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Sunday, December 18, 2005 3:50 PM
This submission/critique via email
on the final draft (#2) of the HRM’s
The reason we are copying to key
staff members of the HRM and to some councillors as well as to others is
explained in Section [XI].
Overall, we feel the
The Table of Contents is
self-explanatory by itself; hence those who do not have the time to digest even
this summary submission can get an `overview’ just by peeking at the eleven (11)
items in the Table below!
Salutations to all the hundreds of
recipients all over HRM, and have a spiritual
Christmas-2005; the Christmas link web page is titled, “'Twas The Night
Before Christmas, and All Through the Watershed”; you may all find it of timely
interest and I adapted it from the massive USEPA down
south!
Table of
Contents with internal shortcut links (the
underlined links here allow the recipient to jump instantaneously to a topic and
return here in literally seconds):-
[I] Preamble:
our primary interest and/or involvement with the Regional
Planning process inclusive of our several written submissions together with
copies of our DVD+R disks containing a vast array of scientific info as well as
20 (twenty) of our 323 half-hour Television shows featuring experts and
Government regulators (e.g., our littoral and underwater cleanups of KEARNEY and
SETTLE lakes; World famous ecologist, Prof. Dr. Evil Gorham DSc; Prof. Dandapani
Thirumurthy PhD PEng, TUNS, under whom most designers of STPs in HRM studied
under; John Theakston MEng PEng, Water & Wastewater Branch, NSEL;
[II] Significant
scientific shortcomings in Chapter 2: Environment, Draft
#2, Regional Municipal Planning Strategy. Erroneous definition of trophic
status used by HRM to date, alas!
[III] The major
scientists who developed the scientific basis of the Lake Carrying Capacity
(LCC) models enunciated in HRM’s Chapter 2 (Environment) are indeed
among our international Scientific Directors and/or
scientific associates; inspite of it, HRM has not paid any pragmatic
attention to our formal written submissions, alas!
[IV] Over-reliance on advisory boards has proven to be
futile!
[VI] The only
sustainable solution is to set up a powerful “LAKES
AUTHORITY” staffed by authentic applied (i.e., practical) limnologists as
proposed by us to the Regional Council in August-2001; such a body could liaise
with all citizens and build `meaningful
partnerships’
[VII] HRM’s
perpetual refusal to include the requirement of a
“QUALIFIED LIMNOLOGIST” in any and all studies involving lakes/rivers, as
well as in the scientific scrutiny of the work of various consultants (see also
Section V.2 of the year-2002 NSEL’s Storm Drainage Works
Approval Policy)
[VIII] Our co-operation with and subsidies given to the HRM and to its
former municipal units at the express requests we received via sixty (60)
unsolicited emails and/or via several follow-up phone calls (for a long time, I
was flattered that they consulted me though)
[IX] Our co-operation with various stakeholder groups and citizens
and the local academia who work for the stakeholder groups within
HRM
[X] Unsolicited compliments (and requests) received from
around the world which included the academia and Government
agencies
[XI] The reason we are copying to key staff members of the HRM
and to some councillors and to others
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[I] Preamble: our primary
interest and/or involvement with the
As an international scientific
society, we concentrate in our self-imposed mandate which is
Even in that, we focus in
BIODIVERSITY and BIOTIC INTEGRITY, since simple chemical sampling of lakes
carried out by/for HRM does not reveal much useful info, especially in shallow and/or dystrophic
lakes, as any research limnologist would attest
to!
Our individual associates, several
of whom are owners of expensive properties all over HRM (e.g., a major estate at
We made several formal written
submissions to your
During early year-2005, we submitted
several copies of our DVD+R disk to you containing a vast array of information
within the specialties of LIMNOLOGY, MOLECULAR BIOLOGY (which included tracking
of fecal suspects using DNA markers), and some MARINE BIOLOGY! They also
contained 20 of our 323 half-hour Television shows that we produced over the
years.
