COMMENTS RECEIVED
FOR THE
DRAFT LSRCA TECHNICAL
GUIDELINES FOR
STORMWATER MANAGEMENT
SUBMISSIONS
R.J. Burnside (Clayton Capes, MSc., P.Eng, Senior Project Manager) –
Comments dated May 20, 2016 regarding the Draft V. 2 Guidelines are
as follows:
1. Section 2.0 – Distribution and Minimization of runoff – The LSRCA has added a
new point regarding the accounting for different storm events. Long duration
rain on snow modelling would require a continuous model rather than a
discrete storm event modelling approach. Is the LSRCA suggesting that a
continuous model be applied? If so please indicate the data source and
requirements (temperature data, wind data, snow pack conditions, degree
days melting etc.). This modelling can become very complicated and models
such as SWMHYMO are not designed to run continuously.
2. Section 2.2.2.2 Flexible Treatment Alternative/Appendix B – Credits
On Page 9 item ix. The LSRCA should define “poor soils” it can be inferred
from Step 2 of Appendix B that poor soils is defined by an infiltration rate of
less than 15 mm/hr which should be repeated here to confirm that when soil
infiltration rates are less than 15 mm/hr no volume credits will be given BUT
flexible options are available when trying to address the 25 mm infiltration
target. In addition we do not agree with an upper limit on the infiltration
rate. It is these areas that should be utilized to the fullest, clean water (roof
tops etc) routed to these areas do not require a slower percolation rate
through them to ensure the quality of the flow. Areas of very high infiltration
could be utilized to their full potential with appropriate quality controls in
place prior to discharge to the soil layer.
Nottawasaga Valley Conservation Authority (Glenn Switzer, P. Eng.,
Director of Engineering and Technical Services) – Comments dated
March 16, 2016 are as follows:
We have a look at the draft guidelines and in general they follow the NVCA
guidelines very closely. As I discussed with you earlier we are using the MTO IDF
curves in the absence of municipal guidelines. If you’re interested, they can be
found at http://www.mto.gov.on.ca/IDF_Curves/terms.shtml. We find these to
be higher than the EC curves for individual stations.
Your concept for LID credit is quite interesting and we have a few comments for
you:
1. We wondered why soils with infiltration rates less than 15 mm/hr would
not be eligible for credits. Without credits there is no incentive to install
LID and soils with this infiltration rate can still support LID
2. Some of the tests may be difficult to determine such as the feasibility of
restoration to original function. Perhaps a little more description of what
you are looking for in evaluating these factors would be helpful
3. I didn’t see any mention of safety factors in the design of LID. Are you
following the MOE manual for this?
Town of Uxbridge (Ben Kester) in consultation with Stantec (Sheldon
Smith, MES, P.Geo.) - Comments dated March 8, 2016 are as follows:
1) The guidelines would benefit from a clear statement regarding
the CA’s interest and regulatory jurisdiction in stormwater
management
Discussion of CA role in development review and added
paragraph on Climate change and extreme wet weather
considerations
2) The glossary should be expanded to include important terms such
as “linear development” “non-linear development” and many
other terms found in the guideline but not defined
Included an Abbreviations section at document front and
expanded on Glossary
3) Pre-submission consultation – summary memorandum – will the
CA acknowledge, review and provide comment to the summary
memorandum?
Text changed from “It is also good practice to circulate a
summary memorandum…” to “It is also required that a summary
memorandum be circulated…”. This is a key acknowledgement
as the now required summary memorandum becomes a terms of
reference for the project.
4) Winter salt-temperature and bottom draw outlets – the statement
is made on page 12 that “… a bottom draw outlet, while effective
a(t) mitigating temperature concerns, may create concerns
related to high salt concentrations as discussed in Section 2.3.3”.
Dissolved salts make water denser which will stratify over time to
denser high salt concentrations toward the bottom. A bottom
draw facility continuously takes water from the bottom serving to
reduce the formation of stratification. Therefore bottom draw
facilities would appear to be an effective approach to mitigating
stratification and high salt concentration release. Please provide
more explanation and justification regarding the use blended
outlets.
Have not addressed this comment.
Further, have now included minimum criteria for blended outlets
with the bottom draw outlet a minimum of 0.6 m from the bottom
and the top a minimum of 1 m the water surface. Ned to
recognize that thermal-and chemostratification are both driven
by density factors. Cool water to 4 C stratifies to lower depths as a
thermocline. Higher salt concentrations make water denser,
stratifying to lower depths as a halocline. SWM ponds are
relatively shallow and if designed appropriately should have
sufficient catchment area to cycle volumetric replacement.
Density gradients in SWM ponds are created due to several
reasons:
a) The sediment forebay normalizes and reduces the turbulence of
the inlet inflow stream through the forebay berm reducing flow
velocity in the pond permanent pool cell. Thus inflows lack the
turbulence to break up density gradients established in the
permanent pool cell.
b) The second driver to density maintenance is our local weather
patterns which typically provides several days of inter-event
period when a SWM pond may not be discharging, facilitating the
time required to stratify an otherwise well mixed waterbody;
c) The third is the outlet configuration. Outlets established too high in
the pond water column facilitate the development of cooler and
higher salinity zones beneath the outlet invert. If a bottom draw
outlet is used it provides a mechanism that continuously releases
bottom water. Thus preventing the formation of haloclines and
thermoclines.
5) In Section 2.3.5.1 the statement is made “However, oil-grit
separators will not be permitted as a standalone control.” Please
elaborate – will OGS units not be permitted alone for retrofits with
limited space availability for LIDs?
Have removed the previous statement that OGS units will not be
permitted as a standalone control. Section 3.3.4.1 now permits
consideration for linear development where use of other quality
control measures are not feasible.
6) Section 2.5 – water balance calculations – how can domestic
water uses such as lawn watering be accounted for?
Not mentioned/addressed
7) Section 3.3.1 – Water quality credit – Please explain how the water
quality credit will be implemented with respect to permanent
pool/total volume storage requirements of SWM end of pipe
facilities and confirm whether MOECC will concur.
Indicating that volumetric credit from infiltration and filtration
system LIDs can be used against the volume requirement for the
Pond wet pool. Does not indicate if the volumetric credit will be
1:1. The qualifying LID must be on municipal property or on an
easement for long term monitoring/maintenance. MOECC and
local municipality must be consulted on the applicability of the
credit. No credit can be applied at the FSR/DPA stage.
Unfortunately, this is the stage at which the Pond block is
developed. Thus if no credit can be gained early in site planning,
the developer will have to plan the site in such a way that
potentially allows more developable lots with no guarantees or
clear criteria to the establishment of water quality credits
acceptable to all regulatory parties.
8) 3.3.4. Oil/Grit Separators – OGS units will be assigned a maximum
TSS removal rate of 50% - With Total phosphorus in stormwater
having a particulate phase component please explain why OGS
units are not being assigned any TP removal?
Statement regarding OGS units not providing Phosphorus removal
removed
9) Section 3.4 – This section indicates “…after the pre-consultation
meeting and charrette has been held in accordance with Section
2.0”. There is no charrette mentioned in Section 2.0. Please clarify
and provide clear expectations of the pre-submission meeting.
”Charrette” removed and indicate that pre-submission meeting is
to be undertaken as per Section 2 of the Guidelines
10) Section 3.5 -Climate Change – what are the Guidelines
recommendations regarding climate change
Section 1.1 now discussed the Ontario Climate Change Strategy
(2015). Section 3.5 now refers to the 2010 MOE document “ Policy
Review of Municipal Stormwater Management in the Light of
Climate Change – Summary Report” regarding climate change
adaptation with respect to stormwater management design. The
guidelines indicate that implementing Guideline
recommendations including the Better Site Design approach and
others will aid in building better climate change resiliency.
11) Appendix A – Section 4 – “…and meander belt assessed
(confined stream systems only). Note that meander belt width
assessments are only required for unconfined of semi-confined
systems
Error persists – now in Section 3
12) Appendix F – “Use stream modeling software such as Geo-X
v.4.3b (or approved equivalent)…” Please identify what Geo-X is
and what is meant by “an approved equivalent”
Still there. How can practitioners use a model or determine an
equivalent if there are no references to the model determining
who makes it, sells it or exactly what it does?
