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December
1995 Newsletter
BARC
Calls for Full Assessment
The
Bay Area Restoration Council (BARC) has requested a full
environmental assessment of the Red Hill expressway and
has issued a 5000-word supporting document detailing its
concerns. The following article summarizes some of the points
made in the BARC statement. The directly quoted material
is in regular type.
BARC
was established in 1991 to "promote, monitor and assess
the implementation of the Hamilton Harbour Remedial Action
Plan" (HHRAP) as well as "assure the protection and
appreciation of the ecosystem of Hamilton Harbour".
The
HHRAP Stage Two report (Rodgers 1992) was issued in November
1992 and subsequently endorsed by the Government of Ontario
and the Government of Canada as well as the Regional Municipality
of Hamilton-Wentworth, the Town of Dundas, the Hamilton
Harbour Commissioners, Dofasco Inc., Stelco Inc., the Royal
Botanical Gardens, the Hamilton Region Conservation Authority,
the Halton Region Conservation Authority, the Board of Education
for the City of Hamilton, and many community stakeholder
groups. The BARC document notes that at least one-third
of the 50 recommendations for the remediation of the
harbour and its watershed have specific relevance to the
future of Redhill Creek and the valley through which it
flows into Hamilton Harbour.
The
document points out that Recommendation #42 is particularly
noteworthy. It reads in full: "That existing environmental
assessment procedures be maintained for all projects conceived
within the area that may have an impact on the Harbour ecosystem
or on the uses for which the Harbour water quality has been
improved."
The
immediately following recommendation (#43) asks "that the
goals of the RAP be recognized in all projects or developments
impinging on the Harbour in the future, with greater emphasis
on ecosystem assessment." BARC points out that private and
public expenditures on the implementation of the Hamilton
Harbour Remedial Action Plan have already exceeded $700
million, with a similar amount envisioned to restore the
beneficial uses of the harbour and its watershed.
The
document continues: With regards to the proposed expressway
and the request to exempt it from an environmental assessment,
it should be remembered that the assessment process carried
out in the 1970s and 1980s on an earlier version of part
of this roadway paid little attention to the impact of the
project on Hamilton Harbour. Indeed, the boundaries for
the study excluded all of Hamilton Harbour (Regional Municipality
of Hamilton-Wentworth 1982, Figure 1). The portion of the
current project in closest proximity to Hamilton Harbour,
the interchange with the QEW, was not included in that assessment,
and we understand has never been evaluated to this day.
In fairness, it should also be noted that the HHRAP process
did not get underway until the year following the Consolidated
Board hearing decision on the project, although this only
underlines the importance of fully evaluating the revised
project's impacts on the Harbour and its watershed.
In
1991, an Environment Canada profile of the Hamilton Harbour
ecosystem (Robinson and Schaefer) predicted that the earlier
version of the expressway "could destroy substantial amounts
of green parkland" and that the "remainder of the natural
greenbelt in the Creek ravine will also be drastically altered
by the introduction of noise pollution and car exhaust.
This development will also create substantial run-off problems
for Hamilton Harbour, by depositing large amounts of suspended
solids into Windermere Basin." (1991, 49)
Other BARC concerns include sewage contamination entering
the Harbour from the stream, the effects of disturbing landfill
sites along its banks, substantial increases in the velocity
of stream flows and their potential to increase erosion
and scour contaminated sediments from closed dumps and Windermere
Basin, aggravation of the road salt problem, damage to existing
ecological functions, loss of wildlife habitat and decreases
in opportunities for public access in the Harbour watershed.
Perhaps
the most profound effect of the expressway construction
on the HHRAP lies in the negation of the positive environmental
reputation which the RAP process has earned theHamilton
area. The severe damage to the city's largest park and natural
area (and the last of 14 streams which once flowed into
the south shore of the bay) flies in the face of the ecosystem
rehabilitation and protection philosophy of the RAP. The
impact will be felt not only on the area's reputation outside
its borders, but most profoundly on the local citizens who
are most committed to the RAP and other environmentally
positive processes. Indeed, many of them have asked us,
often with specific reference to the Red Hill Expressway:
"What's the point of cleaning up the bay if you are going
to keep on destroying its watershed?"
