January 31,2006

Mr. Rob Phillips, C.E.T.
Program Manager
Planning and Infrastructure Approval Division
Planning and Growth Management Department
City of Ottawa
110 Laurier Avenue West - 4th Floor
Ottawa ON
K1P 1J1

Dear Mr. Phillips:

RE: PROVINCIAL AGENCIES' COMMENTS TO CLASS ENVIRONMENTAL STUDIES FOR KANATA WEST LANDS
Further to your submission of December 23, 2005 staff from our three ministries have reviewed the technical documents and their consolidated comments are provided below:


Carp River, Poole Creek and Feedmill Creek Restoration Class Environmental Assessment - Final Report -
December 2005 (Totten Sims Hubicki Associates, Parish Geomorphic, Bruce Kilgour and, Ron Huizer)

Ecology
The City's Natural Environment Systems Strategy (NESS) and Urban Natural Areas Environmental Evaluation Study(UNAEES) involved little, if any, field work. The Brunton's 2000 report, however, does add to the information available for NESS Area 306 (east of Concession II) since it involved field work. The conclusion put forward in the Kanata West documentation that there are no Species at Risk (SAR) within the area of concern using the above materials and the Natural Heritage Information Centre (NHIC) website is to a certain degree unfounded since significant species, including SARs, can occur in very small, specific habitats or areas. For example, some reptiles are quite cryptic by nature and require specific search efforts and methods to provide an adequate degree of confidence to statements about presence or absence. This level of effort was approached only within the area searched by Mr.Brunton. The other areas seem to be acking any type of field work. There are several possible species given the geographic context of the study area and general site descriptions. On the basis of the limited sources of information provided, we cannot support the conclusion that there are no SAR within the Kanata West study area.

Biology
Although no pike were found spawning in the one year of field surveys, this information is not sufficient to demonstrate that pike are not a consideration. However, we note that the report has been written on the basis that there could be a pike population in the Carp River and its tributaries and the restoration work has been planned to include this species.

It is recommended that the monitoring plan specify both spring and summer electrofishimg (or seining) to ensure that both spawning and nursery habitat are investigated. This will indicate what species are successfully reproducing.

As a future consideration in the Carp River watershed, we suggest that it would be beneficial for the City to identify blockages - locations should be noted, if any exist, along the Carp River from Richardson Road to the Ottawa River where there is definitely a pike population - that are preventing pike from moving up the Carp River from the Ottawa River. Please note that this is not a specific requirement for the purposes of this EA.

Factors Affecting Temperature
MNR has expressed concerns regarding factors affecting the temperature of Feedmill Creek indicating that they needed to be addressed in more detail. While the Final Report provides water temperature data for the three water bodies, this represents present conditions and does not indicate how existing water temperatures will be maintained after forested areas are cleared and land is developed. Wooded areas identified through the City's NESS (418 & 306 headwaters to Feedmill, 328 Poole Creek corridor), although they are low to moderate "ecological" significance, are essential in maintaining cold water temperatures in Poole & Feedmill Creeks. The latter were identified as cold water creeks in the Carp River Watershed Subwatershed Study and have a relatively high degree of sensitivity thus, it is important to demonstrate that these creeks will remain as cold water following removal of forest cover in the watershed and increased runoff from the hardening of land with buildings and roads.

Water temperature on the warm water Carp River is also a concern, given this watercourse currently experiences very high temperatures (up to 25oC) during parts of the year. The restoration plan also needs to demonstrate how the recommended ponds along the Carp River will not cause water temperatures in the Carp River to increase significantly. Since the ponds are relatively shallow, with little flow and no riparian plantings of trees and shrubs proposed around them, they could heat up to high temperatures in the summer, contributing very warm waters to the Carp River which could be lethal (at about 29oC) to fish. In addition, we recommend riparian plantings be considered and added to some of the pond areas.

Willow is a species that should be added to the list of species used for riparian plantings since it provides excellent shade, cover and woody debris that will benefit invertebrates, fish and wildlife. We recognize that this is not feasible around the ponds which will be used for pike spawning, but further consideration of plantings is requested in other areas.


Kanata West Road Network Environmental Study Report - Final Draft and Appendices - December 2005 (Delcan Corporation)

Further assessment and documentation of transportation crossings of the main watercourse within the study area and their respective riparian zones is required to demonstrate that ecological functions and features have been thoroughly considered and addressed.

