11. The Ottawa river ACTION PLAN

plan d’ACTION de LA RIVIÈRE DES OUTAOUAIS

Committee recommendationS

That Council:

1. Approve the Ottawa River Action Plan (ORAP) as described herein, valued at $251.64 million.

2. Approve a service level for combined sewer overflows (CSO) of zero overflows during the swimming season in the “average year.”[1]

3. Receive for information the scope and timeline for development of a long-term Water Environment Strategy as described herein.

RecommandationS DU Comité

Que le Conseil:

1. approuve le Plan d’action de la rivière des Outaouais (PARO) tel qu’il est décrit dans le présent rapport et dont le coût s’élève à 251,64 millions de dollars;

2. approuve un niveau de service correspondant à « aucun débordement durant la saison de baignade dans “l’année moyenne” »1 pour les surverses d’égout unitaire (SEU);

3. prendre connaissance de la portée et des échéances d’une Stratégie sur le milieu aquatique à long terme telle qu’elle est décrite dans le présent document.

Documentation

1. Deputy City Manager's report, Infrastructure Services and Community Sustainability, dated 1 February 2010 (ACS2010-ICS-ESD-0007).

2. Extract of Draft Minutes, 9 February 2010.

Report to / Rapport au:

Planning and Environment Committee

Comité de l'urbanisme et de l'environnement

and Council / et au Conseil

1 February 2010 / le 1 février 2010

Submitted by / Soumis par: Nancy Schepers, Deputy City Manager/

Directrice municipale adjointe

Infrastructure Services and Community Sustainability/

Services d’infrastructure et Viabilité des collectivités

Contact Person / Personne ressource: Dixon Weir, General Manager /

Directeur général Environmental Services / Services environnementaux

613-580-2424, x22002, Dixon.Weir@ottawa.ca

City-Wide / À l’échelle de la Ville

Ref N°: ACS2010-ICS-ESD-0007

SUBJECT: The Ottawa river ACTION PLAN

OBJET : plan d’ACTION de LA RIVIÈRE DES OUTAOUAIS

REPORT RECOMMENDATIONS

That Planning and Environment Committee recommend Council:

1. Approve the Ottawa River Action Plan (ORAP) as described herein, valued at $251.64 million.

2. Approve a service level for combined sewer overflows (CSO) of zero overflows during the swimming season in the “average year.”[2]

3. Receive for information the scope and timeline for development of a long-term Water Environment Strategy as described herein.

RECOMMANDATIONS DU RAPPORT

Que le Comité de l’urbanisme et de l’environnement recommande au Conseil :

1. d’approuver le Plan d’action de la rivière des Outaouais (PARO) tel qu’il est décrit dans le présent rapport et dont le coût s’élève à 251,64 millions de dollars;

2. d’approuver un niveau de service correspondant à « aucun débordement durant la saison de baignade dans “l’année moyenne” »¹ pour les surverses d’égout unitaire (SEU);

3. de prendre connaissance de la portée et des échéances d’une Stratégie sur le milieu aquatique à long terme telle qu’elle est décrite dans le présent document.

EXECUTIVE SUMMARY

This report recommends the adoption of a City policy of having zero combined sewer overflow (CSO) in an average year, implementation of 17 projects over the next five years aimed at improving the health of the Ottawa River, and development of a long-term strategy to ensure the health of Ottawa’s water environment for generations to come.

A key recommendation of the report is to build storage facilities in the combined sewer area currently experiencing overflows during wet weather. If implemented, the storage facilities will capture flows during wet weather events. These flows will be pumped out later when the event has passed. By doing so, modelling shows that overflows into the Ottawa River will be greatly reduced.

This report is the result of Council direction.

In June 2009, Council approved a report titled Ottawa River Water Quality Assessment (ACS2009-ICS-WWS-003), which directed staff to:

· Consult with the public regarding a set of 16 projects to be carried out in the short-term (referred to collectively as the Ottawa River Action Plan[3]); and,

· Prepare a long-term strategy to guide management of the watershed over time.

The objectives for the short-term Ottawa River Action Plan were the following:

· Achieve and sustain compliance with regulatory requirements, with a focus on CSO control;

· Optimize recreational use and economic development of the river, with a focus on reducing beach closures; and

· Maintain a healthy aquatic ecosystem, with a focus on addressing challenges presented by existing infrastructure.

Each of the ORAP projects targets one or more of the above, with the CSO Control Project (Project 3) addressing all three objectives (see Table 1). Special attention was given to that ORAP project during the consultations due to the need for a policy decision regarding the community’s preferred level of CSO control.

Four Open Houses, a dedicated web page (Ottawa.ca/riverplan), and an on-line questionnaire were used to provide information to and solicit comments from the public regarding the above. Three options were considered for dealing with flows from CSOs and were tabled for public consultation in the fall of 2009. Option A was designed to meet the provincial target at a cost of $40-$60 million (over 4-5 years), Option B would exceed the provincial target at a cost of $95-$140 million (over 5-6 years), Option C would virtually eliminate overflows at a cost of $1.3-$2.2 billion (over 30-50 years). With respect to controlling CSOs, over 75% of questionnaire respondents endorsed Option B, which equates to a targeted CSO control level of “zero overflows during the swimming season in the «average» year.”

This level of service would be achieved by the following means: a) separating sewers within a 187 ha area comprising a number of streets throughout the core; and b) building storage to accommodate stormflows generated within a 675 ha area that is to remain combined (shown in Figure 1). In some years (i.e., those with more severe weather patterns than the “average” year), overflows would continue to be experienced during the swimming season, depending upon the frequency of intense storm events. For instance, in recent years, (which have experienced high levels of summer rainfall) Option B would have reduced the number of combined sewer overflows experienced from an average of thirty per year to one per year. Cost estimates provided in June 2009 were based upon Option A, with a lower level of combined sewer overflow control and reduction. The CSO control and capital costs have been adjusted in this report to reflect Option B as modified to address concerns raised by the public regarding the need to design for growth, system redundancy, and climate change.

With respect to the remaining ORAP projects, questionnaire results indicate that, while there is good support for the scope and scale of the projects identified, there is still a strong sentiment in the community that more remains to be done. Three key themes emerged from or were confirmed during the consultations:

FIGURE 1 – Ultimate Combined Sewer Area

· The City must address impacts of uncontrolled stormwater runoff as well as CSOs. Several ORAP projects address urban stormwater; however, it is recognized that stormwater pollution is as important an issue as combined sewer overflows.

· Residents and businesses must take responsibility for their discharges to the environment (i.e., source control). At present, the City does not have a communication plan for improving awareness of, and action on, water environment issues at the community level. For this reason, a new project was added to ORAP to allow for improved public outreach and education on water environment matters.

· A watershed approach is needed to ensure that the full range of pollutant sources and impacts are addressed.

The need to develop a long-term Water Environment Strategy, as directed by Council, is clear. A collaborative effort among city departments, agencies, and community stakeholders led by the Environmental Sustainability Branch will be coordinated over the next two years in order to:

· Document the full range of watershed management issues, and determine those within the control or influence of the City of Ottawa.

· Increase public awareness and understanding of the issues, and the actions needed to address them.

· Establish priorities, assess the range of tools available to address them, and set short, mid, and long-term goals and targets to be achieved by the City over the next 20 years.

· Implement an approach for achieving those targets, including timelines and budget envelopes, as well as a collaborative framework for ongoing communication and cooperation between water environment partners such as the Conservation Authorities.

· Define monitoring, reporting, and information management requirements to allow for regular review, assessment and implementation of the strategy.

The total value of ORAP projects over the 5-year period 2009-2013 is approximately $252 million, which includes the CSO Control Project cost updated to allow for implementation of Option B; and all other project costs adjusted to December 2013.

The Environment Commissioner of Ontario reviewed the Ottawa River Action Plan and has endorsed the City’s approach (Document 9).

The following section of this report:

· Presents public feedback regarding the list of projects tabled in June 2009, which are referred to collectively as the Ottawa River Action Plan (ORAP);

· Confirms the list, timing, and cost estimates of ORAP projects;

· Presents public feedback regarding the Combined Sewer Overflow (CSO) Control initiative (ORAP Project No. 3);

· Provides the rationale for recommending Option B to address public concerns; and,

· Establishes the scope and timeline for development of a long-term Water Environment Strategy (ORAP Project No. 13) that will eventually provide a broader context for ORAP.

Consultation

Open Houses were held November 23, 26, 30 and December 1, 2009 in the centre, west, south, and east ends of the city. Public notices were published in the major dailies and community papers, and radio ads were used to promote awareness of the consultation process. An e-mail notice was sent to approximately 200 groups and individuals who have previously expressed interest in environmental and community issues. A web site was established, and an on-line questionnaire was launched to provide public information and gather feedback.

Almost 100 people attended the public meetings, and over 300 questionnaires were completed either at those events or on-line. As well, approximately 50 e-mails had been received at the time of the writing of this report.

The above consultation occurred in addition to ongoing discussions with the National Capital Commission and la Ville de Gatineau on water management issues, and extensive meetings with the Ontario Ministry of the Environment.

Legal/Risk Management Implications

There are no legal/risk management impediments to implementing any of the recommendations in this report. The successful implementation of Project 1 in 2010 (Real Time Control) is expected to bring the City closer to compliance with the Ministry of the Environment’s Procedure F-5-5. Implementation of Projects 3 and 5 will bring the City into full compliance.

The City’s Pollution Prevention Control Plan will be updated to reflect the direction of Council.