Public Access Issues
Recommendation
#3 of the HHRAP focuses attention on the paucity of public
access areas on the shores of Hamilton Harbour and calls
on local municipalities and other authorities to "acquire
and develop land for public use, use existing lands under
their control, and identify new sites as they become available,
in order to provide substantially more physical access to
the shores of the Harbour". Recommendation #24 also calls
for measures to "provide access and opportunities for wetland
appreciation and education". In line with the ecosystem
approach, BARC's concern with public access necessarily
extends into the watershed of the harbour. The proposed
expressway project appears to directly contradict these
HHRAP recommendations.... BARC is concerned that the proposed
expressway project will have serious impacts on public accessibility
to and use of this significant greenspace, including the
educational opportunities it affords.
Sedimentation and Erosion
Recommendations #4, #5 and #6 of the HHRAP focus attention
on the problems associated with erosion and resulting high
sediment issues in the Harbour and its watershed. Recommendation
#6 specifically calls for the location and remediation of
sources of erosion on tributary streams that empty into
the Harbour.
Redhill
is the second largest creek (after Spencer Creek) flowing
into Hamilton Harbour and supplies 14% of the natural runoff.
It drains 62 square kilometres - 75% of this area being
above the escarpment and incorporating most of the urbanized
area of Hamilton Mountain (approximately from West 5th to
Highway 20). Research carried out for the Ministry of the
Environment in 1982 identified 60% of the basin to be agricultural,
although further urbanization of the watershed has taken
place since then. The creek empties into Windermere Basin.
A
1988 Envirosearch study identified agricultural areas south
of Hamilton in the Redhill watershed as "high priority"
for sediment loading. Envirosearch concluded that Redhill
was a significant source of suspended solids entering the
Harbour at Windermere Basin. Although 86% of the flow to
Windermere comes from the Woodward Avenue sewage treatment
plant, the study found that the creek itself provided 67.5%
of the suspended solids. Windermere Basin was dredged in
1989, but it has already become seriously clogged with contaminated
sediment (Rodgers, pers.comm.1994)
The large sediment loadings are closely related to the use
of Redhill as a conveyance for stormwater runoff. Flow regime
monitoring by the Hamilton Region Conservation Authority
(HRCA) has recorded peak flows up to 79 times baseflow in
storm conditions. There are wide daily fluctuations. For
example, the flow went from .411 cubic metres per second
to 35.1 and back down to .551 in a four day period in June
of 1984 (cited in Heagy et.al. 1995). The heavy rains in
October of this year in the aftermath of Hurricane Opal
resulted in extreme flooding in Redhill including the overtopping
of the Melvin Street bridge by at least one metre. The large
concrete channel installed at Queenston Road as part of
the initial construction of the proposed expressway was
also filled to overflowing by this 50-year storm event.
Portions of the floodplain were inundated to depths of at
least two metres (Staton, pers.comm 1995). The creation
of wetland/detention ponds to curb peak flows was one of
the recommendation made by the Hamilton Region Conservation
Authority in its April 1994 recommendations in response
to the Crombie roadway proposals.
Evidence
is accumulating that both peak and total flows in the creek
have increased substantially as a result of urbanization
in the upper watershed. This can be expected to be further
aggravated by increased development on the south Mountain
and in upper Stoney Creek facilitated by the proposed expressway.
In addition, the actual construction process associated
with the proposed expressway, which is expected to extend
over a period of years, poses a serious threat of increased
erosion and sedimentation with deleterious effects on Hamilton
Harbour. The intensity of the flows and their fluctuations
are also a concern at the mouth of the creek in Windermere
Basin which acts as a settling pond for effluent from the
Woodward Avenue STP. Disturbance, and even scouring of these
sediments would have a serious impact on the quality of
water in the rest of the harbour.
