4 months of monitoring completed. • Completed Q4 2018: Draft Wychwood Performance Monitoring Report • Completed Q2 2019: STEP Webinar on Wychwood residential LID water balance results • Q2 2019: Peer review and consultation with municipal partners for Wychwood Performance Monitoring Report • Q3 2019: Annual Update Memo on progress of monitoring project at Mississauga rd. • Q3 2019: Final Wychwood Performance Monitoring Report released on website • Q4 2019: Presentation on Wychwood outcomes at stormwater conference • Q4 2019: CWWF Caledon pond monitoring data collection complete • Q3 2020: CWWF Caledon Pond Monitoring Report (Spring 2018-Winter 2019) • Q4 2020: CWWF SWM Monitoring Protocol – guideline of monitoring and 14
reporting protocols to meet ECAs • Q4 2020: STEP Advisory Committee meeting to communicate flood resiliency strategy and monitoring outcomes 4.1.2 Flood Resiliency Key Performance Indicator strategy • Completed Q3 2018: Preliminary meetings and consultations to initiate working group for KPI • Completed Q4 2018: RFP finalized to hire consultants for KPI development process for Peel climate change special levy budget • Q2 2019: TRCA consultant selection process complete and consultant hired • Q3 2019: KPI Core management team from TRCA and CVCA meets with consultants to develop detailed workplan and schedule • Q4 2019: Consultant completes facilitated TRCA/CVC specific KPI development process (contract completed ) • Q2 2020: Hold consultation meeting to review TRCA KPI and integrate flood resiliency performance monitoring outcomes inform PCCP KPI development including baseline and targets • Q4 2020: Complete KPI development for Flood Resiliency Strategy • Q4 2020: Scope budget and workplan for KPI implementation of Flood Resiliency Strategy as guided by feedback from STEP Advisory Committee Impact Based on the planned milestones, what is The partnership will produce a blueprint (based on the Caledon pilot) for the expansion of an your estimate of the impact that this integrated Flood Resiliency Strategy. It is aimed at the reduction of flooding and legal risk. The strategy will have on the overall outcome pilot strategy will produce maps, data, risk/ risk reduction statistics and costing, as well as a list of detailed recommendations resulting in a statistically supported approach to reduce metric over time? flooding risks. Delivery Who will the leader of this strategy work Chain through in order to implement the strategy 15
at the necessary scale? Draw the delivery chain and consider: What is the end of the chain? This is usually the end-user/citizen and coincides with the definition of success. Between the leader (the beginning of the chain) and the end of the chain, who are all the people or organizations that must be involved in implementing the strategy? How many of each are there? What role does each play? What is the most important line of influence between the beginning and the end of the chain – the single line that is most critical to implementation? Please note: The actual development of the Delivery Chain will be facilitated by SDMR at a meeting with ToCP / Strategy Leads Risks As you look at the delivery chain, are there • Partnership commitment and resource availability: 2018 Deliverables are focused risks to implementation that you see? For on partnership wide activities that align with flood resiliency activities. The each one, how will we manage it? current activities may not currently be prioritized to optimize return on investment. Optimal activities that benefit all or a large % of the PCCP need to be reviewed and listed in order of benefit. Without partnership commitment, activities may proceed in an un-integrated or uncoordinated fashion. To manage and minimize this risk, the lead will work through the PCCP to identify challenges 16
as they occur. • Incomplete mapping: If we don’t have partner input or receive funding to fill data gaps, maps will be completed based on poor/incomplete data. • Funding: Affects staff and planned activities 2020 and beyond. Scope will be reduced or timelines extended. Feedback As you look at the delivery chain, are there Loops any aspects of implementation that you would want to measure to get feedback on implementation? (These would supplement the strategy metric above). 17
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