Financial Implications

The total value of ORAP projects over the 5-year period 2009-2013 is approximately $251.64 million. This value is greater than the June 2009 estimate for the following reasons:

· The CSO Control Project cost was updated to allow for implementation of Option B; and

· All other project costs were adjusted to include all costs up to December 2013, but not beyond.

Table 3 distinguishes between previously committed monies, monies identified in the 2010 budget and beyond, and new budget pressures.

TABLE 3 - ORAP Financial Requirements

	5-year ORAP ($ million)				2014 and beyond[4]
	2009	2010	2011-13	TOTAL	2014 and beyond[4]
Total ORAP per Document 5	$54.13	$23.86	$173.65	$251.64	$11M/yr
Less
Ottawa River Fund Approved in 2009	$19.75	$31.25	$88.0	$139.0
Other Works in Progress (WIPs)	$34.38			$34.38
Costs not previously budgeted		($7.39)	$85.65	$78.26	$11M/yr

The 2010 requirement of $23.86 million has been included in the 2010 Draft Rate Supported Programs Capital Budget. Pending approval of this plan, requirements for 2011 and beyond will be identified in the Long Range Financial Plan to be tabled in the spring.

As several of these projects extend beyond the five-year period of ORAP, it will be necessary to expand and extend the funding envelope over time. For example, the Sewer Separation Outside the Ultimate Combined Sewer Area (UCSA), the implementation of Stormwater Retrofit Plans, and Implementation of the Wet Weather Infrastructure Management Plan are all multi-year projects that extend well beyond 2013. Should Council approve this plan, pre-commitments of future years’ budgets will be required.

Staff will also pursue opportunities for cost sharing with other government bodies.

RÉSUMÉ

Ce rapport préconise l’adoption de la politique « aucune SEU dans l’année moyenne » de la Ville, la mise en œuvre de 17 projets d’amélioration de la rivière des Outaouais au cours des cinq prochaines années et l’élaboration d’une stratégie à long terme de préservation du milieu aquatique d’Ottawa pour les générations futures.

Une des principales recommandations du rapport concerne la construction de réservoirs dans la zone d’égouts unitaires où surviennent actuellement les débordements par temps pluvieux. Ces réservoirs serviraient à capter les eaux pluviales lors des fortes précipitations. Cette eau serait ensuite pompée lorsque la pluie aurait cessé. Les modélisations montrent une réduction considérable des débordements de la rivière des Outaouais.

En juin 2009, le Conseil a approuvé un rapport intitulé Évaluation de la qualité de l’eau de la rivière des Outaouais (ACS2009-ICS-WWS-0003), dans lequel on demandait au personnel de :

· consulter la population au sujet de 16 projets à court terme (appelés collectivement Plan d’action de la rivière des Outaouais[5]); et

· préparer une stratégie à long terme pour orienter la gestion continue du bassin hydrographique.

Les objectifs du Plan d’action de la rivière des Outaouais, qui vise une réalisation à courte échéance, sont les suivants :

· se conformer aux exigences réglementaires, particulièrement en ce qui a trait au contrôle des SEU;

· optimiser le développement économique de la rivière et son utilisation à des fins récréatives, notamment par la diminution des fermetures de plages;

· maintenir un écosystème aquatique sain, en se consacrant surtout aux difficultés que posent les infrastructures existantes.

Chacun des projets qui forment le PARO cible un ou plusieurs des objectifs énumérés ci-dessus. C’est notamment le cas du projet de contrôle des SEU (projet 3), qui englobe les trois objectifs (voir le tableau 1). Ce projet a reçu une attention spéciale au cours des consultations en raison de la nécessité d’établir une politique sur le niveau de contrôle des SEU souhaité par la communauté.

Pour informer la population et recueillir ses commentaires à cet effet, on a organisé quatre réunions portes ouvertes, publié une page Web spéciale (Ottawa.ca/planriviere) et produit un questionnaire en ligne. Trois options ont été présentées aux fins de consultations publiques à l’automne 2009. L’option A a été conçue pour atteindre la cible provinciale à un coût de 40 à 60 millions de dollars (sur une période de 4 à 5 ans), l’option B surpasserait la cible provinciale à un coût de 95 à 140 millions de dollars (sur une période de 5 à 6 ans) et l’option C permettrait pratiquement d’éliminer les débordements à un coût de 1,3 à 2,2 milliards de dollars (sur une période de 30 à 50 ans). En ce qui concerne le contrôle des SEU, plus de 75 % des répondants au sondage se sont dits favorables à l’option B, soit un objectif de niveau de contrôle des SEU correspondant à « aucun débordement durant la saison de baignade dans “l’année moyenne” ».

On compte atteindre ce niveau de service de la façon suivante : a) en séparant les égouts dans une zone de 187 ha qui comprend plusieurs rues au cœur du système; b) en construisant des réservoirs pour recueillir les eaux pluviales reçues à l’intérieur d’une zone de 675 ha où l’on prévoit concentrer les égouts unitaires (illustrée à la figure 1). Au cours de certaines années (c’est-à-dire celles enregistrant des précipitations plus abondantes que « l’année moyenne »), des débordements continueraient de se produire durant la saison de baignade, selon la fréquence des événements pluvio-hydrologiques de grande importance. Par exemple, ces dernières années (au cours les précipitations ont été abondantes en été), l’option B aurait permis de réduire le nombre moyen de SEU par année, le faisant passer de 30 à 1. L’évaluation des coûts fournie en juin 2009 était basée sur l’option A, soit un niveau de contrôle et de réduction des SEU inférieur. Dans le présent rapport, on a ajusté les coûts de contrôle des SEU et les coûts d’immobilisation liés aux SEU pour refléter l’option B, un changement qui vise à répondre aux préoccupations de la population concernant la nécessité d’aménager des infrastructures en tenant compte de la croissance, de la redondance du réseau et des changements climatiques.

En ce qui concerne les autres projets du PARO, les résultats du sondage indiquent que la population appuie en général la portée et l’envergure proposées pour ces projets, mais qu’elle croit fortement qu’il reste beaucoup à faire. Les trois grands thèmes suivants sont ressortis ou ont été confirmés lors des consultations :

FIGURE 1 – Zone définitive des égouts unitaires

· La Ville doit remédier aux effets du ruissellement incontrôlé des eaux pluviales et aux SEU. Plusieurs projets du PARO portent sur les eaux pluviales en milieu urbain. Toutefois, il est établi que la pollution causée par les eaux pluviales est aussi importante que les SEU.

· Les résidents et les entreprises doivent assumer la responsabilité de leurs déversements dans l’environnement (contrôle à la source). Actuellement, la Ville ne dispose d’aucun plan de communication pour sensibiliser les gens aux problèmes liés au milieu aquatique dans leur communauté et les inciter à agir. Pour cette raison, on a ajouté un nouveau projet au PARO, lequel vise à mieux informer la population au sujet des questions liées au milieu aquatique.

· Il faut adopter une approche axée sur le bassin hydrographique si l’on veut s’assurer que toutes les sources de polluants et tous les effets de la pollution soient pris en considération.

Ce dernier point rappelle la nécessité d’élaborer une Stratégie sur le milieu aquatique, comme l’a demandé le Conseil. La Direction de la durabilité de l’environnement supervisera l’élaboration de cette stratégie, qui sera le fruit d’une collaboration entre les services de la Ville, ses organismes et divers intervenants de la communauté au cours des deux prochaines années. Ces efforts concertés visent à :

· décrire l’ensemble des problèmes liés à la gestion du bassin hydrographique et déterminer ceux que la Ville d’Ottawa peut régler ou contribuer à régler;

· sensibiliser le public aux problèmes en question et aux gestes à poser pour les régler, et s’assurer qu’il comprend bien ces notions;

· établir des priorités, évaluer la gamme d’outils disponibles pour y répondre et fixer des objectifs et des cibles à court, à moyen et à long terme que la Ville devra atteindre au cours des 20 prochaines années;

· adopter une approche permettant d’atteindre ces cibles et comprenant un calendrier, une enveloppe budgétaire ainsi qu’un cadre collaboratif pour assurer la communication et la coopération continues entre les partenaires œuvrant dans le domaine de la préservation du milieu aquatique, comme les offices de protection de la nature;

· établir des exigences en matière de suivi, de rapport et de gestion de l’information qui permettront de mettre en œuvre la stratégie et de l’évaluer et la revoir régulièrement.

La valeur totale des projets du PARO sur une période de 5 ans (de 2009 à 2013) est d’environ 251,64 millions de dollars, ce qui comprend le coût du Projet du contrôle des débordements d’égouts unitaires mis à jour pour permettre la mise en œuvre de l’option B et tous les autres coûts de projet ajustés pour tenir compte des dépenses qui seront engendrées d’ici décembre 2013.

La partie suivante du présent rapport vise à :

· présenter les commentaires de la population sur les projets proposés en juin 2009, que l’on appelle collectivement le Plan d’action de la rivière des Outaouais (PARO);

· confirmer la liste des projets du PARO, de même que leurs échéances et leurs coûts estimatifs;

· présenter les commentaires de la population concernant l’initiative de contrôle des surverses d’égout unitaire (SEU) (projet n°3 du PARO);

· indiquer pour quelles raisons l’option B permettrait de mieux répondre aux préoccupations du public;

· établir la portée et les échéances d’une Stratégie sur le milieu aquatique à long terme (projet n°13 du PARO) qui servira plus tard de contexte général au PARO.