Fish
and Wildlife Habitat
A
large number of the HHRAP recommendations are concerned
with improving fish and other wildlife habitat in the Harbour
and its watershed. These include recommendations #8 through
#15 and especially #16 which reads: "that regulatory agencies
apply Canada's Fish Habitat Policy to ensure the regulation
of "no net loss" of fish habitat in Hamilton Harbour, and
once the Fish Habitat Management Plan is developed, to ensure
that developers, landowners, Conservation Authorities and
other regulatory agencies comply with the development application
guidelines for areas sensitive to development."
...The
implementation of the HHRAP has focused a great deal of
attention on enhancement of the fish community associated
with the harbour and its watershed and we are recording
significant successes in this regard. Efforts to re-build
top predator species such as Northern Pike are a major part
of this program, with particular attention on spawning areas
in Grindstone Creek, in the west end of the harbour watershed.
However, pike were also common in Redhill Creek as late
as the 1950s and almost certainly spawned in its wetlands.
The 1995 fish inventory indicates that the creek has significant
fisheries potential. This must be given proper weight in
any examination of potential construction projects affecting
the creek. We understand that the current regional government
proposal envisions up to 25 crossings of the current beds
of the creek and its tributaries (map on display October
1995 at Hamilton City Hall). Documents released by the Regional
government in 1994 (McCormick Rankin) also indicate that
up to four kilometres of the creek bed would need to be
channelized to accommodate the expressway construction in
Red Hill Valley. These features of the proposed road project
suggest that it may have extremely deleterious impacts on
current and potential fish populations in the creek. This
is a matter of great concern to BARC.
In
addition to issues relating to the fisheries potential of
Redhill Creek, the impacts of the proposed expressway on
other wildlife species is also a concern to BARC. In particular,
we note that the wetland areas until quite recently (1989)
have provided nesting habitat to the nationally and provincially
rare Black Tern (Heagy 1993). Recommendation #23 of the
HHRAP specifically notes that "habitat be maintained or
created as necessary in the Harbour, or in Lake Ontario
immediately adjacent to the Harbour to support nesting populations
of colonial waterbirds at selected areas...".
Combined
Sewer Overflows
The Stage Two report focused a great deal of attention on
the negative impacts of sewage effluent on the harbour and
its watershed and made this issue the focus of its first
recommendation. This identified the remediation of combined
sewer overflows and the discharges of ammonia, phosphorus
and suspended solids from regional sewage treatment plants
as the leading priority of the HHRAP. The first two specific
priorities identified in this recommendation are the remediation
of combined sewer outflows impacting on the western and
eastern portions of Hamilton Harbour.
...BARC strongly supports action to deal with the CSOs on
Redhill Creek and in other parts of the Hamilton Harbour
Watershed, and considers that expenditure for the construction
of appropriate detention facilities for these CSOs should
be accorded a high priority by the Region of Hamilton-Wentworth.
Urban
Stormwater Runoff
Recommendation
#25 of the HHRAP focuses specific attention on urban stormwater
runoff, especially as a source of bacterial contamination.
When the recommendation was written in 1992, this had not
been established, but the potential that this problem would
be confirmed incited the authors to include a specific recommendation
that it be dealt with if and when it was identified to be
taking place.
Less
that two years later, in 1994, Bae et.al. examined
stormwater outflow pipes along the east bank of Redhill
creek and determined that nearly all of these were contaminated
by the presence of raw sewage. Further investigations this
year (Lee et.al.1995) concluded that a large stormwater
culvert emptying into Buttermilk Creek (a tributary of Redhill)
was also contaminated, this time at a level surpassing all
previously tested outflows.
BARC considers that these revelations are very serious and
suggests that they also constitute a legitimate claim on
local government expenditures that may also be more pressing
than the proposed expressway project.
