Our organizations recommend choosing Alternative 3 – the Full Removal of Springbank Dam and the naturalization of this section of the Thames River. We submit that full dam removal and naturalization are the preferred solutions from an environmental perspective and would likely prove to be the most cost-effective over the long-term when Life-cycle costs and available provincial and federal funding are considered.
The full Capital and Life Cycle Costs of Rebuilding Riverside Dam were not realistically represented in the ESR and could well end up costing the taxpayers more than double what was presented to the public and City Council. A Rebuilt dam would be considered a new dam, not a repair or expansion of an existing weir, with an assessed High Hazard Potential, and is located within the City of Cambridge in a location that could place multiple residences and businesses at risk in the event of severe flooding or a dam breach. ORA and Partners submit that this Project goes far beyond the screening process provided by a Schedule B, Class EA. Consequently, we submit that this is a major project that should fall into a higher level of assessment.
ORA has fully participated in the Canadian Environmental Assessment Process review and was very hopeful with this government’s promise to “rebuild public trust, protect the environment, advance reconciliation with Indigenous peoples, and ensure good projects get built…” While there are some encouraging components, such as requiring the Minister and Cabinet to provide reasons for environmental approvals and creating a single agency to conduct assessments, it is extremely disappointing that the proposed Impact Assessment Act (IAA) further undermines credibility and trust as well as its ability to protect the environment. It is a very flawed process when after going through years of application review and examination of science-based evidence, that the Minister could make a purely political decision and prioritize economic considerations over meeting climate commitments – as it is doing now with the Trans Mountain Pipeline.
ORA understands the pressure municipalities are under when communities rally to maintain or rebuild their beloved mill ponds. However, it is up to all authorities and municipalities to take a leadership role that places public safety and landscape scale ecological integrity above local individual or group interests.
On 23 – 24 June of 2017, the upstream Gorrie Dam failed and the Howson Dam was at capacity during an extreme rain event and flood when 175 mm of rain fell in just 7 hours, placing more than 150 property owners at risk and resulting in an estimated $11-million in damages in the Town of Harriston. This severe rain event broke previous records by approximately 40% and was the second highest flow on the North Maitland in the 48 years of record. Fortunately, no one was killed; however, it could have been much worse, as in October of 2015, when a South Carolina flood breached 18 dams, and resulted in 16 deaths.
It has come to ORA’s attention that the Gorrie Dam on the North Maitland River failed as a result of flooding during an extreme rain event on 23 – 24 June 2017, and that Maitland Conservation is considering its options. We understand that no one is more aware of the extremes of a volatile and changing climate than Conservation Authorities, and yours in particular; and we understand the pressure that Conservation Authorities and municipalities are under when communities rally to maintain their coveted mill ponds. However, it is up to all authorities to take a leadership role that places public safety and landscape scale ecological integrity above local individual or group interests.
Drought conditions could place additional stress on riverine ecosystems, while more extreme rainfall will heighten the risk of dam failures (18 dams were breached in a South Carolina flood in October of 2015) with rapid release of high volumes of water. There have also been recent dam failures right here in Ontario – the Gorrie Dam failure last year in Wingham was the most recent, putting more than 150 property owners at risk.
This document does not go far enough to place CAs in a central role of watershed planning and management, or in working collaboratively with other municipalities and planning authorities. The CAs have a mandate to ensure the conservation, restoration and responsible management of Ontario’s water, as well as the land and natural habitats; however, municipalities have no such mandate and are more development oriented. It is essential that municipalities are not just using this Watershed Planning Guidance purely for municipal land use planning or a stormwater management tool, but that CAs play a central role, and it is used as an integrated watershed planning and management framework.