Consultation

Des réunions portes ouvertes ont été tenues les 23, 26 et 30 novembre 2009 ainsi que le 1^er décembre 2009 dans le centre, l’ouest, le sud et l’est de la ville. Des avis publics ont paru dans les grands quotidiens et dans les journaux locaux, et on a diffusé des publicités à la radio pour informer les gens du processus de consultation. Un avis par courriel a été envoyé à environ 200 personnes et groupes qui avaient déjà exprimé leur intérêt pour les questions environnementales et communautaires. On a créé un site Web et mis en ligne un questionnaire qui a permis de renseigner le public et de recueillir ses commentaires.

Près de 100 personnes ont assisté aux réunions portes ouvertes, et plus de 300 questionnaires ont été remplis soit au cours de ces rencontres, soit en ligne. Environ 50 courriels avaient été reçus au moment de la rédaction du présent rapport.

En plus des consultations décrites ci-dessus, des discussions ont été menées avec la Commission de la capitale nationale et la Ville de Gatineau au sujet des questions touchant la gestion de l’eau, et des rencontres importantes avec le ministère de l’Environnement de l’Ontario ont eu lieu.

Répercussions Juridiques/Sus la Gestion du Risque

Le rapport ne fait état d’aucune répercussion juridique ni d’aucune conséquence pour la gestion des risques découlant de la mise en œuvre des recommandations. La réalisation du projet 1 (contrôle en temps réel) en 2010 devrait permettre à la Ville de faire des progrès sur le plan du respect de la Procédure F-5-5 du ministère de l’Environnement. La mise en œuvre des projets 3 et 5, quant à elle, devrait permettre à la Ville d’être entièrement conforme à cette procédure.

Le Plan de contrôle et de prévention de la pollution sera mis à jour afin de refléter l’orientation du Conseil.

Répercussions Financières

La valeur totale des projets du PARO dont il est question dans le présent document s’élève à environ 251,64 millions de dollars..

· Le coût du Projet de contrôle des SEU a été mis à jour pour permettre la mise en œuvre de l’option B;

· Tous les autres coûts de projet ont été ajustés pour inclure les dépenses qui seront engendrées d’ici décembre 2013.

Dans le tableau 3, les fonds déjà investis, les fonds prévus dans le budget de 2010 et des années suivantes ainsi que les nouvelles pressions budgétaires sont indiqués séparément.

Tableau 3 – Besoins financiers du PARO

	PARO sur 5 ans (en millions de dollars)				À compter de 2014[6]
	2009	2010	2011-13	TOTAL	À compter de 2014[6]
PARO total selon le document 5	54,13	23,86	173,65	251,64	11 M$/an
Moins
Fonds de la rivière des Outaouais approuvés en 2009	19,75	31,25	88	139
Autres travaux en cours (TEC)	34,38			34,38
Coûts qui n’ont pas encore été budgétés		(7,39)	85,65	78,26	11 M$/an

Les besoins financiers pour 2010, qui sont de l’ordre de 23,86 millions de dollars, ont été inclus dans la version préliminaire du budget d’immobilisation pour les programmes de 2010 soutenus par les tarifs. En attente de l’approbation de ce plan, les besoins financiers pour 2011 et les années subséquentes seront établis dans le Plan financier à long terme et présentés au Conseil le printemps prochain.

Comme la réalisation de plusieurs de ces projets excède la période de cinq ans du PARO, il sera nécessaire d’augmenter et de prolonger l’enveloppe budgétaire. Par exemple, le projet d’aménagement d'égouts unitaires à l’extérieure de la zone définitive des égouts unitaires (ZDEU), les plans de réfections de l’infrastructure de traitement des eaux pluviales et le Plan de gestion de l’infrastructure de traitement des eaux pluviales sont tous des projets pluriannuels qui dont la mise en œuvre sera complétée bien après 2013. Se ce plan devait être approuvé par le Conseil, il faudrait prendre des engagements préalables pour les budgets des années subséquentes.

Le personnel sera donc à l’affût des possibilités de partage des coûts avec d’autres organismes gouvernementaux.

BACKGROUND

The Ottawa River is 1,271 km in length; the watershed 146,222 km² in size[7], with a flow rate that is the sixth largest in Canada. The upper reaches of the watershed are in near pristine condition. The health of the river up and downstream of Ottawa is “Good” when assessed against a variety of measures (Document 1).[8]

The City of Ottawa and Ville de Gatineau are the only major urban settlements on the river. All other communities on the river have significantly smaller and are relatively dispersed. Use of the river for lumber transport ceased in the 1970s, however, pulp and paper mills and other industries draw from the watershed for purposes such as power generation, heating and cooling, irrigation, and as a manufacturing input.

Over the years, the City of Ottawa has continually improved its wastewater system design and operations to reduce local impacts on the river. Fifty years ago, all sanitary waste was discharged to local rivers untreated. Today, less than 1% is discharged untreated. Well over a billion dollars has been spent to achieve this success—making the City a leader amongst national capitals.[9] Currently, a few communities on the river do not have secondary sewage treatment of their sanitary waste discharges.

The City has done much to improve the quality of discharges to the river over the past fifty years, but more effort is needed to address the full range of pollutants and, in particular, to address them at their source. Though the volume and frequency of combined sewer overflows have been lowered over the years, they still contribute to beach closures, shoreline pollution, and contamination of local aquatic habitats. Figure 2 identifies the various sources of E coli to the Ottawa River in the reach extending from Arnprior to Cumberland, and shows that Ottawa CSOs and stormwater discharges are two of the largest local sources of E coli today.

Other pollutants also affect the river and many of its tributaries within the City. In fact, 10 years of monitoring data shows that several of the City’s urban and rural creeks are under stress—suffering from high levels of nutrients that can lead to excessive algae growth and depleted oxygen levels (Document 2); elevated heavy metal levels that threaten fish and other aquatic life (Document 3); other stormwater pollutants that contaminate shorelines and beaches (Document 4); and excessive erosion that clouds the water column and can destroy aquatic habitat. These matters will be addressed by several ORAP projects, in particular the Water Environment Strategy and the urban retrofit initiatives.

Much work remains to be done. This report documents the City’s commitment to do more as proposed in June 2009, as amended to address feedback received during consultations carried out in November and December 2009.

DISCUSSION

Four public meetings were held in late 2009 to inform the community of water quality issues in the Ottawa River, to present the range of City of Ottawa projects planned or underway to reduce impacts in the short-term, and to solicit feedback on the scope of initiatives—in particular the level of CSO control to be achieved with respect to combined sewer overflows. The following sections summarize the feedback received, and the recommended plan going forward.

Short-term Ottawa River Action Plan

The objective of the Ottawa River Action Plan is to address the full range of watershed health issues, starting with the most critical:

1. Achieve and sustain compliance with regulatory requirements, with a focus on CSO control;

2. Optimize recreational use and economic development of the River, with a focus on reducing beach closures; and,

3. Maintain a healthy aquatic ecosystem, with a focus on addressing challenges presented by existing infrastructure.

The sixteen short-term projects tabled in June 2009 and listed in Table 1 will achieve these objectives. Projects 1, 3 and 5 combined will lower the City’s annual contribution of E coli to the Ottawa River by an estimated 65%. Had they been in place in recent years, these projects would have reduced the number of CSO events during the swimming season from an average of thirty (30) per year to one (1) per year.

TABLE 1 – LIST OF ORAP PROJECTS
Project	Purpose	Objective
Project	Purpose	1	2	3
1. Implementation of Real Time Control	Maximize use of existing capacity within the combined sewer collection system through the upgrade of regulators, and use of automated controls.	ü	ü	ü
2. Critical CSO and Storm Outfall Monitoring	Improve system monitoring to allow for timely identification and response to equipment failure; reduce the risk and severity of failures; and improve understanding of how the system responds under different conditions to facilitate continuous improvement.	ü	ü	ü
3. CSO Storage for Ultimate Combined Sewer Area (UCSA)	Achieve regulatory compliance for the frequency and volume of combined sewer overflows during the swimming season, and in so doing reduce beach closures.	ü	ü	ü
4. Review Sewer Interconnections	Identify cross-connections between the storm and sanitary systems in order to: reduce pollutants entering the stormwater system; and reduce the volume of stormwater flows entering the sanitary system that can cause surcharging and overflows.	ü	ü	ü
5. Sewer Separation Outside the UCSA	Reduce the volume of stormwater flows entering the combined sewer system that can cause surcharging and overflows.	ü	ü	ü
6. Development of a Wet Weather infrastructure Management Plan	Develop a comprehensive plan for improving the management of wet weather flows in the urban area to reduce surcharging, flooding, overflows, and pollution of the natural environment.	ü
7. Implementation of a Wet Weather Infrastructure Management Plan	Implement measures to improve management of wet weather flows.	ü		ü
8. Installation of Floatable Traps in Combined Sewer Area Catch Basins	Reduce the quantity of floatables (e.g., plastic bottles, cups, wrappers, oil and grease) entering combined and storm sewers and discharged to the environment.			ü
9. Pinecrest Creek / Westboro Stormwater Management Retrofit Plan	Evaluate approaches to retrofit urban subwatershed and sewersheds to improve water quality, reduce erosion and flood risk, and enhance degraded aquatic habitat.		ü	ü
10. Eastern Subwatersheds Stormwater Management Retrofit Plan	Evaluate approaches to retrofit urban subwatershed and sewersheds to improve water quality, reduce erosion and flood risk, and enhance degraded aquatic habitat.		ü	ü
11. Implementation of Stormwater Retrofit Plans	Reduce pollutants from entering surface waters by implementing the above (9 and 10) and assessing suitability for implementation elsewhere.		ü	ü
12. R.O. Pickard Environmental Control Effluent Dechlorination	Reduce discharges of chlorinated compounds to the Ottawa River through implementation of dechlorination at the City’s sewage treatment plant.			ü
13. Develop a Water Environment Strategy	Establish a comprehensive and integrated plan in cooperation with other agencies for the management of water environment issues in Ottawa.	ü		ü
14. Monitoring and Source Control Programs	Identify and reduce pollutants at source, and track long-term trends in environmental health associated with ORAP projects.		ü	ü
15. Wastewater & Drainage Environmental Quality Management System	Identify and mitigate risks of system failure or human error through implementation of an Environmental Management System (EMS) for the sanitary system.	ü	ü	ü
16. Updates to the Ottawa River Bacterial Water Quality Computer Model	Update the Ottawa River Water Quality Model to allow for the empirical evaluation of pollution management options.	ü	ü	ü
17. Public Outreach and Education (NEW)	Inform the public of the linkages between what they do and the health of the water environment; and increase awareness of ORAP initiatives.

