Saunders Lake

Saunders Lake

October 31, 2016

Vic Moran-Notes re: 2nd presentation at Public Hearing on Proposed Bylaw-Proposed Northwest Saunders Lake ASP, Oct. 25, 2016

Re: NORTHWEST SAUNDERS LAKE

AREA STRUCTURE PLAN

A bylaw is a law, and as such is a community rule recognized as prescribing or prohibiting certain actions. The actions prescribed in the Northwest Saunders Lake Area Structure plan need to be precise, reasonable and unambiguous – this is simply good law.

All legislation should reflect the The proposed Northwest Saunders Lake Area Structure Plan falls short of meeting any environmental expectations, especially since Saunders Lake is acknowledged in the ASP as a Regionally Environmentally Sensitive Area.

How can I say this with such certainty, you might ask?

Well, I imagine a poll being conducted by the Leduc Rep, in which the question is:

· Should the County of Leduc's elected officials exercise their option to increase the width of the proposed Natural Area / Open Space around Saunders Lake, at no additional cost to the tax payer?

The response would be a clear and resounding yes. Or, how about this question:

· Should the County of Leduc's elected officials pass legislation to reduce the toxicity and volume of stormwater entering the fragile habit of the American White Pelican on Saunders Lake, again at no additional cost to the tax payer?

Or even:

· Should the developer be required to install a rewilded nature trail through the Natural Area running parallel with Saunders Lake as part of the development?

Since the answer to these questions is obviously yes, the short comings of this document need to be addressed.

Leduc County has the opportunity to increase the width of the natural area by applying the 10% Municipal Reserve that is available under the Municipal Government Act. In the proposed Area Structure Plan Stantec states that the County of Leduc will take cash in lieu of the land: you can refer to the last sentence of 1.3.1., also, the end of the first paragraph in Section 5.0 and the fine print at the bottom of table 1 in Section 5. In fairness to Stantec, they do contradict themselves by saying in 5.1.11. that the decision to take cash in lieu of land lies with the County. They then go on and complete the ASP as if taking the cash was a fait accompli. To put the area of this Municipal Reserve in context, the 10% would increase the Natural Area / Open Space by over 50%, and would cover the land currently referred to as the Saunders Lake Transition.

The east side of the proposed roadway would be a convenient edge to a rewilded natural area.

Since there is contradiction regarding this matter, we are not sure that if the County approves this document, are they approving Stantec's assumption that they will take the cash or reaffirming that they are yet to make a decision in this matter?

The County could also request a treed and landscaped berm at the east edge of the development, as is allowed for in the Leduc County, Land Use Bylaw 6.5.11.

It is worth noting that the proposed Natural Area / Open Space is made up of "steep slopes" as stated by Stantec in the middle of the third paragraph of Section 5.1. This would make neither an ideal or safe place for a walking trail. The Natural Area / Open Space needs to be expanded west to accommodate a walking trail or multi-way.

In Section 2.5 the Inter-municipal Development Plan is referenced as a statutory document - that the "Area Structure Plan has been prepared in accordance with". There is, however, no execution of Inter-municipal Development Plan Item 4.6.2.5. , which states that "the conceptual networks, locations and alignments of trails within the IDP area shall be included in future Area Structure Plans". Confusion is compounded when we look at the last sentence in the first paragraph of Section 5.1 Natural Area / Open Space where it states, "The Inter-municipal Development Plan also identifies regional trail connections between Saunders Lake and Telford Lake recreational areas, of which trails within this plan area will form a part". So, the ASP recognizes the IDP, and even quotes from the IDP, but fails to put in the ASP what is required by the IDP – namely a walking trail. Why is that? This proposed ASP is deficient.

Item 4.2 of the North Saunders Lake Servicing Report states that "discharge into Saunders Lake is not to exceed pre-development flow rates". This statement is consistent with the Alberta Governments, Water Act, Stormwater Management guidelines. It is interesting to note that under ASP Section 3.3 Natural Features, "Intermittent overland flow of stormwater enters Saunders Lake from within the plan area, but forms no permanent watercourses". This means that the normal pre-development flow rate is zero and consequentially the discharge rate into Saunders Lake is not to exceed zero, or at least until such a time as cultivated agricultural land would be saturated. How does this work for the stormwater that is being diverted from the west side of the Nisku spine road? Stormwater that would never have found its way to Saunders Lake.

In Section 5.3.3 apparently the "lands with Saunders Lake Transition designation" will be held to a higher level of wishful thinking than the remainder of the development, as these lands are "encouraged" to use "Low Impact Development Stormwater Management Strategies". Notwithstanding the logical determination that a zero flow rate of stormwater can enter Saunders Lake, the reduction of stormwater at source needs to be a legislated requirement for this entire stormwater system, including the stormwater generated from the City of Leduc's North Industrial development.

