April 29th 2015 The Honourable Glen Murray Ministry of the Environment and Climate Change 77 Wellesley Street West 11th Floor, Ferguson Block Toronto, Ontario M7A 2T5 Attention: Kathleen Hedley Re: Notice of Completion – Municipal Class Environmental Assessment – Second Avenue (MR72) Infrastructure Improvements. Notice issued April 1, 2015. Requester Details: The following letter of concern is presented by the Ramsey Lake Stewardship Committee, a grassroots organization focused on improving the health and water quality of Ramsey Lake. Ramsey Lake covers 8 km2 and is a small urban lake in the centre of Greater Sudbury. It is a municipal drinking water source for over 60,000 Sudburians. Proponent Details: Reference is made to Notice of Completion issued April 1st, 2015 regarding Municipal Class Environmental Assessment 2nd Avenue (MR72) Infrastructure Improvements by the City of Greater Sudbury. Project Details: It was recommended that Second Avenue (a two lane secondary arterial) be widened to five lanes from Donna Drive to Scarlett Road, widened three lanes from Scarlett Road to Kenwood Street and the storm ditches removed. Concerns: We have a number of concerns related to this project. Project File was not completed in 2014 As noted by the MOECC Environmental Approvals Branch letter, dated Feb. 4, 2015, a project file was not completed for this roadwork in 2014. We, like the MOECC, are concerned that the project was not planned in accordance with the requirement of the Class EA. We have concerns that a Class B EA was chosen for the current assessment instead of a Class C. As well, because of this oversight construction has been delayed and 2nd Ave has been allowed to further deteriorate. No current Transportation Master Plan, piecemealing of costs Since a new Transportation Master Plan (available for initial public consultation May 2015) may speak to how the city will address the transportation of people instead of just cars, we feel it prudent for any new road designs to reflect a more broad approach to transportation and to consider more than the movement of a single passenger vehicle. Had a more up-to-date TMP been available, perhaps building sidewalks to move people on foot, bike lanes to move people on bikes, a pedestrian crossing, and adding bus bays would have not been considered ‘add-ons’ by the proponent. In 2014, they were not considered part of the initial cost of this roadwork (under $1M). (Page 10 of the Project File) Had these non-car related features been initially considered, a Class C EA would have been required due to the elevated cost of over $2.7M. This piece-mealing of costs, to avoid a Class C EA, is unacceptable to the community, as it does not allow for meaningful consultation in a cost-effective and community-minded way. “Projects must not be piece-mealed with component parts or phases being addressed separately” as stated in the Municipal Class Environmental Assessment rulebook for municipal roads, water and sewers. Without a Class C EA, citizens were not provided with other options like building a three-lane road for the entire stretch of 2nd Ave, improving stormwater ditches and using the saving in asphalt for better overall stormwater management. Induced Demand or Congestion? While looking at updating the 2005 Transportation Study, the Infrastructure Services Department identified “the need for widening Second Avenue (MR 72), due to existing and future congestion.” However, the proponent also state that “traffic volumes forecast for the year 2031 Preferred Alternative are expected to remain close to existing 2011 traffic volumes.” We would like all models of congestion to take into account “induced demand”, whereby building a bigger road encourages more people to use the road. “By exaggerating the economic benefits of road capacity increase and underestimating its negative effects, omission of induced traffic can result in over-allocation of public money on road construction and correspondingly less focus on other ways of dealing with congestion and environmental problems in urban areas.” http://vbn.aau.dk/ws/files/67056413/N_ss_Nicolaisen_Strand_2012_Traffic_Forecasts_Ignoring_Indu ced_Demand._A_Shaky_Fundament_for_Cost_Benefit_Analyses.pdf A wider road will contribute more to current sodium and phosphorus drinking water issues We are not just concerned with the process that led to the decision to widen 2nd Ave but also that the widening of 2nd Ave and the removal of storm ditches will increase the amount of impervious surface area in the Ramsey Lake watershed. This is important because 2nd Ave is in a drinking water Issue Contributing Area http://sourcewatersudbury.ca/images/uploaded_files/ARSPP2013/ARMaps2013/3.11_Ramsey_Contrib utingIssues_Aug2011_web.pdf according the Greater Sudbury Source Protection