Letter to TNRD

LAC LE JEUNE CONSERVATION ASSOCIATION 

PO Box 5044

Lac Le Jeune, BC

V1S 1Y8

Mr. Dan Wallace
Thompson-Nicola Regional District 

300 - 465 Victoria Street 

Kamloops,  B. C. V2C 2A9

December 11, 2011

Dear Mr. Wallace:

We are writing to you on behalf of the Lac Le Jeune Conservation Association. We are concerned about the potential impact that the proposed Lake Ridge housing development could have on the water quality at the lake. We are not necessarily concerned about the development per se, but we are concerned that further development could negatively impact the quality of the lake water unless stringent safeguards are identified and employed. Our concerns are outlined below.

1. According to the 2004 Thompson-Nicola Regional District (TNRD) publication "Lakeshore Development Guidelines", Lac Le Jeune has been classified as "Development Lake sub-class" with the notation in the document that there should be "No further development." This classification is based on the two criteria used by the TNRD, namely "perimeter development" and "user unit ratio".

For a lake the size of Lac Le Jeune, the allowable perimeter development is 35%. Even without the proposed development, Lac Le Jeune exceeds this guideline. Data supplied to us by the TNRD indicates that the shoreline perimeter of Lac Le Jeune is 10,000 meters and the current perimeter development is 3935.3 meters, or 39.5%. This already exceeds the guidelines by 12.4%. According to Gregg Lindros, the consultant for the developer, there are now eleven lots of the proposed development within 60 meters of the high water. While technically it is argued that these lakeshore lots do not add to the perimeter development because there is 60 meters of Crown Land between the property lines and the lake, it is interesting that there are a number of properties with homes more than 60 meters from the lake that are included in the perimeter development. Certainly, these perimeter guidelines will be further eroded if one other TNRD guideline for development is adhered to. This guideline states "non-waterfront residential subdivisions SHALL PROVIDE water access and communal boat moorage". Obviously, if this occurs, the perimeter development would be in excess of 40%.

2. The second criteria used by the TNRD for classification purposes is user unit ratio. The recommended user unit ratio is .67 hectares of lake surface per user unit. According to data supplied to us by the TNRD, the current user unit ratio at Lac Le Jeune is .47 hectares of lake surface per user unit. Even without the proposed development the user unit ratio exceeds TNRD guidelines by 30%. Again, based on data provided by the TNRD, an additional 49 lots (or user units) would drop the ratio to .41, a figure that exceeds the guidelines by 39%.

3. The TNRD Lakeshore Development Guidelines states, "when reclassifications are proposed, the proponent will be responsible for preparation of a lake impact assessment." In compliance with this requirement, the developer contracted with Lakeshore Environmental Ltd. to complete an environmental assessment of the proposed subdivision. This assessment was completed in 2008 and we were provided with a copy.

We have a few concerns with this document. After the assessment was completed, the scope of the proposed subdivision changed in subsequent planning. The environmental assessment completed in 2008 looked at the impact of an additional 32 lots. Since the assessment was completed, the proposed subdivision has grown to 49 lots, an increase of 53%. The author of the document dismisses the TNRD criteria of perimeter development and user unit ratio, even though they were established as criteria only four years before the completion of his report and states instead, that "a speed limit on boats be strongly enforced as these parameters have the greatest impact on maintaining a quality lake environment."

Included in this environmental assessment is a table showing "the number of species and cell/ml of phytoplankton in three samples, Lac Le Jeune." The samples were taken in 1992, 1993 and 1996. ) Unfortunately, the 2008 assessment contained no information of this type newer than 12 years earlier.) Also, unfortunately, the author makes no comment about the significance of the information in Table 1. Hugh Burton, a Lac Le Jeune resident and retired biology professor, looked at the document. His assessment of this data is that the level of cyanophyta (blue-green algae) is the best indicator of changes in the pollution levels in a lake (organic forms of nitrates and phosphates). Cyanophyta rose from 53 cells/ml in 1992 to 475 cells/ml in 1996. In the span of four years, the levels of Cyanophyta increased an alarming 896%! Another form of algae, Chlorococcales, increased from 43.4 cells/ml in 1992 to 241.7 cells/ml in 1996. Another alarming increase of 557%. While these levels may not have represented unacceptable levels of contamination in 1996, they were indicative of a significant and rapid shift in the aquatic ecosystem over a very short time span. This increase in indicator phytoplankton appears to have continued, given that in the past few years, heavy blooms of algae have been observed by local fishermen, a phenomenon never seen before in this lake. This is a further indication of the need for a more intensive biological based investigation of the lake ecology prior to any increased lakeside development.

4. Another concern that we have is the sheer volume of water that would be taken from the lake or the water table if the proposed development proceeds. Even if the 49 proposed lots only use 100 gallons of water per day, they will draw 1,788,500 gallons of water from the available supply. If the Ridgemount water system is expanded into the proposed development, the potential draw at 250 gallons per day per household amounts to 4,471,250 additional gallons of water taken from the supply. Can the lake sustain this kind of draw...can the water table? Who is responsible for monitoring water usage in this area?

5. Interior Health testing of water samples taken from the Lookout Road domestic water supply system in October, 1993 and September, 1999, prior to the installation of a filtration system also gives rise to concern. Chloride levels rose from 14.8 mg/L to 31 mg/L, an increase of over 100%. Sodium content also rose significantly, from 9.7 mg/L to 13.9 mg/L, an increase of 43%. Our hypothesis is that the increase is the result of road salt applied during the winter. We are concerned that a new road system created to service the new development will exacerbate this problem.

6. A number of us have already observed a change in the ecology of the lake. Lily pads have begun to emerge in areas where they have never been seen before, and, more importantly, Chironomid hatches have drastically declined. Some of us recall the disaster that befell Stump Lake and we do not want to see that occur here.

7. Gregg Lindros has indicated to us that an engineering firm will be hired to do an impact assessment of the proposed development on the lake. We look forward to seeing this report. However, we suggest that in addition to evaluating sustainable water supply and other engineering issues, this firm employ a limnologist to look into the water quality issues we have introduced above.

Conclusion
Our concern and our responsibility is to ensure the sustainability of the water of Lac Le Jeune for ourselves and future generations. We have seen headlines in the local newspaper in the past year describing the projected death of Okanagan Lake within the next fifty years, we see the decline of Nicola Lake and we read about the fragility of the Great Lakes. Our concerns are real and to support development without full confidence that we aren't causing harm is to do Lac Le Jeune and its future generation of users and enjoyers a huge disservice.

Sincerely yours,
  Members of the Lac Le Jeune Conservation Association Working Committee

  Bob Brown, Hugh Burton, Jim Phillips, and
  David Wyse (PO Box 5006, Lac Le Jeune, BC V1S 1Y8 DKM_Wyse@telus.net )

c.c. 

Darren Bennett, Water Stewardship Officer, Ministry of the Environment 

Al Caverly, Regional Aquatic Ecologist, Ministry of the Environment 

Steve Miricle, Freshwater Fisheries, Ministry of the Environment
Duane Wells, Water Stewardship Officer, Ministry of the Environment 

Dean Watts, Senior Water Use Biologist, Dept of Fisheries and Ocean 

Ronaye H. Elliot, TNRD Representative, Electoral Area J

Rick Van Rijn, President, Lac Le Jeune Conservation Association 

Gregg Lindros, Lake Ridge Project