Town of Whitchurch-Stouffville (Dan Kenth, P.Eng., Manager of
Engineering Services) - Comments dated March 15, 2016 are as
follows:
The development industry would benefit greatly from these guidelines as it
provides guidance and clarification of what would be considered an acceptable
submission. I only have two comments to the document, which are noted below:
1. Infiltration Measures for Peak Flow Control
From a practical point of view, providing credits for using LIDs from a quality
control perspective makes sense. However, providing LID credits for quantity
control measures may have drastic implications especially if the LIDs
fail. Cumulative approvals of these credits within a watercourse reach could
cause downstream flooding in the case of LID failure. Appendix B in your
guidelines eludes to the possibility that LIDs may fail; unfortunately, it does not
provide a remedy. The document should ask applicants to provide alternative
quantity control measures within the watercourse reach to mitigate these
types of concerns.
2. Appendix A Stormwater Management Report Checklist
The checklist should state that if there is a discrepancy between the LRSCA’s,
Municipal, and the MOE requirements, then the more conservative
requirements should prevail.
March 15, 2016
Mr. Tom Hogenbirk
Manager of Engineering
Lake Simcoe Region Conservation Authority
120 Bayview Parkway
Newmarket, ON
L3Y 3W3
Sent via email to: [email protected]
Dear Mr. Hogenbirk,
RE:
LSRCA Draft Technical Guidelines for Stormwater Management Submissions
The Building Industry and Land Development Association (BILD) would like to acknowledge
and thank the Lake Simcoe Region Conservation Authority for the opportunity to comment
on the conservation authority’s Draft Technical Guidelines for Stormwater Management
(SWM).
First, we acknowledge that the purpose of this document is to provide guidance on the SWM
and erosion/sediment control requirements of LSRCA. BILD appreciates that the guidelines
have been developed in order to facilitate better site design throughout the LSRCA watershed
by promoting natural hydrology treatment and Low Impact Development (LID) methods. We
also appreciate that these guidelines are intended to apply a uniform set of standards, provide
consistent stormwater management requirements and fairness to proponents, reduce the need
for resubmissions, streamline the review process and improve client service. For this review,
BILD solicited comments from its Simcoe, Durham and York Chapter members. Below is a
consolidated list of these comments.
Section 1.0 Introduction
Page 1: BILD members suggest that “environmental friendly and sustainable manner” in the
first paragraph could be reworded to strengthen the conservation authority focus. BILD
members suggest replacing it with “environmentally sustainable manner” as sustainability requires
consideration of social and economic impacts outside of the conservation authority or
environmental scope.
Page 1: BILD members note that in the list of types of development review (d) should specify
“toe” erosion study.
Page 1: BILD members note that reference to the Ministry of Environment (MOE) should be
revised to the Ministry of the Environment and Climate Change (MOECC). There are other
instances throughout the document where MOE should be revised to MOECC.
Section 2.0 Stormwater Management
Page 3: Generally, BILD members note that there is no mention of biodiversity in the
document. Specifically, BILD members note that under the “Open space protection and
restoration” and “Distribution and minimization of runoff” bullets there is no mention of
biodiversity, which should be the focus of reforestation. Therefore, BILD members suggest
that LSRCA contemplate adding a biodiversity focus to the document that addresses its
importance as a contributor to the stabilization of natural areas and its associated benefits such
as erosion protection and habitat stability/revitalization, to name a few.
Page 3: With regards to the example of building landscaping being used as a vegetated area for
stormwater treatment, BILD members note that the MOECC will not allow infiltration
within 5 metres of a building envelope. Therefore, it is virtually impossible to use the building
landscaping of low setback infill developments for stormwater treatment.
Section 2.0 Pre-submission Consultation
Page 4: BILD members seek clarification that a pre-submission consultation with LSRCA is
required on all plans of subdivision and site plans greater than 2 hectares, even if the site is not
in a regulated area and is outletting to an existing municipal storm drainage system.
Page 4: BILD members suggest that the second paragraph be reworded to say “the presubmission meeting shall only occur after the developable area on the property has been
estimated by the applicant as it relates to…”. This is to account for scenarios where the
developable area on the property may not have been fully determined by the time a presubmission meeting is desired.
Section 2.1 Stormwater Management Requirements
Page 5: BILD members seek clarification on the purpose of the table on page 5. The
introduction to this table suggests that it includes criteria and requirements; however, it only
speaks to general objectives. We suggest that this should be clarified or revised. BILD
members also note that this table is missing a table number.
Page 5: BILD members suggest that a reference to the MOECC SWM Manual be added to
this section as the document does not contain any reference to targets for temperature or other
contaminants, which is consistent with the MOECC Manual.
Page 5: BILD members seek clarification as to why LSRCA SWM submissions must meet the
requirements set out in the Low Impact Development Stormwater Management Planning and Design
Guide, 2010, CVC & TRCA. These requirements apply to different watersheds and are meant
as a guide, not a manual or criteria.
2
Page 6: BILD members recommend that filter strips and buffer strips be moved from the
“End-of-pipe” section to the “Conveyance Controls” section, as these measures are more
conveyance controls. In addition, biofiltration should be added to the infiltration basins (i.e.
“infiltration and biofiltration basins”) listed under Conveyance Controls. BILD members also
recommend that underground storage be added to the “End-of-pipe” list.
Section 2.2.1 Peak Flow Control
Page 6: BILD members recommend that the first sentence start with “Typically, the increase in
direct…”.
Section 2.2.2.1 Stormwater Volume Control Performance Goals
Page 7: BILD members suggest replacing “hydro-geotechincal” with “hydrogeological” in the last
sentence of the first paragraph.
Page 8: BILD members recommend that the word “should” be used to replace “shall” in this
section. The use of shall should be avoided because there is not enough science and real life
experience to use a word with such a definitive meaning.
Page 8: BILD members recommend adding the definitions of linear and non-linear to the
Glossary.
Section 2.2.2.2 Flexible Treatment Alternative for Sites with Restrictions
Page 8: BILD members note that karst geology is listed as one of the factors to be considered
for each treatment alternative. BILD members seek clarification as to where karst geology
exists in the LSRCA watershed.
Page 9: BILD members seek clarification that for alternative #2 the volume reduction
minimum of 5mm is measured from all impervious surfaces.
Section 2.2.3 Major-Minor System
Page 10: BILD members suggest that the requirements for hydraulic grade line analysis and the
securing of major and minor system flow routes by a municipality should be removed because
this will vary between municipalities. For instance, some municipalities require rear lot
catchbasins to be fully owned by the homeowner.
Page 10: The last paragraph should be revised to add the word “unregulated” so that it reads “In
the case of discharge to privately owned, unregulated land…”.
Page 10: Additionally, BILD members note that the last paragraph does not seem to be
consistent with the third bullet on page 7 (Section 2.2.1) because it states that additional peak
flow or volume control may be required if the site lacks a sufficient outlet or there is a known
deficiency downstream, such as private property.
3
Section 2.2.4 Regulatory Storm Conveyance
Page 10: BILD members request that the statement “it is the developer’s responsibility to
demonstrate safe conveyance of the Regulatory Storm…” be revised for consistency with the
Drainage Act and Riparian Rights. In addition, “adverse impacts” should be clarified. For
example, if there are existing adverse impacts occurring without development, then the
proposed development should not result in any more/further adverse impacts, but should not
be required to eliminate any existing adverse impacts.
Section 2.3.2 Phosphorus
Page 11: BILD members seek clarification on the following questions:
1. Does the LSRCA foresee the creation of a phosphorous tool/calculation separate from
the MOECC tool that allows for the segregation of impervious and pervious surfaces as
opposed to being tied directly to the few land uses provided in the existing MOECC
tool?
2. If not, how does the LSRCA intend to implement the removal of 80% of annual Total
Phosphorus (TP) load from impervious areas specifically?
3. If an area is 70% impervious and is considered ‘High Density Residential’ would the
required removal of annual TP for the whole area be 56% (80% removal x 70%
impervious)? A sample calculation would be beneficial.
Page 11: While BILD members will do their part to mitigate against high phosphorus levels we
note that the agricultural community is also a significant contributor and should be considered
when comparing pre-development conditions versus post-development conditions.
Section 2.3.4 Temperature
Page 12: BILD members seek clarification on how adding bubblers/aerators that will increase
dissolved oxygen levels and assist with temperature mitigation.
Page 12: BILD members suggest that the last sentence be reworded to read “designed with the
following configuration and features (where feasible)”.
Section 2.3.5 Other Contaminants
Page 13: BILD members recommend adding a reference to Section 2.3.4 at the end of the first
paragraph.
