The following letter went to
The Honourable Robert G. Thibault, P.C, M.P.
Minister of Fisheries and Oceans
House of Commons
Ottawa, ON K1A 0A6
and (separately and independantly) to
Prescott District Office
Fisheries and Oceans Canada - Ontario Great Lakes Area
401 King Street West
P.O. Box 1000
Prescott, ON K0E 1T0
2003 July 15
Regarding: ENVIRONMENTAL ASSESSMENT SCREENING REPORT entitled
Creek Reconstruction, Stormwater Management,
Findlay Creek, City of Gloucester
(Leitrim External Storm System)
dated June 2003 and issued on June 17.
Dear Minister Thibault, (*** omitted for Prescott letter)
The purpose of this letter is to request that the above Screening
Report be submitted to a full Panel Review. Our primary reasons are as
- The Report acknowledges that the Leitrim Wetland is a Class I
provincial wetland. Hence the environmental assessment of any proposed
development must be done thoroughly and publicly.
- Qualified professionals in geology and soil mechanics have advised your
department that the proposed hydrological barrier or berm will be of
dubious effectiveness. They anticipate lowering of the water table in the
wetland that is proposed to be saved.
- The Report acknowledges that the berm may not perform adequately, and
recommends a monitoring and remediation program for a period of ten years.
However, the Report does not make the program a legally-enforceable
condition of DFO approval, nor does it acknowledge that it will need to be
ongoing at perpetual expense, if the wetland is to be preserved
- Effects of the proposed Remer developments and stormwater management
system have not been assessed in the Report. Hence, the area identified as
the "core" wetland includes lands that (if the Tartan developments are
allowed to proceed) are also likely to be developed. Consequently, the area
to be preserved is smaller than as shown in the Report.
- Other damaging effects include the following:
- Further reduction in area of the wetland that is already just a remnant.
- Loss of biodiversity.
- Destruction of old-growth forest and other vegetation due to
reconstruction of Findlay Creek.
- Over 4km of fish habitat eliminated.
- Isolation of fish populations between the wetland core, the wetland
south of the Remer land, and the upland wetland on the Rideau-Carleton
- Reductions in local bird populations due to habitat loss, including the
loss of a Great Blue Heron rookery.
- Elimination of a large old-growth cedar grove.
- The negative impact of people and domestic pets adjacent to the wetland,
including the possibility of a catastrophic peat fire due to human
activities and lowering of the water table.
- Conversion of a substantial carbon reservoir into carbon dioxide, as the
peat oxidizes with lowering of the water table (more than 1 million metric
tons of carbon).
The proposed mitigation program, that might preserve for ten years
a part of this multi-thousand-year-old heritage wetland, is unacceptable to
us. In consequence, we request that this matter be submitted to a full
Panel Review, to ensure that the general public can participate fully in
the decision-making process.
Yours sincerely, Stan Rosenbaum
Chair, Conservation Committee, The Ottawa Field-Naturalists' Club