Copies of various versions of the
DVD+R disk were also donated to His Worship, to select Regional Councillors, to
the EMS Department, and to select members of the Halifax Watershed Advisory
Board (HWAB), all during year-2005!
During summer and Christmas of
year-2004, we had submitted copies of our CD+R disks to thirteen (13) of the
regional councillors! The CD+R disks, having lower capacity than the DVD+R
disks, did not contain the Television shows except for the one we produced with
Hence, we collaborated quite
extensively with the HRM and further historical collaboration can be seen in
Sections [VIII] and [IX].
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[II] Significant
scientific shortcomings in Chapter
2: Environment, Draft #2, Regional Municipal Planning Strategy. Erroneous
definition of trophic status used by HRM to date,
alas:--
There are essentially three parts in
this section, (Shortcomings in 2.3 Watershed Planning, E-17);
(Reference is made to the need for lake studies throughout
the Environment chapter); and (Shortcomings in 2.4 Functional
Plans, 2.4.1 Water Quality Monitoring Functional
Plan).
(II-1) Shortcomings
in 2.3 Watershed Planning, E-17:
It mentions studies to be carried
out but it omits that studies have to be carried out by a ‘QUALIFIED
LIMNOLOGIST”. This should be added there.
More on this in our Section [VII] below and we will not duplicate what we
already state there in some detail.
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(II-2) Reference
is made to the need for lake studies throughout the Environment chapter of the
Our section here on the proposed
LAKES
AUTHORITY goes into detail on how HRM could save a lot of money that it
plans to expend on consultants, but at the same time achieve tangible results to
citizens all over HRM!
The premise of basing one’s
conclusion on the limnetic (i.e., open water) parameters alone, as planned for
the near future as well as carried out to date, is wholly
flawed.
This is primarily because most lakes
in HRM are shallow and/or dystrophic. In such lakes, open water samples
generally do not reflect changes in the watershed unless those changes are
massive in relationship to the overall size of the watershed and/or in its
inputs!
To monitor `incremental impacts’ as
a result of new developments, it is far superior to sample at each and every
individual stormwater discharge, e.g., at storm sewer outlets, at outlets of
in-situ devices (CDS, Stormceptor, Vortechnics), and at outlets of
any constructed wetlands.
There are a host of reasons for
this, some of which is summarized in the web page, http://lakes.chebucto.org/shallow.html
but the reader is advised to study the leading published literature on
it.
Further, HRM and/or its consultants
(mostly being non-scientists in limnology) have made massive errors to date in
basing lake trophic status on limnetic parameters
only.
The legal definition as embellished
by Prof. Dr. Bob
Wetzel, a world renown limnologist, in his year-2001 textbook, is
“TROPHY OF A LAKE
REFERS TO THE RATE AT WHICH ORGANIC MATTER IS SUPPLIED BY OR TO THE LAKE PER
UNIT TIME”!
Somewhat similar cautions were also
noted by Environment Canada in their year-2004, 133-page narrative (http://lakes.chebucto.org/DATA/PARAMETERS/TP/ccme.pdf)
where they also cited the aforesaid reference of Prof. Bob
Wetzel.
The various trophic status tables of
the CCME are based on Environment Canada, and are meant only as a first
approximation. Cautionary notes on the shortcomings of same have been noted by
Environment Canada as well in their 2004 narrative referenced
above.
No consulting study to date for HRM
has reflected this legal definition of trophic status,
alas!
A recent major example failure was
at
=== And note the stern caution given
by Dr. Richard Vollenweider relating to severe shortcomings in setting of the
trophic states based on the routine fixed boundary which most local staff and
consultants have been doing; listen to just a 4-minute audio taping (http://lakes.chebucto.org/TPMODELS/OECD/vollenweider.mp3).