Section 2.3.5.1 Oil, Grease and Gas
Page 13: BILD members have advised that it is not reasonable to prohibit the use of OGS
units as standalone quality controls for infill sites. BILD members note there is technology,
such as a Jellyfish filter, that can be used as a standalone oil-grit separator. Therefore, BILD
members seek clarification on why oil-grit separators are not permitted as a standalone control.
This comment also applies to the third sentence of the first paragraph under section 3.3.4
Oil/Grit Separators.
4
Page 14: BILD members suggest that the document elaborate on the acceptable/recommended
treatment for heavy metals. Unlike water salt, temperature, oil, grease and gas, there is limited
guidance on how to mitigate heavy metals.
Section 2.5 Water Balance/Groundwater Recharge
Page 14: BILD members recommend that the first sentence be reworded to read “Urbanization
increases impervious cover which, if left unmitigated can typically result in a decrease in
infiltration.”
Page 15: BILD members assert that it is not typically feasible to maintain pre-development
evapotranspiration rates at a post-development stage and that the criteria listed in the table in
Section 2.1 notes that the objective of Water Balance is “to preserve groundwater and base
flow”. There is no previous suggestion to maintain evapotranspiration.
Page 15: BILD members would also like to confirm if LSRCA has defined evapotranspiration
and if acceptable rates for various surfaces within the LSRCA watershed have been produced.
Page 15: BILD members suggest that "extra thick top soil" be added to the end of the first
sentence of the last paragraph as a means of achieving infiltration targets.
Page 16: With regards to the 6th bullet point under the minimum requirements for conducting
a water balance analysis, BILD members note that grain size analysis for imported fill material
is often not available at the time of the water balance analysis (i.e. at the functional servicing
design stage, or even at the detailed design stage), as the source of the material has not typically
been determined. This section should be revised to consider that in these cases, the
characteristics of the proposed imported fill material can be assumed for the purpose of the
water balance calculation. At the time of earthworks, it must be ensured that the imported fill
material meets the assumed characteristics.
Page 16: BILD members note that the “pre” used the 7th and 8th bullet points should be bolded.
Page 16: With regards to the last bullet, BILD members note that seasonal groundwater levels
and borehole information, including a location figure, are not required for a standard water
balance calculation. A note should be added to clarify that this requirement will only be
considered on a site by site basis.
Section 2.6.2 Erosion Control Requirements
Page 17: With regards to the third bullet point under the LSRCA requirements for a erosion
and sediment control submission, BILD members note that the Erosion and Sediment
Control Guidelines for Urban Construction (2006) does not discuss a maximum drainage area
to a sediment control pond. LSRCA’s Draft Technical Guidelines for SWM should be
consistent with the Erosion and Sediment Control Guidelines for Urban Construction (2006).
5
Section 3.0 Modeling and SWM Facility Design
Page 18: BILD members note that in the last sentence of the first paragraph the word "hydraulic"
is used twice. One of these should be replaced with "hydrologic".
Section 3.3 SWM Facility Design
Page 19: BILD members note that this section is missing information related to underground
SWM facilities. Therefore, BILD members suggest that LSRCA contemplate adding
information on items such as concrete or plastic storage chambers and oversized storm pipes.
Section 3.3.1 Lot Level Conveyance Controls or Low Impact Development (LID)
Page 20: BILD members note that the first and second sentence on this page should be
reworded so that "Manual" is replaced with "Guide".
Page 20: BILD members seek clarification on the reference to “Section 2.2.1 below” in the
second paragraph.
Page 20: BILD members seek clarification as to whether the mention of "water quality credit" is
referring to Appendix B? If so, consistent terminology should be used. In Appendix B they
are referred to as "Peak Flow Credits".
Page 20: With regards to the last sentence of the third paragraph, BILD members seek
clarification as to why infrastructure would be designed for a 25mm rainfall event in a case
where only a 5mm credit may be given as per the tables in Appendix B.
Section 3.3.2 SWM Facility Requirements
Page 20: With regards to the Outlet Headwall requirement, BILD members note that it may
not be feasible to locate the outlet headwall outside of the watercourse setback, all natural
heritage features and the Erosion Hazard Limit. Therefore, the sentence should start with “to
the extent feasible, the outlet headwall is to be…”
Page 22: With regards to the Location requirement, BILD members note that the first bullet is
not consistent with the previous text in the guidelines that indicates SWM facilities can be
located between the 100 year and Regulatory floodlines. In addition, SWM facilities should be
allowed to be situated within the buffers associated with environmental features and valleyland
setbacks, subject to an environmental evaluation, especially if these areas are currently
disturbed (i.e. farmed).
Section 3.3.3 Parking Lot Storage and Rooftop Storage
Page 25: BILD members note that the last bullet should clarify that the infiltration measures
are not on the roof.
Page 25: With regards to Specific Design Requirements for Rooftop Storage, BILD members
suggest adding consideration for evaporation and water balance from rooftops.
6
Section 3.3.4 Oil/Grit Separators and Filtration Devices
Page 26: BILD members seek clarification that the T.S.S. removal rate of 50% is 50% of the
total (i.e. 100%) T.S.S. and not 50% of the 80% suspended solids removal efficiency.
Page 26: BILD members suggest that “be previously certified for use by NJCEP” in the fourth
bullet point be removed as previously certified units may no longer meet current NJDEP or
ETV certification criteria.
Section 3.4 Stormwater Management Report Submission
Page 27: BILD members note that the charrette process has not been previously discussed in
the document. The charrette process should be described and the document should note that
the charrette process is optional.
Section 3.5 Climate Change
Page 29: BILD members seek clarification on whether all of the listed climate change
implications provided on this page need to be addressed. Additionally, BILD members seek
clarification on if incentives will be provided for addressing this list as some items appear to be
beyond compliance.
Section 4.0 Glossary
Page 30 “Pre-development”: BILD members recommend that “pre-development” be defined as
the “existing site condition”. BILD members note that the purpose for using a maximum predevelopment impervious percentage of 50% in some municipalities (i.e. City of Toronto) is to
alleviate pressures on a storm sewer that is predominantly in a combined sewer or undersized
sewer situation. These situations are not as likely to occur in the LSRCA watershed, and it
does not utilize infrastructure that has been installed assuming a higher impervious percentage
from undeveloped properties.
Page 31 “Sufficient outlet”: BILD members suggest that the definition of “sufficient outlet”
should include a regulated drainage route.
Appendix A Quality Control
Pages A4 and A5: BILD members request that the word “preferred” be added before the words
“pipe slope” in all applicable Outlet Design bullet points under Quality Control.
Pages A5 and A6: BILD members suggest that it may be worthwhile to place the
“Hydrogeology” section ahead of the “Quantity” section. This may help to reinforce the shift
in thinking on water balance from the traditional quality/quantity approach. Furthermore, the
overall quality and quantity depend on the water balance and the at-source approaches
proposed.
Page A6: Similarly, BILD members suggest that LSRCA consider moving ESC for
Construction to the beginning of this Appendix to mimic the first stage of construction.
7
Appendix B Low Infiltration Rate
Page B2: The asterisk notes that the infiltration rate for initial screening is based on a
preliminary soils study, however the document does not describe what the acceptable methods
are (i.e. grain size analysis, in-situ testing, etc.). BILD members highlight that there are studies
indicating that infiltration facilities can be effective where infiltration rates are less than 15
mm/h, when they are properly designed. Therefore, consideration should be given to lowering
the minimum infiltration rate as a constraint to the peak flow control credit.
Page B2: BILD members suggest that the word “Security” be added to the “Ease of
Maintenance” Row of the Design Phase and Construction Phase Chart be so that is reads
“Security and Ease of Maintenance”. This is to acknowledge that there is more certainty that
LIDs will remain in place if they are located on public property versus private property. BILD
members also suggest that the public property credit specifically reference parks, school sites
and municipal rights of way as examples to ensure LIDs are contemplated in these areas.
Page B2: BILD members request that LSRCA provide a definition of scores for all numerical
values (i.e. 1 to 5). For example, in the “Soils Studies Completed” row, what would a score of
1 or 4 represent? BILD members suggest that if those scores are not applicable, it may be
beneficial to clearly identify them as such.
Page B3: BILD members seek clarification on whether the credit for Construction Inspection
is obtained at the design stage (i.e. notes on contract drawings stating regular inspection by
geo-technical engineer) or whether the credit is achieved following construction after
documentation of regular inspections.
