Lake Waseosa Ratepayers' Association
c/o 21 Cottage Lane, RR#3
Huntsville, Ontario
Canada
P1H 2J4
September 26, 2008
Terry Sararas, Director of Planning,
Town of Huntsville
37 Main Street East
Huntsville, ON
P1H 1A1
Re: Application for expansion of Camp Huronda
File Number Z/41/2008/HTE (Camp Huronda)
Dear Sirs:
Camp Huronda, owned by the Canadian Diabetes Association, is a provincially significant resource for children facing type 1 diabetes. The Camp administration has historically demonstrated responsible management and good citizenship. The LWRA supports the principle of a controlled, responsible expansion of Camp Huronda.
We have been aware of their general intent and preparations for the last several years. They have kept us apprised of their plans both through meetings with our Board of Directors and presentations to our membership. These preparations have included long-term studies designed to explore the impact further expansion will have on the water quality of the lake. On two occasions, our membership has passed a motion supporting the expansion plans in principle.
We are aware of a considerable delay and expense in the planning process that resulted when one portion of the groundwater investigations were found to be invalid. Where it not for the decision to expand the investigation, it is possible the CDA would have made this application a year ago.
While the Camp did not made formal application prior to adoption of the new Comprehensive Zoning By-law we suggest that in view of the responsible long-term planning process leading to this application, provisions which might otherwise serve to prevent this expansion should be waived.
The planning process has been an exercise in refinement. Over time it has evolved to the current application and the various designs and studies, having been completed at various times, reflect these refinements. This past summer, the CDA provided the Board of Directors with the completed collection of these studies, and we have now had the opportunity to review them in detail.
The current expansion plans consist of two fundamental intentions. First and foremost is the intent to expand the capacity of the camp's residential facilities to accommodate an increase of staff and campers in residence at any one time. The second is the intent to expand the operation of the camp from it's traditional seasonal use into year-round capability.
The original design criteria of the proposed tertiary septic treatment system by Kontek Engineering was for a total of 260 persons. Having studied past usage patterns, the CDA suggests that this system is actually capable of handling the effluent of up to 290 persons. This approach of refining a design based on empirical data has a sound scientific basis.
That said, in this case, it does not necessarily apply as the underlying assumption is that past usage will remain constant, in contrast with the expressed intent to extend the season. While off-season use will likely produce lower daily consumption that the peak consumptions the system is designed to handle, the total annual production is liable to increase. It may well be possible that the system could handle more than 260 residents, it should not be considered until and unless proven under the proposed expanded season. Note that we are specifically referring to residents, that is, those for whom sleeping accommodation is provided. This should not be deemed to limit the occasional and infrequent visitation by day visitors, such as may occur during such events as intramural competition with other area camps, "Parents' Day" and so forth as such temporary visitors are not prone to high consumption activities.
The redesign of the septic system abandons the use of old bed #10. However, it suggests that the bed could be reconnected in the future if additional capacity is needed. This bed is located far closer to the lake than would be permitted under current practices. The LWRA believes this bed should be decommissioned permanently. If further capacity is required some time in the future, a new bed located an acceptable distance from the lake should be constructed.
We note the presence of a pipe intended to by-pass the tertiary treatment equipment, controlled by a valve. Such a bypass may be necessary in times of maintenance or repair but constitutes a potential human error failure point. If inadvertently left open, it would render the tertiary treatment equipment ineffective. There should be a written procedure governing operation of this valve and all related equipment. This valve should be an indicating type such as an OS&Y or PIV. It should be secured in the closed position and automatically monitored via the same system monitoring pump operation. If this is not practical for technical reasons a protocol of regular logged visual inspections at intervals of not less than weekly should be mandated. Log books of said inspections should be maintained on site at all times.
The plans and studies are silent on the effluent from livestock. Animal husbandry has been demonstrated to be a significant contributor to nutrient accumulation in water bodies. Currently the camp maintains a stable of horses during the summer season. Any increase in this number should not be contemplated prior to a comprehensive study of the impact and any available remedial measures.
The Storm Water Management Report is equally vague on the impact of human activities on soil erosion after construction has been completed. This has historically been a challenge for the camp, requiring regular maintenance, and will only become a greater challenge with increased use. Some areas of this site are gently sloped but other areas, particularly along the north end of the shoreline, are relatively steep. Of particular concern for the LWRA is the lake trout spawning area identified in the Fish Habitat Assessment, which would be particularly sensitive to runoff and silting. While hard landscaping could mitigate some effects, it is not consistent with Huronda's general philosophy nor is extensive hard landscaping consistent with good shoreline management practices. Children being children and apt to follow their own paths, it is of dubious benefit anyway. Alternative measures may be required both in terms of guiding traffic patterns and reinforcing soils. A long term monitoring program should be in place following site construction.
In summary, the LWRA recommends and requests that the expansion of Camp Huronda be permitted, subject to the following:
- That occupancy be limited to 260 over-night residents, not including occasional day activities.
- That old septic bed number 10 be fully decommissioned and not considered for future use.
- That the bypass valve around the tertiary septic system be monitored electronically and/or manually and records be maintained of all tests and inspections.
- That the number of livestock kept on site be maintained at the current level until and unless it can be demonstrated that changes will not impact sub-surface or lake water quality.
- A long-term soil erosion and runoff monitoring plan be established.
Sincerely,
Bruce Howlett, President
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c/o 21 Cottage Lane, RR#3 • Huntsville, Ontario • P1H 2J4 Phone: 705-788-3693 • Fax: 705-788-9126 • secretary@lwra.net |
cc Lanny Dennis, Associate Planner, Wayne Simpson and Associates
Gary O'Conner, Director, Canadian Diabetes Association
John Davis, Councillor, Town of Huntsville (Chaffey Ward)
Brian Thompson, Councillor, District of Muskoka