Things we've been sounding off about
Writing letters. Who, us? Here's a few that we've sent off to various organizations regarding various topics!
Heather Ross
Wednesday, January 24, 2007 - 07:00
EH! requests proof of benefits; professional site evaluation
An open letter to Haliburton County council regarding a permanent asphalt plant for the county
Dear Warden Fearrey and Councillors:
For close to a decade there has been continuous concern and opposition by county residents to the establishment of a permanent asphalt plant. At the committee of the whole, January 10, council indicated that it would support the siting of a permanent asphalt plant at the placePlaceNameBark PlaceTypeLake quarry as such a plant would bring benefit to the county.
As this is a project that is so strongly and consistently opposed by county residents, Environment Haliburton! Requests that Council release the study which demonstrates that a permanent asphalt plant will create more benefits than costs to the County.
As a permanent asphalt plant is apparently a public good, one that does impose costs on neighbours and the environment, we also ask that the County undertake a professional site evaluation study to ensure that such a plant is located where it will pose the least damage to the environment and the neighbourhood and where it will maximize benefit to the County.
The placePlaceNameBark PlaceTypeLake quarry is located adjacent to a site where rare and endangered species have been identified. It is adjacent to a proposed major cottage and resort development. Would the Bark Lake quarry be rated as the best site for an asphalt plant? There is no way we can know until a site evaluation study is done.
Heather Ross
Environment Haliburton!
EH! MEMBER WRITES TO MINDEN 
HILLS TO OPPOSE BOATHOUSES
Municipality of Minden Hills, March 17, 2004
Minden ON. K0M 2K0
Att: Council,
IT IS WITH deep concern that I learned, according to your draft Comprehensive Zoning Bylaws, the municipality of Minden Hills intends to allow boathouses on all lakes. Just when other municipalities are realizing the scourge these structures are on waterfronts, are we really going to go down that ugly road?
Even Muskoka which has a heritage of boathouses is revisiting their bylaws in light of the congestion and degradation to shorelines caused by those structures - particularly on smaller lots. There are many areas now on Muskoka Lakes that have boathouses lining the shores so that if you sit on your beach, you are peering through a walled tunnel attempting to see the rest of the lake. Even those who thought they really wanted a boathouse, realize that if they are allowed one, so is everyone else and so the problems escalate.
Let’s face it, when you own several thousand feet of shoreline, a boathouse is not such a crisis, although any boathouse is a bad boathouse in most people’s view.
Minden Hills Official Plan plus all the public meetings around planning stressed the priority of maintaining natural, healthy and beautiful shorelines. Your taxpayers bought property on lakes to enjoy the beauty of trees, nature and wildlife – certainly not to see structures every 75 ft. Remember, if one lot is allowed a boathouse – all have the same rights, and in our smaller lakes with the prevalence of 100’ lots and many 50’ lots so the jamming will be significant.
Please look at the bylaws of the Municipality of Dysart. They have invested much time and money to develop an excellent policy for boathouse. I know there is the one case they have had to deal with but other municipalities have similar bylaws so the OMB in this case was influenced unduly. Dysart is now strengthening their bylaws to ensure the shorelines are adequately protected. Property values in Minden Hills will diminish significantly in comparison to the Dysart area when it becomes obvious our bylaws only pay lip service to protecting shorelines.
You will have done the natural environment of Minden Hills a huge act of kindness if you eliminate all potential for boathouses.
Looking forward to a positive response,
Sincerely, Jeanne Anthon
Minden.
The following letter/report contains Environment Haliburton's comments on:
The Michalski Nielsen
Associates Ltd. Report
Entitled "Site Evaluation
Report, Elephant Lake"
Copies of EH's comments were delivered to the Township of Dysart et al and Patricia Reilly, who currently are or who soon will be going through OMB deliberations.
(Above, an aerial photo of Elephant Lake.)
865026 Ontario Limited owns approximately 690 acres of land consisting of Part Lots 27 to 29, Concession 8, Part Lot 27 and all Lots 28 to 33, Concession 9, Township of Harcourt, County of Haliburton. The company has decided to sever part of the shoreline in order to create 8 lots comprising, in total, approximately 75 acres of land in Part Lots 27 to 29, Concession 8 and Part Lot 27 and Lot 28, Concession 9. The company would retain the remainder of its property (about 615 acres) as backshore property. As the subject property is on or adjacent to one of the two provincially significant wetlands in the County of Haliburton, the company asked Michalski Nielsen Associate Ltd. to prepare a site evaluation report demonstrating the site's capability to sustain a development of this type and scale and to show how any unacceptable environmental impacts would be minimized. Pursuant to this request, Michalski Nielsen Associates Ltd. has produced a report entitled Site Evaluation Report, Elephant Lake. These comments are directed to the findings and recommendations contained in this report (the Report).
General Comments:
The 75 acres of land contained within the proposed development are adjacent
to the Provincially Significant Baptiste-Elephant Lake Wetland Complex.
Docking facilities to enable water-based recreational activities are an
integral feature of this proposed development. To the detriment of this
wetland, such docking facilities would be located in the wetland. The
Baptiste-Elephant Lake Wetland Complex is a place of unspoilt beauty. This
pristine environment is rightly identified for its natural features and
ecological functions. Development in this particular wetland would
jeopardize the wetland and the sense of wilderness it creates. Such places
as Elephant Lake are treasures that we should strive to harbour for the
benefit of all. They are, unfortunately, becoming scarce in Haliburton
County.
EH! acknowledges that under the current Provincial Policy Statement development may be permitted on lands adjacent to wetlands and, indeed, within the wetlands themselves in the Canadian Shield if it has been demonstrated that there will be no negative impacts on the natural features or ecological function for which the area is identified. EH! has grave concerns about the wisdom of this policy. We believe that there should be no development in Provincially Significant Wetlands. Our concerns have been made known to the Minister of Municipal Affairs (see attached letter).
In view of the fact that the Report indicates that there is significant capacity for further development on Elephant lake and that the proposed development of 8 lots may set a
standard for developers contemplating development in similar circumstances, EH! recommends that :
Best practices be used in the development of the lots;
The precautionary principle of no damage be applied;
the developer and the lot owners enter into a lot design process that includes input from local governments and cottage associations;
Eh! further suggests that these principles be a condition of approval and that they gain force through incorporation into control orders, registry on title and contractual agreements.
(Paddling on Elephant Lake last November)
Specific Comments:
1. Research Issues
Issue #1
One of the significant features of the wetland evaluation conducted on Elephant Lake is the presence of Bald and Golden Eagles during the winter season. These two species alone accounted for 225 points; a significant portion of the total 791 points. Although, these species are listed as a feature of the Provincially Significant Wetland (PSW) in the Site Evaluation Report, there is no investigation into the relationship between the subject property and the presence of the eagles.
EH! recommends that there be an investigation to determine whether the Bald and Golden Eagles are present on the subject property and to ensure that the proposed development will not negatively impact these species.
Issue #2
As will be discussed further in relation to docking facilities, a key characteristic of the littoral zone is the slope. Based on the slope, the length of dock required to reach a depth sufficient for propellers to clear the substrate can be calculated. If the slope is slight, than impacts to the substrate and adjacent vegetation are anticipated. The Report does not record the slope of the littoral zone.