Page B3: BILD members seek clarification on how to apply the tables on pages B2 and B3.
Currently, BILD members assume, but are not certain that regardless of design credit obtained
volume equivalent to 25 mm needs to be provided.
Page B4: BILD members seek clarification on how Post Construction Phase credits are
implemented. Specifically, is there an opportunity to reduce the size of an existing quantity
control facility to create additional lot yield because the upstream infiltration measures were
monitored to provide an additional quantity control credit? BILD members recommend that
consideration should be given to how this may be implemented through the planning process.
Page B4: BILD members note that routing the 10 hectare LID area through a pond may lead to
modeling confusion. The 25mm volume credit may be best synthesized as a 25mm initial
abstraction in a model such as a Visual OTTHYMD; not routed through a pond.
Appendix C Typical Hydrologic Values and References
General: BILD members request that LSRCA include clearer versions of the charts referenced
in Appendix C. Many of the charts, tables and graphs are not legible.
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General: BILD members note that the Ministry of Transportation (MTO) tables included in
Appendix C should reference the 1997 version of the MTO Drainage Manual, not the 1989
version.
Page C2: BILD members note that under the list of Appendix C sections, tables the title of
C.13 uses “Timp” twice. The second “Timp” should be revised to “Ximp”.
Page C7: BILD members seek clarification on the reference to Chart 1.09 on Page 26.
Specifically, is Chart 1.09 on Page 26 referring to the 1989 or 1997 MTO Drainage Manual?
Page C19: BILD members note that the Total Impervious Percentage (TIMP) values are low
relative to current typical impervious values for the various residential land uses.
Appendix D Oil / Grit Separators
General: BILD members seek clarification on why the document does not reference the
Canadian ETV standards.
General: BILD members suggest that similar to Appendix D, LSRCA should consider
including an Appendix for criteria and design guidelines for filters in this document.
Page D2: BILD members seek clarification on if pre-development in the following sentence
should be replaced by post-development: "maximum flow directed into an oil/grit separator
must be no greater than the 2 hour 1:2 year pre-development peak flow". Additionally, BILD
members suggest expanding this statement by adding “unless otherwise accepted by the LSRCA per
manufacturer’s documentation and testing with respect to resuspension of TSS”. BILD members note
that OGS manufacturers design systems per the inflow to the unit and size bypass structures
or weirs as required.
Appendix F Criteria for Stream Erosion Control Study
Page F2: With respect to the criteria required for a stream erosion control study, BILD
members seek clarification on the following:
 When characterizing the existing channel, what is the extent of the study i.e. how far
down stream needs to be analysed?
 What storm event should the erosion thresholds be based on?
 What is the purpose of modelling without SWM controls?
Furthermore, BILD members are concerned that the criteria for comparison of the erosion
potentials and the adjustment of the proposed release rates and storage may inadvertently
result in undertaking SWM Pond design for all outlet locations with a sediment pond.
Page F2: BILD members note that "Selection of Study Sites" is listed twice under Description
of Study Area.
Appendix G Erosion and Sediment Control Standards
9
Page G2: BILD members suggest that LSRCA consider providing detail for “Tracking” of
slopes to lessen rill erosion under ESC details.
Page G2: With regards to the requirement for identifying topsoil stockpile locations in all
erosion and sediment control plans (4 b.), BILD members recommend separating out the
requirements for identifying volume of fill in regulated areas and source of fill from topsoil
stockpile locations. Alternatively, the word “topsoil” should be removed from 4b).
Page G2: BILD members request that the word "rock" be removed from 4d) as check dams can
be made out of a variety of materials. Additionally, BILD members seek clarification on the
inclusion of municipal capacity standards in the section. What if these do not exist for all
municipalities?
Page G3 4g): BILD members recommend that a definition of "regular basis" be included in the
Glossary.
Page G3 4g): BILD members request that 4g) be reworded from "after every rainfall event" to
"after every significant rainfall event (i.e. > 10mm).
Page G3 4h): BILD members suggest that the “sediment control facility” in the first sentence
should be replaced with “sediment pond” so that the sentence reads “A clear statement in the
notes that the SWM pond is to be constructed at the beginning of site grading and used as a
sediment pond”. Additionally, BILD members note that it may not always be possible to
produce this work at the beginning of site grading as the existing grade may not be permissive.
Page G3 4i): BILD members seek clarification on the purpose of including cut/fill volume as
this information may not be available at the time of application.
Page G3 4j): BILD members recommend rewording "all areas which will remain disturbed for"
to read "all disturbed ground left inactive for".
Page G3 4m): BILD members note that the items listed are typically not available at the time of
ESC Drawing submission as a contractor is required to determine locations. BILD members
request that the provisions for these items be included in a note stating that they are to be
provided by a contractor.
Page G4: BILD members note that sizing of temporary ESC ponds (and sediment traps)
should be consistent with Erosion and Sediment Control Guidelines for Urban Construction
(2006) guidelines (i.e. 125 OR 185 m3/ha).
Page G4 5d): BILD members note that the stage storage table indicating drawdown time does
not provide the contractor with any directions on pond construction. Therefore, BILD
members recommend that it should be included in the engineering design report, not on the
drawings.
10
Page G5: BILD members suggest adding “(see following pages)” after the title “Erosion and
Sediment Control Drawing Index” so that the reader knows the drawings are attached.
Erosion and Sediment Control Notes: BILD members seek clarification as to why SWM ponds do
not replace the need for localized temporary sediment ponds or temporary traps. BILD
members believe that they do.
Erosion and Sediment Control Notes: BILD members seek clarification on if Note 12 applies when
the ultimate SWM Pond is being used as a temporary ESC Pond as noted in Note 9. If not,
BILD members request that further information be provided as to how temporary sediment
ponds with a drainage area greater than 10 hectares and a single outlet point will be dealt with.
Please revise accordingly or remove.
Erosion and Sediment Control Notes: With regards to Note 16, BILD members note that
temporary cut off swales are temporary and are constantly changing on-site to adhere to an
evolving stripping and earthworks program. To be required to design these swales to convey
the 25 year flow does not seem feasible or required given the duration the swales will be in
place. BILD members suggest removing the capacity requirement and instead have a
minimum depth/width or the document should be consistent with TRCA's 5 year
requirement.
Sediment Control & Double Sediment Control Fence: BILD members suggest using 1.0 metre as the
minimum height of a sediment control or double sediment control fence instead of the
current 1.2 metres. BILD members note that a typical temporary sediment control fence is 1.0
metres high.
Sediment Control & Double Sediment Control Fence: BILD members note that the illustration
states woven geotextile and Note 6 states woven or non-woven. BILD members recommend
specifying a minimum standard for the geotextile to ensure a durable material is chosen.
Temporary Sediment Basin & Outlet Details: BILD members suggest that Note 1 be reworded to
read "Pond is to be constructed coincident with initial site works required to facilitate pond
construction”.
Temporary Sediment Basin & Outlet Details: BILD members suggest removing Note 3 because it
does not add information relevant to pond construction.
Temporary Sediment Basin & Outlet Details: BILD members note that Note 5 should not apply to
private developments as the general public is not allowed to enter private property. This
should be identified in the document.
11
Appendix I Typical Hydraulic Values and Sources
Page I4: BILD members recommend that the first sentence in the second paragraph under Cross
Section Data should be reworded to “Typical values for Manning’s roughness selection are
provided in this Appendix (Section I.7).”
Page I5: BILD members note that the reference to I.9 in the last sentence in the second
paragraph should be I.8.
Page I6: BILD members note that in the second paragraph, reference to FlowMaster should be
replaced with CulvertMaster.
Page I6: BILD members suggest adding "and CulvertMaster" after reference to FlowMaster in
the 1st paragraph of the Structure Design Hydraulic Analysis section.
Once again, BILD appreciates the opportunity to submit comments on LSRCA’s Draft
Technical Guidelines for Stormwater Management. We trust that you will take these
comments into consideration. If you have any questions or concerns, please feel free to contact
the undersigned.