It was indeed Dr. Vollenweider’s work that both the CCME as well as Environment
Canada utilized in their standards! ===
[Return]
(II-3)
Shortcomings in 2.4 Functional Plans, 2.4.1 Water Quality Monitoring Functional
Plan:
We are deeply distressed that
advisory boards are included in the consultation loop but not the general
public; the general public also includes scientists and research engineers who
are lot more eminently qualified than any present members of the three watershed
advisory boards as far as the relevant specialties of APPLIED LIMNOLOGY and
STORMWATER TREATMENT are related! More info on this is in our Sections [IV] and [V]
below.
The approach of the HRM is
essentially `regressive’!
The solution is to hold informal
round table discussions with those of the general public that are interested in
extremely important aspects like Lake Carrying Capacities (LCC), Stormwater
treatments, etc.
Some of us have attended scores of
public info meetings organized by the P&D department, but staff never
discussed these in public, alas!
The round table methodology of
consulting the informed public is the way to go and see our web page, http://lakes.chebucto.org/INFO/STEWARDSHIP/communitygoals.html
on it.
Further, nowhere in the planning
documents did we observe firm commitments by the HRM mandating TOTAL STORMWATER
TREATMENT which is capable of removing almost all inevitable post-development
stressors to a high degree.
For urban stressors see, http://lakes.chebucto.org/SWT/pollutants.html
and for successful treatment case histories from elsewhere see, http://lakes.chebucto.org/SWT/treatment.html
Our web page on stormwater treatment
(http://lakes.chebucto.org/SWT/treatment.html)
also contains independent reviews of the low removal efficiencies, of the
typical post development stressors, in the insitu devices, e.g., CDS,
Stormceptor, and Vortechnics.
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[III] The major
scientists who developed the scientific basis
of the Lake Carrying Capacity (LCC) models enunciated in HRM’s
Chapter 2 (Environment) are indeed
among our international Scientific Directors and/or scientific associates;
inspite of it, HRM has not paid any pragmatic attention to our formal written
submissions, alas:--
Some leading scientists cited in the
CCME handbooks are either our formal Scientific Directors and/or
associates.
We even posses the original data
that those models were based on. Hence, we speak with considerable
authority!
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[IV]
Over-reliance on advisory boards has proven to be
futile:--
The whole aspect of professional
lake management is quite specialized and should not be restricted to advisory
boards which do not have any eminently qualified scientists in
No advisory board has published any
credible papers or handbooks relating to APPLIED LIMNOLOGY and BIODIVERSITY and
BIOTIC INTEGRITY of our invaluable freshwater
resources.
Hence, how can HRM rely totally on
such boards?
As appointees of the various
Community Councils, the advisory boards should definitely be consulted, but not
in exclusion to the public.
If the HRM does not include any and
all interested lake stakeholders, we herewith caution you that you will totally
fail in managing and/or restoring lakes, as has already occurred all over HRM,
alas!
You should learn from the past
massive failures of HRM and of its former component
municipalities!
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[VI] The only sustainable
solution is to set up a powerful “LAKES AUTHORITY” staffed by authentic applied
(i.e., practical) limnologists as proposed by us to the Regional Council in
August-2001; such a body could liaise with all citizens and build `meaningful
partnerships’:--
On August 21, 2001, we pleaded with
the Regional Council to set up such a Lakes
Authority.
Staff responded positively to the
Regional Council in a timely manner on September 19, 2001 (see http://lakes.chebucto.org/HRM/HISTORY/lakes_authority.html#staff),
but there has been no progress to date.
We once again plead that HRM set up
such a Lakes Authority staffed with only two to three limnologists. They all do
not need to have doctoral degrees, but it is preferable they have proficiency in
practical limnology and lake management.
In this manner, staff could carry
out in-house lake/river studies rather than expending large public funds on
mostly consultants who have no credibility in
limnology.
This Authority could also address
regular public concerns of lakes and rivers and could work pragmatically to
solve the problems rather than perpetually passing the buck, as has been the
case to date!
