January 27, 2025
Andrew Payne
Municipality of Grey Highlands
206 Toronto Street
Markdale, ON
N0C1H0
[email protected]
Re: Markdale Brackenbury-Lawler Reconstruction and Stormwater Class EA
The Escarpment Corridor Alliance (ECA) is a conservation charity in South Georgian Bay. This is a letter of concern regarding the Brackenbury-Lawler Reconstruction and Stormwater Class EA project.
The ECA supports the recommendations made by Jack G. Imhof of Trout Unlimited and Andrew McCammon of the Ontario Headwaters Institute in their delegations on January 15, 2025 to Council.
We are concerned about the cumulative effects and the cross-jurisdictional watershed impacts of partially treated stormwater entering the Rocky Saugeen River. As it was outlined in the delegation, the proposed remediation measures (oil and grit separators) are insufficient as they will not capture the dissolved organic and inorganic material. This material includes phosphorus, sulfates, herbicides and pesticides from agricultural runoff and road salts. Allowing these materials to enter the Rocky Saugeen River will harm the water quality and fish and amphibian habitat.
Additionally, we are concerned about the temperature of the stormwater entering the Rocky Saugeen. The temperature of rainfall from hot summer days can cause warm stormwater runoff and change the temperature of the stream which can cause irreparable damage to fish and fish habitat. The Rocky Saugeen River is one of the last cold-water streams in Central Ontario that supports Brook Trout, a keystone species which cannot survive if river temperatures increase. The species has seen an 80% decline over the past 50 years (source: Ontario Rivers Alliance).
The ECA supports the recommendation of Trout Unlimited for the infiltration galleries alternative and the creation of a Watershed-based Master Stormwater Management Plan and a Municipal Charter for Water Security (Ontario Headwaters Institute).
The ECA also recommends that the municipality explore a Comprehensive Environmental Assessment process as the municipal Class Environmental Assessment process does not provide thorough community consultation due to the sensitivity of the project to the community. As per the recent updates to the Environmental Assessment Act, Indigenous communities are the only entities that can submit requests to bump-up the assessment to a comprehensive assessment. The public can no longer make a Section 16 Order to the Minister.
It is also critical that the Saugeen Ojibway Nation is comprehensively consulted on this important project that could have significant and adverse impacts on Aboriginal and Treaty Rights. SON has traditionally stewarded these lands since time immemorial and practicing Aboriginal and Treaty Rights are dependent on the health of our ecosystems and aquatic habitat. It is the duty of the municipality to ensure that consultation has occurred.
The Rocky Saugeen River is a precious resource for both wildlife and people and an important part of the regional watershed.
Sincerely,
Jarvis Strong
Executive Director