Section 7.2 states that "the ultimate, (meaning last, final, beyond which no other exists or is possible), receiving body for stormwater from the plan area is Saunders Lake". This can be taken as an admission that wishful thinking has no place in an ASP and that no stormwater is expected to be diverted. The opening paragraph goes on to say that "the majority of the plan area naturally drains towards the lake", this is somewhat misleading. Although the ground slopes towards the lake, the majority of rainwater that currently falls on the plan area evaporates followed by a similar percentage of vertical seepage into the ground. From the information that I have researched the amount of all rainfall that will enter Saunders Lake will likely go from approximately 25% to 90%, and the quality will drastically diminish. This is the difference between rain falling on porous farmland and falling on developed hard surfaces such as asphalt, concrete and metal roofs. For this development the increased amount of stormwater is in the order of hundreds of millions of gallons a year. It is possible to absorb rainfall throughout the development using the aforementioned "Low Impact Development Stormwater Strategies", which are also known as "Source Control Practices" and commonly deployed in LEED certified projects, which coincidentally are also "encouraged" in Section 5.3.3., but not noted as required.

In Section 5.1 it is stated that the intention of the Natural Area / Open Space is to "conserve wildlife habitat and movement corridors" and yet within this area they intend to build two boat launches. Boating is contrary to conserving wildlife habitat on the lake, as it scares adult birds off of the nest and leaves their eggs available for predators, it can also stress waterfowl, for example a pelican chick cannot fly until 10 weeks of age and live in groups called crèches from 3 to 10 weeks of age making them extremely vulnerable to predation.

It is clear that the threat to wildlife on Saunders Lake is real and accordingly we request that the County of Leduc require that an Environmental Impact Assessment report be completed and submitted as part of this ASP. The completion of this report is an option that exists under item 9.2.8 of the Leduc County Land Use Bylaw, which is specifically written to address environmentally sensitive areas. This information is necessary for the elected officials of Leduc County to make an informed decision regarding the approval of an ASP and to negate the possibility of unintended consequences.

In summary this Area Structure Plan is not ready for approval until the contradictions are resolved, the requirements of the IDP are met and the County of Leduc's elected officials have had the opportunity to reflect on the legacy they will leaving for following generations. We understand that the City of Leduc is quite challenged in completing a trail around Telford Lake, do not saddle our children with the same burden by duplicating this challenge. Now is the time to act with definitive and actionable legislation.

Vic Moran-Notes re: presentation at Public Hearing on Proposed Bylaw-Proposed Northwest Saunders Lake ASP, Oct. 25, 2016

BY-LAW NO. 933-2016

My objection with this by-law is not so much with what it says, but rather with what it does not say. The City and County do not need a by-law to say that they will follow the law and meet minimum standards.

This is truly not an inspiring or It is neither decisive nor defining. It exists to ensure that the City's North Leduc Industrial development can proceed and the stormwater from this development will be received by the County and dumped into Saunders Lake.

First a couple of housekeeping items, as gibberish devalues the entire process:

1. Section 4.6.2.12 – "Owners of lands with existing tree stands will be encouraged to retain them to the extent possible at the time of the development". If you Google "tree stands" you end up on Cabelas website where you can purchase the equipment to hide up in a tree and take pot-shots at wildlife. I'm pretty sure that the author intended to say "stands of trees", similarly a coppice, copse or grove.

2. Section 5.3.2. – Since the former area C is now area B, and the remaining area C is on the west end of the City of Leduc this is redundant. Like saying that the Civic Centre is in the City of Leduc. This section should be deleted.

3. Section 5.8.1 - Policy area C is no longer adjacent to areas G or J and so this section is redundant and should be deleted.

If one understands that a by-law is a law made by local government that applies only to a local area, then one can appreciate that a law has to be actionable and contain words such as "shall" and "must". Words such as "encouraged", and undefined phrases such as "sustainable future" and "protect and enhance" could be viewed as contrived negligence. Specifically:

Section 4.6.2.12 says that owners in the Saunders Lake vicinity will be encouraged to retain existing trees and plant additional trees. This begs the questions, how will they be encouraged? What will success look like? If one tree is planted is it a success? If only one original tree remains is this a success? This type of initiative needs to be measurable in both time and quantity or it is simply meaningless.

Section 4.8.1 talks of the integration of growth management, land use planning, and municipal services to move toward a more sustainable future. This all sounds very positive, but what is being sustained? Is it industry, employment, the status quo, the profitability of development? Future sustainability is generally linked with positive environmental action and green projects, but there is no evidence in the by-law of any action of this type that would support use of this "motherhood" phrase.