Sincerely,
Emma Barron, BURPl
Planning Coordinator, BILD
Cc:
Paula J. Tenuta, BILD, Vice President, Policy & Government Relations
BILD York, Simcoe and Durham Chapters
12
May 31, 2016
Mr. Tom Hogenbirk
Manager of Engineering
Lake Simcoe Region Conservation Authority
120 Bayview Parkway
Newmarket, ON
L3Y 3W3
Sent via email to: [email protected]
Dear Mr. Hogenbirk,
RE:
LSRCA Draft Technical Guidelines for Stormwater Management Submissions
(Version 2)
The Building Industry and Land Development Association (BILD) would like to acknowledge
and thank the Lake Simcoe Region Conservation Authority for the opportunity to comment
on the conservation authority’s Draft Technical Guidelines for Stormwater Management
(SWM) (Version 2).
First, we would like to thank you and your team for taking the time to meet with us to discuss
our preliminary comments on the draft technical guidelines. Our members found the meeting
to be helpful and we appreciate that a majority of the recommendations we discussed have
been incorporated into the revised document. We appreciate that these guidelines are a living
and breathing document that should evolve as the body of science on Low Impact
Development continues to develop and should reflect our growing experiences in designing,
constructing, monitoring and maintaining them.
After a comprehensive review of the revised Draft Technical Guidelines for SWM
Submissions (version 2), we submit the following comments.
Section 2.2.2.2 Flexible Treatment Alternative for Sites with Restrictions
General: BILD members seek clarification on if there are specified criteria for moving to the
alternatives.
Section 2.3.2 Phosphorus
Page 11: BILD members seek clarification as to why the requirement to remove 80% of the
annual Total Phosphorus load from the entire site, not just the impervious area, has been
included. BILD members do not believe this criterion is in the Lake Simcoe Protection Plan.
Section 2.3.4 Temperature
Page 13: BILD members seek clarification on why the guidelines specify a north-south
configuration. We note that an east-west configuration with southern planning would also
provide shade. Therefore, BILD members suggest revising the guidelines to acknowledge that
an appropriate orientation could be provided with a shading plan.
Section 2.3.5.1 Oil, Grease and Gas
Page 13: BILD members recommend that throughout the section references to OGSs be
revised to Manufactured Treatment Devices (MTD) as more than just OGSs can provide this
function (eg. Filtration systems, strictly oil interceptors, etc.).
Section 2.6.2 Erosion Control Requirements
Page 17: BILD members continue to note that these Guidelines should be consistent with the
Erosion and Sediment Control Guidelines for Urban Construction.
As discussed in our meeting, BILD members express concern over the use of a 10 ha
maximum drainage area to a sediment pond. In development with ultimate SWM Ponds, it
will force additional earthworks and potentially additional outlets to sensitive areas despite
having an adequately sized pond downstream. It was discussed that this requirement be
revised to state “A maximum uncontrolled drainage area of 10 ha is to be conveyed to a
temporary ESC Pond. Intermediate controls such as sediment traps can be applied in series to
allow for a drainage area greater than 10 ha.”
Section 3.3.1 Lot Level and Conveyance Controls for Low Impact Development
(LID)
Page 20: BILD members suggest that an FSR for a draft plan of subdivision could address both
traditional SWM sizing and a reduced size based on assumed credit. This should be considered
with Section 3.4.1 – Stage 1 which states that an FSR “will require sufficient details to
demonstrate that proposed SWM / LID facilities size/configuration are suitable”.
Section 3.3.2 Design Requirements
Page 22: With regards to the Location heading within the table, we had discussed that grading
associated with SWM Ponds in a buffer or setback area is an acceptable practice in the correct
situation. Therefore, BILD members recommend removing “associated grading” from the first
line.
Section 3.3.3 Parking Lot Storage and Rooftop Storage
Page 23: BILD members continue to recommend adding consideration for evapotranspiration
and water balance from rooftops within the ‘Specific Design Requirements’.
Section 3.3.4.1 Oil/Grit Separators
Page 24: BILD members note that not all OGSs use gravity to settle out grit, some use screens.
Therefore, we recommend removing the statement “by gravity”.
2
Page 25: BILD members suggest that this section also recognize that small non-linear development
can use OGS, in order to account for infill development. As a suggestion, this may be
incorporated into the document by providing a size under which an OGS would be acceptable.
Section 3.3.4.2 Filtration Devices
Page 25: BILD members recommend replacing “are used to primarily” with “have the ability
to”.
Section 3.3.4.3 Manufactured Treatment Devices
Page 25 first and last paragraph: BILD members note that “Oil/Grit separators” should be
replaced by “MTDs”
Page 25: BILD members assume that the 50% credit only applies to OGSs and not Filtration
Devices (similar to City of Toronto, etc.), please clarify in the text.
Section 3.3.5 Maintenance Requirements
Page 26: BILD members note that “Oil/Grit separators and “OGS” should be replaced by
“MTD’s”.
Appendix B Peak Flow Control Credits – Infiltration Systems
General: As appendix B is new we would appreciate the opportunity to schedule a further
technical discussion with LSRCA to discuss the proposed changes including the applicability
of some of the criteria provided.
General: BILD members seek clarification as to whether there is a minimum design infiltration
amount that will still allow for a credit? BILD members note that an all or nothing approach
for credit to peak control using infiltration does not promote the use of infiltration beyond the
water balance requirement.
General: BILD members note that the application of credit after it is built does not provide a
benefit to smaller or infill sites. Therefore, BILD members suggest that when applying these
guidelines, increased consideration for higher density infill and small developments should be
given.
Pages B2 & B3: BILD members strongly suggest removing the Constraint of Low Infiltration
Rate from both the Pre-Screening and Design Phase tables. It has been shown through a
collection of studies on the STEP website that low permeability soils still have infiltration
capacity and if the LID’s are sized based on the current TRCA/CVC LID manual with the
correct in-situ testing results these LID’s will perform as designed and can provide very
predictable results. We recommend speaking with Tim Van Seters at TRCA if you have any
doubts or require additional research information. BILD members also suggest that the Step 1
verbiage be revised to note that type A and B soils are best suited for LIDs as they will provide
the most efficient design, but that all soil types have the ability to provide infiltration benefit.
3
Appendix D Manufactured Treatment Devices
General: BILD members note this section only speaks to OGSs. It was discussed at our
meeting that Filtration device criteria would also be added. Therefore, BILD members
recommend updating all references of OGS to MTD if not filtration specific criteria to be
added.
Appendix G Erosion and Sediment Control Minimum Requirements
3. K) BILD members recognize that the active storage component is now in line with the
GGHCA ESC Guidelines, but we continue to suggest the permanent pool be updated as well
as 125/185.
3. L) Same comment as in Section 2.6.2 regarding maximum drainage area.
3. O, iv) BILD members seek clarification on if this is only applicable if the stockpile is not
surrounded with sediment control fence. BILD members note that installing both doesn’t
provide a measurable benefit. Perhaps a fence offset of 0.5 m from the toe of the pile would be
more applicable.
3. Q) BILD member seek clarification on situations where the entire site is in a regulated area?
Please add (if possible).
4. A) See 3. K)
4. C) BILD members suggest adding ‘if outletting to the natural environment’ to the end of
the sentence that starts “The outlet must have an animal grate” for times when the pond outlet
is connected to an existing storm sewer, etc.
4 E) BILD members continue to note that the stage/storage table indicating drawdown times
does not provide the contractor any direction and would likely not be referenced by an
inspection officer and therefore should continue to be included in the design report, not on
the drawings.
Erosion and Sediment Control Plan Notes
1. BILD members continue to suggest revising current text to read “must be installed
coincident with initial siteworks required to facilitate sediment control measure construction
prior to the commencement of site works”.
18. BILD members request that “if possible” be added as some sites are fully within the
regulated area.
19. Same comment as 18.
4
Temporary Sediment Pond and Outlet Details
1. BILD members continue to suggest revising current text to read “must be installed
coincident with initial siteworks required to facilitate sediment control measure construction
prior to the commencement of site works”.
3. BILD members continue to suggest noting that Note 3 should not apply to private
developments as it is private property and the general public is not allow to enter the site.
Once again, BILD appreciates the opportunity to submit comments on LSRCA’s Draft
Technical Guidelines for Stormwater Management (version 2). We trust that you will take
these comments into consideration. If you have any questions or concerns, please feel free to
contact the undersigned.