EH! recommends that there be an investigation of the slope of the substrate in the littoral zone to determine the length of dock required to minimize disturbance of the substrate, and adjacent and submerged aquatic vegetation.
Issue #3
Christie et al (1991) reports the presence of Potamogeton praelongus, a regionally rare pondweed, to the south of the subject property. Although the Report includes Christie
et al (1991) in their literature review, this species was not mentioned in the Michalski Nielsen Associates Ltd. Report. Rare and uncommon species are often difficult to detect, as, due to their very nature, investigators are often not familiar with them. It is therefore important to familiarize oneself with rare species known to be in the area, prior to the field investigation to enhance the possibility of their identification if encountered. For this reason it is of concern that the regionally rare species of pondweed identified south of the property by Christie et al (1991) is not mentioned in the report. Regionally rare species are scored during a wetland evaluation and would be a "natural feature" of the wetland warranting protection. The investigators awareness of Potamogeton praelongus should be determined to ensure that this species was not overlooked.
EH! recommends that an investigation be conducted to ensure Potamogeton praelongus is not present in either of the wetland vegetation communities subject to dock development.
Issue #4
Michalski Nielsen Associates Ltd. report that Red-shouldered Hawk nesting habitat does exist on the subject property and that the Natural Heritage Information Centre have element occurrences of Red-shouldered Hawks in the area. The most recent field investigation was conducted during the month of July when the canopy is fully foliated and stick nests would be virtually invisible. As the construction of seasonal dwellings could significantly impact Red-shouldered Hawk breeding sites, a stick nest inventory is recommended to ascertain their presence.
EH! recommends that a stick nest inventory be conducted to determine the presence of Red-shouldered Hawk breeding sites and provide the necessary protection if identified.
Issue #5
According to the wetland evaluation, the vegetation communities adjacent to the subject lands and subject to dock development represent more than fish habitat. Another feature identified in the wetland evaluation was moose aquatic feeding habitat. Yellow water-lily, water-milfoil and pondweeds were identified during the field investigation: species indicative of moose aquatic feeding habitat. Though identified, these features have not been addressed specifically in the site evaluation.
Wild rice was also recorded in the open water marsh adjacent to the subject lands by Michalski Nielsen Associates Ltd during their field investigation. Wild rice is one of the 56 variables assessed by the Ontario Wetland Evaluation System. In the original evaluation, wild rice was recorded as absent from the wetland.
Therefore, the wild rice documented during the site evaluation by MNA represents the only occurrence of wild rice in the wetland complex. Any detrimental impacts to this feature could result in "absolute loss" of this feature from the complex as a whole.
EH! recommends that the impact of dock development on wild rice and moose aquatic feeding habitat be addressed.
Issue #6
As will be discussed further under docking facilities, the map of the wetland provided in the Michalski Nielsen Associates Report does not accord with the map of the wetland provided by the Ministry of Natural Resources. An accurate depiction of the wetland is important in order to properly locate docking facilities having access to the main channel and to avoid creating a navigational hazard.
EH! recommends that the wetland be accurately mapped identifying the navigation channel and any side channels there may be during the boating season.
2. Site Planning Issues
The Report recommends that:
final development plans for the eight proposed lots incorporate 30 metre shoreline buffer strips or setbacks for all primary building structures; and
as a condition of approval, a covenant restricting activities in the 30 metre shoreline buffer or setback be registered on title or through an agreement under Section 53 (12) of the Planning Act and any other development of servicing agreements to be executed between the Municipality of Dysart et al and the applicant. The covenant would require that the shoreline be disturbed as little as possible, consistent with access, safety and provision of views." (viii)
EH! is concerned that, over time, this approach to shoreline protection will prove insufficient. The recent OMB approval for a boathouse within the shoreline setback gives impetus to this concern. During the OMB hearing itself, the planner for the Applicant "asserted that through setback, natural and added vegetation the boat storage building would be invisible from the water." The Board approved the amendment relying on the assurance it received that "the Applicant will leave the appearance of undeveloped wilderness, and the existing visual characteristics of the shoreline will be maintained." However, at a subsequent municipal meeting to approve the required amendment the spokesperson for the Applicant made it clear that the OMB decision did not mean that the structure would be invisible. Simple assurances, therefore, are not to be relied upon.
While the Report in its discursive passage (viii) suggests that "…no clear-cutting or removal of native plant species would be allowed, although some trees and underbrush could be cut to permit a 2 metre wide path to the shoreline and views…", the recommendation quoted above is much less restrictive. In practice leaving the shoreline undisturbed is interpreted as permitting the clearing of 25% of the shoreline. This would mean that at least 60 metres of the shoreline would be altered. Finally, there is nothing to prevent the much reputed landowner practice of girdling trees in order to create dead and diseased trees to be removed.
EH! believes that the approach to shoreline protection recommended in the site evaluation report will fail and reflects neither best practices nor the precautionary principle. EH! suggests that the approach to shoreline protection proposed for the Fraser Property on Stoney Lake be adopted. Part of this property is covered by a provincially significant wetland. The developer of the property has worked with the Stony Lake Environment Council made up of representatives from cottagers associations and the town of Burleigh Falls. Together the developer and Council have designed a plan for a large subdivision that will protect shoreline, wetlands and each other's interests. One element of the plan is to vest the 30-metre shoreline easement in a government agency (likely the Trent Severn waterway) to ensure that the easement will be left in its natural state and that no buildings including docks will encroach on this land. Communal docking facilities are proposed. (For further information, visit www.stonylake.on.ca/fraserplan) EH! suggests that the approach taken in respect of the Fraser property on Stony Lake be adopted in respect to the property on Elephant Lake and that the proposed 30 metre shoreline setback be deeded to the Township of Dysart as an easement. We would note that this approach is not extraordinary, as a developer has made this suggestion for a proposed development on Eagle Lake.
The Report recommends that:
to every extent possible, on-site B horizon mineral soils be used in the construction of leaching/filter beds for the eight proposed lots owing to their high capacity to irreversibly complex phosphorus; and
the tile fields be located as shown in Figure A" (ix).
EH! appreciates the thoroughness and extent of the literature review that has gone into the discussion of septic fields in the Report. As has been noted earlier, development on these lots represents a major challenge to protection of wetlands in "northern" Ontario. EH! strongly recommends that such development must incorporate both best practices and the precautionary principle. Therefore EH! suggests that a more rigorous standard be applied to the siting of septic fields than is recommended. EH! suggests that the 46-metre (150 foot) setback from the wetland in effect in some jurisdictions be the standard adopted for these sites.
The Report recommends that:
a stewardship brochure be prepared by the applicant and included in all offers of purchase and sale, and registered on title. The contents of such a document would include but would not be limited to: the character and importance of the
Provincially Significant Baptiste-Elephant Lake Wetland; biophysical aspects of the property; care of the littoral, shoreline, riparian and upland habitat; dock approval, construction and maintenance; woodlot management for deer; water supply; and types of sewage treatment systems including approvals and maintenance. (v)
EH! agrees that, should the lots be developed, the purchasers should be aware of the significance of the properties, of the privilege of developing adjacent to a Provincially Significant Wetland and the stewardship responsibility they will be taking on with the purchase of these lots. EH! is very much in accord with the development of a purchasers handbook, such as the excellent one appended to the Report. EH! suggests that the handbook be developed in cooperation with the OMNR and Ducks Unlimited. EH! will certainly be pleased to participate in such an enterprise, if requested. EH! further recommends that the portion of each lot not included within the building envelope be subject to a restrictive covenant to help ensure minimum change to the property, the trees and other growth.
