Bruce Beach Drainage Project Comparison to Key &Guiding Principles Presented to HK Council/ Dietrich
Key principles:
Key Principle #1: Options developed are acceptable to residents of Bruce Beach Rd.
Progress to Date: In order to assist owners to understand the benefits versus the costs, a step was missed. Landowners are tax payers and they do not want to see their money directed into solutions that do not represent significant/ commensurate benefit. We prefer to see low cost and low tech solutions tried out before considering spending money on high cost/ high tech solutions. All the options/soultiions were not all costed and were not presented to the landowners on a cost-benefit basis. We respectfully request this work be completed and shared with owners.
Principle # 2. Ensure protection of persons, property & the environment- beach & water
Progress To Date: The proposal for a Storage Water Management ( SWM) Facility on the farmers land is in harmony with the above Principle. The Farmer will receive a grant to cover the majority of his costs relating to his land.The two solutions/options presented, the infiltration gallery at Highland Drive and the SWM do not address solutions for storm water management and ponding occurring on for the entire road from Highland Drive to the 8th Concession. The gaps are as follows # 136 to #99 and # 97 to #84-2 Bruce Beach Rd.
Planning and Design Issue for the SWM: There is an issue with continuing to allow water from Lake Range Rd and the 200 Acres of farmland to drain from the SWM through the Bruce Beach Ravine/Gully above the outlet at #98. This is unacceptable to us for the following reasons:The gully at #98 is collapsing in, as the base erodes to get to the lake level. The trees are lost and the sides are unstable and over 1/3 to 1/2 of the trees have fallen into the Gully/ Ravine and many more are at risk. Buildings and property at #724 (most at risk) #722 #728 Lake Range Rd and at # 95-2, Bruce Beach Rd are at risk and some these properties will eventually fall into the gully (in several years time) with continued use of the gully to drain the SWM and Lake Range Rd. This current solution to use the Bruce Beach Gully/ Ravine above outlet at #98 will contribute to the erosion and destabilization of the Gully/Ravine at an accelerated rate. The soil that is picked up through the movement of these volumes of water through the gully at #98 contribute to significant algae development in the lake and on the beach and bacteria development in the lake affecting water quality. The culvert outlet to the beach at #98 gets plugged with sand in storms. (Pictures previously sent to HK and Dietrich.) This Outlet at #98 is not a sufficient outlet for managing the Stormwater water and we recommend it be abandoned. Should we have a large rain storm and the outlet at #98 is plugged, #98 residence and those properties immediately adjacent will be in danger of flooding. This in fact has happened in the past on two occasions, one with the entire home flooded at #98 to be torn down and rebuilt, local basements were flooded and a patio was entirely destroyed. If the SWM design continues to use the Gully/Ravine above at #98 for stormwater management and drainage then we are confident that Huron Kinloss will face a law suit, based on negligence in planning. We would rather see the resources, our taxpayer dollars, not to defend a lawsuit but to go towards building a more responsible solution: A municipal drain going down the 8th as HK Council did on the 10th concession. This would avoid the use of #98 gully, result in cleaner water going into the lake and will preserve the Gully/ Ravine habitat and stabilize the environment within. Huron-Kinloss Councils of the past have chosen to use the Bruce Beach Ravine/Gully above #98 as an outlet for the agricultural lands, over 200 acres and for drainage of all the development on Lake Range. This decision by HK Council was a low cost approach and has resulted in ongoing damage to the gully, forestry, property, deterioration of water quality, algae and loss of enjoyment of our beach and lake by Bruce Beach Residents.
The recent decision by HK Council to approve the construction of drains on both sides of Highland Drive that funnelled all Highland Drive stormwater onto Bruce Beach Rd was ill founded and has resulted in downloading of a stormwater management issue for Highland Drive owners to property owners of Bruce Beach Rd without the consent or without consultation with Bruce Beach Rd residents.
Long term owners of Bruce Beach properties can attest to the damage done by past Huron Kinloss Councils drainage planning decisions without considering our environment or long term implications of these decisions. We hope this is not repeated in this project and we would appreciate correction and remediation of these past decisions.
Key Principle #3. Public Safety: Process to Date: Gaps to address Public Safety were identified under principle two. We hope to see these addressed in future for the school bus children who travel this road daily, for owners and recreational users of Bruce Beach Rd between Highland Drive and Concession 8. There is significant ponding and soft areas (vehicles sink down some 6 inches) during a rain event and in the spring on the easterly side of Bruce Beach Rd,. along the length of Bruce Beach Rd from Highland Drive to the 8th Concession. This would be mitigated by a ditch on the east side ( as has been suggested by Jim Clark #120 at the open house in May2019). Children or adults hiking the ravine/ gully are at risk and in extreme danger given the current condition of the Ravine/Gully and should the water from the SWM and Lake Range Rd ditches not be diverted, continued destabilization of the sides of the Ravine/ Gully above 98 outlet will present a significant risk for a catastrophic injury as well as property loss and damage.
