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2. AUDIT
OF CARP RIVER WATERSHED - APPROVAL OF TERMS OF REFERENCE FOR A THIRD PARTY
REVIEW VÉRIFICATION DE L’ÉTUDE SUR LE BASSIN HYDROGRAPHIQUE DE LA RIVIÈRE CARP – APPROBATION DU CADRE DE RÉFÉRENCE POUR L’EXAMEN PAR UNE TIERCE PARTIE |
Committee recommendationS AS AMENDED
That Council:
1. Approve the amended
draft Terms of Reference for a third party review of the Carp River Restoration
Project as presented on 24 June 2008 and amended by the following:
a.
The third party reviewer consult
with the Auditor General and Parts II Order requesters;
b.
That the two-zone policy be reviewed
as per the Auditor’s General report.
2. Direct
staff to proceed with a Request for Proposals to secure a qualified third party
engineering firm;
3. Authorize the City Manager to approve the selection and hiring of the pre-qualified third party engineering firm to undertake the work outlined in the approved draft Terms of Reference and to approve the funding through delegated authority to an upset limit of $300,000; and
4. Establish a new project authority in the amount of $300,000 to be funded from the Wastewater Capital Reserve Fund.
6 Delegate
minor adjustments to the Terms of Reference, as a result of further
consultation with MOE, MNR and the Auditor General (AG), to the City Manager
and that any changes made be communicated to City Council.
RecommandationS modifiÉeS du Comité
1. approuve l'ébauche du cadre de
référence modifié en vue de l’examen par une tierce partie du Projet de
restoration de la rivière Carp, tel que présentée le 24 juin 2008 et modifiée en vue d’inclure les points suivants :
a.
que la tierce partie qui assure
l’examen consulte le vérificateur général et les demandeurs de l’Arrêté de la
Partie II;
b.
que la politique relative aux deux
zones soit examinée conformément au rapport du vérificateur général.
2. enjoigne le personnel de procéder à une
demande de propositions afin de s’assurer de retenir les services d’une tierce
firme d’ingénierie qualifiée;
3. autorise le directeur municipal à
approuver la sélection et l’embauche d’une tierce firme d’ingénierie qualifiée
en vue d’entreprendre le travail énoncé dans l'ébauche du cadre de référence
adopté, et le financement par pouvoir délégué jusqu’à une limite maximale de
300 000 $; et
4. établisse une nouvelle autorité de
projet d’un montant de 300 000 $ qui sera financée à partir du Fonds de réserve
en immobilisations des eaux usées.
5. demande
que des lettres soient envoyées au ministère de l’Environnement (MEO) et au
ministère des Richesses naturelles (MRN) en vue d’aborder les questions de
juridiction et les demandes contradictoires concernant les conditions visant la
tierce partie pour ce qui concerne Kanata-Ouest.
6. confie les
rectifications mineures au cadre de référence, découlant des prochaines consultations
avec le MEO, le MRN et le vérificateur général, au directeur municipal, et que
le Conseil municipal soit informé des autres changements apportés.
Documentation
1.
Deputy
City Manager's report Planning, Transit
and the Environment dated 16 June 2008 (ACS2008-PTE-ECO-0018).
Report to/Rapport au :
Planning and Environment Committee
Comité de l'urbanisme et de l'environnement
and Council / et au Conseil
16 June 2008 / le 16 juin 2008
Submitted by/Soumis par : Nancy Schepers, Deputy City Manager
Directrice municipale adjointe,
Planning, Transit and the
Environment
Urbanisme, Transport en commun et
Environnement
Contact Person/Personne ressource : Rob Mackay
Economic
and Environmental Sustainability/Direction de la viabilité économique et de la
durabilité de l’environnement
(613)
580-2424 x 22632, rob.mackay@ottawa.ca
REPORT RECOMMENDATIONS
That the Planning and Environment
Committee recommend Council:
1. Approve the amended draft Terms of Reference for a third party review of the Carp River Restoration Project;
2. Direct staff to proceed with a Request for Proposals to secure a qualified third party engineering firm;
3. Authorize the City Manager to approve the selection and hiring of the pre-qualified third party engineering firm to undertake the work outlined in the approved draft Terms of Reference and to approve the funding through delegated authority to an upset limit of $300,000; and
4. Establish a new project authority in
the amount of $300,000 to be funded from the Wastewater Capital Reserve Fund.