For example, under the Rapid Transit Assessment and evaluation of results (Section 7.1.3.3 ) there is no mention of the impacts on Feedmill Creek and its corridor even though T1 (the option selected) crosses Feedmill Creek and part of the Transit Corridor falls within the Feedmill Creek Corridor as it runs parallel to the creek. The Carp River Watershed Subwatershed Study recommends protecting Feedmill Creek and its corridor. Selecting the TI option contradicts this recommendation. While the second option T2 does not cross this sensitive cold water creek or run within its corridor it is not clear in the report why T1 was selected and not T2. If the Rapid Transit Corridor (RTC) must cross Feedmill Creek consideration should be given to co-ordinating with the existing Huntmar Drive crossing of Feedmill Creek instead of a second crossing further east.

The Road Network Environmental Study Report does not consider nor evaluate combining the Campeau Drive extension crossing over the Carp River and the RTC across the Carp River which are very close to one another. The three proposed crossings of the Carp River could be reduced to two. Similarly, we note three crossings planned over the sensitive cold water Poole Creek. There was no assessment nor evaluation to determine if such scenario could be reduced by combining the Huntmar Road extension crossing with the RTC and the North/South Arterial Road crossing over Poole Creek to result in only one crossing over Poole Creek.

It is our opinion that options minimizing the number of crossings of the Carp River, and of Poole and Feedmill Creeks and their respective riparian zones need to be explored in more detail and documented in the environmental assessment. Such analysis will serve to minimize impacts on watercourses as well as maintain infiltration and baseflow contributions during low flow conditions.

Further, we note that many of the crossings proposed are double concrete closed box culverts and recommend that alternative designs, such as open bottom box culverts or arched culverts, which are better for fish populations, should be considered and evaluated.

In regards to replacing inadequate or old crossings, such work could he undertaken at anytime, however, a thorough analysis of improving the crossings on a reach basis must ensure that the downstream property owners will not experience increased erosion rates and that appropriate remedial measures are implemented to preserve the original form and function of the watercourse.


Flow Characterization and Flood Level Analysis Carp River, Feedmill Creek and Poole Creek -Report - October 2005
Sensitivity Analysis of Width Parameter in XPSWMM Model for the Carp River - Memorandum -December 20, 2005
Appendix A - Post-Development Analysis - Report - December 2005 (CH2MHilI Canada Limited)

There remains a concern regarding the hydrologic analysis reflecting the actual conditions in the Carp River. An outstanding question that was posed in a meeting with the City and was not adequately responded to relates to the predictions of the hydrologic models for the stream flow analysis at the Kinburn stream flow gauge downstream. As stated before, the Consolidated Frequency Analysis (CFA) of the said stream flow gauge, reported in the Carp River Watershed Subwatershed Study Report, indicated that the 100-year peak flow is 139 m3/s compared with 100.4 m3/s suggested in the 1983 floodplain mapping report.

These flows need to be reconciled in some fashion with the findings of the hydrologic analysis conducted to assess the impact of new development on the hydrology of the Carp River Hydrologic modeling using simulated rainfall distributions appears to provide estimates of flow in the Carp River that are less than those measured.

An SCS 12-hour storm - representative of a rural watershed - was used in the hydrologic analysis for the existing and future development scenarios. As indicated in the QUALHYMO analysis, the time of concentration for the future urbanized development area is between 2 to 4.5 hours, which would be expected of an urban watershed. Justification is required to explain why an urban hydrologic analysis was not conducted for the proposed development area. A hydrologic sensitivity analysis using urban hydrology modeling, for urbanized catchments, would provide confirmation as to the impact of urbanization on the flows in the Carp River.

From the hydraulic analysis of the Carp River it is evident that under the future full development scenario the clearance at the Highway 417 eastbound bridge will be reduced to 0.0 m for the 100-year storm event. This result is based on the channel restoration and filling to be approved by the Mississippi Valley Conservation Authority (MVCA). This situation cannot be acceptable and both the City and the MVCA need to provide the basis for proceeding with the proposed development with such an impact being predicted.

It is unclear from the information provided if the impacts of replacing some of the water crossing structures on the Carp River have been accounted for in the hydraulic analysis (for example, Hazeldean Road will be widened and the bridge crossing the Carp River replaced). The Carp River Watershed Subwatershed Study indicated that a number of the crossings are in fact providing flow control. As such, replacing these structures with larger structures will have an impact on downstream structures, sediment transport, erosion and flooding. The impact on downstream structures has to be specifically addressed to ensure that such changes have no detrimental impacts on the safety of these structures.

The hydraulic information provided is not complete as the analysis with the proposed and complete build out of Kanata West has not been submitted. Until this analysis is completed, reviewed and approved, the proposed channelization works cannot be considered a final document.