Section 5.2.7 concerns recreational connectivity between Saunders Lake and Telford Lake. This should have been the defining moment for collaboration between the City and County, to create a benefit for future generations and yet there is essentially an agreement to do nothing. It starts out promising enough, "The City and County shall jointly examine feasible solutions for increasing recreational connectivity", and it even talks about interconnected trails, but concludes with deference to the ASP that will follow. Since we now have the ASP for Saunders Lake - one must ask when will this joint examination take place? After approval of this by-law and before consideration of the Saunders Lake ASP, that follows this meeting? The Saunders Lake ASP has no indication of a walking trail, (future or otherwise), to connect to a link between the two lakes. Again, this is an agreement between the City and County to do nothing. Everyone here should be aware that a wildlife corridor exists between Telford Lake and Saunders Lake. This natural occurrence is both observable and documented, and yet this by-law does nothing to recognise and acknowledge this fact, or put in place mechanisms to preserve and maintain this corridor. In short this by-law needs a commitment to maintain the corridor and build a trail between the two lakes – Area I needs to be contiguous between the lakes and not interrupted by area J at the east end of Telford Lake. It would also be visionary to acknowledge that Telford Lake is used for recreational boating and therefore not ideal wildlife habitat, increasing the need to preserve the wildlife habitat on Saunders Lake. We do not need boat launches in nesting areas, as suggested in the Saunders Lake ASP.

Section 5.10.4. Talks about protecting and enhancing natural features within open spaces and greenways. Saunders Lake is specifically named, and one wonders as to how do you protect and enhance Saunders Lake? Is it by dumping millions of gallons a year of saline and chemically laden stormwater from the North Leduc Industrial Park, the Saunders Lake Industrial Park and the Nisku Spine Road through two outfalls, directly into the area of the lake where American White Pelican congregate and nest? Sadly the preservation of existing wildlife is not covered in this by-law; this omission needs to be corrected. A visionary by-law would require that stormwater volume be reduced at each individual business location by incorporating source control practices, such as required by progressive municipalities. You can reference work done by Sustainable Technologies for the City of Toronto and requirements from the City of Calgary's Water Resources. Requirements and reduction percentages for source control practices need to be legislated at this level, they will not voluntarily be required at the ASP level, or be incorporated in subsequent planning and design stages. Source control practices include:

1. Absorbent landscaping

2. Vegetated swales

3. Bioretention areas

4. Rainwater harvesting

5. Porous pavement

6. Soakaways

7. Infiltration trenches

8. Dry swales

The Area Structure Plan for Saunders Lake goes as far as saying that the use of "Low Impact Development Stormwater Management strategies" is encouraged. Again encouragement does not belong in law; people do not pay their taxes because they are encouraged to do so. They pay their taxes because there are consequences for not doing so. Interestingly, the City of Leduc's Industrial ASPs for Leduc Energy Park and Cathton-Farm Air do not even set the lofty goal of encouraging the reduction of stormwater, even though they were written by the same consultant and the Public Hearing is not until November 7th, 2016. It is also worth noting that the North Leduc Industrial ASP dated March 2001 stated on page 4-4 that, "Storm drainage will generally be accommodated with the use of swale ditches" and further on page 4-9 that "Individual property owners will be required to provide some level of on-site stormwater management to minimize the downstream storage requirements. Given the nature and uses of most commercial / industrial sites, onsite storage should not be difficult to incorporate into the site designs." Is it possible that while the rest of the world is moving towards environmental protection, that the City of Leduc is moving backwards?

In summary, if this by-law is solely for the cooperation between the City and County to expedite development then this is an opportunity lost for the citizens of Leduc, since those developments will directly limit the possible opportunities for the enjoyment of nature in and around the lake district of Leduc. Our elected officials need to set the bar higher, while imaging the consequences of inaction. The people of Leduc want an interconnected walking trail around both lakes; they want ecotourism and a connection to nature. It is not that long ago that a Mayor of Leduc wanted to drain Telford Lake, what a mistake that would have been; I am encouraged that some reasoned opposition prevented this from happening.

Environmental Studies done in the Saunders Lake Area

Over recent years, several good Environmental Studies have been done regarding the Saunders Lake Area.