RECOMMANDATIONS DU RAPPORT
Que le Comité de l’urbanisme et de
l’environnement recommande au Conseil :
1. d’approuver l'ébauche du cadre de
référence modifié en vue de l’examen par une tierce partie du Projet de
restoration de la rivière Carp;
2. d’enjoindre le personnel de procéder à
une demande de propositions afin de s’assurer de retenir les services d’une
tierce firme d’ingénierie qualifiée;
3. d’autoriser le directeur municipal à
approuver la sélection et l’embauche d’une tierce firme d’ingénierie qualifiée
en vue d’entreprendre le travail énoncé dans l'ébauche du cadre de référence
adopté, et le financement par pouvoir délégué jusqu’à une limite maximale de
300 000 $; et
4. Que
le Conseil établisse une nouvelle autorité de projet d’un montant de 300 000 $
qui sera financée à partir du Fonds de réserve en immobilisations des eaux
usées.
BACKGROUND
In 2007, in response to a report
to the Fraud and Waste hotline, the Office of the Auditor General (AG)
conducted an audit of the Carp River Restoration projects. At City Council on
April 23, 2008, the Auditor released a report ‘Audit of the Carp River Watershed and Related Projects’ which
contained numerous recommendations along with the City’s Management responses.
As a result of the recommendations 8,9, 10, and 11 and a coding error discovered by staff that lead to missed water volumes in the restoration modelthe
input received from the public and stakeholders, , management
recommended that a third party engineering firm be retained to undertaken
a review of the modeling work and to address the various concerns.
Council Meeting
At the meeting of 14 May 2008, Council approved this recommendation and passed the following motion for staff to:
a) Proceed with a third party review;
b) Post the Terms of Reference on the City’s
website in order to receive public feedback;
c) Address,
as part of a staff report, input and comments from the public for final
approval of the Terms of Reference at the June 24, 2008 Planning and
Environment Committee meeting and the following Council meeting;
d) Respond
to the Inquiry on Hiring of Consultants for Studies in order to discuss at the
same June 24, 2008 meeting.
This report presents the amended Terms of Reference for the third party review with a discussion of the public and agency input received to date and the staff response as directed by Council.
A copy of the public’s comments
can be found in the attached Document 2.
The motion pertaining to the Inquiry of Hiring of Consultants for
Studies has been addressed under a separate report on this agenda.
DISCUSSION
The intent of the Terms of Reference is to engage an engineering firm to conduct a complete, objective third party review and assessment of all aspects of the hydro-technical models for the Carp River Restoration Plan, and the impacts of any changes on the design of the Carp River Restoration Project. The selected firm will be required to review and validate whether the EA documents can still be applied with confidence to implement the Restoration Project.
Scope of Work for the Third
Party Review
The current scope of work includes 3 phases: 1)
a technical phase to review, validate and re-run the models; 2) a review phase
to address other related issues raised in the Auditor General’s report or via
staff and public comments; and 3) if necessary, at the discretion of the City, apply
the recommendations, updates and adjustments to the Carp River Restoration
Plan. Consideration for a Phase 3 will
be dependent upon the recommendations that are proposeds by the consultant
undertaking the review. under this review. Should this step be taken aA
report will be presented to Committee and Council on the recommended next
steps.
The selected firm will be under
the guidance of a technical review team comprised of a City staff team and a
representative from Mississippi Valley Conservation Authority (MVCA).
Staff are also proposing the creation
of a Project Advisory Committee composed of key agencies and stakeholders who
will receive briefing sessions from the third party consultant. at the end of Phase 1 and 2. A A PPublic
Information session will be held at the end of Phase 2, culminating with a
presentation to Planning
and Environmental Committee. Council. It
is anticipated that the work envisioned for Phase 1 and 2 will take
approximately three to four months to complete, once the 3rd party
consultant new firm isis in place.