...Elevated chloride levels and resulting high conductivity
readings are another on-going problem in the creek waters
flowing into the harbour. The major source of these problems
appears to be road salt. This is already a serious problem
with the waters of Redhill Creek, where it may be aggravated
by the municipal practice of dumping snow and associated
debris collected from city streets on the site of the closed
Rennie Street Landfill. The establishment of a major transportation
artery on the floor of the valley can be expected to greatly
increase salt and other contamination of the creek and the
Harbour. This is also a matter of serious concern that must
be addressed in any assessment of the impacts of the proposed
expressway.
Contaminant
Flows Into Hamilton Harbour
Another
high priority of the HHRAP and BARC is the achievement of
zero discharge or virtual elimination of the discharge into
the Harbour ecosystem of trace metals and trace organics
within as short a time as possible. This is addressed in
a number of HHRAP recommendations including #17 and #28.
Of particular concern in this direction is the presence
of a number of operating and closed landfills in the watershed
of Redhill Creek. BARC's concerns include evidence that
some or all of these sites are leaching into the creek,
as well as the threat posed to the integrity of these toxic
sites by any proposed construction activity.
At
least four landfills are located in the Redhill watershed,
three of them on the banks of the main creek in proximity
to the expressway. Leachate flows from each have recently
been reported. The largest of these landfills (the Taro
West Quarry located on Davis Creek near Felker's Falls)
covers 24.3 hectares in an unlined fractured limestone quarry.
The escape of contamination from this landfill into Davis
Creek (a tributary of Redhill Creek) led to MOEE orders
for remedial actions in 1993. More recently, three potential
leachate sites on the escarpment face below this site characterized
by dead vegetation have been reported (Kurelek 1995). Taro
expects to complete the filling of this site in 1995 and
is currently seeking approval to convert an adjacent quarry
into a second landfill.
The
Upper Ottawa Street landfill also sits in a former quarry
on fractured bedrock in contact with groundwater. It covers
16 hectares with wastes up to 58 feet in depth. It was closed
in 1980 in the midst of considerable public controversy
over health problems of nearby residents (Bourns 1986).
Although a leachate collection system was installed at closure,
both the Bourns report and a 1994 report by Proctor and
Redfern reports visible leachate seeps at locations along
Redhill Creek. This was confirmed by investigations earlier
this year (Lee et.al. 1995) which suggested that
the site is unstable. In 1993, the dome of this facility
unexpectedly sank into a saucer-shaped depression. A leachate
collection system was installed in the 1980s, but only encloses
three sides of the site. The missing side is adjacent to
Redhill Creek. Lee et.al. (1995) report that leachate
with a high level of toxicity is escaping from several locations
along this north side of the site. The contents of the landfill
are uncertain but it is known to contain large amounts of
liquid industrial waste which was processed on the site
in the 1970s.
The
1986 study (Bourns) made a number of recommendations for
management and monitoring of the closed landfill, but government
financial constraints have limited the extent of their implementation.
The Bourns study noted that the water table inside the Upper
Ottawa Street Landfill was "about seven metres above the
surrounding ground level" and concluded that "(u)ntil the
water mound recedes below ground level, leachate springs
will continue to be a problem" (1986, xi). The study also
concluded that "it is likely that a 'plume' of leachate
now exists in groundwater over the nine kilometre distance
between the landfill and Lake Ontario." Noting further that
"groundwater immediately to the east [of the landfill site]
is less than one metre below ground surface", the report
recommended that "no excavation work be undertaken in the
low lying area immediately east of the landfill..." (1986,
xv-xvi). The east-west portion of the proposed expressway
that is currently under construction, lies immediately north
of the site and includes an interchange with Dartnall Road
located along the east side of this landfill.