3. Docking Facility Issues
The Report recommends that each of the eight lots to be created for seasonal residences have a small finger dock on poles (p. 43) in the location on the shore of the lot shown in Figure A. The Report assumes that small finger docks of the relative size shown on Figure A would extend far enough from shore to reach a depth of 1.0 to 1.5 m above the aquatic plant life. The studies referred to in the Report suggest that very little impact occurs from boating where plants are 1.0 to 1.5 m below the surface of the water. The Report does not make clear what the overall depth of the water is where the plants are 1.0 to 1.5 m below the surface.
The Report describes the foreshore area as relatively flat to gently sloping with a backshore area whose topographic relief is considerable typically exceeding 20% to 25% and constituting a rock knob (p. ii). The Report indicates that three drainage channels are located on the property with one at the eastern end and two in the middle. Much of the drainage from western slopes of the rock knob runs into one of these drainage channels, which directs the flow into Elephant Lake. The most substantial of the drainage channels is the most northerly. (p. iii)
The Report classifies the majority of the property as being fronted by Type I fish habitat (i.e., limiting to the overall productive capacity of fish) although it is suggested that there are considerable stretches and open water that are free of vegetation comprising Type II fish habitat (p. iii and iv).
The Report claims that the docks indicated on the site plan (Figure A) will not encroach into Type I fish habitat since they are sited in areas essentially devoid of aquatic plants signifying Type I fish habitat (p. vi). Further, the Report recommends that any docking facility be supported by poles or by using a floating or cantilevered system or by
conventional cribs that do not have a footprint on the bed exceeding 15 square metres. In addition, the Report recommends that prospective owners be made aware through notice on title of need to contact MNR if these specifications are not to be followed and the need to contact DFO to ensure that docking facilities do not constitute an offence under the Fisheries Act. The Report states that "[b]y locating the docking facilities as shown in Figure A, impacts from recreational activities on the wetland's features and functions will be minimized" (p. vii).
The Report acknowledges that the purpose of docking facilities is to support boating activities. The recent attempt to mediate this matter made it evident that docking facilities and recreational boating are essential to the proposal. While MNA concedes that power boating will produce adverse affects on the aquatic environment, it believes that reasonable levels of use will produce no substantially adverse consequences. MNA believes that "…there is more than enough open water and channels within which recreational boating occurs to safely accommodate boating traffic" (p. x).
The Report concludes that:
In respect of impacts on fish habitat: "Type I fish habitat contiguous with the subject property could potentially be affected by proposed docking facilities and related uses. However, if carefully located, such structures can be constructed away from the sensitive areas, as shown in Figure A."
In respect of the Provincially Significant Baptiste-Elephant Lake Wetland Complex: "…the sites for dock placement (Figure A) have been selected such that minimal disturbance of aquatic vegetation will occur through either the construction of a dock or subsequent boat traffic."
In respect of water quality: "….the quality of Elephant Lake for bathing, swimming and aesthetic appeal would not be diminished." (p. xi)
These conclusions depend upon a controversial definition of the term "loss" as it is found in the 1997 Provincial Policy Statement. The definition employed in the Report is that "…the loss of natural features or ecological functions for which the area is identified" means absolute loss and not just reduction and diminishment (p. 45).
EH! is concerned that the Report does not accurately describe the physical characteristics of the site.
A visual inspection conducted by EH! of the bottom of the lake in front of proposed lots 1 through 5 does not support the general description provided by the Report. EH! found the following:
There is a gradually sloping bottom;
Where the bottom is devoid of vegetation at the shoreline, a thick bed of vegetation is present 5m from the shore in water less than 1m deep;
There are no obvious "boating" channels free of vegetation allowing for the easy ingress and egress of boats to and from docking facilities;
A thick mat of emergent vegetation lies between the shore and the navigation channel inhibiting access by motorboats.
A comparison of the location of the wetland as shown in the Report on Figure 3 and as shown on MNR digital maps of the wetland complex reveals discrepancies in the boundaries of the wetland complex. Further, the configuration of the wetland as shown on the aerial photographs that constitute the basis of the figures in the Report and the actual mapping of the wetland on Figure 3 appear discrepant. Finally, it appears that MNA identified the "access channels" using an aerial photograph and circling the extent of the apparent vegetation. We are concerned that the extent of the vegetation revealed by the aerial photos is subject to the time of year in which the photos were taken and by the fact that the photos do not reveal the extent of the submerged vegetation. While MNA indicates in s. 2.2 of the Report that the general vegetation community boundaries on the subject properties were ground truthed and adjusted in situ, it is not evident that MNA also ground truthed the boundaries of the wetland vegetation and made adjustments accordingly.
It is not clear from the Report whether the small finger docks shown on Figure A are drawn to scale. The Report does not specify the depth of water at the end of each of the docks shown on Figure A or the distance of the dock from shore.
The Report does not address the suitability of the depth of water and the bottom for bathing and swimming activities although the Report assumes that these will take place. From EH!'s observations, the water is too shallow, the bottom too silty and the vegetation too abundant to be suitable for swimming.
The Report has not addressed the affect of tile beds and mantles and the housing structures on the drainage pattern from the rock knob. It is likely that drainage contributes to the scouring of any channels that may be present. The affect of any alteration in the drainage may impact any channels that may be present in the wetlands.
EH! is concerned that the docks depicted on Figure A in front of lots 5, 6 and 8 may constitute navigational hazards. There is no assurance that the length of the docks as
depicted in Figure A is sufficient for the purposes of boating in the particular circumstances of the Elephant Lake Wetland. Longer docks may be required to achieve the requisite depth creating an even greater navigational hazard. From a site inspection conducted by EH! with a canoe, the dock in lot 5 is located in a thick mat of weeds. It may be expected, therefore, that clearing will take place to allow for boating activities. Further, given the unsuitability of the near shore for swimming and bathing, it may be reasonably assumed that clearing of the vegetation will occur. This will have an obvious negative impact on the wetland complex.
It is likely that the type of motorboat most suitable to exploit the Elephant Lake environment is the personal watercraft. The research adduced in the Report to support its proposals indicates that while all boating activity adversely affects the aquatic environment (p. 62 -63), the affect is most pronounced by motor boats running at moderate speed and by PWC's. These are precisely the speeds and types of motorboats most likely to be used in the highly sensitive Elephant Lake wetlands. It is EH!'s view, that the siting of docks in the wetlands with all their associated activities will have a significant impact on the wetland.
Eh! recommends that:
as proposed under 2) above, a 30 metre shoreline setback be deeded to the Township of Dysart as an easement;
Lot 1 be owned in common by the owners of the other seven lots;
In the ownership agreement for Lot 1 and under the terms of the easement with Dysart et al, provision be made for a common dock on Lot 1 as well as the siting and operation of a common swimming raft in a place /suitable for such purposes accessible from Lot 1;
all of the recommendations in the Report in respect of the construction of docks be registered on title for Lot 1; and
The seven lots be marketed as a `green' experience and targeted to those not wishing to use powerboats.