Pre-qualification of Short
Listed Firms
Pre-selection criteria was established and Staff
created a screening questionnaire and distributed to a list of
Engineering firms that were referred to the City by several sources including technical
agencies, staff and others. it to engineering firms
potentially capable of conducting the third party review assignment for the
City. Using
the criteria, sStaff
assessed corporate capabilities and experience in order to arrive at a short
list of potential third party firms.
Telephone interviews were then conducted to reconfirm that no conflicts
of interest with the City or land developers existed and that these
companies had the . Staff also sought to
confirm that these firms had the appropriate resources to
undertake the full scope of work. At the end of this
process, Staff
was able tofive engineering firms were pre-qualifiedy 5
engineering firms and all have expressed an that are interested interest in
responding to the a City’s Request for Proposals.
All firms except
Philips Engineering who worked on a workshop in the initial phase of the City’s Storm
Water Management Strategy in Spring 2007 have confirmed that they have
not worked for the City of Ottawa in the past five years. None of these firms have worked or had any affiliation
with any of the
Kanata West land developers. As well all
five firms
have indicated
that they have no No declaration of conflict of interest in undertaking the third party review assignment.
was declared for the land developers.
Staff have reviewed the assignment that was undertaken by Philips Engineering. Given this assignment was completed in May 2007 and is not related to the current review, staff are satisfied that no conflict of interest would exist if this firm competed and won the 3rd party review assignment.
The short
list of five pre-qualified firms is:
1.
Philips
Engineering (Burlington)
2.
Greenland Group of Companies, (Collingwood),
3.
XCG Consultant Ltd. (Cambridge ON),
4.
Coldwater Consulting (Ottawa),
1. SNC
Lavalin, (Toronto). The
final selection of the winning engineering firm/ bid will be made by the City
Manager.
As per the recommendation section of the report, staff are proposing that
the City
Manager select the
winning firm to undertake the review.
Public Input
on the Terms of Reference
As per Council’s 14 May 2008 motion, the Terms of
Reference wereas
posted on the City’s website for public input. They were also circulated to the Province for comment with
a request that an MOE official be available to explain the Province’s position on this matter at the June 24 CSEDC meeting. Several calls and emails were submitted to
MOE requesting their attendance at the June 24 meeting and their written
comments on the Terms of Reference.
Nine responses were received from the public. Several of the
comments received have been previously addressed by the City in the
Environmental Assessment (EA) consultation process and documented in the June
2006 Kanata West EA Consultation Report. The key issues raised included questions
concerning the two-zone flood policy, the designation of the Carp River as a
municipal drain, the lack of calibration of the model and extending the project
to downstream of Richardson Side Road. A summary of the main issues is found outlined
below.
On Friday June 13, prior to tabling the report for printing, staff received MOE’s comments on the third party Terms of Reference. Unfortunately there was not sufficient time to review these comments and take a final position on all the comments received and make the final amendments to the Terms of Reference. As well the Ministry of Transportation contacted staff on June 13, 2008 and advised that their provincial agency would be submitting comments to the City during the week of June 16 These comments would be received after the Committee report is printed and published on the City’s web site. Staff have yet to hear from MNR and at the time of finalizing this report, it was unclear as to whether this ministry will be submitting comments on the Terms of Reference.
A) Two-Zone Floodplain Policy
Respondent:
Several respondents requested that the Terms of Reference include a review of the application of the two-zone floodplain policy to this project.
This review would determine
whether, in this instance, modifying the floodplain to accommodate development
in the flood fringe area was appropriate.
Staff Response:
The two-zone approach was a recommendation of the Watershed/Subwatershed Study, and was addressed during the EA project consultation. The Carp River flood plain can best be described as a wide, flat, unconfined and shallow with extremely slow water flows.
Given these characteristics applying the two-zone concept (i.e. filling and removing any development area from the present flood plain, to provide adequate flood proofing), is an appropriate application of policy and flood plain management. This was confirmed in the “Technical Guide – River and Stream Systems: Flooding Hazard Limits” (MNR 2002) and later in a letter from the Minster of Natural Resources dated April 26, 2007.
