Public Hearing
Comments
The mandate of our Association is stewardship. We are not
opposed to development. We are opposed to development when due diligence in
ensuring the sustainability of the area’s water resource has not been carried
out.
We have the following concerns:
1. All
criteria developed by the Thompson-Nicola District (TNRD) regarding Lakeshore Development
have been ignored. According to the 2004 TNRD publication, “Lakeshore
Development Guidelines”, Big 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”, both of which
are currently exceeded.
Again, based on TNRD criteria, Little Lac Le Jeune, the lake the
proposed development will be adjacent to, has been classified as “Critical”
with the notation that there should be NO FURTHER DEVELOPMENT. Little Lac Le
Jeune has been given a Critical designation because of several factors. It has
a mean depth of less than 5 meters. The size of Little Lac Le Jeune (between
60 and 100 hectares) allows for 20% perimeter development. Currently there is approximately
40% development. Ministry of the Environment personnel have determined that
Little Lac Le Jeune is eutrophic. (overly rich in nutrients…i.e. nutrient
pollution)
2. The
TNRD requires that an environmental impact assessment be completed prior to
any lakeshore development. Our letter to the TNRD dated December 11, 2011
outlines our concerns with the study done by Lakeshore Environmental Ltd.
(Please refer to #3) Further to
the concerns we mentioned, we are particularly concerned that the assessment
was done on Big Lac Le Jeune when the proposed development is immediately
south of Little Lac Le Jeune. We are also concerned that the data used was
extremely dated. The most recent data cited in the report came from 1996 with
the bulk of the data thirty-five years old from 1977. Wrong lake with data
over a third of a century old!
3. In
our December letter, we expressed concern regarding the sheer volume of water
that would be taken from the lake or water table if the proposed development
proceeds. We are concerned about the potential draw of 4,471,250 gallons of
water from the supply (based on 250 gallons per day with 49 proposed homes). Can
the lake and water table sustain an additional draw of this annual amount?
4. Since
we wrote the December letter to the TNRD we have undertaken a water monitoring
program supported by the Ministry of the Environment and the British Columbia
Lake Stewardship Society.
Preliminary reports from our monitoring since ice-off in May, 2012
indicate an alarming increase in the phosphorous levels (over 1300%) and an
almost doubling of the Specific Conductivity of the lake since the reports
cited by Lakeshore Environmental Ltd. This information is in addition to the
concerns raised by testing of water samples taken from Lookout Road by
Interior Health prior to the installation of a filtration system mentioned in
Concern #5 in the December letter.
5. Since
earlier this year, the proposed development has moved over 60 feet closer to
the lake (from 60meters from high water mark to 40 meters).
Lakeshore Environmental Ltd.
was contracted to write the Cariboo District Lakeshore Development guidelines.
In that document, Mr. Holmes writes “ENSURE THAT (our capitalization) buffer
leave strips are required on ALL developments within 150 meters of a low
sensitivity lake and 250 meters of a high sensitivity lake to protect water
quality.” (Little Lac Le Jeune
would be defined as a High Sensitivity Lake.) He also states that “prior to further development there
should be a water quality sensitivity rating. This should include a map of the
lake basin morphometry, lake volume, depth, surface area, perimeter
development, chemical sampling of lake at spring overturn, calculation of mean
phosphorous concentration rate, calculation of flushing rate, watershed
boundaries and information on land uses within the watershed. Mr. Holmes also
recommended that a “Lake Carrying Capacity” measurement be done to “determine the
capacity of the lake to support additional development. Of course, none of
this good advice was followed when Lakeshore Environmental Ltd. wrote its
environmental impact study to support Lakeridge development.
6. We
were informed that an engineering firm would be hired to do an impact
assessment of the proposed development on the lake. This has not materialized.
7. We
described a number of anecdotal concerns in the December letter (refer to
concern #6). Subsequent to this, we were alarmed this spring at the significant
fish kill in the little lake. While there is usually some fish kill over
winter, long term residents report that they have never seen anything that
approached the magnitude of the fish kill this spring.
Perhaps Don Holmes of Lakeshore Environmental Ltd. said
it best when writing for the Cariboo District. “Even if each development was properly managed, this might
not be adequate to protect lakes from the cumulative impact of many
developments in high demand areas.”
Photographs to support these comments are available
online:
http://goo.gl/bosWu
Thank you for considering our concerns.
Sincerely,
David Wyse, President, LLJCA