City's introductory statement
According to the City's Official Plan, future development will significantly increase the imperviousness of the subwatershed. The additional runoff volume generated by the increased imperviousness can result in potential impacts on the creek, including flooding, erosion and degraded water quality. In order to ensure that impacts on the creek are mitigated, the existing SWM criteria for Feedmill Creek needs to be revisited. Where SWM alone may be insufficient, recommended stream rehabilitation works are to be identified
This study will confirm stormwater management requirements for the remaining development within the subwatershed and identify retrofit opportunities for existing development. The study's objective is to ensure the impacts of new development on Feedmill Creek are mitigated.
This Municipal Class Environmental Assessment (Class EA) goal is to confirm quantity control criteria for the remaining future development in the Feedmill Creek subwatershed. As part of the results, an optimal combination of stormwater management criteria was developed in order to mitigate the impacts of future development on stream function, peak flows and water level including erosion control and flood control.
Comment:
Rehabilitation measures focus on water capacity concerns with no apparent reference to environmental protection or enhancement. The report (pg 4) describes the creek's general environment as:
Blanding’s turtles have been observed by City staff, residents and Provincial biologists at several locations along Poole Creek and within Stittsville;
Headwater wetlands contribute to creek baseflow;
The creek supports a tolerant cold water fish community and a diverse warm water fishery;
Temperatures remain in the range suitable for cold water species and are generally 3-5C lower than Carp River
Narrow and fragmented deciduous forest riparian borders provide some watercourse buffering and limited corridor and wildlife functions.
Yet, aside from Reach 2 where there's mention of re-planting a riparian woodlot, there's no indication of protecting or improving the creek's ecosystem - it's all about water capacity which has always been the focal point of the Carp River restoration plan (CRRP).
However, a “Decision” was posted on the EBRR on Nov. 22nd regarding “Minto Communities, Permit for activities with conditions to achieve overall benefit to the species - ESA clause 17(2)(c)” from the OMNRF in regard to Blandings Turtles and their habitat in relation to Minto’s new subdivision to be built on the north side of Hazeldean Road in Stittsville. A permit has been issued.
The permit requires Minto Communities Inc. to undertake a number of measures to minimize adverse effects to Blanding’s Turtle, including:
Retaining a qualified professional to assist with implementing conditions of the permit;
Avoiding tree clearing and vegetation removal that may impact the species during sensitive times of year (e.g. nesting);
Implementing erosion and sediment control measures on site so that impacts to aquatic habitat is minimized;
Minimizing the amount of habitat damage and destruction;
Fencing and marking any habitat to be retained during and after construction to reduce the likelihood of impacting habitat and harming individual Blanding’s Turtles;
Installing temporary and permanent exclusion fencing to completely exclude Blanding’s Turtles and prevent future access to the development area, the existing subdivision and roads west of the site. This activity will reduce mortality and harm to individual Blanding’s Turtles during construction and future development; and
Undertaking awareness training for employees so that they are aware of the species presence and habitat to be retained, as well as what actions to take if a Blanding’s Turtle is encountered.
The permit requires Minto Communities Inc. to undertake a number of actions to achieve an overall benefit to Blanding’s Turtle within a reasonable time, including:
Installing fencing around the habitat to be retained along Feedmill Creek in order to prevent members of the species from entering nearby roadways and developed areas;
Retaining a 4.53 ha area of high quality and safe habitat for the species;
Enhancing a total of 0.18 ha of Blanding’s Turtle habitat through plantings and creation of key habitat features (e.g. nesting basking habitat);
Installing wildlife crossing signage along roadway of neighbouring existing development to reduce road mortality;
Installing Blanding’s Turtle educational signage at park locations; and
Monitoring and maintaining the enhanced habitat and signage for 5 years.>
Proposed stream rehabilitation works
The Feedmill Rehab. project is defined as seeking approval for detention, retention and stream work (cleaning/removing culverts, strengthening /broadening banks, channel modification, riparian shoreline vegetation etc).
Feedmill Creek's 8 reaches
Reach 1
Reach 2
Reach 3
Reach 4
Reach 5
Reach 6
Reaches 7 and 8
- no rehab. required
Map of the existing and proposed SWM ponds
Comment
Detention work is defined on page 5 as involving SWM ponds yet the presence of 6 existing and 2 proposed ponds in the subwatershed are not referred to, nor is there any indication of constructing new ones. So what was the purpose of referring to this type of stormwater management? Ideally a reference to these pond approvals (buried deep in the bowels of the CRRP archives) would have provided more understanding for the current EA approval request.
The only retention work will be done in Reach 2 with the replanting of the riparian woodland area although there's no mention on what's being planted, how many or the guarantee.
Stream work - there's no indication how aquatic life will be protected during the reshaping of the channel and all the other in-stream work. Will the erosion and sediment control requirements applied to Poole Creek and the river floodplain be applied to Feedmill and is there any assurance of enforcement?
Point source remediation as a form of stormwater management is not mentioned as an alternative even though Phase 1 of the Tanger Mall displays surface water management and riparian buffering which is being recognized as a model for low impact development, including the use of permeable pavement. This should be public knowledge to provide more informed EA feedback and for future understanding of the wetland dynamics.