Staff and MVCA believe the
application of the two-zone approach has been sufficiently reviewed and
confirmed by the
Ministry of Natural Resources as an appropriate approach.
This difference of
opinion remains more one of a philosophical approach.
Designating the Carp River as
a Municipal Drain
Respondent:
Several comments were received on the issue of declaring the Carp River as a municipal drain.
Staff Response:
This issue was also addressed during the EA consultations. Although there is some documentation to support that a portion of the Carp River is a Municipal Drain, only through a determination of the Drainage Referee could such a conclusive finding be made. Referring this issue to the third party will provide little value as the final decision remains with another provincial authority, the Drainage Referee.
At present, this watercourse has
no legal status as a municipal drain under the Drainage Act. The Ontario
Ministry of Municipal Affairs also supports this viewpoint. As a side note,
remedies under the Drainage Act are provided to landowners along the Carp River
who wish to challenge this status.
Model Calibration
Respondent:
The lack of calibration of the
modells used was noted as a concern in
several of the responses.
Staff Response:
Staff acknowledges that although desirable, reliable stream gauge data is not usually available for small urbanizing catchments or sub-catchments like the Kanata West area. In fact, there are very few stream gauges installed on similar watersheds across Canada. As a result, a hydrograph simulation model is applied to estimate flood flows from an assumed design storm, relying on similar data from adjacent watersheds, experience and judgement to produce reliable results. This process is considered the best practice available until new data can be reliably collected.
Three monitors are now in place and full data collection is now proceeding. Recognizing it may require many years to establish and measure any significant flow events, the implementation plan does provide for adjustments to be made as data collection becomes available.
In view of the above, staff continue to support the process of adaptive management chosen for the Carp River Restoration Project as it represents best practice. The issue of model calibration is part of the Terms of Reference for the third party review.
Project Extension Downstream of Richardson Side Road
Respondent:
It was requested that the project be extended beyond Richardson Side
Road.
Staff Response:
The project limitation was defined as a result of the urban boundary. The restoration would have provided little or no benefit to the rural/ agricultural landowners. The restoration of the Carp River was therefore limited to the Kanata West lands where financial resources could be generated through the development process to support the restoration plans. Extending the boundary will change the project scope and definition of the EA and would trigger a new EA process.
Fernbank Lands
Respondent:
Fernbank lands should now be included as part of this process.
Staff Response:
At the time of the Carp Water/ Sub-Watershed Study was undertaken, the Fernbank Lands were outside the urban boundary. Due to subsequent changes in the Official Plan, this area is now included. As part of this land development, the Fernbank project must provide their own storm water management within their boundaries in order to ensure they have no impact upon the Carp River throughout the restoration reach and downstream development. To include these lands in the Carp River Restoration Plan now would trigger a new EA process and delay the restoration plan by several years, thereby permitting further degradation of this watercourse.
A table summarizing these comments and staff’s responses are attached in Document 3, “Public Feedback Table on Terms of Reference”.
Timeline and Next Steps
Upon approval of the RFP, respondents will be provided two to three weeks to prepare their bid submission. The selection of the winning firm is anticipated to commence by mid-August with work being completed by the end of November/ early December 2008.
CONSULTATION
Per Council's direction, the Terms of Reference (ToR) was posted on the City's website for comments from May 27 to June 9. In addition, the posting was advertised in The Citizen and Le Droit as well as in the west end community newspapers: Kanata Kourier, Kanata EMC, West Carleton Weekender, West Carleton EMC, Stittsville News and the Stittsville Weekender.
A Public Service Announcement was
also issued, and interested parties informed by e-mail.
In addition, input was sought
from the Ministry of the Environment (MOE) who typically inform the sister provincial
ministries and the Mississippi Valley Conservation Authority (MVCA). At the
time of the authoring this report, no comment had been received from the MOE
MVCA’s comments were incorporated in the posted ToR document.
FINANCIAL IMPLICATIONS
Funds are available for Transfer from the Wastewater Capital Reserve Fund.