4. The Issue of Net Loss
The Report suggests that the interpretation of loss in the Provincial Policy Statement "must be an absolute one, meaning that a particular feature or function would no longer continue to exist in an area, or utilize the subject area" (p. 45). The Report goes on to cite the St. John's Road Development Corporation OMB ruling.
EH! disagrees strenuously with the Report's interpretation of loss as absolute. EH! suggests that the more relevant OMB ruling would be the recent Cloud Bay ruling in which the board refused development of a trailer park as "the use will encourage: boat launching into the Cloud River for the inevitable fishing expeditions in Lake Superior; uncontrolled access into the wetlands and estuary; seadoo use on the Bay; damage to the emergent and submergent vegetation and a consequent damage to the food chain and environmental balance within the estuary". This ruling does not consider loss to be absolute but relative.
EH! Recommends that:
Additional research be conducted to evaluate the relative loss of wetland function that can be anticipated from the entire development; and
Mitigation measures to ensure no loss of wetland function from the development of the lots be incorporated into control orders, registry on title and contractual agreements.
Prepared by Environment Haliburton, February 2004
EH! WRITES TO THE MINISTRY
OF THE ENVIRONMENT REGARDING
PINE SPRINGS SEPTAGE LAGOON PROPOSAL
Ian Parrott
Supervisor, Waste Unit
Environmental Assessment and Approvals Branch
Ministry of the Environment
2 St. Clair avenue West, 12A Floor
Toronto, ON M4V 1L5
Feb. 25, 2004
RE: Application for a Provisional C of A for a Waste Disposal Site, Lots
1 & 2 con. 12, Township of Minden Hills, Haliburton County, Pine Springs
site
Dear Mr. Parrott:
Environment Haliburton! is a recently formed non-governmental
organization in Haliburton County. Our mandate is to take a
comprehensive view of environmental issues and provide a strong voice to
encourage positive initiatives and oppose those that could have an
adverse effect on the environment.
Environment Haliburton! has been concerned about the proposed
development at Pine Springs since it was first publicly announced last
summer, as the attached correspondence indicates. Environment
Haliburton! is very much supportive of the development of sewage
disposal systems in the county. We believe that waste should be handled
at home. We know that hauled septage is the way in which sewage disposal
does and will happen in the county. We are very much opposed to
spreading septage on fields. We also know that Haliburton County is the
headwaters for four river systems. We believe in the precautionary
principle of erring on the side of caution.
Environment Haliburton's concerns in regard to the proposed development
at the Pine Springs site are as follows:
1. Waste management in Haliburton County
Haliburton County has recently adopted its first Official Plan. The
Townships of Algonquin Highlands, project proponent, and Minden Hills,
site jurisdiction, have also recently adopted new Official Plans. In all
of the plans there is a strong emphasis on environmental protection,
recognizing that the Haliburton economy is green. The Haliburton County
Official Plan calls for a comprehensive waste management plan for the
County. Development of septage lagoons will be/should be part of this
comprehensive plan. The District of Muskoka has an excellent management
system for septage that could be emulated in Haliburton County.
2. Site selection
There has been no site selection study for development of the septage
lagoon. The site has been chosen because it is currently a landfill site
operated by the proponent. Is it the best site? Is it a good site? How
does it compare with other sites? There is no way of knowing as there
has been no study.
3. Environmental assessment
The Pine Springs development has two phases, the first for trash tanks,
septage lagoon and summer field spreading of the septage and the second
for a second lagoon, polishing pond and disposal trenches. This
application is the beginning of the development of a permanent septage
disposal site. As such, it is a Class C project under the Municipal
Class Environmental Assessment. It should come under the full five step
planning process outlined in the Class Assessment or should be assessed
under the rigour of the Environmental Assessment Act. Review as a
revision to a provisional certificate of approval is not sound
environmental stewardship.
4. Cross boundary issue
The Pine Springs proposal is not located in the jurisdiction from which
the waste will be generated nor in the jurisdiction of the proponent.
The Township of Minden Hills, in its Official Plan, states: “The
establishment of new waste disposal or waste treatment facilities
including landfill or recycling facilities, salvage yards, sewage
lagoons, or sites used for the disposal of wastes from septic or holding
tanks, shall require an amendment to the Official Plan, in order to
address feasibility, site suitability, traffic and haul routes and to
assess impacts.” To the best of our knowledge and as indicated on the
application for the Provisional C of A this provision in the Minden
Hills Official Plan is being ignored.
5. Water quality
The Township of Algonquin Highlands is to be commended for hiring Grace
and Associates to carry out the hydrogeological and soil assessment
study on the Pine Springs site. The study indicates that the water
quality on the site is currently stressed. Surely this finding alone is
sufficient cause for further investigation and impact assessment. The
water flows from the site into Kushog Lake. The most recent study of
water quality of Kushog Lake was undertaken by the cottagers association
in 1990 and it found the lake was stressed. There is no adequate
baseline data from which the impact of the proposed development on
Kushog Lake can be either predicted before development or evaluated
after development. Again wise environmental management suggests that a
full environmental assessment of the impact of the entire project, both
phase 1 and phase 2, be undertaken. EH! was disappointed to note that
the hydrogeological and soil assessment study referenced neither the
recently completed groundwater study in the county nor the Ducks
Unlimited rapid wetlands assessment work in the county which includes as
assessment of the Pine Springs wetland.
6. Downstream users
The Pine Springs site is in an headwater area. It feeds into the Gull
River system. Poor environmental management in the headwaters impacts on
the entire watershed. Indeed the Ontario government has just released a
White paper on Watershed-based Source Protection Planning designed to
protect the sources of our drinking water. The White Paper proposes “a
process for assessing threats to sources of drinking water, best
management strategies to protect watersheds and innovative funding
mechanisms and incentives”. Were the proposals in the White Paper
adopted, the Pine Springs development, in total, would be a 'high risk”
activity and would be subject to study based on the precautionary principle.
In conclusion, Environment Haliburton! supports the development of
septage treatment systems in the County - when undertaken within the
framework of wise environmental stewardship. We do not know that the
Pine Springs site is the best site for a permanent septage lagoon. We do
not know what the impact of the entire project will be on the site, on
Kushog Lake, on the watershed. We do not even know the scope of the
entire project. These are our concerns.
Yours sincerely
Heather Ross, chair
c.c. Reeve Eleanor Harrison, Township of Algonquin Highlands
Reeve Ross Rigney, Township of Minden Hills
Bruce Hancock, MOE, Peterborough District Office
Ross Fair, Director, Eastern Municipal Services Office, MMA
EH! MEMBER WRITES TO MOE
IN PROTEST OF SEPTAGE LAGOON
PROPOSAL NEAR LAKE KUSHOG
Feburary 18, 2004
Supervisor, Waste Unit
Environmental Assessment and Approvals Branch
Ministry of the Environment
2 St. Clair avenue West, 12A Floor
Toronto, ON M4V 1L5
Dear Sir/Madam:
I am a property owner on Kushog Lake, and write you to register my opposition to the application for the Proposed Certificate of Approval for a Transfer Station for Hauled Domestic Sewage for the Pine Springs Landfill Site (Lots 1 & 2, Con. 12, Hinden Township, County of Haliburton).