The MNR's September 27, 2005 letter to the City identified that, in order to be approved under the Lakes and Rivers Improvement Act (LRIA), the proposed channelization works must, as a minimum, meet the following criteria: (a) the total channel storage and incremental channel storage is equal to or greater than the existing channel for all flood frequencies; (b) no increase in upstream water levels; (c) no increase in downstream erosion rates; and, (d) no decrease in travel time. We note that the proposed channelization works extends beyond the low flow channel. As depicted in the cross sections and data tables, the net result is increased flood levels. Therefore, please be advised that the proposed works do not adequately address the LRIA. The channelization works must be redesigned in order to obtain LRIA approval.

Following proper calibration of the hydrologic model and a more definitive channelization works proposal, we anticipate that the consultants will have an improved ability to provide the technical reasons supporting a stormwater management approach that will necessitate, or not, control of urban flows with a return period greater than 5-days before they reach any of the local streams. To date, in the absence of any decision from the MVCA with respect to the future Kanata West development meeting regulatory flood levels, the uncontrolled release of flows to the Carp cannot be endorsed.


Kanata West Concept Plan Master Servicing Study - Volumes 1 and 2- December 23,2005 (Stantec Consulting Limited, Cumming Cockbum Limited/IBI)

The comments provided in MNR's September 27,2005 correspondence in relation to the August 12, 2005 Master Servicing Study Report are not addressed in the December 23, 2005 revised report. Additional hydrogeological and water balance information related to infiltration and contributions to baseflow is needed in support of this environmental assessment. We request further information with respect to how the stated infiltration rates were obtained including site-specific data (as obtained from test pits or boreholes) to substantiate the values used to quantify the amount of water that is expected to infiltrate the subsurface in the short and long terms following the disturbance created by the construction. Although the Paleazoic limestones have been assigned infiltration numeric values, no discussion of the rock was provided. The values for infiltration in carbonate rock can vary greatly.

With respect to water budget, we note that the Carp River Watershed Subwatershed Study indicates a maximum of 112.28 mm/year available for infiltration under existing conditions. Supporting documentation must demonstrate that the proposed development plan can be designed to maintain or enhance the amount of infiltration to groundwater and maintain or enhance baseflow in all watercourses. In addition, please include how the proposed infiltration system will function during and after construction in conjunction with addressing the compaction of soils limiting their  infiltration capabilities.

On August 31, 2005 MOE indicated that stormwater management ponds should not be located within the Carp River floodplain. Lining of the stormwater management ponds is required to prevent interference of groundwater to the sedimentation process. In addition, the banks of ponds located in a floodplain are vulnerable to erosion and may become unstable with elevated river levels. Additional information on the construction techniques used to stabilize the pond liners, in the presence of groundwater upwelling, need to be included in the environmental assessment report. Also, methods to floodproofing the stormwater management pond banks must also be provided.

Of final note, we have reviewed Appendix H - Table 3 concerning the Huntmar Road sanitary sewer main alternatives. The preferred alternative 1 is the only option of the three alternatives which involves a crossing of the Poole Creek, yet all three alternatives have been given an evaluation rating of "3 moderate or no impact" for criteria N3 - impact on Aquatic Systems. We cannot agree that alternative 1, involving a crossing of the Poole Creek, should be ranked the same as alternatives 2 and 3 which do not include a crossing of the Poole Creek. The evaluation ranking for "impact of aquatic systems" for Alternative 1 should be reconsidered and scoring adjusted accordingly.

In accordance to what was communicated by Charles Goulet in an e-mail sent last January 23rd, all three ministries' concurrence with the technical studies are dependent upon the Mississippi Valley Conservation Authority providing its clearance on the hydrologic and hydraulic analyses of the CarpRiver and tributaries.

It is our understanding that the MOE's Environmental Assessment and Approvals Branch will be in contact with you at a later date with regards to the integration of the Class EA studies and the Planning Act requirements.

Should you have any questions, please feel free to contact any of the undersigned.

Regards,



Steve Burns
District Manager
Ottawa District
Ministry of the Environment
2430 Don Reid Drive
Ottawa ON
K1E 1H1
 Ted Lane
Head
Planning and Design
Eastern Region
Ministry of Transportation
l355 John Counter Blvd
P.O. Box 4000
Kingston ON
K7L 5A3
 Grant Ritchie
District Manager (Acting)
Kemptville District
Ministry of Natural Resources
10 Campus Drive
P.O.Box 2002
Kemptville ON
K0G 1J0