Sincerely,
Emma Barron, BURPl
Planning Coordinator, BILD
Cc:
Paula J. Tenuta, BILD, Vice President, Policy & Government Relations
BILD York, Simcoe and Durham Chapters
5
Contech Engineered Solutions LLC
9025 Centre Pointe Drive, Suite 400
West Chester, OH 45069
Phone: (513) 645-7000
Fax: (513) 645-7993
www.ContechES.com
Comments on LSRCA Technical Guidelines for Stormwater Management Submissions
14th March 2016
Page 13 - 2.3.5.1 Oil, Grease and Gas



To substantiate claims of hydrocarbon removal by OGS systems, manufacturers must provide third party
lab or field test data. Following, the adoption of ETV, all OGS devices should be compelled to provide
proof of passing the ETV “oil capture” test.
Sorbent material can be utilized to enhance hydrocarbon removal within an OGS unit. Third party test
data must be supplied to validate increased performance claims with use of Sorbent material.
Heavy Metals: The new guidelines place great emphasis on the need for optimization of LID measures. As
such, consultants should be required to demonstrate rationale behind selection of filter material with
respect to removal of specific heavy metals.
Page 25/26 3.3.4 Oil/Grit Separators and Filtration Devices
OGS Qualification Criteria





Contech agrees that units should be either certified for use by the current Canadian ETV program or be
registered as well as currently undergoing testing. The third party laboratory that is conducting the testing
should provide proof that testing is in process. The Canadian ETV lab testing process is extensive and it
will take time for manufacturers to complete the process. It is recommended that a stipulation is added
that manufacturers must have certification by Canadian ETV by January of 2017 to be considered going
forward. This will ensure a high standard for treatment devices and environmental stewardship within the
LSRCA.
It should be noted that OGS systems are also designed to capture and retain trash and debris from
stormwater runoff up to the design storm. Hydraulic calculations should be provided that demonstrate
retention of previously captured trash and debris during the design storm and if applicable, during peak
storm events if the unit is utilized in an online application.
Contech agrees that units should be currently certified for use by NJDEP as it provides the most logical unit
performance and testing process comparison as we continue to progress towards the higher standard
embodied by the Canadian ETV certification process.
It should be noted that the current NJDEP testing requirements varies significantly from previous NJDEP
testing requirements and as such, only currently certified units should be considered for use.
In response to the bullet that states that OGS units will be re-certified by NJDEP by January 2017, we
strongly advocate that LSRCA adopts a policy that encourages and compels manufacturer’s to work on and
aim towards a critical certification date in relation the Canadian ETV certification exclusively. NJDEP is
intended for interim use only as we transition towards the ultimate higher standard of ETV. As such, for the
interim period only currently NJDEP certified units should be considered.
Contech Engineered Solutions LLC
9025 Centre Pointe Drive, Suite 400
West Chester, OH 45069
Phone: (513) 645-7000
Fax: (513) 645-7993
www.ContechES.com





It should be noted that only units currently approved for online use by NJDEP should be allowed for online
applications
Contech is strongly opposed to the eligibility of OGS devices previously certified under NJDEP for
consideration for the following reasons:

Enables OGS units with inferior performance capabilities to be included in LSRCA
projects


Retrogresses all improvements and advancements in NJDEP testing in recent years
Diminishes and puts into question the high standard of consistent, stringent and
firm LSRCA enforcement policy of the NJDEP standards in recent years

The PSD and test requirements related to the current certification process are
closely aligned with the Canadian ETV testing process.

There was no consistency in the PSD used for testing by various manufacturers – the
PSD was often much courser than the specified NJDEP PSD. The LSRCA standards
require that NJDEP protocols are fully followed. No manufacturers were considered
compliant with this requirement and all were required to re-test under the new
NJDEP standard effective January 2015.
It is stated that based on current studies, OGS units do not provide phosphorus removal and therefore do
not comply with the LSRCA guidelines. Contech recommends that this note be rephrased to provide more
clarity by adding an additional sentence stating that “as such, hydrodynamic separators (HDS) units will
not be granted phosphorus removal credit.”
It would be beneficial to have a section in the guidelines that delineates when the design consultant can use
an HDS product and when they should use a filter.
The ideal Filter standard to aspire to would have been a comparable ETV certification protocol for filters. In
the absence of an ETV filter certification process, the following standards would offer the greatest
consistency with respect to product approval and testing:

Similar to HDS products, NJDEP is requiring all filtration products to retest to the new
NJDEP filter test standard by January 2017. We recommend that LSRCA should mandate
certification to the current NJDEP standard and the new NJDEP filter test standard by
January 2017.

The NJDEP filtration test standard does not address phosphorus removal but the
Washington State Department of Ecology test standard does address phosphorus removal.
We propose that LSRCA should point to the Washington State Department of Ecology
(WASHDOE) as the regulatory standard for P removal.

Contech advocates for the policy of having all submitted test data clearly declaring influent
concentrations of phosphorus and the partitioning between dissolved and particulate
form. Only technologies with reactive media should be given credit for any removal of the
dissolved fraction of P.
Contech Engineered Solutions LLC
9025 Centre Pointe Drive, Suite 400
West Chester, OH 45069
Phone: (513) 645-7000
Fax: (513) 645-7993
www.ContechES.com
Page D2 Appendix D

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


Regarding Table D.1., the particle size distribution is a hypothetical distribution created by a single
manufacturer. A PSD more representative of actual site runoff characteristics such as the NURP should
be utilized.
Contech recommends that any reference of phosphorus removal credit applied to an OGS unit be
removed as only particle bound phosphorus removal is achievable via an OGS unit and the variability of
dissolved phosphorus from one site to the next is significant.
The statement that all OGS must be registered with the Canadian ETV program should be removed as
clarification for certification requirements is provided on page 25. Further registration with ETV (Globe
Canada) does not provide LSRCA any guarantee that a manufacturer will actually test their product. As
noted earlier we strongly recommend a sunset date of January 2017 for testing.
Hydraulics should be expanded to include headloss calculations for OGS devices to demonstrate correct
weir height.
Phosphorus influent concentration. It needs to be highlighted to LSRCA that a separate appendix is
required stated site criteria for testing must fall into similar characteristics as is found in LSRCA territory
– table with typical P concentrations with particulate/dissolved partitioning should be presented.
Page E2 – Appendix E Phosphorus Loading


Again, Contech recommends that any reference of phosphorus removal credit applied to an OGS unit be
removed as only particle bound phosphorus removal is achievable via an OGS unit and the variability of
dissolved phosphorus from one site to the next is significant.
Preference should be given to technologies that have real proven third party, field and laboratory
performance test data over LID technologies where P removal is mostly theoretical.
May 19, 2016
The following is specific recommended language in its entirety for sections and appendices that deal
with oil/grit separators, filtration devices, and adsorptive materials within the May 6, 2016 draft version
of LSRCA Technical Guidelines for Stormwater Management Submissions.
It is recommended that Section 3.3.4.3 Manufactured Treatment Devices (MTD) Requirements be
deleted, given the revised specific language for Section 3.3.4.1 Oil/Grit Separators and Section 3.3.4.2
Filtration Devices and Adsorptive Media (see below).
Additionally, in Appendix E Phosphorus Loading, the fourth paragraph makes reference to Section
3.5.4, which does not exist. This should be edited to show Section 3.3.4.
3.3.4.1 Oil/Grit Separators (OGS)
Oil/grit separators (OGS) are water quality control devices designed to allow grit to settle by gravity and
allow oils to float and be separated out. They may also be used for spill control. Generally, OGS devices
are not to be used as a stand-alone measure for stormwater quality control, but rather upstream of
other measures as part of a multi-component “treatment train”. OGS devices are typically used for small
sites or infill development (typically 5 ha or less). For linear development, an OGS device may be
considered as a stand-alone measure if the use of other stormwater quality control measures is not
feasible.
The Canadian Environmental Technology Verification (ETV) program has published the Procedure for
Laboratory Testing of Oil/Grit Separators for the purpose of bringing consistency and proper
methodology to the evaluation, sizing, and scaling of OGS devices. An important part of this document is
the specification of a particle size distribution (PSD) that is used for the evaluation of TSS removal
performance and scour testing of OGS devices. The ETV-specified PSD contains particle size fractions
that are reasonably representative of particle size fractions that are found in urban stormwater runoff.
This PSD must be used for sizing OGS devices. See Appendix D for details on the methodology for sizing
and scaling of OGS devices.
For OGS devices that are installed in pretreatment applications as part of a treatment train, the device
must be sized to remove a minimum 65% of the ETV-specified PSD. A Total Suspended Solids (TSS)
removal credit of 50% shall apply to the OGS device in these instances.
