The Commission's evaluation of a RAP at any stage includes consideration of an ecosystem approach to the restoration and protection of beneficial uses and an assessment of the adequacy of public consultation as well as the Annex 2 requirements for that particular stage RAP submitted for the Commission's review and comment. Thus, the Commission's review and comments on the Stage 2 Severn Sound RAP reflect an assessment of the document submitted in relation to the five Stage 2 requirements outlined in the introduction , consideration of the implementation of an ecosystem approach to the restoration and protection of beneficial uses plus the two general principles. These 7 aspects of the document are addressed in turn.
An evaluation of remedial measures in place
Chapter 4 of the Stage 2 RAP is entitled Evaluation of Remedial Actions. This chapter notes five actions which had already been undertaken such as a Severn Sound shoreline pollution survey that included an examination of private sewage systems. The document and the RAP have taken a proactive approach toward remediation and the RAP outlines actions that have occurred when the need for remedial actions became obvious. No evaluation of these actions is presented in the document.
An evaluation of alternative additional measures to restore beneficial uses
The RAP outlines nine categories of recommended actions resulting from discussions of remedial options with technical experts, the Public Advisory Committee (PAC), interest groups, and key stakeholders. The document provides an extensive evaluation of each recommended action. The evaluation regarding potential actions to reduce phosphorus concentrations and loads is particularly comprehensive.
Two of the proposed Severn Sound delisting objectives are "to encourage the restoration and creation of fish habitat in target areas by proponents of new shoreline development" and "to develop plans for rehabilitation or development of new coastal wetland areas as opportunities arise". It will prove challenging to measure progress towards these objectives without additional information. Page 116 of the RAP states "Sufficient information about fish habitats in Severn Sound is only available to develop an interim fish habitat management plan . ." While the document reflects targets of the interim fish habitat management plan, evaluation of an array of numerical goals for the restoration and protection of wetland habitats would be beneficial.
The RAP was printed in April 1993 with much of the data provided even earlier, such as the number of boatslips and the decrease in wetland habitats. Capturing these data over time will be critical to tracking the progress in the RAP and evaluating the effectiveness of measures. Additionally, as the fish habitat management plan becomes finalized, an opportunity exists to quantify how habitat losses or threats from development will be addressed.
A selection of additional remedial measures to restore beneficial uses
Chapter 6 of the Stage 2 RAP details priorities for action. Accordingly, the selection of measures recommended to the restore beneficial uses has been completed. The document notes that the public is interested in seeing virtually all of the remedial options implemented. In addition, several actions already taken by the RAP Team to promote implementation are outlined. These actions (Page 147) include:
The action involving support for demonstration of a no-till drill complements the encouragement of the adoption of conservation tillage and accordingly, if conservation tillage is selected as a remedial action, it would be productive to track "before and after" application rates of conservation tillage so that an estimation of environmental benefits that accrue can be accomplished.
A schedule for their implementation and an identification of the persons or agencies responsible for implementation of remedial measures
A detailed 5 year implementation schedule is presented in Table 6.1 (Page 149) for the phosphorus control strategy. This schedule includes construction costs where appropriate. This proposed "fast track" scenario of RAP implementation was slated for 1992/93 to 1996/97. Implementation priorities and responsible implementors for all the proposed remedial actions are outlined in Table 6.2. Responsible leads include municipalities, landowners, provincial ministries, and conservation groups.
An ecosystem approach to restoring and protecting beneficial uses
The Stage 2 RAP does not specifically mention the adoption of a systematic and comprehensive ecosystem approach to restoring and protecting beneficial uses. It is unclear if impacts of certain predicted future conditions, noted on page 144, such as the proposed 2,600 condominium units and the planned 2,600 additional boat slips are fully incorporated, beyond predicted future water supply and sewage treatment needs, in the RAP. While potential economic benefits in regard to these developments are mentioned, no details of potential adverse environmental effects are provided.
The document notes (Page 52) the potential of mercury contamination from either regional geological or atmospheric sources, but no further information is provided on either pathway. The report also states that "no apparent sources of mercury exist within Severn Sound." However, Table 2.7 (Page 49) shows the mercury levels for Penetang Bay considerably higher than for the surrounding areas which might indicate a local source. If a local source is confirmed, consideration should be given to developing a remedial measure to the extent warranted. Further information on the pertinent pathway(s) related to mercury levels in fish could contribute toward protection of the objective to have no restrictions on consumption of fish and wildlife from Severn Sound attributable to local contaminant sources.
The Interim Fish Habitat Management Plan for the Severn Sound which is dated August 1993 does mention an ecosystem approach in its foreword. This interim management plan also notes "the construction of marinas and mooring area has lead directly to losses of wetlands." An opportunity exists to better explain the effect of wetland loss on the ability to restore and protect certain beneficial uses.
The public is consulted in all actions undertaken
Chapter 7 of the RAP acknowledges the role of the public in RAP development and details public consultation in decision making. The public involvement program wisely aimed their effort at important target groups. Public consultation efforts were also divided into phases beginning with an effort to inform and educate the public about the RAP process and concluding with obtaining public feedback on the draft RAP for Severn Sound.
The Commission notes that the Severn Sound Environmental Association (SSEA), established on January 1, 1997, includes among its responsibilities the duty "to involve the Severn Sound community in remediation, monitoring and conservation." SSEA continues to support the Public Advisory Committee (PAC) and the PAC continues to meet monthly to keep up to date on projects and monitoring results and to discuss environmental issues that affect Severn Sound.
The RAP document appears to confirm that adequate public consultation occurred during RAP development. The PAC continues to provide the public with adequate opportunity for meaningful consultation during the implementation of remedial measures.
Conclusion
The Severn Sound Stage 2 RAP outlines remedial actions selected for implementation in a satisfactory manner. The 1993 RAP document notes that research into fish and wildlife habitat is expected to be completed by 1995. Implementation of "fast track" implementation elements, other remedial measures determined by the fish and wildlife habitat research and remedial actions outlined in Table 6.2 should result in improved water quality conditions within the Severn Sound AOC. The Commission looks forward to the confirmation of restored beneficial uses in its future review of a Stage 3 RAP for Severn Sound AOC.