From: Paul Renaud Sent: August-08-10 8:04 PM To: 'Bourgon, Guy'; 'Wilkinson, Marianne' Cc: 'Herweyer, Don'; 'Marc, Timothy C'; 'Rygus, Kathy'; 'Conway, Darlene'; 'Steve3 Hulaj'; 'Lalonde, Alain'; 'Cullen, Alex'; 'Doucet, Clive'; 'Matt Muirhead'; 'Gordon Henderson' Subject: SWM Issues Documented Regarding Kizell Wetland & Beaver Pond Attachments: SWM Draft 20100808 Exec Summary.pdf; Zoning Map-4.jpg Further to my earlier email, we have documented very serious issues regarding storm water management in and around Kizell Wetland and Beaver Pond. A draft copy of our full report (over 10 MB in size) may be downloaded from: http://www.renaud.ca/public/Water_Related/Kizell-Wetland-Issues/ Attached is the executive summary for the report. There is no reason to believe, and substantial evidence to the contrary, that Beaver Pond has the capacity to handle existing developments – let alone having enough cumulative capacity for Phase 6. The flooding event of this spring and the flooding event of July 24, 2009 present serious questions regarding the regulatory flood capacity of Beaver Pond. Has the city even compared regulatory flood levels to the measured level of flooding that already occurs? Incredibly there is no evidence that the existing SWM facilities for KNL’s development on the south side of Kizell Wetland were done subject to an EA even though these facilities dump storm water into natural protected wetlands. The existing CoA for these facilities should be revoked. * There is no published master servicing / environmental management plan for KNL’s development yet the City has permitted development to proceed piece meal to-date and, based on your prior correspondence, appears ready to continue to allow this situation to continue. * How does this comply with the MoE’s Stormwater Management & Planning Manual (2003: http://www.ene.gov.on.ca/envision/gp/4329e_2.htm) which pre-dates KNL’s subdivision approval? How is it possible that the same natural protected wetlands can be designated Urban Natural Feature and zoned as Environmentally Protected (see attached) – and simultaneously used as a dumping area for untreated storm water without even the benefit of functional energy dissipaters? Yet this is already the situation in both Beaver Pond and Kizell Wetland. * Isn’t this in contravention of the Ontario Water Resources Act which states that “Any abnormal discharge of a contaminant into the natural environment is considered a spill.” or has the City conducted studies to confirm that storm water from this subdivision is free of contaminants? * It should be noted that the applicable Subwatershed Study documented the presence of a Species-at-Risk, Bridle Shiner, in Kizell Wetland. Other studies document the presences of other species at risk in and around Kizell Wetland – including other aquatic species such as Blanding’s Turtle and Snapping Turtle. Is the DFO aware that untreated storm water may be damaging fish habitat? It is evident from these and the other issues documented in our report, that the piece meal approach to SWM planning & approvals in the SMH is a spectacular failure that has created a non-sustainable situation. It is evident that further development in the area is infeasible and will remain infeasible until the existing issues are remediated subject to holistic planning and sound environmental management practices. Paul Renaud