I am opposing this application because I believe that many of the important concerns outlined by residents to the Township Council continue to exist and have not been resolved. The concerns, outlined for Council (in writing, by email and in person) by many, remain unheeded regarding the increased and immediate risk to Lake Kushog related to:
- transportation safety and spill prevention,
- lack of monitoring and controls at the site 24 hours a day/7days a week,
- prevention of future increased volumes of septage, and
- lack of responsible decision-making on the part of Council in refusing to consider an alternate less risky site a few km. further on Pine Springs Road.
- Understatement of the numbers of people impacted by the proposal. Since water from Kushog Lake flows south through a chain of highly populated lakes eventually entering the Trent Waterway the numbers impacted are significantly more than reported on the application,
- Inadequate public consultation. Only one public meeting was held at preliminary stages (Nov 2002) to introduce options. Since many residents are seasonal at least one of the consultation meetings should be held during the peak summer months.
In addition I have a very deep concern, while not based on science, that observation in recent years suggests that enrichment of the Lake is increasing and vegetation growth underwater is also on the rise. Whether the nutrient level of the effluent after treatment is low or not, the proposed lagoon will still be concentrating a high volume of nutrient enriched liquid (an est.1.5 million imp. gals per year) discharged into a water source for the Lake. I do not believe the existing condition of the Lake or its ability to cope with this inflow has been adequately considered. This represents an incalculable risk to our Lake and those who receive water from it down the waterway. We cannot accept that risk. Undertaking the Lagoon project at this site and its attendant risk to the Lake without seriously considering a nearby alternate site (over the watershed and about 3 or 4 Km up the same road) is irresponsible.
A copy of a detailed Chronology of Events related to my concerns is attached, along
with a copy of my earlier letter written to Gerald Bain, Clerk of the Township, which will assist you to understand the critical issues brought before Council.
I urge the Ontario Ministry of the Environment to act responsibly and refuse to grant the Proposed Certificate of Approval for a Transfer Station for Hauled Domestic Sewage for the Pine Springs Landfill Site until the above issues are resolved and the safety of our wetlands and lakes is assured.
Yours truly,
A.L. (Sandy) Mackay
cc Gerald Bain, Clerk
Municipality of Algonquin Highlands
Wayne Black, President
Kushog Lake Property Owners Association (KLPOA)
HELP CELEBRATE WORLD WETLANDS DAY
The following letter was sent to Reeve Eleanor Harrison and the Township of Algonquin Highlands on January 9, 2004. Similar letters were also sent to the County of Haliburton (Warden Bill Davis), Highlands East (Reeve Keith Tallman), Minden Hills (Reeve Ross Rigney) and Dysart et al (Reeve Murray Fearrey).
January 9, 2004
Reeve Eleanor Harrison and members of Council
Township of Algonquin Highlands
RR#2
Minden, ON
K0M 2K0
Dear Reeve Harrison and Councillors:
Subject: World Wetlands Day, February 2, 2004
Congratulations to all on the recent municipal election and best wishes for a prosperous and happy new year.
Environment Haliburton! wishes to inform you of a special event happening internationally on February 2, 2004: World Wetlands Day (WWD).
World Wetlands Day marks the date of the signing of the Convention on Wetlands on February 2, 1971, in the Iranian city of Ramsar. It was celebrated for the first time in 1997. Each year, government agencies, non-governmental organizations and groups of citizens have undertaken actions aimed at raising public awareness of wetland values in general and the Ramsar Convention in particular. From 1997 to 2003, the Convention's web site has posted reports from more than 80 countries, (including Canada) of all kinds of events, from lectures and seminars, nature walks, children's art contests and community clean-up days, to radio and television interviews and letters to newspapers, to the launch of new wetland policies, new Ramsar sites and new programs at national levels.
The Mission Statement of the Ramsar Convention is "the conservation and wise use of all wetlands through local, regional and national actions and international cooperation, as a contribution towards achieving sustainable development throughout the world."
EH! invites Algonquin Highlands, as well as all other municipalities in Haliburton County, to participate in World Wetlands Day in order to increase public awareness about wetlands in our own community and around the world. EH! has obtained colourful posters from the World Wetlands Day headquarters in Switzerland. Would you be willing to post one in the front lobby of the municipal office?
Respectfully yours,
Heather Ross, chair,
Environment Haliburton!.
WETLANDS: PROVINCIAL POLICY STATEMENT
The following letter was sent to John Gerretsen, Minister of Municipal Affairs, Dec. 22, 2003.
Hon. John Gerretsen,
Minister of Municipal Affairs
Whitney Block
777 Bay Street, 17th Floor
Toronto, Ontario
M5G 2E5
December 22, 2003
RE: Provincial Policy Statement in regards to protection of wetlands
Dear Minister:
Congratulations on your win in the recent provincial election and your posting as Minister of Municipal Affairs.
Environment Haliburton! (EH!) was formed last January when an enthusiastic group of people decided an organization was needed to give environmental issues in the County a strong voice. We have been involved in a variety of projects: commenting on local Official Plans as they have been written, holding workshops about land trusts and woodlots, and getting involved in contentious local issues involving matters such as asphalt plants, gravel pits and shoreline development.
One of these contentious issues is a proposal for a cottage development adjacent to, with docks in, one of the two wetlands in Haliburton County that have been evaluated and found to be provincially significant - Baptiste-Elephant Lake Wetland Complex. This Wetland was fully protected from development until 1997 when the province moved the definition of "north" to the edge of the Canadian Shield. This policy now allows development in a Provincially Significant Wetland on the Canadian Shield, as long as a study shows the development will have no negative impacts on the natural features or on the ecological functions of that wetland.
The new Offical Plan of the Township of Dysart et.al. indicates a clear desire for the protection of wetalnds. However, the Council did approve the necessary re-zoning, feeling that their hands were tied because the developer had followed the rules as laid out in the 1997 Provincial Policy Statement. This, they said is a provincial issue. EH! couldn't agree more.
Environment Haliburton has two concerns with the existing Provincial Policy Statement in regard to the protection of wetlands. We believe, along with other environmental groups, that all provincially significant wetlands should be protected. The higher standard currently afforded for Provincially Significant Wetlands south of the Canadian Shield is, we recognize, a direct result of the loss of 70% of these valuable wetlands in southern Ontario. Lake country is experiencing considerable pressure to develop wetlands as the more desirable lots have already been developed. It is important that the province give municipalities the tools they need to ensure they are able to protect wetlands. Surely, we don't want to wait until northern Ontario's loss of significant wetlands equals that of southern Ontario!
We are requesting that the new Liberal Government give priority to changing the Provincial Policy Statement.
1. We request, under section 2.3.1. Natural Heritage, that the Provincial Policy Statement be revised by the removal of the qualification "south and east of the Canadian Shield".
The intended consequence of this would be to give equal value to protection of all Provincially Significant Wetlands in Ontario [no matter where they are found in the Province].