Plan, which came into effect April 1, 2015. We expected this to be mentioned in the environmental sections of the project file. Technically, there are two drinking water issues for this area. See threats in Appendix A. For both sodium and phosphorus, a threat is: The establishment, operation or maintenance of a system that collects, stores, transmits, treats or disposes of sewage, which includes stormwater. The application of road salt. http://sourcewatersudbury.ca/images/uploaded_files/ApprovedSPP_Sept2014/Greater_Sudbury_Sourc e_Protection_Area_Approved_SPP_Sept_19.pdf (pg. 12 SPP) Although the additional 7,500 square metres of road (according to the project file) may not seem like a lot, it does mean an additional 300 kg of salt per snowfall. (using 40g salt/m2 road.) Since the City of Greater Sudbury, on average, experiences 23 days a year of 5-20cm snowfalls (http://www.currentresults.com/Weather/Canada/Ontario/Places/sudbury-snowfall-totals-snowaccumulation-averages.php), the city will use 23 x 300 kg = 6,900 kg of extra salt for the expanded roadway per year. This salt will go into the groundwater or will directly wash into Ramsey Lake. The city has a salt management plan but with more roads expected to be built in the watershed (Silver Hills Road), the salt use will continue to go up and so will salt levels in Ramsey Lake. The sodium level in Ramsey Lake was measured by the city as 55 mg/L in 2010, and already over the 20mg/L reportable level. We expected some mention of this in the project file. We are also concerned about the stormwater coming from this area. Much of the stormwater will flow to Frobisher Creek, which originally was a natural creek but is now a stormwater management area. Of particular concern are the phosphorus levels measured from outflows from Frobisher Creek to Ramsey Lake. In the last year tested (2010), phosphorus was measured at 110.5 μg/L, (Bradley, J. MSc. Urban and industrial drivers of phytoplankton communities in Sudbury, Ontario, urban lakes. Laurentian University, Sudbury, ON. Dr. Ramcharan) significantly over the Ontario Provincial Water Quality Objective guidelines of 30 μg/L for protection of streams. https://www.ontario.ca/document/water-management-policiesguidelines-provincial-water-quality-objectives We have some concerns that this stormwater management area is showing signs it may not be able to perform to an ‘enhanced level’ especially when more stormwater is expected to flow through it. The environmental impact of choosing to widen the road to 5 lanes in one area and three lanes in the other will increase impermeable land, increase stormwater run-off, and phosphorus & salt inputs to Ramsey Lake. As a community stewardship group we would have liked to have options presented to us which would have allowed for better flow of traffic on 2nd Ave, (three lane option) while still considering the environmental effects on Ramsey Lake. Sincerely, Lilly Noble Co-Chair Ramsey Lake Stewardship Committee Cc: Clerk, City of Greater Sudbury Director, Environmental Approvals Branch, MOECC Rosanna White, Environmental Planner/Environmental Assessment Coordinator Appendix A Greater Sudbury Source Protection Plan Policies http://sourcewatersudbury.ca/images/uploaded_files/ApprovedSPP_Sept2014/Greater_Sudbury_Sourc e_Protection_Area_Approved_SPP_Sept_19.pdf Policy S4EF-PI Where S3F-PI does not apply and where a sewage system (existing and/or future) is in an area where this activity could be a significant drinking water threat, the Ministry of the Environment shall ensure that the Environmental Compliance Approval that governs the sewage system includes appropriate terms and conditions to ensure that: a. The sewage system (existing) ceases to be a significant drinking water threat; or b. The sewage system (future) never becomes a significant drinking water threat. This policy applies to all sewage threats, including stormwater infrastructure. Policy S7F-LUP The City of Greater Sudbury shall incorporate into its official plan policies related to reducing stormwater runoff volume and pollutant loadings from developments in the vulnerable areas where stormwater management facilities could be a significant threat. These policies shall: a. Encourage implementation of a hierarchy of source, lot-level, conveyance and end-of-pipe controls; b. Encourage the implementation of innovative stormwater management measures; c. Consider flexibility in development standards to incorporate alternative community design and stormwater techniques, such as those related to site plan design, lot grading, ditches and curbing, drive way surfaces, and the use of open space as temporary detention ponds; and d. Support implementation of source control programs, which are targeted to existing areas that lack adequate stormwater controls.