For OGS devices that are installed in stand-alone applications due to practical constraints that prevent
installation of other stormwater quality measures, the device must be sized to remove a minimum 70%
of the ETV-specified PSD.
For oil and fuel spill “hotspots”, such as fueling stations, fast food restaurants, and convenience stores,
the installation of an OGS device is required.
Imbrium Systems
407 Fairview Drive | Whitby, ON L1N 3A9
1
Ph 416.960.9900
Ph 800.565.4801
Fax 416.960.5838
imbriumsystems.com
To be considered for use with the Lake Simcoe watershed (prior to June 30, 2017), OGS devices must:
• be certified by the Canadian Environmental Technology Verification (ETV) program, or;
• be registered for testing or have verification of testing completed by the Canadian ETV;
• be currently certified by New Jersey Department of Environmental Protection (NJDEP), or;
• be previously certified by NJDEP.
Only OGS devices verified through the Canadian ETV program will be allowed after June 30, 2017.
Two (2) or three (3) alternate OGS devices should be specified on submitted drawings and reports. Sizing
calculations and documentation regarding ETV registration and/or certification must be provided in the
SWM report for any proposed OGS device. Refer to Appendix D for further information
3.3.4.2 Filtration Devices and Adsorptive Media
Filtration devices are stormwater water quality control devices that are primarily used to remove fine
particles (less than 20 microns). In some filtration devices, an adsorptive media may be used to improve
removal of specific dissolved pollutants, such as dissolved phosphorus or metals. Typically, filtration
devices should be used as part of a treatment train approach, and installed downstream of a
pretreatment measure.
To be considered for use, filtration devices must have third-party verification of field test performance
for removal of Total Suspended Solids (TSS) and Total Phosphorus. Adsorptive media must have thirdparty verification of laboratory and field test performance for removal of the targeted dissolved
pollutant, such as Dissolved Phosphorus.
Only Filter devices verified through the Canadian ETV program will be allowed after June 30, 2017.
See Appendix D for details on the methodology for sizing and scaling of filter devices and adsorptive
media.
Appendix D – Manufactured Treatment Devices
Sizing and Scaling of Oil/Grit Separator (OGS) Devices
The Canadian Environmental Technology Verification (ETV) program has published the Procedure for
Laboratory Testing of Oil/Grit Separators for the purpose of bringing consistency and proper
methodology to the evaluation, sizing, and scaling of OGS devices. An important part of this document is
the specification of a particle size distribution (PSD) that is used for the evaluation of TSS removal
performance and scour testing of OGS devices. The ETV-specified PSD contains particle size fractions
that are reasonably representative of particle size fractions that are found in urban stormwater runoff.
This PSD must be used for sizing OGS devices.
Imbrium Systems
407 Fairview Drive | Whitby, ON L1N 3A9
2
Ph 416.960.9900
Ph 800.565.4801
Fax 416.960.5838
imbriumsystems.com
Either of the following sizing methodologies are permissible for sizing OGS devices for pretreatment
applications and credit for 50% removal of Total Suspended Solids (TSS):
• Methodology using continuous simulation, local rainfall data, and Stokes’ Law principles to
achieve a minimum 65% average annual removal of the ETV-specified PSD as shown in Table 1
below, while treating a minimum 90% of the average annual runoff volume.
• Methodology using ETV-certified laboratory testing performance results and local rainfall data
to achieve a minimum 65% net annual removal of the ETV-specified PSD, while treating a
minimum 90% of the average annual runoff volume.
TABLE 1
Particle Size Distribution for Sizing Oil/Grit Separators
Particle Diameter (Micron)
% by Mass of All Particles
Specific Gravity
1000
500
250
150
100
75
50
20
8
5
2
5%
5%
15%
15%
10%
5%
10%
15%
10%
5%
5%
2.65
2.65
2.65
2.65
2.65
2.65
2.65
2.65
2.65
2.65
2.65
For stand-alone applications, OGS devices must be sized to remove a minimum 70% of the ETV-specified
PSD, using either of the methodologies described above.
Proper scaling of OGS devices is very important to ensure that devices are not undersized for the site of
interest. Proper scaling methodology is addressed in Section 6.0 of the Procedure for Laboratory
Testing of Oil/Grit Separators, and must be used for proposed OGS devices.
Sizing and Scaling of Filtration Devices
Treatment performance and service longevity (maintenance frequency) of filtration devices is highly
dependent on the degree of occlusion of the filter media used within a filtration device. The rate of
occlusion is dictated by sediment load, organic material load, presence of oil/grease in runoff or spills,
and biological activity on and within the media which may create occluding biofilms. Third-party verified
field testing is required to ensure that performance and maintenance claims are realistic under actual
runoff conditions.
Sizing of filtration devices must be based on both a flow rate basis and a sediment loading capacity
basis, as follows:
• Determine the flow rate associated with the 90% average annual runoff volume and select the
appropriate filter size to treat that flow rate; and
Imbrium Systems
407 Fairview Drive | Whitby, ON L1N 3A9
3
Ph 416.960.9900
Ph 800.565.4801
Fax 416.960.5838
imbriumsystems.com
•
•
Determine the projected annual sediment load that will be transported to the filter device
(based on the assumption of EMC of 100 mg/L of suspended solids, or greater, depending on the
consulting engineers’s assessment of site characteristics) and select the appropriate filter size
that provides the appropriate annual sediment mass loading capacity
Select the larger of the two sizes from the determinations above for installation
Scaling of filter devices must be consistent with the field tested device in the following parameters:
• Ratio of settling area within the system to media surface area
• Surface loading rate on the filter media
• Depth below the filter media
• Driving head on the filter media
• Sediment mass loading capacity of media
It is recommended that filter devices be used in off-line applications only to prevent rapid occlusion of
filter media during high intensity storm events and consequent high maintenance frequency. If it is
necessary to install a filter device on-line due to practical site constraints, the filter device should be
sized to treat the flow rate associated with the 100% average annual runoff volume, and additional
sediment storage capacity should be added.
It is recommended that filter devices be inspected a minimum twice annually and maintained on an
annual basis, unless site conditions and inspection history indicate a shorter or longer maintenance
interval.
Sizing and Scaling of Adsorptive Materials
Adsorptive materials, such as certain types of granular media, red sand, or compost, have the capacity
to remove dissolved pollutants from stormwater, such as dissolved phosphorus or dissolved metals.
Adsorptive materials are typically characterized for specific adsorption capacity of a specific pollutant by
conducting controlled laboratory studies with clean water that has been doped with a target
concentration of the specific dissolved pollutant. However, in real world runoff conditions, the influent
has varying water chemistry conditions and many more interfering constituents, including suspended
solids, oil and grease, organic particulates, and various concentrations of other pollutants. Performance
under real runoff conditions may be substantial lower than in controlled laboratory conditions.
Adsorptive materials are permitted only if multiple third-party studies, comprising laboratory and at
least one field study, have been conducted and the following parameters measured:
• At least one third-party laboratory study that characterizes adsorptive capacity by both
adsorption isotherm (jar test) and column studies. The number of bed volumes of influent of a
target and realistic pollutant concentration required to exhaust the media adsorption capacity
must be determined.
• At least one third-party field study that characterizes dissolved pollutant removal performance
over a minimum one-year period, using natural runoff or simulated runoff.
Imbrium Systems
407 Fairview Drive | Whitby, ON L1N 3A9
4
Ph 416.960.9900
Ph 800.565.4801
Fax 416.960.5838
imbriumsystems.com
•
If the adsorptive material is organic in nature, data must be presented that characterizes the
potential for breakdown and release of nutrients.
Adsorptive materials, whether used as an amendment in a media-based treatment measure or as the
primary constituent in a structural treatment measure, should be installed downstream of a
pretreatment measure that removes a high percentage of the suspended solids and hydrocarbon loads
that might otherwise prematurely occlude the adsorptive media and compromise its adsorptive
capacity.
Treatment measures containing adsorptive materials should be sized to provide a minimum 5 years of
adsorptive capacity for the target dissolved pollutant(s).
It is recommended that BMPs containing adsorptive materials be installed off-line to prevent rapid
occlusion and compromise of adsorptive capacity of the media during high intensity storm events.