Document 5 provides the implementation timeline and cost estimate for each ORAP project.

Over sixty percent of questionnaires received indicated that they “agreed” or “strongly agreed” that the list of projects was appropriate. However, most respondents also expressed the desire that the plan address stormwater pollution to the same degree as CSOs; and to involve residents and businesses in reducing pollution of surface waters at the lot level. Several felt that as the nation’s capital, the City of Ottawa should be a world leader in CSO control and protection of the Ottawa River watershed.

The results illustrate the need for the City to do a better job demonstrating that it is a world leader in CSO control, that implementation of these works will strengthen Ottawa’s leadership position amongst communities with combined sewer systems, and that it will make significant improvements in watershed protection. Furthermore, these results show the need to increase public awareness of the role that households and businesses have in protecting the watershed.

Upon completion of Projects 1, 3, and 5, few if any cities of Ottawa’s size and age in Canada will match our level of CSO control (less than 0.5% untreated discharges per year). Furthermore, by addressing the impacts of uncontrolled stormwater runoff, the City will make significant improvements in stormwater discharges, and be in a position to lead by example on broader watershed issues. This is a comprehensive short-term plan that will yield both short and long-term results, and which addresses key issues that are the responsibility and within the control of the City of Ottawa.

As noted previously, the need for enhanced public education was identified as a key ingredient to success at all public meetings. For this reason, a 17^th project is recommended for the short-term plan: Public Education on Watershed Issues. The City has not actively promoted water environment awareness and understanding for several years. It is carried out on an ad hoc basis in association with special events and specific capital projects, but there is no on-going effort to raise awareness and to remind residents and businesses of their impacts on the environment, what the City does to mitigate those impacts, and how they can adjust their behaviours to further reduce pollution of the watershed.

At present, many in the community are focused on E coli from CSOs because it can be harmful to humans and causes beach closures. As important in terms of watershed health are other pollutants that are harmful to aquatic species. Many of those pollutants come from chemicals we use in our yards, garages and pools, from our vehicles, and from our pets. Many watershed problems arise when we fail to properly dispose of wastes, handle chemicals improperly, ignore fluid leaks, remove vegetation and alter slopes near creeks, and harden shorelines. The Public Education project will raise awareness of the linkages between daily behaviours and the health of our water environment.

It is recommended that $75,000 per year be allocated to Project 17 for the next five years as part of the short-term plan. Activities would include speaking to community and business associations, outreach at local malls and beaches, special events in cooperation with local water environment partners, tours of community stormwater facilities for area residents, and the development of educational materials.

No other changes to the short-term action plan are recommended.

The General Manager of Environmental Services Department will oversee implementation of the Ottawa River Action Plan and will be responsible for progress monitoring and reporting to Council and the public. A variety of departments will lead implementation of specific ORAP projects, as identified in the Disposition hereto.

CSO Control for the Ultimate Combined Sewer Area – ORAP Project 3

The City of Ottawa is required to meet targets set out in the Ministry of the Environment (MOE) Procedure F-5-5 for the capture and treatment of flows from the combined sewer area (CSA). The primary criterion to which all municipalities with combined sewer systems must comply concerns the “volume” of overflows permitted. For municipalities with downstream beaches impacted by CSOs, a second criterion applies concerning the “number” of overflows permitted during the swimming season, and the impact of those overflows on beach closures. The City’s Combined Sewer Area Pollution Prevention Control Plan (PPCP), sets out the activities required to meet the volumetric requirement, and the need for storage should downstream beaches be affected by the CSOs.

The City has been in compliance with the volumetric criterion for several years, and will further improve system performance upon commissioning of ORAP Project 1, Real Time Control. The purpose of the CSO Storage for the UCSA and the Sewer Separation Project (Projects 3 and 5) is to bring the City into compliance with the “numeric” target set by the province, which is a maximum of two (2) overflow events during the swimming season, during the ‘average year.’ During public consultations for this project, the community was asked whether the provincial target was acceptable, or if a more stringent level of CSO control was desired.

What is the Ultimate Combined Sewer Area (UCSA)? (Refer to Figure 1)

· Approximately 2,952 ha of the downtown was originally developed using a single-pipe system to collect both sanitary and stormwater, and is called the Combined Sewer Area (CSA).

· Most of the CSA (65%) has undergone sewer separation meaning that the single pipe has been replaced with “separate” sanitary and storm pipes.

· There is a 675 ha area within the CSA that cannot undergo separation without significant difficulty and cost because there are no nearby locations to discharge the stormwater.

· After all other areas of the downtown have undergone sewer separation, the City’s Pollution Prevention Control Plan confirmed that this area continues to be served by a single-pipe system, and thus is called the “ultimate” combined sewer area.

Three options were considered for dealing with flows from the UCSA and were tabled for public consultation in the fall of 2009 for achieving the provincial target, as well as more stringent service levels (see Table 2). All three options meet regulatory requirements, assuming implementation of Project 1: Real Time Control (RTC); and Project 5: Separation of the remaining 187 ha of sewers lying outside of the UCSA over the next 20-25 years.

TABLE 2 – SUMMARY OF OPTIONS A, B, AND C
OPTION A (per PPCP)	OPTION B	OPTION C
Meet provincial target.	Exceed provincial target.	Virtual elimination of overflows.
$40 to $60 million 4-5 years	$95 to $140 million 5-6 years	$1.3 to $2.2 billion 30-50 years
Storage capacity would be added to the combined sewer system to temporarily hold surplus flows during wet weather events, preventing them from overflowing to the Ottawa River. The amount of storage constructed would ensure compliance with current provincial requirements for combined sewer overflows, (i.e., no more than two overflows during the swimming season in the average year). Several storage facilities would likely be required, consisting of underground storage tanks sited at key locations downtown, but could also consist of a tunnel.	Even more storage capacity than proposed under Option A would be added to the combined sewer system to temporarily hold surplus flows during wet weather events, preventing them from overflowing to the Ottawa River. The amount of storage constructed would ensure compliance with current provincial requirements (i.e., no more than two overflows during the swimming season in the average year) and due to the greater storage capacity this option would achieve fewer overflows during wet years as well. Storage would likely be linear, for example a deep tunnel running west to east through the downtown or near the shoreline, possibly extending as far as the Robert O. Pickard Environmental Centre treatment plant. Alternatively, underground storage tanks could be sited at key locations in the City’s downtown (more numerous and/or larger than those required by Option A).	Ottawa’s 675 hectares of Ultimate Combined Sewer Area would undergo full sewer separation. The City’s Partially Separated Area, roughly 2,000 hectares, comprising 58,000 households would undergo the following: · Disconnection of roof downspouts and foundation drains from the sanitary sewer; · Installation of new sewer laterals leading from homes to the storm sewer in the street; and · Installation of sump pumps in basements where sewer laterals cannot be installed. Separation work would be carried out on a priority basis, addressing first those areas requiring rehabilitation and replacement of infrastructure or flood relief. Several storm outfalls to the Ottawa River would be constructed, each with a stormwater centrifuge (vortex separators) that would provide partial removal of some pollutants.

Because all three options achieve regulatory compliance, moving to a higher level of CSO control offered by Options B and C is at the City’s discretion. To aid in this policy decision, each option was evaluated against a set of criteria developed using existing City environmental, social, and financial policy. The results of those analyses are contained in Document 6.

In summary, staff, the community (over 70% of completed questionnaires), the Environmental Commissioner, and the Ottawa Riverkeeper endorse Option B for the following reasons:

· By providing greater storage, Option B will:

o Reduce the number of overflows from an annual average of thirty (30) per year to one (1) per year, with significant reductions in the number of beach closures;

o Capture greater volumes from the more frequent and severe storms predicted to occur as a result of climate change; and,

o Allow for treatment of a greater volume of urban stormwater—another major pollutant source.

· Option B will capture all frequent sized storms, with only extreme wet weather events overflowing. The more severe the storm, the greater the amount of stormwater entering the system, and the larger the volume of overflow. However, these overflows will be very diluted due to the large volume of stormwater present.

· If designed as a linear facility, Option B provides opportunities for the following operational improvements:

o If extended from downtown to the sewage treatment plant, a tunnel could provide redundancy to the Ottawa Interceptor Outfall Sewer, which is over 50 years old.

o It may be possible to pick-up stormwater from other locations for treatment at the sewage treatment plant to reduce pollution from urban stormwater run-off.