Environment Haliburton has a second concern with the Provincial Policy Statement. The requirement that a study show no negative impacts is being interpreted, in the case of the Elephant Lake development, as a prohibition on absolute loss. Reduction and diminishment in the function and/or features of the wetland, it is argued, is acceptable under the Provincial Policy Statement.
2. We also request that, under section 2.3.2, the words "no negative impacts" be replaced with the words "no loss" (of the natural features or the ecological functions for which the area is identified).
Such a change would clarify the intent of the Provincial Policy Statement to protect the functions and features of provincially significant wetlands.
The Liberal Party promised change when it was campaigning this year. We strongly supported the commitment of the Liberal Party to completely stop development on the Oak Ridges Moraine. We are extremely sorry that your ability to deliver this promise has been thwarted by the deficit you inherited [Heather - was it the deficit or the cost of breaking binding contracts for development as entered into by the previous government?]. We do believe that both you, Minister, and your Government have a strong commitment to environmental protection.
We believe that our request for changes to the Provincial Policy Statement is reasonable, timely and without cost. We hope that you will give this matter your urgent consideration.
Sincerely yours
Heather Ross, Chair
cc. Hon. David Ramsay, Minister of Natural Resources
cc. Hon. Leona Dombrowsky, Minister of the Environment
cc. Laurie Scott, MPP
WORLD WETLANDS DAY
The following letter was sent to Haliburton County and the townships of Dysart et al, Algonquin Highlands, Highlands East and Minden Hills.
Warden Bill Davis and members of Council
County of Haliburton
P.O. Box 399
Minden, ON
K0M 2K0
Dear Warden Davis and Councillors:
Subject: World Wetlands Day, February 2, 2004
Congratulations to all on the recent municipal election and best wishes for a prosperous and happy new year.
Environment Haliburton! wishes to inform you of a special event happening internationally on February 2, 2004: World Wetlands Day (WWD).
World Wetlands Day marks the date of the signing of the Convention on Wetlands on February 2, 1971, in the Iranian city of Ramsar. It was celebrated for the first time in 1997. Each year, government agencies, non-governmental organizations and groups of citizens have undertaken actions aimed at raising public awareness of wetland values in general and the Ramsar Convention in particular. From 1997 to 2003, the Convention's web site has posted reports from more than 80 countries, (including Canada) of all kinds of events, from lectures and seminars, nature walks, children's art contests and community clean-up days, to radio and television interviews and letters to newspapers, to the launch of new wetland policies, new Ramsar sites and new programs at national levels.
The Mission Statement of the Ramsar Convention is "the conservation and wise use of all wetlands through local, regional and national actions and international cooperation, as a contribution towards achieving sustainable development throughout the world."
EH! invites the County of Haliburton, as well as all other municipalities in the Highlands, to participate in World Wetlands Day in order to increase public awareness about wetlands in our own community and around the world. EH! has obtained colourful posters from the World Wetlands Day headquarters in Switzerland. Would you be willing to post one in the front lobby of the municipal office?
Respectfully yours,
Heather Ross, chair,
Environment Haliburton!
WORLD WETLAND DAY PRESS RELEASE
The following story was sent to the Haliburton County Echo on January 26, 2004.
By Cathy Olliffe,
Environment Haliburton (EH!)
In our part of the world, February 2 is known more for its groundhogs than for its wetlands which are pretty much frozen solid at this time of year.
But all over the world, even in places where there are no groundhogs and no ice (imagine!), people are marking this date on their calendars as World Wetlands Day, a celebration that is intended to spread the word that wetlands are an integral part of the planet.
From the mountains to the sea, wetlands work for us. Yet, according to the Ramsar Convention on Wetlands, they are drained, polluted, over-exploited and under-valued. This year the Ramsar Bureau and Environment Haliburton (EH!) want people to understand that wetlands are an essential part of our lives. Ramsar has chosen the theme "From the Mountain to the Sea, Wetlands at Work for Us," to emphasize how important wetlands are to people, the animal world and the environment. Wetlands work for us every day providing water storage and purification, flood water control, groundwater replenishment, nurseries for freshwater and marine fish, shoreline stabilization and protection against storms, nutrient and sediment retention, carbon storage, support for biological diversity, climate change mitigation and recreation and tourism. It's the responsibility of each and every one of us, Ramsar representatives say, to consider how we might help in their conservation and sustainable use.
World Wetlands Day is organized every year by the Ramsar Bureau in Switzerland, an arm of the Convention on Wetlands (signed in Ramsar, Iran, in 1971), an intergovernmental treaty whose mission is "the conservation and wise use of wetlands by national action and international cooperation as a means to achieving sustainable development throughout the world." There are presently 138 Contracting Parties to the Convention, including Canada, with 1328 wetland sites, totaling 111.9 million hectares, designated for inclusion in the Ramsar List of Wetlands of International Importance.
There are several Wetlands of International Importance in Canada, including the Oak Hammock Marsh in Manitoba, where the headquarters for Ducks Unlimited is built, and Polar Bear Provincial Park.
There are no Wetlands of International Importance in the Haliburton Highlands as of yet. But Haliburton County is home to two Provincially Significant Wetlands (Paudash and Elephant lakes) as well as many wetlands that may, some day, be declared Provincially Significant. Then there are the countless, nameless large and small wetlands all over the Highlands - wetlands that may not attract a lot of attention by people but are home to a host of plants, animals, fish and insects.
"Soon we will have some new data on wetlands in the county, thanks to Ducks Unlimited and the County. We are likely to find that we have a lot of wetland that is important to us," says Heather Ross, chair of Environment Haliburton. "Wetlands are important habitats and play a vital role in maintaining water quality, reducing erosion and flooding. Caring for our wetlands is important in the Haliburton Highlands as so much of our economy is based in our clean and productive waters."
EH! would like Highlanders to take time on Feb. 2 to take notice of wetlands in their own backyards, to appreciate how hard wetlands work for us and to think about what they can do to help protect wetlands in Haliburton County and around the world.
As EH! members like to point out, there are plenty of reasons to celebrate World Wetlands Day.
"At this time of year, we need celebrations!" Ross says. "For far too many decades we have treated wetlands as if they were wastelands. This has been short-sighted. In parts of southern Ontario more than 70% of wetlands have been lost. A day to celebrate wetlands reminds us of their importance and celebrating with others throughout the world magnifies the efforts we are making here to protect our wetlands."
To celebrate, EH! is sending letters and posters to local municipalities and having Steve Galea, an award-winning outdoors writer, speak to students at Wilberforce Elementary School on Feb. 3.
For more information about World Wetlands Day, what types of wetlands are found in Haliburton County and what the provincial policies are regarding wetlands, please see EH's web site: www.environmenthaliburton.ca.
OEN NEWSLETTER SUBMISSION
The following letter was sent on January 27, 2004 to the Ontario Environment Network for inclusion in their newsletter.
By Cathy Olliffe
What could be more Canadian than EH!, eh?
With the possible exception of back bacon on a bun, "eh" is about as Canadian as Canadian gets. And, in the Haliburton Highlands, it's also pretty darn environment-friendly. EH!, which is short for Environment Haliburton!, is a new kid on the green block; only a year old but full of ideas for making Canada a greener, cleaner place to live.
