February 12, 2002

The Commission’s review and comments on the Stage 1 and 2 Wheatley Harbour RAP reflect an assessment of the document submitted in relation to the seven Stage 1 and 2 requirements outlined in the introduction , consideration of the implementation of an ecosystem approach to the restoration and protection of beneficial uses, and an assessment of adequacy of public consultation.

Is the environmental problem detailed and defined?

The document describes five existing beneficial use impairments. These are: restrictions on fish and wildlife consumption, degradation of fish and wildlife populations, restrictions on dredging activities, eutrophication or undesirable algae, and loss of fish and wildlife habitat. This description of the environmental problem in the AOC appears reasonable with the exception of the described status of the restrictions on fish and wildlife consumption. This status should be updated to reflect current information. Table 1 of the document states that all fish are safe for human consumption except for certain size classes of carp, white bass, and channel catfish. This table also states that as of 1995/1996 no separate consumption guideline is provided for Wheatley Harbour. The 2001-2002 Guide to Eating Ontario Sport Fish outlines restrictions for the consumption of yellow perch, white bass, brown bullhead, channel catfish, carp and freshwater drum from Wheatley Harbour. Therefore, the status of this use impairment should be updated to note that a separate advisory for Wheatley Harbour has recently been published and consumption restrictions are recommended for the 6 fish species noted above. It would be informative to directly compare the Wheatley Harbour restrictions to those of Lake Erie.

The RAP notes the historical discharge of polychlorinated biphenyls (PCBs) from fish processing plants in the AOC. In 1983 and 1984, trace concentration of PCBs were detected in Omstead Foods Limited’s effluent. According to the RAP, PCB contaminated sediment in the harbour is being land disposed after dredging. The document also notes concern in regard to potential leaching from unconfined sediment disposal sites. Since the document notes that sediment PCB concentrations are 2 to 5 times higher than the Provincial Sediment Quality Guidelines and above levels noted in Lake Erie, it would be useful to adopt a monitoring program as recommended in the RAP document. Data from this monitoring effort would allow a more precise definition of the environmental problem that is posed by the contaminated fish.

Are the causes of the use impairment defined?

The RAP provides a comprehensive definition of the causes of use impairment. As noted above, a more detailed monitoring program for PCBs in the AOC would allow a more precise description of the causes of the fish and wildlife consumption use impairment.

Have in-place remedial measures been evaluated?

Improvements in water quality parameters that have accrued as a result of remedial measures are captured in Chapter 3 of the Stage 1/2 RAP. Major upgrades to industry wastewater treatment systems that have been completed over the past two decades have resulted in improved water quality.

Have alternative additional measures to restore beneficial uses been evaluated?

Alternative additional measures were evaluated in a draft remedial options discussion paper. The contents of this paper were then compiled and used in consulting the public.

Have additional remedial measures to restore beneficial uses been selected?

The RAP Team met with local residents, industry representatives and other stakeholders for the purpose of selecting additional remedial measures. A listing of the entire array of possible measures and a set of evaluation criteria were utilized to facilitate the selection process. This information is presented in Chapter 7 of the RAP document. The selected remedial measures are referred to as the proposed remedial measures and are enumerated in Table 8.1 of the RAP document.

Has a schedule for implementation been adopted and have persons and agencies responsible for implementation of remedial measures been identified?

No specific schedule for implementation is detailed in the RAP document. Responsible persons and agencies are clearly noted in the document.

Has an ecosystem approach been taken to the restoration and protection of beneficial uses?

The RAP document endorses the utilization of an ecosystem approach to the restoration and protection of beneficial uses. Specifically, the document notes that the principle of the ecosystem approach was central to the selection and evaluation of the options for remediation. Based on this information, it appears the RAP effort has utilized an ecosystem approach to the restoration and protection of beneficial uses.

Was the public consulted adequately?

Public consultation efforts of the Wheatley Harbour RAP effort are well documented since 1988. More recently, AOC residents were invited to participate directly in the selection of recommended actions to restore and protect water quality in the AOC.

Conclusion

The environmental problem is reasonably well documented in this Stage 1/2 RAP. With minor updating, the documented beneficial use impairments will reflect existing conditions in the AOC. The proposed remedial measures are sound and require only the addition of a schedule for implementation.