As recommended by several members of the public, staff recommends that the above opportunities be investigated, as well as consideration of opportunities to size and design the project to offset the impacts of urban intensification.

By comparison:

· Option A does not allow for any of the above, and is vulnerable to climate change.

· Option C would take several decades to complete, likely necessitate interim measures, and would result in increased pollution of the Ottawa River from urban stormwater run-off[10]. Though the costs per year for sewer separation are relatively affordable, the cost per unit of CSO diverted from the river is roughly seven times the cost of providing a storage solution ($7,000 versus $1,100 per m³ of CSO removed in the average year). Furthermore, it is a much more disruptive solution.

Additional options were raised during public consultations that are hybrids of Options A, B, and C, and which are discussed in Document 7.

Development of the Long-term Water Environment Strategy (WES)

The previous sections dealt with activities and works to be carried out over the next five years. A strategy is needed that identifies long-term watershed objectives and how to achieve them on an ongoing basis; and that ensures that the City addresses water environment issues in a coordinated and integrated manner in cooperation with agency partners and community stakeholders. Staff propose to carry out comprehensive consultations over the next 2 years in order to:

· Summarize the current state of knowledge regarding water environment issues in Ottawa (urban and rural, surface and groundwater, short and long-term, localized and city-wide, as well as water quality and habitat/ecological functions);

· Establish long-term water environment goals, objectives, and targets to be achieved by the City over the next 20 years;

· Confirm the scope of matters within the control or influence of the City of Ottawa and develop an approach for City actions and works beyond ORAP;

· Document programs and projects in place today that contribute to achievement of the above;

· Identify service gaps, opportunities and barriers to success;

· Establish priorities and an approach for achieving strategic goals, objectives, and targets;

· Establish an approach for addressing gaps, opportunities, and barriers;

· Prepare timelines and budgets for the above initiatives;

· Establish a collaborative framework to guide ongoing communication and cooperation between the multiple agencies and stakeholders involvement in the water environment;

· Define monitoring, reporting, and information requirements and budget that allows for regular review and assessment of progress towards strategic goals, objectives, and targets, and implementation thereof; and,

· Ensure that the resultant Water Environment Strategy has the support of the community.

Given the number of interested stakeholders, the City recognizes the importance of broad consultation. To that end, the NCC, Ville de Gatineau, Conservation Authorities and other non-governmental organizations such as the Ottawa Riverkeeper will be invited to participate in this initiative.

Community consultation as well as interest-specific consultations will be needed to ensure that the Strategy is based upon the input of a cross-section of the population, and enjoys broad community support. A variety of consultation and communication methods will be employed to achieve that result.

The City has already made significant efforts on watershed issues in recent years that will provide a foundation for this work, namely:

Stormwater Management (SWM) Strategy

Existing stormwater conditions within the urban area were assessed in 2006. Council approved stormwater goals, objectives, and policies for those areas in 2007.

Preparation of a Stormwater Management Planning Guideline is to be completed in 2010. And, ORAP Project 9, development of a retrofit plan for Pinecrest Creek/Westboro is underway, and will be used to evaluate and test alternative means of managing urban stormwater. All of the above was or is being carried out in consultation with the public and will be used as the starting point for the WES.

Lower Rideau Watershed Strategy

The Lower Rideau Watershed Strategy was developed by a multi-agency task group to guide the planning and delivery of watershed management by the City and partner agencies. It encourages an “environment first” approach to the watershed and supports regular monitoring and reporting. The strategy’s main objectives include:

· Protection of stream function and habitats in small tributaries; and,

· Reduction of the amount of nutrients, such as phosphorous, in the water, as nutrients contribute to excessive algae in the streams.

The WES will include the watershed issues identified in the Lower Rideau Watershed Strategy and reflect or update the commitments made therein.

The long-term Water Environment Strategy is to cover a 20-year period, and those components requiring approvals under the Municipal Class Environmental Assessment will be prepared in accordance with the master planning process. The project will be a collaborative effort led by the Director of Community Sustainability.

ENVIRONMENTAL IMPLICATIONS

Both the Ottawa River Action Plan and the longer-term Water Environmental Strategy will reduce the impact of discharges to the Ottawa River, and will assist in fulfilling the goals of Ottawa 20/20 and the City’s Environmental Strategy for protection of the water environment. Combined, Projects 1, 3, and 5 will allow the City to achieve full compliance with MOE Procedure F-5-5, and significantly reduce the City’s discharge of E coli to the Ottawa River.

RURAL IMPLICATIONS

CONSULTATION

An e-mail notice was sent to approximately 200 groups and individuals who have previously expressed interest in environmental and community issues. A web site was established, and an on-line questionnaire provided information and gathered public feedback.

Almost 100 people attended the public meetings, and over 300 questionnaires were completed either at those events or on-line. Approximately 50 e-mails had been received at the time of writing of this report.

LEGAL/RISK MANAGEMENT IMPLICATIONS

The City’s Pollution Prevention Control Plan will be updated to reflect the direction of Council.

TECHNICAL IMPLICATIONS

FINANCIAL IMPLICATIONS

The total value of ORAP projects over the 5-year period 2009-2013 is approximately $251.64 million. This value is greater than the June 2009 estimate for the following reasons:

· The CSO Control Project cost was updated to allow for implementation of Option B; and

· All other project costs were adjusted to include all costs up to December 2013, but not beyond.

Table 3 distinguishes between previously committed monies, monies identified in the 2010 budget and beyond, and new budget pressures.

TABLE 3 - ORAP Financial Requirements

	5-year ORAP ($ million)				2014 and beyond[11]
	2009	2010	2011-13	TOTAL	2014 and beyond[11]
Total ORAP per Document 5	$54.13	$23.86	$173.65	$251.64	$11M/yr
Less
Ottawa River Fund Approved in 2009	$19.75	$31.25	$88.0	$139.0
Other Works in Progress (WIPs)	$34.38			$34.38
Costs not previously budgeted		($7.39)	$85.65	$78.26	$11M/yr

As several of these projects extend beyond the five-year period of ORAP, it will be necessary to expand and extend the funding envelope over time. For example, the Sewer Separation Outside the UCSA, the Implementation of Stormwater Retrofit Plans, and Implementation of the Wet Weather Infrastructure Management Plan are all multi-year projects that extend well beyond 2013. Should Council approve this plan, pre-commitments of future years’ budgets will be required.

Staff will also pursue opportunities for cost-sharing with other government bodies.

SUPPORTING DOCUMENTATION

Document 1 Ottawa River Water Quality in the Ottawa Reach (Arnprior to Cumberland)

Document 2 10-year Average Phosphorous Levels

Document 3 10-year Average Copper Levels

Document 4 10-year Average E coli Levels

Document 5 ORAP Cost Estimates and Project Schedule/Status

Document 6 Evaluation Results for Options A, B, and C

Document 7 Review of Hybrid Solutions and Other Ideas Offered by the Public

Document 8 Summary of Questionnaire Methodology and Findings

Document 9 Environment Commissioners’ Report on the Ottawa River Plan

DISPOSITION

· Financial Services will adjust the 2010 and 10-year capital forecast to include the short-term ORAP projects as identified herein.

· Infrastructure Services Department will lead completion of Projects 1-8.

· Infrastructure Policy Unit will lead completion of Projects 9-11.

· Community Sustainability Department will lead completion of Project 13.

· Environmental Services Department will lead completion of Projects 12, and 14-17; will carry out development of the long-term Ottawa River Action Plan; and will report back to PEC on the status of all the above in one year.

DOCUMENT 6 – Evaluation Results for Options A, B, and C

Criterion / Option		A	B	C
Criterion / Option		Achieving Provincial CSO Control Targets	Meeting CSO Control Targets… and More	Virtual Elimination of CSOs
Environmental Criteria
E1	Does the option mitigate the impact of pollutants on the Ottawa River?	M	M	L
E2	Does the option distribute environmental benefits equitably or address broader watershed issues?	M	M	L
E3	Does the option impact the quantity and quality of greenspace?	M	M	M
Social Criteria
S1	Does the option enhance sewer system resiliency, or reduce risk of regulatory non-compliance?	M	H	L
S2	Does the option reduce the risk of localized flooding of private property?	M	M	M
S3	Does the option reduce the average frequency of beach closures?	H	H	L
S4	Does the option pose a risk of permanent loss of heritage values or features?	M	M	M
Financial / Economic Criteria
F1	Does the option facilitate urban intensification or growth?	M	M	M
F2	Does the option yield or prevent achievement of other infrastructure benefits?	H	M	L
F3	What are the estimated capital costs of the project?	$40-60M	$95-140M	$1.3-2.2 B

DOCUMENT 7 - Review of Hybrid Solutions and Other Ideas Offered by the Public

Hybrid Solutions

During consultations the public asked whether the City could develop hybrid solutions, specifically:

a) Implement A and moving towards B over time; or

b) Implement A or B and moving towards C over time.

Hybrid 1 - Combination of A and B

Under this scenario, storage would be added either in the form of a tunnel or tanks, and the City would monitor the effectiveness of the system in achieving the MOE Guideline F-5-5 target, and to assess impacts on the environment.

Phase 1 - Storage would be designed to achieve the level of CSO control specified under Option A. Depending upon the outcome of subsequent monitoring, additional storage capacity would be added during Phase 2 (via an extension to the tunnel or more tanks) to elevate CSO control to that specified under Option B.

Staff Comments

This approach is feasible and cost effective.