The name was chosen in part because of its Canadian identity but also because it implies a sense of fun. And belonging to EH! certainly is fun. But EH! also takes environmental issues seriously. It's the main reason everyone braved a cold day in January 2003 to meet in a Haliburton Village church basement and talk all day about establishing a new citizens' environment group. The impetus for EH! came when the County of Haliburton's environment committee, CACE (County Advisory Committee for the Environment), was disbanded in 2002. CACE members decided to try to get a citizens-run organization together so an advertisement was put in the local newspapers inviting green-minded people to attend a meeting.
Right from the beginning, the lead was taken by Davis Lake resident Heather Ross, an environmentalist and planner by training. On that first day, people at the meeting chose Heather to be pro tem chairperson; later the "pro tem" moniker was lifted when she was officially elected EH's first chair.
Brian Cross, a Minden resident and a retired professional forester, took on the job of treasurer. Wallis Smith, a Carnarvon-area resident and retired anthropologist, agreed to become the group's secretary. Later, when the group executive was rounded out, Drag Lake resident Bill Beatty, a maple syrup producer, and Cathy Olliffe, a Carnarvon-area journalist, were added to the roster as executive-at-large members.
Although only a year old, EH! has already accomplished many things:
Last year all five municipalities in the Highlands were involved in creating new Official Plans. An EH! committee was struck to provide comments on those OPs;A community forum on land trusts, organized by EH!, was extremely successful. As a result of the forum, a committee was formed to start the process of forming a Land Trust for Haliburton County;
A woodlot tour was held for people who own small woodlots and want to know how to best look after them;
Bookmarks, featuring important information on wetlands, were printed up and distributed;
EH! partnered with a university student to help create cloth shopping bags - a greener alternative to plastic grocery bags;
The group was incorporated and a set of by-laws created;
A Well Aware workshop was held; and
EH! also got involved in several local and provincial issues including a gravel pit, an asphalt plant, pesky Canada Geese, a septage lagoon, forest management taxation and the policy regarding Provincially Significant Wetlands.
Just before Christmas, EH! held a special meeting to brainstorm for the future. Many ideas and concerns were discussed - too many to name here! Suffice it to say that EH! will continue to take an interest in the environment, working to protect it and make the world we live in better for everyone.
EH's motto is "to take a comprehensive view of environmental issues and provide a strong voice to encourage positive initiatives and oppose those that could have an adverse effect on the environment. EH! recognizes and wants to work with the existing organizations that have an interest in specific environmental subjects, forest, wetlands, head-waters, trails, recreation, lake associations etc."
EH! members strive every day to make that motto a reality.
And if working hard isn't Canadian, well, we don't know what is, eh?
Environment Haliburton meetings are held monthly at Sir Sandford Fleming's Sisco Centre campus in Haliburton Village. Membership costs $20 a year. For more information, email info@environmenthaliburton.ca or visit www.environmenthaliburton.ca.
THE RAIL TRAIL
The following letter was sent to The Rail Trail Committee in the Haliburton Highlands, Nov. 16, 2003.
November 16, 2003
Jim Blake, Chairman
The Rail Trail Committee
c/o Trails and Tours
General Delivery
Carnarvon, Ontario
K0M 1J0
Dear Jim Blake
Environment Haliburton is a non-governmental organization established in January of this year. Environment Haliburton’s mission is to take a comprehensive view of environmental issues affecting the county and to provide a strong voice encouraging positive initiatives affecting the county while opposing those that could have an adverse impact on the environment. Environment Haliburton recognizes and wants to work with the existing organizations that have an interest in specific environmental subjects such as forests, wetlands, head-waters, trails, recreation, lake association, etc. Our objectives are as follows:
1. To advocate for and to support others who are advocating for environmental protection and conservation;
2. To disseminate educational materials and information throughout the county on environmental issues and concerns;
3. To lobby governments and their agencies to enact legislation and regulations to protect and conserve the county’s environment;
4. To undertake, support and encourage environmental research in the county; and
5. To join with others in the county, province and nation who are also working for the protection and conservation of the environment.
Environment Haliburton has just this week had an opportunity to review the draft Master Plan for the Rail Trail. We are concerned that the three season mixed used option which is being proposed for implementation has grave implications for environmental degradation of a site which, while not pristine, has remarkable potential for benign uses such as hiking, bird-watching, nature photography and natural education. The more remote wilderness areas of the trail exemplify much of the scenic beauty that draws people to spend time in Haliburton County.
If it is necessary to create a plan which involves motorized use, we suggest that this option be restricted to the use of snowmobiles in the winter months (November to April) along the lines of the existing contract with the Haliburton County Snowmobile Association. In point of fact, the Plan recognizes that there should be no sharing of motorized and non-motorized uses, in the winter, through eliminating its use by cross-country skiers. This principle is lost in the application of shared uses in the remaining months.
Wherever ATVs have used roads or trails for the purpose of adventure recreation, there has been damage to the roadway, culverts, bridges and the natural environment. If one speaks to anyone in the logging industry responsible for maintaining forest access roads, or foresters and biologists in the Ministry of Natural Resources responsible for protecting particular sites, it is readily apparent that this devastating impact is the not the exception, but the rule. ATV use of these roads is seen as an issue which is extremely hard to control and rules are seen as being unenforceable. While perhaps some damage can be mitigated in the Rail Trail case by the hard surface of the trail bed itself, snowmobile associations, elsewhere, have also been reticent to share use of their trails with ATV users, specifically because of the damage that frequently results, and the fact that ATV users have not yet shown themselves to be responsible for correcting the expensive damage that occurs.
In addition to physical damage to the terrain, it is highly likely that ATV use will cause irreparable damage to the natural habitat of a variety of species. It is unlikely that the current use of the trail for observing the annual Christmas Bird Count , the annual Butterfly Count and the update of the Ontario Breeding Bird Atlas can be sustained. There is no evidence that the consultants have studied the potential impact of ATV use on local species’ population.
We also believe that there is an alarming degree of public risk if there is to be three season shared used of motorized and non-motorized activities. In fact, we believe that the result of such a plan will discourage all non-motorized use of the Rail Trail. In practical terms, the use of the Rail Trail will be monopolized by ATV and Enduro Bikes. Hikers, nature photographers, birdwatchers and school children are unlikely to want to spend time in an environment that is excessively noisy, chokes them with air pollution and risks their physical safety, nor should they.
Given the track record of accidents involving ATVs, it is no surprise that the insurance industry is extremely cautious in considering applications for liability insurance for clubs of ATV users. There may be no insurer in Ontario who would be prepared to consider such a policy, and any policy provider such as Lloyds of London, would undoubtedly charge premium rates which would be exorbitant to the point of being unaffordable. ATVs travelling on a trail for their exclusive use would be rated a much higher risk by the industry than snowmobiles, based on experience. If they are entitled to travel on a mixed use trail, involving non-motorized uses, the rates will skyrocket to cover the risk.