Principle #4. Successful longterm outcome for storm water management: Progress to Date: The SWM represents a best practice in Storm Water management and is in harmony with Principe # 4. The infiltration Gallery is an expensive solution to accomplish Storm Water Management south of Highland Drive. We do not support this approach at this point. The benefits are not commensurate with the estimated costs. The existing ditch constructed at our request in December 2018 significantly managed over 80% of the storm water from Highland Drive. With expansion of this solution and a modification to best practice with rubble, we are confident will address the remaining 20% of the storm water not managed at a cost more in line with the benefit
Guiding Principles
Guiding Principle #1: Develop options without increasing the number of outlets to the beach Existing: #1 Bruce Beach Rd and Boiler Rd. #2. 98 Gancevich’s #3. Cameron Lane Progress to date: Compliance Yes The options developed do not increase the number of outlets to the lake and are in harmony with this guiding principle. However given that the Outlet at #98 gets blocked with sand is deemed to be too high risk and NOT a sufficient outlet it is recommended that the 98 outlet be abandoned and a new outlet be created at Concession #8 similar to what exists with the municipal drain at Concession 10 immediately north of the mailboxes. This municipal drain outlet at Concession 10 has not interfered with beach enjoyment as constructed.
Guiding Principle #2 Eliminate the outlet at 98 Bruce Beach Rd. Progress to Date: Compliance: No The solutions proposed to date do not address Guiding Principle #2. We request that all Lake Range Storm Water Drainage and the SWM facility drain though a Municipal Drain that would go down the 8th concession and manage all the Storm Water that is proposed to go down the Bruce Beach Ravine/ Gully at #98 .This may include the Stormwater from Lake Range Rd both north and south of Concession 8. This is how Concession 10 storm water management is managed. Concession 8 should be no different. The additional benefit of a Municipal drain at Concession 8 is that the Lake Range storm water could be inexpensively redirected from the Cameron Lane Gully/ Outlet . This would be safer, and solve a public safety issue with the children we have observed playing in the purulent bacteria laden effluent that ponds and develops at the Cameron Lane outlet after a storm due to the topography. This would also significantly reduce the algae on the beach, reduce the bacteria and improve water quality for both residents and fish habitat. By eliminating the use of the outlet at #98 and using a Municipal Drain at Concession 8. Guiding Principles #1 and 2 would be met.
Guiding Principle # 3 Use Concession 10 and Concession 8 as the main outlets. Progress to date: Compliance No Not achieved in the current plans.
Guiding Principle #4 Inspect all properties on Lake Range and Highland for drains to the west and reroute: Progress to Date: Compliance No. We think the township staff should direct this work and cannot understand why this has not been undertaken. Please facilitate this work.
Guiding Principle #5 Eliminate/manage all sources of storm water. Progress to Date: Compliance Partial. The SWM facility does substantively manage the stormwater from the Agricultural lands. It does not appear to manage stormwater from Lake Range Rd ditches. The proposal for a infiltration gallery manages the Stormwater from Highland Drive is deemed to costly to proceed and given the recent ditch constructed south of Highland Dr on Bruce Beach Rd this managed 80% of the storm water? It is recommended that a best practice swale ditch be constructed at a lower cost. This should be tried before proceeding to the high tech, high cost high maintenance infiltration gallery. There is nothing proposed to manage stormwater on the East side of Bruce Beach Rd from #136 to# 84-2. This whole length of the road is beside a high degree slope/ bluff and NO thought has been given to the management of ponding and stormwater. We believe a ditch would solve these problems on the east side of Bruce Beach Rd. The ponding and storm water along the entire length of the road between Highland Dr and Concession 8 needs to be addressed in any solution.
Guiding Principle #6 Use Best Practice in Storm Water Management, flood control/retention ponds: Progress to Date: Compliant. Infiltration Galleries are subject to clogging, need maintenance and is a very costly solution for what has now been recognized as a minor problem since the ditch was introduced. Dietrich agreed at Council meeting on their last presentation of October 21 2019, to present a costing of a low tech swale /ditch extension. They agreed to complete this for our next meeting on November 30 2019, to present a low cost low tech approach to The Flooding on Bruce Bach Rd from Highland Drive. This may include “Grassed Swales: Historically, grassed swales were constructed for stormwater conveyance. However, stormwater objectives have changed and now grassed swales are being used to store, infiltrate, and convey road and on-lot stormwater run-off. The grass or emergent vegetation in the swale reduces flow velocities, prevents erosion, and filters stormwater pollutant” p 25 of SOURCE AND ON-SITE CONTROLS FOR MUNICIPAL DRAINAGE SYSTEMS :A BEST PRACTICE BY THE NATIONAL GUIDE TO SUSTAINABLE MUNICIPAL INFRASTRUCTURE March 2003. We wish to see a low cost, low tech approach as suggested above implemented as a trial. The ditch constructed south of Highland Drive in December 2018 was very effective and dealt with 80 percent of the stormwater from Highland Drive. We would like to see this approach extended all along the east side of Bruce Beach Rd south of Highland Drive to Concesion #8 to reduce ponding and improve road surface.
