[All] Fw: Cambridge West Master Environmental Servicing Plan:

Thu May 8 16:22:35 EDT 2014

Hi folks

The MOE got back to me regarding my Part II order for the Cambridge West Master Environmental Servicing Plan (re: Barrie's Lake)
They stated I can request specific bump ups on components of the master plan and they required further info so here is what I've sent in.

Lulu 

----- Forwarded Message -----
From: Louisette Lanteigne <butterflybluelu at rogers.com>
To: "souwanda at cambridge.ca" <souwanda at cambridge.ca>; "trevor.heywood at ontario.ca" <trevor.heywood at ontario.ca> 
Sent: Thursday, May 8, 2014 4:18:30 PM
Subject: Cambridge West Master Environmental Servicing Plan: 

Hi Mr. Heywood and Ms Souwand. 

This email is in response to MOE file ENV1283MC-2014-1117 dated May 2, 2014 which was a correspondence to me (Louisette Lanteigne) from Ross Lashbrook. (Mr. Heywood if you can run this by Mr. Lashbrook I'd appreciate.)

I'd like to provide more specificity with concern to a Part II order request I submitted previously regarding the proposed Cambridge West Master Environmental Servicing Plan proposed by the City of Cambridge. 

I requested a Part II order to bump up the EA process to a Class EA schedule D process. This was in reference to the The construction of new collector roads (currently a Class C)  and the Re-alignment of Blenheim Road (Currently a Class C) associated water servicing infrastructure.  I am also concerned about using Barrie's Lake as a point of discharge for storm water from a nearby subdivision project so that may fall under the criteria for "establishment of new storm water management facilities". I wasn't sure what subcategory that fell under but it's an issue that needs to be addressed. 

The monitoring of endangered species in this area is in my view, insufficient because species were found but no delineation of critical habitat has been established. With the absence of that data it is difficult to reasonably predict what other components of this master plan may be impacted. In BC, Alberta and other areas, the Supreme Court ruled that Species At Risk Act is not permissive. Discretionary powers by ministries at the Federal or Provincial level cannot be used to negate the need to establish critical habitat zones within a reasonable time frame. I ask these studies be done in compliance with both the Endangered Species Act and the Species At Risk Act before we proceed to various approval stages so we can make informed decisions before investing further resources into the project and finding out about constraints at a later date. I will give a local example. 

Years back, the proposed River Road Extension through Hidden Valley was estimated to cost $21 million to help bypass traffic volumes on Fairway Road in the City of Kitchener. The planning started in 2004, but the project stalled in 2007 when Jefferson salamanders, an endangered species, were discovered near the planned route in Hidden Valley. The salamander delay may have added $11 million or more in extra costs. This includes a $5 million redesign, more than $4 million in inflation related construction delays and $2 million from failing to time a new bridge across Highway 8 with widening recently completed on the highway. Today the project is estimated at $75 million dollars. Taxpayers could have saved millions if they prioritized the critical habitat delineation prior to designing the bridge. We need not repeat bad patterns. We have the chance with this project to identify constraints early on to mitigate the risks and associated costs and plan
 them in before designs are finalized. 

When I see projects involving Jefferson salamanders and Badgers it indicates primary recharge areas for local water supplies because those animals exist only where the sediment is loose or moist enough to dig in. They burrow. It's sandy. The salamanders require moisture to survive because they breath through their skin indicating high recharge for groundwater. These lands are headwaters. 

We have the ability to mitigate risks for approvals but nature has no regard for man made design constraints. If we make the wrong decisions today, especially in the age of global drought and climate change, the risks are worse. If we don't design this right we'll pay for it so let us build safer designs in safer areas and bump up the protection of source water recharge zones instead of building roads with road salt that can contaminate at the source adjacent to these water bodies. 

The reason I work to protect those animals is because in protecting them we protect our water supplies for the long term. There are no reasonable laws in place to protect recharge zones away from well-head delineation areas because it conflicts with the Provincial aggregate interests. Conflicts exists within the Provincial ministry when they act as both the promoter and regulator of aggregate materials. The Ministry of Transportation is the largest user of aggregates and locally sourced aggregates are cheaper but here in Waterloo Region it comes at the cost of our primary water supply so the Endangered Species Act is all we have legislatively to balance the issue to help protect these source water areas today. 

Our water is the most important resource we have in Ontario. It's the backbone of a 55 billion dollar agricultural industry and Waterloo Region is the second largest food belt.  Our water supports communities here and downstream and is a source for Lake Erie.  We have to actually protect it if we want it to continue to providing clean drinkable water and that's what I am asking the MOE to do in regards to this issue. It shouldn't take a salamander and/or badger to stop projects like this but that's all we've got legislatively speaking and when areas are blessed to actually have these species, that's when I get involved. We can design safer, we can divert roads away from water supplies and I have faith that many of the objectives of this proposal can be done safely while balancing the need to protect the water by protecting these animals and their habitats. 

The area of Cambridge generally south and west of the current termination of Bismark Road and west and north of the Canadian Pacific (CP) railway tracks had been designated for urban residential development since the early 1980s. This pre-dates much of the hydrogeological knowledge that we have of this area currently. It also pre-dates the establishment of protective laws including the Source Water Protection Act, The Species At Risk Act, Ontario Endangered Species Act and our current understanding of climate change risks that we face today. Just because it was given a preliminary approval in the past does not mean it is reasonable to proceed in a business as usual way in light of our current understanding of risks. According the MNR Senior Policy Advisor Gail Jackson who I spoke with, the Endangered Species Act cannot be grandfathered. Any risk to an animal today, is addressed with the most current version of the law. Any work being done, regardless
 of the approval date must have regard to this legislation today. 

Are we planning the totality of this project with regard to increased precipitation risks? Many projects being done by the Grand River Conservation Authority now consider 200 year storm events into baseline design rather than 100 year storm events and this is in my view, is a far better model to plan on to reduce risks and costs at the municipal level. 

Being a resident of Columbia Forest in Waterloo, we were one of the first areas built on top of primary recharge in Waterloo Region. The EIS for my subdivision negated spring thaw water volumes and each spring basements would flood, houses would shift and our water mains broke frequently along Erbsville Road.  The water mains were over high recharge areas. When the spring thaw came, the ground turned to silt and the pipes sank 12 feet according to construction crews we spoke with. To the north of my subdivision on Wilmot Line in Waterloo, work crews dug to put in phone infrastructure and hit a shallow aquifer. The roads sank in, the area flooded and they had to install hundreds of wells to divert the water. The water went into a storm water management pond flooding the area, then it was released into Clair Creek creating significant temperature changes that may or may not have killed fish. I want to warn you of impacts like that to prevent similar
 situations from happening in Cambridge. 

There is money in destruction for those who are not so ethically inclined who really don't care about the costs to taxpayers as long as they reap the fiscal benefits so as a taxpayer my advice is buyer beware. I don't want people to die from contaminated water because we avoided common sense measurements needed to secure safe engineering of water mains or structures. Avoiding spring thaw, shallow bore hole levels, undermined risks of climate change and lack of regard for sediment types can leave communities without water if we don't design things properly. I'm trying to save lives and money by securing proper engineering work and to stop past mistakes from repeating. Are these water mains going to be built over peat moss that rises and swells? Will they be in flood zones? We need to get proper data to estimate costs and risks before approval. 

I hope this helps to better illustrate my concerns. 

Yours in good faith

Louisette Lanteigne
700 Star Flower Ave.
Waterloo Ont.
N2V 2L2
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