Hybrid 2 - Combination of A and C

Under this scenario, the UCSA would undergo partial separation, i.e., a second pipe would be installed to collect storm run-off from roads only. Individual properties would not be connected to the new pipe. The new storm sewers would collect and direct wet weather flow to the Interceptor via regulators until the capacity of the interceptor was reached. At this point all remaining flows would be discharged to the river, but would flow through a centrifuge wherever possible to removed suspended solids. This option would also require construction of several new stormwater outfalls to the river.

The number and size of new storage tanks would provide for the level of CSO Control specified for Option A.

Staff Comments

Opportunities to separate sewers in the combined sewer area using existing outlets, or via the construction of new outlets have been largely exhausted. The remaining 187 ha planned for sewer separation represent the last reasonable opportunities for sewer separation in the City.

While anything can be engineered, the creation of a stormwater collection system in the UCSA is impractical, with or without storage, with or without treatment, and with or with connection to individual homes and businesses. Notwithstanding, the above, there is nothing in Option A or B that prevents subsequent consideration of Option C at a later date.

Hydrid 3 - Combination of B and C

Same as Hybrid 2, but with the volume of storage designed to achieve the level of CSO control specified for Option B.

Staff Comments

Same as under Hybrid 2.

Other solutions/modifications suggested during public consultations:

Public Suggestion	Staff Comments
1. Options A and B should be designed to accommodate intensification, i.e. build now to meet future needs.	Agreed. Staff will examine how to recover that portion of costs attributable to growth via the next update to the Development Charges By-law.
2. Options A and B should be designed to accommodate climate change, i.e. oversize.	In that Option B provides a higher level of service than Option A, it inherently accommodates climate change to some degree. However, the challenge is that there are no design standards for such. This is of concern to municipalities and the engineering community alike. Staff will consult with the MOE on how best to approach this issue in the short-term.
3. Source controls should be required in the partially and combined sewer area to mitigate the need to build larger storage facilities; and to reduce the volume and impact of overflows when they occur.	Agreed. Furthermore, new development in these areas should require “best practice” design for stormwater quality and quantity control.
4. Greater stormwater treatment should be included with each solution, including new technologies, to mitigate impacts of stormwater discharges.	None of the cost estimates provided for Options Q B, and C allow for the acquisition of land that would be required to also install stormwater treatment facilities. However, Projects 9, 10, and 11 provide for improvement stormwater management and pollutant removal.
5. System redundancy should be built into Options A and B to yield greatest benefits.	Agreed. Staff will investigate opportunities to build system redundancy into the design of the preferred solution.
6. Design standards should be more stringent to mitigate impacts of new development through greater on-site control (e.g. green roofs.)	Agreed. Design standards are reviewed at intervals, and the City itself has begun to implement new design approaches to test and demonstrate their effectiveness. Direction would be needed to accelerate application of new standards to the larger community.
7. Option C or combination thereof should be used to address aging infrastructure in the core.	Renewal of infrastructure in the core has and will continue to be carried out regardless of the option chosen. In areas undergoing sewer separation, the two activities (sewer separation and sewer replacement) are harmonized wherever possible.
8. Hydroelectric opportunities should be examined during design of the preferred solution.	Preliminary calculations indicate that this option is not cost effective due to the relatively significant cost required to harness a relatively small amount of energy from infrequent wet weather flows that contain particulate matter.

Document 8 - Summary of Questionnaire Methodology and Findings

(Prepared by Grant Consulting, January 2010)

Introduction

The City of Ottawa is working on several projects that will improve sewer infrastructure in Ottawa with several more in the planning stages. Collectively these projects are known as the Ottawa River Action Plan (ORAP) and they represent a significant investment on behalf of taxpayers.

In order to ensure that they are meeting the needs of residents, staff from the City undertook a public consultation exercise designed reach out to citizens and secure their thoughts on a series of proposed short and long term objectives. From November 23 to December 1, 2010, the City of Ottawa held four open houses in Ottawa to present the objectives of the ORAP to the public. During the open house sessions the public had an opportunity to review 52 panels, listen to four presentations and ask questions of all presenters. This effort was supported with a communications plan to raise awareness and encourage participation; the production of supporting print materials to explain issues; and the development of a City web site http://www.ottawa.ca/residents/waterwaste/river_action/index_en.html .

To capture feedback from residents on the ORAP, an feedback tool was developed. It was linked to the City web site and paper copies of the feedback form were made available at the open houses. This report is a summary of the results collected using the feedback tool.

Design of the Feedback Tool

The online feedback tool was developed to meet two key objectives.

Ÿ Provide open house participants with a way of providing comments to the City in a clear and manageable way.

Ÿ Provide visitors to the City web site and members of the public who were unable to come to the open house events with a way to review the material and provide comments to the City in a clear and manageable way.

To build a tool to meet these objectives the project team used Survey Monkey as the electronic platform for data collection. Using this tool the project team was able to develop a flexible tool that allowed residents to submit feedback electronically. In addition staff were able to use the tool to manually input comments collected in paper formats at the open houses.

In the design of the feedback tool, the project team chose to present residents with a series of questions to answer, using different question formats to collect data. This included use of the following questions:

Ÿ In order of priority, with 1 being the top priority, please rank the reasons why you think the Ottawa River is important.

Ÿ In order of priority, with 1 being the top priority, please rank how you think ORAP funds should be allocated from 1 to 12.

Ÿ We are interested in what you think about the Ottawa River Action Plan and its 16 projects. For each statement please indicate the extent to which you agree or disagree with it.

Ÿ Which combined sewer overflow (CSO) option do you favour?

Ÿ Why do you favour the option that you selected above?

Ÿ In your review of the Evaluation Results for CSO options, please consider the Environmental Criteria and indicate the degree to which you agree or disagree with them.

Ÿ In your review of the Evaluation Results for CSO options, please consider the Social Criteria and indicate the degree to which you agree or disagree with them.

Ÿ In your review of the Evaluation Results for CSO options, please consider the Financial/ Economic Criteria and indicate the degree to which you agree or disagree with them.

Ÿ Do you have any other comments?

The feedback tool was set up to allow one response per computer to reduce the likelihood that a resident would submit a response more than once. Respondents were not forced to answer any questions but some of the questions did force ranking of two or more options. Where respondents completed the survey using paper and did not follow the instructions, staff were instructed to input the data that was presented clearly.

Respondents were residents who became aware of the public consultation initiative as a result of the communications campaign and who chose to take the time to respond.

In the design and roll out of the feedback tool there was some confusion with regard to the use of the word survey, some of which resulted from the use of the Survey Monkey tool. The feedback tool was erroneously referred to as a survey when in fact it was not a survey, nor was it intended to be a survey. It was designed to obtain comments and feedback from participants in the consultation process in an organized and easy to manage electronic format.

Findings

Over the period from November 23 to December 15, 2009, a total of 309 people submitted feedback on the ORAP using the feedback tool in either electronic or paper format. This is more than double the total number of people who attended the open houses. Respondents were not screened on any demographic points other than language, with 306 people choosing to respond in English and 3 choosing to respond in French.

Priorities for the Ottawa River

In the feedback tool, respondents were able to indicate why they felt that the Ottawa is important. They were able to select from a list of statements and to include their own comments.

Ÿ Over 65% of respondents indicated that the number one reason why they felt that the river is important is because it is a valuable natural resource.

Ÿ In the analysis of the 110 people who provided written feedback on this question, the top two responses were concerns related to drinking water (26%) and concerns related to the protection of natural habitat (25%)

Priorities for Distribution of ORAP Funds

In the feedback tool, respondents ask to rank 12 ORAP projects based on how they felt that the funds should be allocated.

Ÿ Reducing combined sewer overflow discharges was selected as the number 1 funding priority by 49 % of respondents.

Ÿ Preventing pollutants from entering stormwater was the most common number 2 funding priority selected by 29% of respondents.

Ÿ Treating stormwater was the most common number 3 funding priority selected by 27% of respondents.

Ÿ Overall 61 people provided feedback on this question, with 15 citing another issue as a top priority.

Opinions on the Ottawa River Action Plan and Projects

In the feedback tool, respondents were asked to consider the ORAP and its 16 projects. For those who attended an open house they were able to review the information panels and to listen to the presenters. For all others they had to rely on the information provided on the City web site.

Ÿ 58% strongly agreed or agreed with the statement that the list of projects is appropriate.

Ÿ 42% strongly agreed or agreed with the statement that the level of financial investment is appropriate.

Ÿ 80% strongly agreed or agreed with the statement that more should be done to protect the Ottawa River in the short-term (within 5 years).

Ÿ 82% strongly disagree or disagree with the statement that too much is being invested in the Ottawa River.

Ÿ 18% of respondents also included a written comment.

Favoured CSO Solution

In the feedback tool, respondents were asked to indicate which of the three proposed combined sewer overflow (CSO) options they favoured and why. Option B was overwhelmingly favoured with 76% of respondents selecting it. 11% of respondents favoured Option A and 13% favoured Option C.

In our review of the feedback, the project team looked at the responses by option favoured. Respondents were able to select more than one reason for favouring an option and were able to include their own reason in the comment box.

Ÿ In our review of respondents who favoured Option B, 78% indicated that it is a good environmental solution and 51% felt that it provides good value for money.

Ÿ In our review of respondents who favoured Option A, 43% indicated that it is a good environmental solution, 43% felt that it was the best use of taxpayer's dollars and 47% felt that it provides good value for money.

Ÿ In our review of respondents who favoured Option B, 57% indicated that it is a good environmental solution while 73% provided their own reason in the comment box with most of those comments reflecting the belief that Option C is the best long term solution.

