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The OHI has made comments on the draft new COA. Our two main comments are entwined and focus on a key gap that we perceive in the existing agreement: the absence of a systems-based framework to protect the Great Lakes Ecosystem, creating an unbalanced focus on the water in the Lakes themselves, and a corresponding lack of a perspective on the Basin and watershed management. See the full submission at  https://ontarioheadwaters.ca/submissions-ppts-etc/.