SUPPORTING DOCUMENTATION
Document 1- Public Comments
DISPOSITION
Staff acknowledges that the provincial comments are important and may
trigger modifications to the position staff have
taken on some
of the matters raised above and the draft terms of reference. Staff proposes that the City Manager
sign off on these final changes and the consulting firm hired to undertake the third party review. Should this process not
be acceptable staff will need to bring the Terms of Reference back to the next Planning and Environment
Committee in July and Council for authority to release the RFP.
Staff
will proceed the release of
the approved draft ToR to the five pre-qualified shortlisted engineering firms.
Upon receipt of the bid submissions from the pre-qualified consultants, the
technical advisory group will undertake an evaluation process and present its
recommendation to the City Manager who will finalize the selection of the
winning firm.
PUBLIC COMMENTS DOCUMENT 1
-----Original
Message-----
From: Ted Cooper
Sent:
June 09,2008 6:44 AM
To:
Carp River Restoration
Subject:
Comments on Terms of Reference
Please
find below my comments on the proposed Terms of Reference for the Third Party
Review.
Comments
on Third Party Review Terms of Reference
I have
prepared these comments with the knowledge of the alternative Terms of
Reference prepared by Darlene Conway, which I take the position are superior to
those offered on the City of Ottawa's website, and should form the basis on
which the Third Party Review should proceed. As a result, I am submitting below
only high-level comments on fundamental requirements of the audit that appeared
to be lacking in the proposed version of the Terms of Reference made available
for comment.
Floodplain Policy
The scope of the terms of reference needs to be expanded to
include examination of floodplain policy.
Given that staff will be required to prepare reports for
consideration by Committee and Council supporting future Rezoning of Hazard
Lands / floodplain overlay in Kanata West, there is a need for an independent
review of natural hazard policy issues.
Given the recent successful outcome of my OMB Appeal of the Jock
River floodplain development - it should be apparent to Council that future
staff reports prepared for PEC need to provide the policy basis on which
development of existing One-Zone floodplain can proceed. In the case of the
Jock River floodplain development proposal, the RVCA would not allow 7 lots to
be developed from the floodplain - yet the MVC appears to be willing to allow
something hundreds of lots to be developed in the 28 Ha of Carp River
floodplain. How can there be such inconsistency in the application of OP
Policies and the PPS within the City of Ottawa? The Third Party Reviewer should
be asked to explain how there could be such a divergence in application of
Natural Hazard Policies in the same municipality, employing the same OP
Policies.
I have an outstanding Appeal of the Richcraft Plan of Subdivision
in Kanata West and it will be necessary for the City to defend the basis on
which that Approval was given based on floodplain policy.
There will be a need for future Zoning Bylaw Amendments and Plans
of Subdivision to be approved that could be subject to Appeals to the OMB.
Unlike the Trinity OMB Hearing, the MVC will be summonsed in future Hearings to
defend its approach to floodplain management, particularly if they continue to
use the 1983 floodline for planning and regulation purposes, given the number
of changes that have occurred in the watershed since 1983. (A Section 43
Request for Review has been filed with the OMB regarding the April 25, 2008
Trinity OMB Decision. A Judicial Review has also not been ruled out).
Carp River as a Municipal Drain
The status of the Carp River as a municipal drain needs to be
resolved - and the sooner the better. The Third Party Review could prove to be
entirely pointless should a determination be made that the Carp River is a
municipal drain. In some ways this should be the first task to be completed in
the review, because it could require a complete shift in the process through
which the Restoration Project must proceed.
There is a lot of evidence available to support the position that
the Carp River has status as a municipal drain. There are engineering drawings,
the 1909 OCA Decision, reference to the Carp River Drain on the OMAF Municipal
Drain Index Mapping, etc. I have recently learned that a Borrowing Bylaw that
was passed by a former municipality has been discovered that adds to the
evidence of the Carp River being a municipal drain.
The Third Party Review should provide recommendations about how to
proceed once a determination is made about the status of the Carp River as a
Municipal Drain. The qualifications of the Consultant to be selected should
include some familiarity with the Drainage Act.