Comments on the Environmental Assessment of CSO Options

Staff from the City of Ottawa completed an environmental assessment of the three options for CSOs and presented the results at the open houses and online. Respondents were asked to consider the environmental, social and financial/economic criteria separately.

Overall very few respondents disagreed with the results of the assessment.

Ÿ 54% of respondents generally agreed with the environmental results, 35% had no opinion and 11% disagreed with the results.

Ÿ 53% of respondents generally agreed with the social results, 40% had no opinion and 8% disagreed with the results.

Ÿ 50% of respondents generally agreed with the financial/economic results, 40% had no opinion and 10% disagreed with the results.

Overall Comments

In the feedback tool, respondents provided with an opportunity to provide comments after answering the feedback questions. In total 115 responses were provided.

Ÿ 40% (46 responses total) were generally supportive and/or urged the City to move forward.

Ÿ 13% (15 responses total) were critical of the solutions and/or the public consultation process.

Ÿ 12% (14 responses total) of respondents misunderstood a critical idea or concept presented in the open houses and the web site.

Ÿ Several other opinions were offered falling into categories where there were fewer than 10 common responses in total.

Detailed Results

The detailed results have been sorted by question and presented to the City for further assessment and review. In addition, all comments and suggestions that highlighted an alternative approach to one or more of the 16 projects were pulled together into a single document entitled Analysis of Alternatives Presented in Feedback Responses.

THE OTTAWA RIVER ACTION PLAN

PLAN D’ACTION DE LA RIVIÈRE DES OUTAOUAIS

ACS2010-ICS-ESD-0007 CITY WIDE/ À L’ECHELLE DE LA VILLE

Dixon Weir, General Manager of Environmental Services; Felice Petti, Manager of Strategic and Environmental Services; and Sally McIntyre, Program Manager of Environmental Programs, were present to provide an overview of the Ottawa River Action Plan (ORAP.) Staff spoke to a PowerPoint presentation that was circulated and is held on file with the City Clerk.

By way of background, Mr. Weir provided the following details on the City’s approach to water and wastewater management:

· The City of Ottawa has its own municipal water cycle to treat approximately 300 million litres of drinking water daily and distribute it through 2800 kilometres of water distribution system including treatment facilities, pumping stations and storage facilities.

· Taken together, this water cycle has an estimated replacement of approximately $17 billion and a currently depreciated value of $10 billion. The City spends approximately $95 million on these services and will invest over $190 million in capital improvements in 2010.

· Drinking water and wastewater services were originally rooted in protecting public health, with the focus on ensuring potable water was distributed, and that sanitary and storm sewage was collected.

· In the 1960s and 70s these services were adjusted such that environmental protection was added to that responsibility. Today, the services are geared to ensure protection of both the public’s health and the environment.

· The City is shifting to a watershed-based approach to measure the performance of major facilities and their impact on the environment, using new tools and measuring systems. This provides a more comprehensive, integrative, effective, and sustainable approach.

Mr. Weir then provided an overview of ORAP, which is comprised of 17 different projects that fall under three different categories: improving existing systems and control; improving Combined Sewer Overflow (CSO) Control; and planning for the future. Details and costing was provided as part of the presentation.

Ms. McIntyre reviewed the projects related to implementation of Real Time Control and development of CSO Storage for the Ultimate Combined Sewer Area, and the rationale behind staff’s recommendations on same. She highlighted the following points:

· By the end of 2010 full implementation of real-time control would reduce combined sewer overflows we estimate by 60 per cent by volume.

· Three options (A, B and C) were considered during the consultation process for addressing the surplus outflow that will remain after implementation of Real Time Control.

· Option A would build sufficient storage to enable the City to meet regulatory requirements as they stand today.

· Option B would build roughly three times the amount of storage to exceed what the provincial requirements, and thus enable the City on an average basis in an average year to achieve zero overflows.

· Option C is full sewer separation in the ultimate combined sewer area.

· As outlined in the presentation, Ms. McIntyre reviewed the pros and cons of each of the three options in terms of their impacts on volumes of outflow, frequency of overflows, impact on downstream resources, and relative cost.

· After consideration of the relative benefits and costs of each option, staff are recommending Option B.

· Results of the public consultation support staff’s recommendation.

By means of an animated illustration, Ms. McIntyre demonstrated for Committee the impact of real-time control on e-coli levels in the Ottawa River after a significant rain event, in comparison to what exists today. She also demonstrated the impacts of options A, B and C on these levels, with B being the option recommended to Committee, highlighting how it affects various downstream resources. She noted how the incremental benefit in terms of actual impact of E coli on the River is not that significant between options B and C, yet there is a large cost differential between those options.

It was acknowledged that, under all options, there were areas where e-coli would remain well after a rain event, including around Petrie Island. These E coli issues arise from surface water discharges, even when all CSOs have been eliminated. It was emphasized that, while ORAP’s first priority is addressing CSOs, it recognizes the work to be done on this other problem, and many of the projects in the plan address it.

In response to questions from Councillor Monette, Mr. Weir provided the following information:

· While the top five ORAP projects do address the CSO issue, the others are still necessary in order to deal with other issues, such as the remaining E-coli impact on Petrie Island as a result of storm water. Another example is the R.O. Pickard Environmental Centre effluent disinfection, which is a regulatory requirement.

· The is an integrative plan that staff feel rests very much on the contribution of all the elements.

· With regards to the possibility of more economical “hybrid” solutions than what is proposed, Mr. Weir emphasized that staff reviewed the options and feel that the ORAP as presented provides the best value for money, the best improvement and protection of the environment, and represents the appropriate spending.

· With regards to whether the Province had offered the City additional money to achieve their goal that is in excess of the provincial standards, Mr. Weir confirmed that they had not.

· In terms of the proposed education campaign, Mr. Weir explained that, while the details had not yet been worked out, the campaign would focus on increasing the public’s understanding and appreciation of their impact on the water environment and how best to protect that environment. It would be wide-ranging and staff feel it would offer very significant advantage.

· With respect to the pollution being generated from the Gatineau side of the river, Mr. Weir acknowledged that Gatineau is a contributor. He emphasized that this plan is about bringing about changes to areas the City of Ottawa can control.

· Staff has met several times with Ville de Gatineau, who have been helpful in contributing information. While that City is not at the same stage as Ottawa, continued communication and participation would be a useful tool.

Councillor Monette wondered how the inter-provincial process could be expedited, as pollution is coming from both sides of the river. He proposed the City needs to be proactive, not only in their own actions, but also in getting the provincial and the federal governments to the table to recognize that both sides of the river need to do something and they need to do it in a coordinated way.

Mr. Weir noted that, in addition to the dialogue through the NCC and the Ville de Gatineau, Ottawa is also having discussions with the provinces. He suggested these discussions are important when looking at the Ottawa River from a watershed perspective. He surmised that this was the extent of the influence the City has at this point.

Councillor Hunter noted that, with all the options (A, B or C) a significant portion of the e-coli problem at Petrie Island would remain untreated. He suggested that, if the problem is at Petrie Island, the plan should start with addressing that problem first. Mr. Weir and Mr. Petti reiterated that this issue was unrelated to CSOs; rather it is the result of storm water discharge. While staff feel CSOs are the priority, it is acknowledged that storm water is also a problem, and there are activities as part of ORAP to address that issue as well.

An example of such an activity is the pilot program underway on the Pinecrest Creek watershed, where the experiences will be applied to the eastern watersheds that have a more direct impact on Petrie Island. The City needs to deal with CSO control and source management, not just with storm water management.

Councillor Hunter noted that CSOs had been an issue for many years, with the City and former municipalities undertaking various initiatives and studies to address it. In particular, he referenced a study undertaken by the former Regional Municipality of Ottawa Carleton on what was known as the “Somerset Street Tunnel,” and inquired why those plans were not being used instead of spending more money restudying it.

Mr. Weir agreed that the Somerset tunnel was very similar to Option B of this plan. At the time it was not pursued as Real Time Control was considered to be adequate to reduce the volume and the frequency of CSOs. Since then, the regulatory environment has changed and there are now recreational resources downstream resulting in a public health issue. Real Time Control is no longer sufficient to meet the current regulations established by the Ministry of the Environment, so the concept of storage is being reintroduced. With regards to why the plans could not be taken off the shelf and used, there are several reasons. Firstly, the volume of storage is not the same as originally conceived with the Somerset tunnel, due to the implementation of Real Time Control and the fact that the technology available now was not available at that time. Also, the conceptual designs for that project were not yet at a point where they are implementable. Councillor Hunter wondered how much money the region and the City of Ottawa spent to get these designs that were not implementable.

Councillor Hunter expressed his concerns with the way Public Health conducts its beach water testing. He noted that in many cases over the previous summer, beaches were closed even when the E-coli level was under 100 parts per 100 ml of water. Conversely, there were several cases where the beaches were open even when the levels exceeded that threshold. He attributed this to the fact that the testing is delayed by a day. He strongly recommended that Public Health implement real-time, on-site water testing.

In response to questions from Councillor Feltmate, Mr. Weir provided the following information:

· The Environmental Commissioner came to Ottawa in early September and was quite supportive of the plan proposed by staff

· Where the commissioner had criticism was that the City hadn’t adequately communicated with and engaged the public. Staff took that feedback to heart in developing the public information and communication program for ORAP.

· The public has also commented that on an ongoing basis there needs to be greater public outreach and communication to increase the awareness and appreciation of people’s impacts on the environment.

· It is staff’s understanding through the public consultations that the public is engaged in the issue and very supportive of the ORAP as proposed.

