For the record: On Sep 22, 2020 Council passed progressive by-law that will help protect lake water quality

Sandy Lake, but not Marsh Lake and Jack Lake receives waters from storm sewers

At a special meeting of Halifax Regional Council on Sep 22, 2020, councillors passed Item No 11.1.4 Grade Alteration By law and Halifax Stormwater Standards for Development Activities.

Said Sackville Rivers Association President Walter Regan in a letter to Mayor and Councillors:

Please vote and pass Item No 11.1.4 Grade Alteration By law and Halifax Stormwater Standards for Development Activities

This new by law will help all of HRM and the environment by keeping the silt out of our local water courses ( including the Sackville River) and water in the ground where it’s needed for ground water recharge and the slow release of clean, cool and clear water to our rivers and lakes.

It will help reduce the capital and maintenance costs of infrastructure.

If done correctly can add to the beautification of local areas, protect wetlands and save our lakes and rivers from pollution and negative impacts from construction and storm water runoff while maintaining natural water cycles.

Will help reduce the negative impacts of Climate Change and local flooding (especially in areas like Bedford and Sackville).

Here are my comments:

1) At a future date should include T.D.M.L
2) Floodplain Mapping should be carried out for ALL major watercourses in HRM, ( at least one Watershed per year)
3) No direct discharge of Stormwater to watercourses 4) HRM Staff draw, design Master Stormwater Drainage Plans for all watersheds in HRM, when new or redevelopment happens, their ( Developers Stormwater Plans ) fit into HRMs and do not change local drainage and water course flow.
5) We must do End of Pipe Storm Water Treatment.
6) We must stop local Storm water surge of local small feeder brooks and start fixing and restoring them from the negative effects of faster Stormwater runoff
7) We must start the Restoration of local damaged water courses.
8) We must have in the new regulation the ability to make Developers clean out our local watercourses from silt runoff and pollution from their sites.
9) No more “water jails” but engineered Wetlands with habitat features.
10) Daylighting of Watercourses be a priority and better intent to get our local water courses dug up and restored again. HRM HW has done an AWSOME job of Daylighting Sawmill River in Dartmouth!!
Let’s do Howe Brook in Northend Dartmouth, Wright’s Brook and others now.
11) We MUST start the Water Quality Monitoring Functional Plan for all Water courses in HRM NOW (2009 Stantect Study).
12) WE MUST HIRE MORE HRM WATER QUALITY and Environment STAFF, one Water Person IS NOT ENOUGH.
13) BUFFERS (in Public Ownership) to all watercourses and Wetlands of at least 30 meters or more – not just setbacks.

 Other comments
 – Page 5, Application – ” interference and damage to water courses or waterbodies is limited;” – I would use the word “avoided” rather than “limited” (“limited” suggests there is no way damage can be avoided – need stronger language)
 – Page 5, Application – ” apply to the development of lands over 0.5 hectares in size” – why set a minimum development size to apply to? Many small impacts from small developments can have as much impact as a single large development – Page 7, Securities and Remedy Provisions
– ” A security deposit of $2,500 per 0.5 hectare of disturbed land is currently required under the Bedford Grade Alteration and Topsoil By-laws” – the related cost of the BMP’s regarding these activities are likely much higher than the security deposit… may not be much of a deterrent, and the security deposit is  likely insufficient to remediate the impact of the violation.

 In general this is not bad, as long as improving funding for inspection/enforcement goes hand in hand with improved regulations – leaving any industry largely to the honour system can be, and often is, problematic.

On a related note, any regulation needs to be complemented with a clear plan of action when regulations are not met – it needs to be spelled out what happens when a violation occurs – i.e. what happens to the jobsite (i.e. shut down) and for how long, what steps must be taken for specific types of infractions, who determines that, and timeframes to remedy, and what are the consequences of non-compliance. Leaving the regulations to stand on their own without procedures for violations often leave room for interpretation and action on a case by case basis – all of which can result in a slap on the wrist if anything, and violations continuing/perpetuating. Potential non-compliance must be avoided with clear consequences, otherwise some may just ignore the regulations and hope that the regulators give them a break (if they get caught at all).

Please vote and pass the Grade Alteration By-law and Halifax Stormwater Standards for Development Activities

Think Globally Act Locally

Walter N. Regan
President
Sackville Rivers Association

Thx Walter Regan, Thx HRM Mayor & Regional Councillors

I sent this related but unfortunately  belated message to City Hall:

I just read Walter Regans letter of support for passing pass Item No 11.1.4 Grade Alteration By law and Halifax Stormwater Standards for Development Activities, and agree with his reasons for supporting it being passed.

Regretfully, I have not kept up with this issue, as I do have concerns about roadsalts entering  lakes in HRM via storm sewers.  I checked the 84 page document-  Appendix A Halifax Stormwater Management Standards For development activities (https://www.halifax.ca/sites/default/files/documents/city-hall/regional-council/200922rc1114.pdf) and searched it for ” salt”. The only reference is on page 21 where it is noted that ” Chloride de-icing salt is a potential contaminant that has been known to mobilize heavy metals in soils; therefore, pre-treatment prior to infiltration or avoidance of de-icing salt hot spots may be necessary where groundwater contamination is a risk.”

I would like simply to flag an increasingly serious issue in HRM, which is the gradual accumulation of salt in the deeper layers of stratified lakes over time, and which can eventually result in a lake not turning over seasonally, and in turn in “death” of the lake unless extra measures are taken to stir the water as at Oathill Lake. 

Ultimately, I believe, we need to find substitutes for roadsalts (not urea!) or introduce monitoring of storm waters for salt content and diversion of high salt water to the ocean.

I simply wanted to flag that issue at this time and in connection with Item No 11.1.4   for future consideration.

Please see these web pages for more about it:

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