HomeMy WebLinkAboutINS-16-009 - Department of Fisheries and Oceans Canada Habitat Banking Agreement
REPORT TO: Community and Infrastructure Services Committee
DATE OF MEETING: February 8, 2016
SUBMITTED BY: Hans Gross, Director, Engineering Services
519-741-2200 ext.7410
PREPARED BY: Nick Gollan, Manager Stormwater Utility
519-741-200 ext.7422
Melissa Ryan, Design and Construction Project Manager
519-741-2200 ext.7827
WARD(S) INVOLVED: All
DATE OF REPORT: January 21, 2015
REPORT NO.: INS 16-009
SUBJECT:Department of Fisheries and Oceans Canada Habitat Banking
Arrangement
____________________________________________________________________________________
RECOMMENDATION: That the Mayor and Clerk be authorized to execute a habitat
banking arrangement document with Her Majesty the Queen in Right of Canada
as represented by the applicable signing officers of the Department of Fisheries
and Oceans, that any Deputy CAO be authorized to execute any renewals of said
arrangement document on behalf of the City, and that applicable staff within the
City's Stormwater Utility be authorized to execute any routine reports and other
documents that may be required from time to time in connection with the
administration of the habitat banking arrangement.
BACKGROUND:
The Stormwater Utility wishes to enter into an arrangement with the Department of
Fisheries and Oceans Canada (DFO) for the purposes of creating a fish habitat bank for
the 1.8 km stream naturalization works that occurred at Filsinger Park on the Henry
Sturm Greenway and Sandrock Greenway completed in 2015. This habitat bank
outlines the positive enhancements and/or creation of fish habitat obtained from this
type of work and reflects endorsement from the DFO. The banking arrangement would
require the signature of the Mayor and Clerk however it is a non-legally binding
document that is intended to be used as a guide for how “credits” are to be accumulated
for this type of work. It will require that monitoring of this stream be completed however
there will be minimal costs involved as the City currently monitors a number of creeks
within the City through the annual Stormwater Management (SWM) Audit. A summary
*** This information is available in accessible formats upon request. ***
Please call 519-741-2345 or TTY 1-866-969-9994 for assistance.
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of the conditions of the stream will be provided to DFO on an annual basis. Additional
fish habitat enhancements could also be added to the bank in the future as well.
Should there ever be a project undertaken by the City that might cause serious harm to
fish through projects such as a road widening that crosses multiple watercourse, a
sanitary sewer crossing beneath a creek, construction of bridge abutments within a
watercourse, etc. a Fisheries Act Authorization may be required. Under the Fisheries
Act, projects that require an Authorization also require a suitable “offset” plan. The
existence of a viable habitat bank streamlines the authorization process. With the
“offset” completed and approved by DFO prior to carrying out the works, the City would
be exempt from the requirement of a costly “Letter of Credit”, minimize time for
approvals and lower its regulatory risk. In a banking scenario, the City would be able to
“debit” the approved “credits” that have been banked for Filsinger and any other banking
projects the City may undertake in the future that meets conditions of this arrangement.
In contrast, the City of Waterloo recently had to obtain a Letter of Credit worth
approximately $400,000 as a requirement by the DFO prior to undertaking stream works
in Forwell Creek to provide a contingency fund to DFO in case the offsetting plan was
not built or did not meet the conditions of the Authorization. If the City of Kitchener were
in a similar situation, having a habitat bank might give the City the option to use the
banking done on the Henry Sturm Greenway and Sandrock Greenway as fish habitat
“credits” that would represent an approved offsetting plan and thus help speed up the
approval time, reduce costs, respect previously completed works, be exempt from the
requirement of a Letter of Credit and all but eliminate regulatory risk of the offsetting
plan failing.
REPORT:
The Department of Fisheries and Oceans Canada has had proponent led fish habitat
banks in place in various parts of the country for a number of years. These banks are
generally set up in anticipation of future habitat impacts elsewhere in the system. This
makes creek restoration work more effective as longer channel work can be done and
be proven to enhance fish habitat ahead of any future negative impacts. The level of
risk to DFO and to the proponent is reduced and therefore costs and approval time is in
turn reduced.
The arrangement is valid for five (5) years with the ability to renew on an ongoing basis
and would establish certain monitoring requirements. These monitoring requirements
can easily be incorporated into the annual SWM Audit monitoring that the City has been
undertaking since 2002 which consists of water quality and biological monitoring of
various creeks across the City.
Once a banking arrangement has been created, additional fish habitat enhancement
projects can be added. It is anticipated that the list of potential additions will be known
as the City is concurrently working on the integrated SWM Master Plan which will
identify the priority of capital and maintenance work to our stormwater management
assets, including any creek rehabilitation, for the next 15 years. The list of proposed
works can be vetted through DFO staff to help determine which projects might be
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eligible to be banked and thus this banking potential can be included in those projects at
the time when we are retaining consultants and preparing detailed design plans.
There is no risk involved in signing this arrangement as it is not legally binding. No
future offsets or debits (i.e., works causing serious harm to fish) are anticipated in the
near future. It is recommended that the City capitalize on this opportunity and by taking
part in the arrangement, it helps to solidify DFO’s acknowledgement and endorsement
of the positive and environmentally beneficial work that the City of Kitchener has
undertaken. It is noted that DFO does not allow a bank to be created once the work is
completed and therefore we wish to conclude this arrangement promptly in order to
meet their timing requirements. Discussions with DFO had begun prior to the
completion of the project and took almost a year to complete as they were in the
process of creating a national habitat template when we began the process.
The City’s Legal division has been consulted and recommends that the Mayor and Clerk
be authorized to execute a habitat banking arrangement and that any Deputy CAO be
authorized to execute any renewals of the said arrangement document on behalf of the
City, and that applicable staff within the City's Stormwater Utility be authorized to
execute any routine reports and other documents that may be required from time to time
in connection with the administration of the habitat banking arrangement.
ALIGNMENT WITH CITY OF KITCHENER STRATEGIC PLAN:
The recommendation of this report supports the achievement of the city’s strategic
vision through the delivery of core service.
FINANCIAL IMPLICATIONS:
Minimal as the only requirement for the City will be to provide annual monitoring reports
which can be done using the existing framework for the annual SWM Audit. In the long
term this arrangement may present a significant cost savings opportunity to the City.
COMMUNITY ENGAGEMENT:
INFORM – This report has been posted to the City’s website with the agenda in
advance of the council / committee meeting.
CONSULT – The stream naturalization project was previously vetted through the public
via two Public Information Centres as well as through letters to residents prior to
construction. A dedicated webpage was created and frequent updates were made as
the project progressed. A tour of the project was held in the summer of 2015, which a
few residents attended, to highlight the environmental benefits of the stream
naturalization and ever since construction began, the City has received comments in
support of this work.
ACKNOWLEDGED BY:
Justin Readman, Interim Executive Director of Infrastructure
Services
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