Need to establish definition of Existing Conditions
The Terms of Reference, as proposed, appear to be pre-occupied
with correcting only the deficiencies with the post-development model. There
appears to be no identification that there is a need to first establish a
credible definition of existing conditions from which an impact assessment can
be conducted.
There have been many changes in land use and alterations made to
the Carp River floodplain since 1983 when the floodplain mapping was first
completed on the Carp River. There have even been many changes since 2000, when
the Subwatershed Plan was initiated - and since it was approved in January
2005.
The impact assessment is being conducted on a very loose
definition of "Existing Conditions". In some cases the comparison is
being made between the recent (2006/2007) floodplain modeling work and the 1983
floodplain report findings. In other cases it is between the non-calibrated
existing and future floodplain analysis completed by CH2M Hill.
What is clear is that there is no up-to-date definition of
existing floodplain conditions consistent with the "Technical Guide River
& Stream Systems: Flooding Hazard
Limits (2002)". Furthermore, the "City of Ottawa"
(PWS, presumably) raised a number of concerns with the CH2M Hill existing
conditions study that are included in the Class EA documentation. In
particular, at point 9, the City of Ottawa's position is that "It is
recommended that design not proceed based on flows from this analysis."
Therefore, a fundamental requirement of the Third Party Review is
establishing clarity in the definition of "existing conditions" from
which the impact assessment of the proposed Restoration Plan is to be based.
Apparent Problems with Modeling
There are a number of problems with the modeling that need to be
corrected before any work on model calibration, etc. proceeds. These are
problems whereby there are inconsistencies between what is modeled and what is
actually found in the field. The best examples of this are:
1.. The encroachment of
the Sensplex into the Carp River floodplain during its development;
2.. The encroachment of
the SMART Technologies development in the Carp River floodplain during its
development; and
3.. The actual
topographic conditions that exist north of the future Campeau Drive, between
Didsbury Drive and the Carp River
In the case of the Sensplex and SMART Technologies developments,
because there was never any compensating cut required by the MVC to offset the
impact of the large volumes of fill that were placed during the development of
those sites, when the necessary changes are made to the HECRAS model, the Third
Party Reviewer should comment on whether those changes should be made to the
existing conditions model or the post-development model.
In the case of the area north of the future Campeau Drive a
determination needs to be made by the Third Party Reviewer, from a floodplain
policy perspective, whether those lands will be deemed to be within the
floodplain - as shown in Figure 2 of Appendix E of the Post-Development CH2M
Hill report.
I believe the above issues raise a very important question that
the Third Party Reviewer needs to answer - should the City give any weight to
the 1983 floodplain conditions in it's impact assessment? In other words, while
the 1983 floodplain mapping may be used by the MVC for Regulation under the
Conservation Authorities Act, given the investment the City has made in
updating the hydrologic and hydraulic assessments using more detailed
topographic mapping and up-to-date watershed conditions, once the modeling is
completed to standard, should any consideration be given to the 1983 conditions
while Council is deliberating the approval of applications under the Planning
Act?
Model Calibration vs. Sensitivity Analysis & Adaptive
Management
The Third Party Reviewer should be asked to summarize model
calibration requirements from the "Technical Guide - River & Stream
Systems: Flooding Hazard
Limits (2002)", and the Lakes and Rivers Improvement Act
Technical Guidelines, and to comment on the differences between model
calibration and sensitivity analysis.
Furthermore, given that flooding is a health and safety issue that
also poses risks to property, the Third Party Reviewer should be asked whether
the precautionary principle should be applied given the uncertainty of the
aerial extent and elevation of flood levels. The Third Party Reviewer should be
required to provide a Professional Engineering Opinion on the appropriateness
of employing Adaptive Management on an engineered system where the public's
health and safety are at risk.
Development unaccounted for in Present Impact Assessment
There are at least three major developments unaccounted for in the
impact assessment completed to date:
1.. The expansion works
planned for Highway 417 that will affect the hydrology (expansion of impervious
areas and drainage improvements), and the hydraulics of the Carp River
(lengthening/widening the bridges through which the river must be conveyed);
2.. The Fernbank
Development area that will add 200 Ha of urban area to the watershed; and
3.. The Carp Road
Corridor.