Although the SWM is compliant with best practice, the plan for The SWM and Lake Range drainage outlet using the Ravine/ Gully and the outlet at #98 is not compliant with the best practices in the SOURCE AND ON-SITE CONTROLS FOR MUNICIPAL DRAINAGE SYSTEMS :A BEST PRACTICE BY THE NATIONAL GUIDE TO SUSTAINABLE MUNICIPAL INFRASTRUCTURE March 2003 p.98 It may also be impractical and too costly to use Buffer Strips as the Ravine /Gully is so severely damaged.
Guiding Principle #7: Employ best practice in quality of water management to reduce the impact on Lake Huron. Progress to Date: Partly Compliant. Using the Bruce Beach ravine/gully outlet at #98 is not compliant with water quality objectives contributing to erosion, deterioration of fish habitat, formation of algae and material contamination of the lake, contributing to pollution and bacterial contamination with health implications and loss of enjoyment for Bruce Beach users.
Guiding Principle #8 Manage the forest and tree plantings.Progress to Date: Not addressed We request that Saugeen Valley be consulted and that they provide a report to the Bruce Beach Community as to what steps should be taken with respect to restoration of the Ravine/ Gully above the #98 Outlet and the forests abutting and on the bluff along the east side of Bruce Beach Rd. To date Council nor Dietrich have not addressed this as part of the planning that would need to occur to mitigate the storm water management.
Guiding Principle #9 Scope: Address Flooding and Risk along entire Bruce Beach Rd Length ( cottages 88 to 177) . Progress to Date : Not Compliant. Most of the owners from Cottage 134 to cottage 87 Martyn Lane are assessed between $600 to $1000 with absolutely No benefit and without being a contributor to the flooding or storm water. Yet Lake Range Rd. property owners, the source of a tremendous amount of storm water: #790 to #762 are assessed at $400 to $600 and #760 to #728 assessed at $300 to $500 and #724 to #702 assessed at $700 to $1000. This is an illogical and an unfair assessment when you compare the tow areas. Lake Range Rd properties are huge contributors of storm water. From our on site observations during moderate rainfall Lake Range Rd properties generate huge amounts of stormwater that is fast flowing and they have been under assessed. The Bruce Beach and Martin Lane light green section on the Assessment Map for the Bruce Drainage is bearing the burden of the costs that should be attributed to Lake Range Rd. We recommend this be corrected otherwise it will form a strong basis for appeal.
Guiding Principle #10: Communicate in person with residents July -August 2019. Not Compliant. In person public meetings were scheduled by Council May 25th and November 30th 2019. The result is that the Bruce Beach Rd Community feels that Council is just trying to railroad the solutions they want. The Drainage Act calls for public engagement. In future communication of all in person meetings should be scheduled in July- August Time Frame. When Council schedules meeting outside the time frame requested they are not honouring the request of the 71 owners directly on Bruce Beach Rd. Neglect of this requested Guiding Principal on multiple occasions is not respectful of the owners/ taxpayers. So far HK council has chosen to not provide the opportunity in the time frame requested for in person questions and feedback and continues to rely on HK Have Your Say. This mechanism of feedback is only friendly to computer savvy individuals. Most of our owners approx 80% are not computer savvy and are older. HK council has been told on two occasions that scheduling meetings outside of times that owners can be present is counterproductive and not acceptable. Only about 6 out of 71 owners are full time residents on the Bruce Beach Rd. and when these meetings are scheduled out of July or August time frame, owners would be expected to travel 6 hours to 12 hours to attend, a hardship that is unreasonable. "The Drainage Act is required to be a very public process which functions best when all those affected participate. Landowners are to have an opportunity to provide input throughout the report development process and also have full rights to appeal after the report has been adopted by Council. " If Council and the Consultant wishes to consult and to avoid appeals then you need to be mindful of the parameters you were given at the outset. Stop scheduling meeting at times when the majority of owners cannot be present.
Guiding Principle #11 Target a response from 75 % of residents on Bruce Beach Rd.on options. Progress to date: Non compliant. HK takes attendance but to date it is not reported the # owners who have responded. Please report on response rate.
Guiding Principle #12. Ensure review of options and input by the following organization before presenting to residents: Conservation Ontario, Environment and Climate Change Canada, Ontario Ministry of Natural Resources & Forestry, Saugeen Valley, The Lake Huron Centre for Coastal Conservation: Progress to Date: To date not reported.
Thank you for the opportunity to comment and we hope these comments are helpful to this project moving forward.