This raises a further ethical concern which must be seriously considered by all those who are in a position to make public policy. There is nothing that could do more damage to the business community and the County of Haliburton, indeed to Trails and Tours itself, than an accident involving a serious injury or death. Such an incident would throw into question the wisdom of creating for public use a facility which would invite potential hazard. Even if all of the “damages” were covered in such an incident, the moral liability would impact the County of Haliburton and Trails and Tours, not just the ATV association with formal liability. It would surely undermine any continued beneficial economic benefit of the trail to the community
As to the issue of what trails are to be used by ATVs, it is our position that it is the responsibility of the clubs representing them to create through land purchase and negotiated rights of way the trails which they would use exclusively, and which they would maintain exclusively. This is what snowmobile users did several years ago. The precedent is there. It is our view that there is no public obligation to provide ATV users with these trails. That is a matter for the resolution of the clubs which support the sport.
Environment Haliburton believes that the County of Haliburton has a rare opportunity to protect the Rail Trail as a natural corridor, while fully supporting a wide range of non-motorized uses which will indeed bring beneficial economic returns to the County. The fact that there is a huge amount of public support for a hiking trail was evidenced by the recent enormous turnout for the Hike Haliburton event. There are numerous examples of shared non-motorized use of trails in Ontario on which to model the operation of the Rail Trail. Hike Ontario and trails operated by the Federation of Ontario Naturalists are some examples. We suggest the Rail Trail Committee give consideration to some of these.
We strongly encourage your Committee to revisit the option you have chosen to promote, and to come forward with a proposal for a wide range of non-motorized uses, exclusively, during spring, summer and autumn.
Sincerely
Heather Ross
Chair
cc. Gary King,, C.E.O., County of Haliburton
Trails and Tours
Ontario Trails Council
The Haliburton Echo
The Minden Times
The Courier, Wilberforce edition
CUMULATIVE IMPACT STUDY NEEDED
ON COLEMAN LAKE GRAVEL PIT SITES
The following letter was sent to Reeve Murray Fearrey and the Township of Dysart et al on July 18, 2003.
Reeve Murray Fearrey
Township of Dysart et.al.
Box 389
Haliburton ON K0M 1S0
July 18, 2003
RE: Application for re-zoning of Pt. Lot 19 Concession 7
Dear Reeve Fearrey
Environment Haliburton! is taking this opportunity to comment on the proposed re-zoning of the site from rural to an industrial extractive zone. Environment Haliburton! recognizes the importance of gravel, gravel pits and portable asphalt plants to the continued economic welfare of the County and member townships. However Environment Haliburton! is clear that the ability to enjoy a non-industrial natural experience is a very large part of the County economy. Gravel pits and asphalt plants are not part of this experience. The development of such activities must be handled in a way that clearly recognizes the primacy of the natural environment. As the new draft Official Plan states "recreation and tourism are and will continue to be the Municipality's most significant industry".
The proposed zoning amendment, the continuing operation of the municipal "wayside" pit and the municipal purchase of adjacent lands in a site recognized for its gravel potential suggest a major gravel pit development is in the making on the Coleman Lake Road. Environment Haliburton! shares the concerns of the CLRRRA regarding road and bridge safety, impact on the road and lake community, impact on the Redstone River and watershed, noise and air pollution. We are also concerned that a major development may be created on the Coleman Lake road one small project at a time. The cumulative impacts may be great. They will certainly be unexplored as one project after another is approved.
Environment Haliburton! requests that a cumulative impact study be carried out on the potential development of the three adjacent sites. The impact assessment should include assessment of the impact of the cumulative development of the three sites on the environment as well as on the lake and road community. Until such as study is completed and the cumulative impact of the development of the three sites understood, Environment Haliburton! suggests that the re-zoning be deferred or rejected.
Yours sincerely
Heather Ross
Chair, Pro-tem
NO ASPHALT PLANT IN IRONDALE
The following letter was sent on July 25, 2003 to Monique rolf von den Baumen-Clark, the District Manager of the Ontario Ministry of Natural Resources in Bancroft.
Ms. Monique Rolf von den Baumen-Clark
District Manager
Ontario Ministry of Natural Resources
Bancroft District
Highway 28 South
Box 500
Bancroft ON K0L 1C0
RE: Proposal for Royale asphalt plant on Highway 503, near Irondale
July 25, 2003
Dear Ms. Rolf von den Baumm-Clark;
Environment Haliburton (EH!) is a non-profit organization in Haliburton County with the goal of ensuring the protection and, where need be, the rehabilitation of the Haliburton highlands. It has come to our attention that Royale Paving Company has plans to place a so-called temporary asphalt plant at the site of their gravel pit on highway 503.
Our understanding of the project, as there has been very little public information to date, is as follows:
In 1999, Ontario Ministry of Natural Resources entered into a twenty one year lease arrangement with Royale to establish the gravel pit which became operational the following year. The operation of the pit has created considerable community opposition due to noise, traffic and air pollution.
At least one pond has been drained with the obvious consequence to amphibian and aquatic life.
Royale is now requesting a site plan alteration in order to place a "temporary" asphalt plant at the site, permanently.
The proposed plant is temporary in name only. It takes several days to set up and to take down. In the 1960s when the plant was built, it may indeed have been temporary. It is not a temporary plant within the current technological environment.
The plant, being 30+ years old, was developed prior to any environmental legislation and its operation has simply been grandfathered in rather than subjected to environmental scrutiny.
Asphalt plants do not make good neighbours. A report prepared for Environment Canada and the Canadian Council of Ministers of Environment in 2002 indicated that, in Ontario, the hot-mix asphalt sector produced the following:
3,200 tonnes of particulate matter in total
160 tonnes of sulphur dioxide
320 tonnes of nitrogen oxides
140 tonnes of volatile organic compounds
2,000 tonnes of carbon monoxide
1.3 tonnes of polycyclic aromatic hydrocarbons
216,000 tonnes of carbon dioxide.
The report went on to identify best available technologies for minimizing the environmental impact of asphalt plants, pointing out that stringent controls are appropriate where pristine air quality is to be protected. Are the best available pollution control technologies proposed for this site?
EH! has reviewed the Class Environmental Assessment for MNR Resource Stewardship and Facility Development Projects. We have looked at the screening criteria and suggest that this project has a high potential for negative impact on several criteria including air quality, drainage, contaminants, traffic patterns, recreational importance, excessive waste, noise, aesthetics, adjacent uses, community character, public health and safety, local economies, tourism values and land claims. While the actual project, an application for site plan alternation, sounds like an inconsequential matter, it has, in fact, very large potential environmental consequences. How is the Ontario Ministry of Natural Resources planning to address these environmental concerns? Is this project to be assigned to either Category C or D within the Class Environmental Assessment?
While the project is on crown land, OMNR has adopted a policy of having regard for municipal Official Plans. The draft Highlands East plan does not allow for any large scale industrial development in rural areas. It does, of necessity, accept wayside pits and portable asphalt plants. However the Royale proposal for a permanent siting of a
"portable" plant in no way meets the "average" person's understanding of portable. Indeed, in this case, portable appears to be a generic not a descriptive label.
Given the potential environmental, economic and community impacts from this proposal, EH! requests that the site plan alternation not be approved and that a full and open cumulative environmental assessment of the proposed asphalt plant and the gravel pit be undertaken.
We look forward to your timely response to our letter and our questions.
Yours sincerely
Heather Ross, Chair, pro-tem
c.c Reeve K. Tallman, Highlands East
No asphalt plant in Irondale
Bruce Hancock, District Manager, MOE
Dr. G. Hunnius