The Third Party Reviewer must provide recommendations about how
the consideration of these development areas are to be factored in the impact
assessment such that future planning approvals that are to be based on the
supporting analysis have been completed using an approach that "is
consistent" with the Provincial Policy Statement.
Interim Development and Identification of Stormwater Management
Criteria
One of the first tasks that the Third Party Reviewer should be
asked to complete is an examination of supporting documentation to determine
whether there is any basis on which to assign stormwater management criteria
(quantity control criteria).
Since the grading plan shown in the Kanata West Infrastructure
Master Plan is based on the assumption that there is no need for quantity
controls above the 10-year event, major system drainage has been directed to
outlet directly to the tributaries and to the Carp River, with no opportunity
for off-line stormwater management.
As a result, the Third Party Reviewer must comment on whether it
is prudent to allow development to continue on the basis of the grading plan
from the Kanata West Infrastructure Master Plan, or if there is a need to
develop a different grading plan that would provide flexibility, in case the
subsequent findings of the Third Party review are such that quantity controls
up to the 100-year event are found to be required.
Steve
Hardaker
Thank you for the opportunity to comment on the
draft TORs for the Third Party Review of the Carp River Restoration Plan.
First, the Restoration Plan is a very credible
document that puts forward a valid plan for the restoration of a very sick
river system. It is absolutely
necessary to restore this river to a healthy watercourse, regardless of whether
development is occurring in this reach of the river. The partnership between the City, Conservation Authority and land
owners offers a cost sharing opportunity that will benefit the taxpayers of the
city. Without this partnership, the
restoration must be completed. Without
this partnership, the cost would be borne completely by taxpayers.
Some individuals and groups have commented that the
restoration plan does not go far enough down the Carp River. That stopping at Richardson Sideroad will
only push the problems farther downstream.
While this later comment may not be factually correct, not going beyond
Richardson Sideroad is a valid concern.
The current Carp River problems go beyond Richardson Sideroad and these
reaches should also be considered for restoration. This supports an entire watershed approach to the restoration of
the river. Under Review of Other
Related Issues, I would like to see the third party reviewer comment on whether
the city should be considering restoration beyond Richardson Sideroad. These comments should include a number of
cost estimated options for completing the work. As most landowners north of Richardson Sideroad are iprivate
landowners and farmers who do not possess the funds to contribute or can afford
to freely give buffer land for the work, some options for land compensation
should also be explored and provided.
Thanks again for the opportunity.
Steve
Hardaker
-----Original Message-----
From: Rod MacLean
Sent: June 08,2008 11:30 AM
To: Carp River Restoration
Cc: Feltmate, Peggy
Subject: Carp River Restoration Plan 3rd Party TOR
Hello Sandra Stone,
The
following is my concern for the Terms of Reference for Third Party Review of
the Carp River Restoration Plan.
Should
engaging external independent groups from outside Eastern Ontario and Western
Quebec to conduct a quality control assessment of studies so as to vet
reliability and validity a) the hydrological, geological and climatology
assumptions and b) test the program variables and models for not just internal
logic and coherence under not only normal but also reasonably possible
circumstances – become a normal practice?
Yours,
Rod MacLean
From: Jimjlougheed
Sent:
June 02,2008 8:30 PM
To:
Christensen, Carol
Cc:
Schepers, Nancy; Stone, Sandra; Mackay, Rob
Subject:
Lougheed Comments Posting of Terms of Reference for Third Party Review
Dear Ms. Christensen, I am replying to your email with my comments
on the Terms of Reference because the address provided was returned as unknown.
I would like to comment on the Terms of Reference proposed for the
third party review of the Carp River Restoration Plan.
Previous Technical Models have failed to include chemical and
biological contaminant estimates or the downstream impact of such
material. Stormwater from any extensive
development can reasonably be expected to contain significant quantities of
dissolved road salt, automotive residues, pet droppings, lawn & garden
products, spills etc. that may not be mitigated by sedimentation and will be
passed along to the Carp River. This is
a major change to the current state and utilization of the river and its
effects should be modeled.