The
Brampton Street Dump is located immediately behind the Woodward
Avenue sewage treatment plant near the mouth of Redhill
Creek. It was closed in 1974 before current regulations
for securing of landfill sites were put in place. According
to Proctor and Redfern (1994), "there is limited available
information on the types of waste accepted at the site and
the development of the site", although they do confirm the
disposal of 10,000 cubic yards of sewage sludge there during
the 1970s. Leachate seeps are visible at several locations
along the side of the landfill bordering Redhill Creek and
Red Hill Marsh. Last December, the Hamilton Spectator drew
attention to surface ponding of leachate in areas frequented
by local youth. The original version of the Region's proposed
expressway was scheduled to pass directly over (through)
this landfill site as part of the interchange with the Queen
Elizabeth Way (Regional Municipality of Hamilton-Wentworth
1982).
Investigations carried out last year by consultants to the
Region in response to the alternative roadway proposals
put forward by David Crombie (1994) also reported the existence
of an "old municipal dump site" adjacent to Redhill Creek
and immediately south of the Brampton Street Dump (McCormick
Rankin 1994). This "Rennie Street Landfill" is located under
the municipal works yard where large amounts of snow and
road detritus are placed during the winter. A number of
leachate flows from this area are easily observed along
the banks of the creek (Staton, pers.comm. 1995).
It
is likely that other disposal sites also exist along the
creek. ...
It
is particularly troubling to read the comments on this issue
made by Mr. Michael Jefferies, the Chairman of the Consolidated
Board that examined the earlier version of the proposed
expressway ten years ago. In his dissenting opinion issued
at the conclusion of those hearings, Mr. Jefferies stated:
"For reasons which I fail to understand, little attention
was given in this assessment to an investigation of any
potential problems relative to the said landfill sites [Mr.
Jefferies is referring to the Upper Ottawa Street and Brampton
Street sites] and it appears that the Ministry of the Environment
was either unaware of the location of these landfill sites
relative to the proposed roadway or, alternatively, was
unconcerned with respect to any adverse environmental impact
which might arise from the construction of the roadway."
(1985, 274). We are extremely fortunate in having a second
chance to address these crucial issues. We must not fail
to do so.
This
collection of potential and actual sources of toxic contamination
of Redhill Creek and Hamilton Harbour is a matter of serious
concern for BARC. As with the CSOs, spending priority should
be given to addressing unresolved problems at these landfill
sites. Proposals for construction of an expressway in proximity
to these sites should be subject to full and exacting assessment
to ensure that present problems are not further aggravated.
The examination of this potential should include the impacts
of altered flow regimes in Redhill Creek that could accelerate
erosion at one or more of these sites with a resulting increase
in the release of toxic materials.
BARC
concludes its statement by emphasizing the importance of
an ecosystem approach which advocates a shift in policy
framework from short time-frame to long time-frame, and
from point individual analysis to analysis of cumulative
effects. It illustrates this by reproducing a table from
the Stage Two report which compares the ecosystemic approach
to more backward methodologies such as egosystemic and piecemeal
approaches. The table notes that an egosystemic approach
to infectious diseases would take the form of quarantines,
while a piecemeal approach would advocate pills. An ecosystemic
approach, on the other hand, would focus on prevention.
Another example in the table is the various solutions offered
to traffic congestion. The backward egosystemic approach
is to build more roads through cities, and the piecemeal
methodology is the construction of more super highways.
The ecosystemic approach supports public transport and decentralization.
The
report concludes that the collective experience of a
decade of developing and implementing the HHRAP confirms
that the ecosystem approach provides the kind of advanced
thinking that is so critically necessary if we are to avoid
the disastrous mistakes that resulted in the degradation
of Hamilton Harbour and the extremely costly remediation
efforts required to restore it to health. Full public examination
of large projects such as the Red Hill Creek Expressway
is critical to ensure not only that the advances we have
made are protected, but to also guarantee to the greatest
extent possible that future generations won't be forced
to conclude that we too have failed to learn the central
lessons placed in front of us by past environmental mistakes.
The price of such a failure is far too high.
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