1. Leduc County with EDA did an extensive study in 2008 on the Saunders Lake area and its' biodiversity, named:
Parks and Open Space Concept Plan, Saunders Lake, Leduc County, Prepared by EDA Collaborative Inc.
2. Ducks Unlimited did A Wildlife Habitat Report for Sunnyvale Farms October, 2007. Natural Advantage: The on-farm wildlife and biodiversity Planning Service, Ducks Unlimited Canada, Natural Advantage Office, Red Deer AB 403 342 1314
3. May, 2004, The Leduc and District Regional Waste Management Authority did an extensive study in preparation for their End Use Conservation Plan in 2007. They studied the wildlife corridor and listed all the area species, mammals, birds, trees and shrubs, grasses and grass like, and forbs.
Titled: May 2004 End Use Plan for the Waste Management Facility approved by Leduc and District Regional Waste Management Authority Resolution #6504 "From Refuse to Refuge".
4. The Alberta Fish and Game Association, Parkland Stewardship Program in 2006 did a Natural Resource Inventory at the Shute Family Farm,
Titled: Natural Resource Inventory 2006 Shute Family Farm.
Edmonton 780 437 2342.

Lois Shute's presentation at Public Hearing on Proposed Bylaw-Proposed Northwest Saunders Lake ASP, Oct. 25, 2016

The following was presented by Lois Shute at the Public Hearing on Proposed Bylaw-Proposed Northwest Saunders Lake ASP, Oct. 25, 2016
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Honorable mayors Whaley and Krischke, Leduc County Councillors, City of Leduc Aldermen.

Thank you for responding to our concerns for Saunders Lake, notably the widening of the green zone.

The more I read about wetlands and riparian areas, the more convinced I am that we need to make every effort to respect our environment, specifically Saunders Lake. We need to do our part for the health of the world, the wildlife within this area and the people who are here. Whether people are aware of it or not, there is a bond between humans, animals and the environment. In God's plan for creation we are all interdependent. What strengthens one, strengthens us all.

This fall as we watched the pelicans leave, the cranes go by on their way south and the swans arrive for their annual visit for a few weeks and the little native birds stop by, we know this lake is important to them and to us. Being in nature enhances our health and well being and even our productivity.

Light pollution makes it impossible to watch the stars, disconnecting us with the universe. I can pull the blinds to sleep when the industrial lights shine into my home from 4 miles away. But what about the animals who live around the lake? Where will they find darkness to sleep or for some, to hunt and to discern direction from the stars?

I realize that much effort is being made by Stantec in their We also know that mechanical things can malfunction at times. What natural filters could be put in place to protect the lake from these inadvertent spills? I've been reading about ALUS (Alternative Land Use Services) ALUS partners with county councils landowners and community groups to help with riparian protection and habitat for wildlife and native pollinators among other things. Parkland County is one of the Alberta Counties who are part of this group. They have planted an "eco-buffer" with help from the Agroforestry Woodlot and Extension Society to include native species of trees shrubs and forbs to provide pollinator and wildlife habitat, shelter for livestock, nutrition recycling and groundwater recharge. The various rooting depths pick up nutrient runoff. Lots of synergies happen in this kind of biodiverse community. I would love to see this right around Saunders Lake. The south east side of the lake still has a natural eco buffer. Other areas around the lake have been cleared of trees and need some restoration. Why can't we as a community begin this process. Perhaps the County could make this a requirement for the developers to complete before the fields are stripped of topsoil and weeds take over the vast clay areas. Mr. Manning representing the developer commented that unfortunately this is part of the process of development. But this carelessness, clay washing down the hills, weed seeds contaminating the countryside for a year, maybe 2 o3 years, is disgustingly unacceptable around Saunders Lake. For a reasonable time, an eco-buffer could help filter out the runoff even as the drainage system and roadways are being built.

Does industrial development along Saunders Lake affect us? Probably not. We have lived beside the lake for 42 years. We may be gone by the time it happens, but we care. We care about our own grandchildren and their children. We care about the 2000 Leduc kids who came to Sunnyvale Camp from 1991-2011. They gloried in this unforgettably beautiful part of God's creation. – even the grungy shore line and those leeches on the bottom of the canoes. We care about your grandchildren too, the waterfowl on the lake – the common ducks and geese, gulls, terns and herons. We care about the rare birds we have seen only once - the Avocets, the Parasitic Jager, and the Black Crowned Night Herons. We care about the Eagles, Hawks, Pelicans and Tundra Swans, the coyotes, foxes, beaver, mink, muskrats, deer and moose that frequent the Lake.

Telford Lake has been cleaned up at great expense after years of abuse. Oldtimers told us 50 years ago about the grain elevator burning down and all the debris being dumped on the ice on Telford Lake, essentially killing the lake.

We appreciate the integrity of our county councillors and realize that you have a lot of things to balance with the threat of the land grab by the Edmonton city. And we appreciate your stated priority to preserve the environment across the county. The way wetlands are being destroyed across Canada and the world, we need to be vigilant and do what we can. We need to set the standards high to guide future representatives.

Let's restore and protect Saunders Lake while there is still an opportunity. Lets not let economics trump the environment. Let's not let finances dull our wisdom and steal this treasure.