I request that the Terms of Reference include Technical Models of
the stormwater chemical and biological loads and analyses of their impact on
the Carp River Watershed / subwatershed.
Thank
you,
Jim
Lougheed
-----Original
Message-----
From: Coolican,Joscelyn
Sent: June 09,2008 2:48 PM
To: Carp River Restoration
Subject: Public Consultation- ToR for 3rd Party Review
Attn: Sharon Stone,
I am currently on maternity
leave from my position as environmental analyst with the federal government and
have had some time to follow local issues in the media. The Carp River
Restoration Project is of interest to me given that my education is in urban
planning, my position is in the field of water management- and it has truly
become an interesting story to follow! As a concerned citizen, I have
provided a few general comments based on a quick review of the Terms of
Reference.
- First, there should be clarification on whether the river is an official municipal drain.
- The 3rd Party review should include a policy and legislative review.
- The recommendations of the Mississippi Valley Conservation should be reviewed since it is unusual for flood plain development in greenfield situations to occur these days. i.e. (last week's OMB decision to remove Taggart lots from the Jock River flood plain based on Rideau Valley Conservation Authority's comments).
- In my experience, I have seen some projects run inefficiently and sometimes fail because those who have the knowledge base, experience/corporate memory were often not involved/consulted. The 3rd party needs to outline a planning process for developing an acceptable River Restoration plan that involves all parties who have expressed an interest in the project to date. To not do so runs the risk of more Part II orders and other blocking strategies.
- Also, I hope city staff members (Cooper and Conway) who seem to have the watershed planning and management experience (and I believe discovered the errors in the consultants report) were/are involved in writing/finalizing of the ToR, and are integral part of the plan- as I understand they were often working on their own time on this project and not as City of Ottawa employees.
Sincerely,
Joscelyn Coolican
-----Original
Message-----
From: Pam Cain
Sent: June 09,2008 4:33 PM
To: Carp River Restoration
Cc: 'Jim Cain'
Subject: Carp River Development Plan
To
the attention of: Project contact:
Sandra Stone, Planning, Transit and the Environment
From: Pam and Jim Cain
As someone who lived for many years
adjacent to homes which were built on the Mississippi River flood plain, and
watching the consequences of that every spring, I wish to express my interest
in the Carp River Restoration Plan. While neither I nor my husband is qualified
to assess the Terms of Reference which are guiding current discussions about
flood plain development, we do wish, as responsible taxpayers, to lend our
voice of support to those who have the expertise to thoughtfully consider the
most responsible use of the Carp River watershed.
By way of guiding principles, we ask
that a transparent and inclusive communication plan be followed. In our
experience, much time can be wasted when participants in a debate conduct their
business in a way which leaves room for concern and perhaps suspicion. It is
possible to lose sight of the key issues when the credibility of the key
players takes precedence in the public's mind. To an observer, it appears that
the Carp River project has been the victim of misunderstanding and mistrust.
Clarification of terms and definitive answers to long-standing questions should
alleviate most of this confusion.
At the risk of stating the obvious,
we ask that residential development in potentially fragile natural environments
be held to a much higher standard than might be expected in less sensitive
areas. Should errors occur in the process, as has been documented in the CRRP
case, every effort must be made to correct those errors so that decisions are
based on accurate evidence, notwithstanding the economic implications, both
positive and negative, which must become secondary to environmental concerns.
As a final point, given the price of
gas and the city's stated objective of reducing urban sprawl and populating the
city's core with more residents, perhaps the larger question has to do with
evaluating the need to attract more families to live beyond the green belt, and
potentially compromising a vital habitat for a variety of birds, fish and
animals. Maybe the most important question is the What If? What if the Carp
watershed were left for Nature to manage, and people were encouraged to live in
the heart of the city where services would be maximized, thus reducing the
overall cost? Careful intensification of the city's core may be more beneficial
to our nation's capital than investing in projects that ultimately distress and
sometimes destroy our wetlands.
Do we really need to "pave
paradise" and "put up a parking lot"?
Pam and Jim Cain