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[VII] HRM’s perpetual
refusal to include the requirement of a “QUALIFIED LIMNOLOGIST” in any and all
studies involving lakes/rivers, as well as in the scientific scrutiny of the
work of various consultants (see also Section V.2 of the year-2002 NSEL Storm Drainage Works
Approval Policy):--
HRM has never required a study by a
“qualified limnologist”, although pure common sense would dictate such a
requirement.
It is not unlike the need for a
cardiac surgeon to carry out a heart operation, and not by a general
practitioner (GP)!
But since year-2002, there has been
a provincial policy recommending that a study by a “qualified limnologist” is
preferable where lakes are located at outfalls or downstream of outfalls of
proposed developments (see Section V.2 in http://lakes.chebucto.org/DOE/sdwap.html#sdwap).
Our section here on the proposed
LAKES
AUTHORITY goes into detail on how HRM could save a lot of money that it
plans to expend on consultants, but at the same time achieve tangible results to
citizens all over HRM!
[UP]
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the Table of Contents]
[VIII] Our
co-operation with and subsidies given to the HRM
and to its former municipal units at the express requests we received via sixty
(60) unsolicited emails and/or via several follow-up phone calls (for a long
time, I was flattered that they consulted me
though):--
Our direct/indirect contribution to
the HRM has been in the range of $400,000 to $500,000 (2004 dollars); see the
overview letter we sent His Worship, Peter Kelly MBA (click on http://lakes.chebucto.org/HRM/CORRESPONDENCE/2004/mayor2004_10_3.PDF).
A sampling from the sixty (60) of
the emails that this writer received from HRM’s staff asking for info; many of
them needed extensive follow-up emails as well as phone discussions from this
writer (for a long time, I was flattered that they consulted me
though):--
From Renee Roberge PEng of the EMS
Dept., asking advice on Morris and
From Renee Roberge PEng of the EMS
Dept., complimenting me on my response to the above email: http://lakes.chebucto.org/EMAIL/REQUESTS/Roberge2000_Russell.html
From Renee Roberge PEng of the EMS
Dept., asking advice on
From Renee Roberge PEng of the EMS
Dept., asking advice on
From Renee Roberge PEng of the EMS
Dept., asking for donation of my treatise on freshwater macroinvertebrates: http://lakes.chebucto.org/EMAIL/REQUESTS/Roberge2002_Tolerance_Values
From Dr. Tony Blouin of HRM asking
for info on
From Dr. Tony Blouin of HRM asking
for info on constructed wetlands: http://lakes.chebucto.org/EMAIL/REQUESTS/blouin_wetlands2005.html
From Tomar Naipal PEng of the EMS
Dept., asking for INFO ON Long
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[IX] Our co-operation
with various stakeholder groups and
citizens and the local academia who work for the stakeholder groups within
HRM:--
Please see the relevant sections of
the web page, http://lakes.chebucto.org/accomplishments.html
as well as our overview letter to His Worship, Peter Kelly MBA, http://lakes.chebucto.org/HRM/CORRESPONDENCE/2004/mayor2004_10_3.PDF
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[X] Unsolicited
compliments (and requests) received from around the world which included the
academia and Government agencies:--
See our web page, http://lakes.chebucto.org/COMPLIMENTS/compliments.html
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[XI] The reason we
are copying to key staff members of the HRM and to some councillors and to
others:--
We have the ardent hope that they
would be interested based on their emails to us and/or on our recent/past
dealings with them.
Also Cc’d to relevant and dedicated
MLA’s and to the NSEL (Nova Scotia Dept. of Environment & Labour)’s Water
& Wastewater Branch.
Further, based on several of our
verbal discussions that we have had with some key members of the
We have also received emails to that
effect from His Worship Peter Kelly and from former CAO, George
McLellan.
The discussions referred to above
have not been exclusively this writer, Shalom M. Mandaville, had but also that
several of our associates had with HRM’s staff!
But overall, we feel that the
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Shalom M.
Mandaville Post-Grad Dip.,
Chair
& Scientific Director (902-463-7777)
Soil
& Water Conservation Society of Metro
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