· In terms of bringing together the various municipalities impacting the Ottawa River watershed, along with the federal and provincial governments, it was suggested the responsibility really rests with the Ministry of the Environment, and the City is trying to promote that to the extent it can.

· The City has asked the Minister of the Environment to convene the parties, and the Minister has agreed to do that. While he has not yet given a timeframe, it is likely to be in the near term.

· There is also an existing protocol between the province of Quebec and Ontario for cooperation specific to environmental issues. To date the only element that has been implemented pertains to the air sector, and the City has been suggesting it would be appropriate to do the same for the water environment.

Councillor Holmes noted she had obtained from the archives the former study related to the Somerset tunnel storage tank, noting it was first considered 1992 in a report to the former Region and City of Ottawa. She noted there was a significant amount of work done, and inquired whether any of that work could be applicable to today’s situation. Mr. Weir suggested it may have some application; however, staff is not yet at the stage of exploring the detailed engineering design. They are currently trying to determine what level of service would be appropriate, which will feed into the environmental assessment process. At the appropriate time staff will look back at those plans to see what information may be of use, and where they are useful staff will take advantage of them. He confirmed that they do not yet know what capacity will be needed for the storage tank. “Option B” is identifying 30-60 thousand cubic metres of storage as the range, but this will be refined as part of the ongoing environmental assessment process.

Councillor Holmes emphasized that there needed to be a commitment to the storage tank, and hoped it would be bigger than required for today’s needs, so that the City would not have to go back a few years later to enlarge it as the City grows. She indicated her support for the action plan, and hoped it would proceed, using whatever information is useful from the former study

Councillor Doucet noted he had mixed feelings about building an underground storage tank. He suggested the City’s storm water overflow problem was due to the rapid drainage caused by the abundance of asphalt and concrete. He proposed that the solution could be to begin breaking up the asphalt so that the water can run into the land and be stored there for free, rather than construct a holding tank.

He suggested the plan should include removing asphalt driveways and encouraging interlock or gravel. Whereas the city now does not permit gravel driveway, perhaps there should be a penalty for an asphalt driveway/and or an incentive for an interlock or gravel one. He wondered why nothing was being done on this front.

Chair Hume noted that the plan did include pilot programs looking at alternative surface treatments to allow drainage into the ground. Mr. Weir pointed to the Westboro/Pinecrest creek pilot project, which looks at more passive ways to deal with storm water and come up with some other means of dealing with storm water rather than bringing it into a collector like Pinecrest Creek. This is being done as a pilot program embedded in ORAP, with the lessons learned to be applied to the Eastern sub-watersheds.

Councillor Doucet noted that when it came time for a final vote on money towards the plan, he would not be supporting it, as it does not contain a comprehensive passive water retention system. Rather, he saw it as another way of subsidizing asphalt. While he was willing to take the step forward to do what is needed now, ultimately he could not support it without the other system in place.

At the end of Committee’s discussion, Ms. McIntyre made the following concluding points:

· Only the first five ORAP projects pertain to CSOs. Everything else has to do, in one way or another, with source control.

· The Wet Weather Management Flow program and the Pinecrest-Westboro Stormwater Retrofit program address some of the points raised by Councillor Doucet.

· With respect to the work previously done on the tunnel, she noted that by implementing real time control, staff saved the municipality millions of dollars by intervening at a time when the City could meet the regulatory requirements through that means alone. Those regulatory requirements have changed.

· She suggested it would not be as simple as reopening the old plans and implementing the storage tank. The new tank being proposed would be cheaper and smaller.

· She concluded by emphasizing that ORAP is an excellent plan that the City should be proud of.

At the suggestion of the Chair, Councillor Feltmate moved the following direction to staff:

DIRECTION TO STAFF:

That the Chair of Planning and Environment Committee and the General Manager of Environmental Services convey the Ottawa River Action Plan to the Environmental Commissioner once approved by Council

Committee then approved the report recommendations as presented.

That Planning and Environment Committee recommend Council:

1. Approve the Ottawa River Action Plan (ORAP) as described herein, valued at $251.64 million.

2. Approve a service level for combined sewer overflows (CSO) of zero overflows during the swimming season in the “average year.”

3. Receive for information the scope and timeline for development of a long-term Water Environment Strategy as described herein.

CARRIED

[1]The Ontario Ministry of the Environment has accepted 1980 as having “average year” wet weather patterns for engineering design purposes. Overflows will continue to occur in years with more severe wet weather than what occurred in 1980. For example, in recent years, a system designed to the proposed service level would have experienced on average one (1) overflow per year. The existing system averages over thirty (30) overflows/year.

[2]The Ontario Ministry of the Environment has accepted 1980 as having “average year” wet weather patterns for engineering design purposes. Overflows will continue to occur in years with more severe wet weather than what occurred in 1980. For example, in recent years, a system designed to the proposed service level would have experienced on average one (1) overflow per year. The existing system averages over thirty (30) overflows/year.

[3] Formerly referred to as the Ottawa River Integrated Protection Plan.

[4] This does not include the cost of the sewer separation program, which sees significant annual variations in expenditures.

[5] Anciennement appelé Plan de protection intégrée de la rivière des Outaouais

[6] Les coûts du programme de séparation des égouts, dont les dépenses varient considérablement chaque année, ne sont pas compris.

[7] Source Water Quality in Ottawa’s Rivers & Streams, WEPP, May 2006.

[8] “Good” as defined by the methodology established by the Canadian Council of Ministers of the Environment.

[9] On a percentage of gross flow, as well as on a volumetric basis, Ottawa’s CSOs will be less than Washington DC, Oslo, London, Paris, and Rome to name a few.

[10] The efficacy of centrifuges located at stormwater outlets under Option C would be significantly less than that of the Robert O. Pickard Environmental Centre; and is inversely related to the severity of the storm, i.e. the more severe the storm, the less effective it is at pollutant removal.

[11] This does not include the cost of the sewer separation program, which sees significant annual variations in expenditures.

Document 5 - ORAP Cost Estimates & Project Schedule/Status
ID No.	Project	*5-year Budget ($Million)**	Schedule/Status
1	Implementation of Real Time Control (RTC)	$30.0	Over 90% complete. To be completed 2010.
2	Critical CSO and Storm Outfall Monitoring	$5.0	Feasibility assessment has commenced. New monitoring stations to be installed by 2012-2013.
3	CSO Storage for Ultimate Combined Sewer Area (UCSA)	$140.0	EA has commenced. To be commissioned 2013-2015 depending upon design solution.
4	Review & Implement Sewer Interconnection Program	$4.0	Commenced. To be completed 2013.
5	Sewer Separation Outside the UCSA	$47.0	On-going initiative that will continue until program is complete (estimated 20-25 years).
6	Development of a Wet Weather infrastructure Management Plan	$0.14	Commenced. To be completed 2010.
7	Implementation of a Wet Weather Infrastructure Management Plan	$7.325	To commence 2011 and take several years to complete at an estimated cost of $2M/year.
8	Installation of Floatable Traps in Combined Sewer Area Catch Basins	$3.55	Over 30% complete. To be completed 2011.
9	Pinecrest Creek / Westboro Stormwater Management Retrofit Plan	$0.25	Commenced. To be completed 2010.
10	Eastern Subwatersheds Stormwater Management Retrofit Plan	$0.75	To be carried out 2011-2012.
11	Implementation of Stormwater Retrofit Plans	$4.0	To commence 2012 and take several years to complete. Long-term costs commencing 2014 are estimated at $9M/year.
12	R.O.Pickard Environmental Centre Effluent Dechlorination	$7.44	To be carried out in 2010.
13	Develop & Implement a Water Environment Strategy	$1.0	Strategy to be developed 2010-2011.
14	Monitoring and Source Control Programs	$0.26	On-going initiative that will continue over the life of ORAP.

1 February 2010 / le 1 février 2010

Contact Person / Personne ressource: Dixon Weir, General Manager /

Directeur général Environmental Services / Services environnementaux

613-580-2424, x22002, Dixon.Weir@ottawa.ca

REPORT RECOMMENDATIONS

RECOMMANDATIONS DU RAPPORT

EXECUTIVE SUMMARY

Consultation

Financial Implications

RÉSUMÉ

Consultation

Lower Rideau Watershed Strategy

CONSULTATION

FINANCIAL IMPLICATIONS

SUPPORTING DOCUMENTATION

DISPOSITION

Document 1 - Ottawa River Water Quality in the Ottawa Reach (Arnprior to Cumberland)

Document 2 - Total Phosphorous Levels, 10-year average

Document 3 - Copper Levels, 10-year average

Document 4 - E coli Levels, 10-year average

Document 5 - ORAP Cost Estimates & Project Schedule/Status

Hybrid 1 - Combination of A and B

Staff Comments

Hybrid 2 - Combination of A and C

Staff Comments

Hydrid 3 - Combination of B and C

Staff Comments

Introduction

Design of the Feedback Tool

Findings

Priorities for Distribution of ORAP Funds

Opinions on the Ottawa River Action Plan and Projects

Favoured CSO Solution

Comments on the Environmental Assessment of CSO Options

Overall Comments

Detailed Results

15	Wastewater & Drainage Environmental Quality Management System	$0.15	To be developed in 2010.
16	Updates to the Ottawa R. Bacterial Water Quality Computer Model	$0.40	To be carried out in 2010.
17	Public Outreach and Education (NEW)	$0.375	To be carried out over the period 2010-2013.
	TOTAL	$251.64