Respectfully submitted,
Joel Garbon
Regulatory Manager
Imbrium Systems
503-706-6193
[email protected]
Imbrium Systems
407 Fairview Drive | Whitby, ON L1N 3A9
Reagan Davidson
Regional Manager
Imbrium Systems
416-930-5125
[email protected]
5
Ph 416.960.9900
Ph 800.565.4801
Fax 416.960.5838
imbriumsystems.com
DETAILED COMMENTS
DRAFT LSRCA TECHNICAL GUIDELINES FOR STORMWATER MANAGEMENT
SUBMISSIONS
SECTION 1.0 – INTRODUCTION
In the first sentence of the last paragraph, the Guidelines use the term “development
community.” Can you provide clarification if the definition includes municipal road
reconstruction projects? Further, clarity is also required on “arterial roads” with respect to roads
application compared to subdivision agreement and again when reference is made to a plan of
subdivision or site plan (page 2, 1st paragraph).
SECTION 2.0 – STORMWATER MANAGEMENT
1. Page 3 - Should evapotranspiration not be included in this section as a consideration?
2. Page 4 – Pre-submission Consultation
a. More clarification on how this section addresses redevelopment on arterial road
requirements and additional explanation on how this is applicable to roads, road
widening and urbanization
b. MOECC is also a critical stakeholder that has a fundamental influence on the
design, operation, maintenance and monitoring of stormwater management
facilities and as such should be invited to participate in the discussions and
establishment of approval requirements for specific developments
c. These meetings should also include discussion on the types of contaminants
typically associated with the contemplated land use or specific to certain activities
that will be undertaken
3. Consider including a section that discusses storm runoff (particularly nutrient loading)
from rural sources such as feed lots and livestock corral areas that have a high nutrient
runoff. Report should note that where the feedlot is close to streams or headwaters –
quality control management methods should be considered
4. Required Documents - Which document takes precedence if there’s a conflict in
requirements?
SECTION 2.1
5. Pages 5/6 – Pre-submission Consultation SWM criteria table:
a. It may be very difficult to accommodate temperature, phosphorus and other
contaminate treatment on our road projects. (Specific “attainable” objectives
need to be identified as it pertains to linear projects). Please note that the table
reference number is missing
b. It is recommended to have a more complete list of quality parameters that are
being considered when designing and installing stormwater management
facilities eg. List should note chlorides, nitrates, Ecoli, heavy metals, oils. These
all have a quality impact on receiving water and should be targeted in the design
of SWM facilities
6. Porous Pavement (1st bullet)
a. Given the arterial nature of York Region roads, this would be a major structural
and continual maintenance concern because high volume traffic loading on a
reduced structural pavement. This will quickly deteriorate the road. (Science is
not there yet.)
b. Is this section just for development areas and, if so, should it be defined that
way?
7. Conveyance Controls with respect to pervious pipe system and pervious catch-basins
(bullets 2 and 3):
a. This is a non-reinforced pipe that may not be suitable for our road projects. Also
there is the frost/freeze/thaw issue for shallow or close to frost depth locations
b. Is this section just for development areas and, if so, should it be defined that
way?
8. End-of-pipe (EOP) Stormwater Management (all bullets) - A number of these would not
be possible or would have an impact to our limited ROW space and the amount of
infrastructure we have to provide within the ROW
a. Is this section just for development areas and, if so, should it be defined that
way?
9. Last Paragraph dealing with stormwater runoff being discharged to a roadside ditch.
Discharges from storm water management pond to Region’s infrastructure will be
subject to temporary dewatering discharge approval and need to comply with the Sewer
Use Bylaw limit. The Region has some applications to discharge when they clean the
pond. It is proposed that the following statement be added to Section 2.1 (second to the
last paragraph of Section 2.1):
“No water shall be discharge to the municipal sanitary or storm sewer system without
approval from the applicable upper and lower tier municipality involved.”
SECTION 2.2
10. General Comments on Stormwater Quantity Control:
a. Historically stormwater management measures and facilities have been designed
to provide a certain level of sediment removal as described in the MOE SWM
manual. At the moment there appears to be a desire for these facilities to control
other contaminants. The MoECC has recently required the monitoring, at
different locations, of parameters such as Alkalinity, Calcium, Chloride ,
Conductivity, Phenols, Sodium, Sulphate, Total Ammonia Nitrogen, Total
Suspended Solids (TSS), Chemical Oxygen Demand (COD), Total Phosphorus,
Arsenic, Boron, Cadmium, Chromium, Copper, Iron, Lead, Magnesium, Nickel,
Potassium, and Zinc in addition to pH and Temperature
b. Industry should understand whether the expectation is to design their
management measures on the basis of achieving an understood improvement in
runoff water quality by applying certain industry accepted measures/practices or
whether there are specific removal efficiencies or effluent limits (such as the
provincial water quality objectives) for these other contaminants
c. If there is a move to more effectively and quantitatively control additional water
quality parameters then a broader discussion should be considered with a view
to establish new guidelines for additional parameters; effectively a
revision/update of the 2003 MoECC guidelines
SECTION 2.2.1
11. First Bullet - Very problematic to achieve such peak flow rates given the very limited
ROW space on almost all of our road projects
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DETAILED COMMENTS: draft LSRCA Tech Guidelines for SWM Submissions
Page 2
12. General comment on Peak Flow Control - Recently we’ve seen ECA conditions that
affect the operation of stormwater management facilities by requiring the closing of the
control outlet in the event that a trigger water quality parameter exceeds the provincial
water quality objectives. Quantity control operating rules used during such events should
therefore be considered such that the peak shaving function of the facility is maintained
to at least a certain agreed to level understanding that the full post- to pre- (ie. The runoff
from a 1:100 year rainfall event) control will not be available for a certain period of time
SECTION 2.2.2.1.
13. General comment to this section - Instead of only quantifying new or reconstructed
impervious surfaces, you may want to consider capping a total site percentage typical to
parking lot design, i.e. parking lot surface to green space ratio
14. The definition of Major Development (extracted from LSPP) does not include impervious
surfaces. However, the draft Guidelines go on to say that new development is
considered Major Development if the impervious area is over 0.5 hectares. The
proposed major development definition York Region is using for source water protection
includes both buildings/impervious area of 5000 square metres or more. So as a result,
major development within the Guidelines is very similar with the same intent as the draft
York Region definition. It is suggested that this definition also be included in the
Glossary section for ease to locate it
15. 2nd sentence – it is very problematic to achieve the volume reduction techniques given
the very limited ROW space on almost all our road projects. (Must be attainable on
linear road projects)
16. 4th sentence – With respect to the recommendations of the reports, we would have to
provide these reports for almost all our road projects given that most of our typical
widening projects (including intersection improvements) would increase or create 0.5ha
of new impervious surface. See rough calculations in the next comment below. (This is
completed at EA stage, and does not need to be repeated.)
17. Redevelopment and Linear Volume Controls with respect to the reference of
redevelopment projects that create 0.5 ha or more of new reconstructed impervious
surface (two boxes on page 8) - Our typical road widening projects (from 2 to 4 lanes)
equals 7m of additional impervious surface width. Therefore the 0.5ha threshold would
mean any road project 714m in length or longer would fall under these two controls.
(Rough calculation: 5000m2/7m = 714m). These must be attainable on linear road
projects
18. Redevelopment and Linear Volume Controls with respect to the reference of sites
“without restrictions” – Can you please clarify what does “without restrictions” mean?
19. Redevelopment Volume Control – Since it pertains only to new and/or full reconstructed
impervious surfaces, developers may establish a staged development approach in order
to bypass requirements of this guideline
SECTION 2.2.2.2.
20. Within the flexible treatment options for sites, SGRAs, WHPAs and IPZs are factors
which could contribute to as why alternatives may be required. From a source protection
perspective, the Region is encouraged this is included
21. Factors to be considered – This list should also include:
a. Property restrictions
March 15, 2016
DETAILED COMMENTS: draft LSRCA Tech Guidelines for SWM Submissions
Page 3
b. Infrastructure conflicts/restrictions (i.e. utilities, existing storm, sanitary etc.)
c. Conflicts with existing private property (i.e. buildings, entrances, structures,
vegetation, landscaping, etc.)
22. Alternative #3 box – The first sentence states that the mitigation equivalent “can be
performed off-site.” This would be very difficult to achieve on our road reconstruction
projects. Many times there is no alternative available to go offsite for mitigation
SECTION 2.2.3
23. Last paragraph in this section with respect to a proponent requiring to “obtain a legal
right of discharge registered on title”. Would this apply to situations where the existing
drainage already outlets to private property? Can you please clarify?
SECTION 2.3.2
24. 2nd paragraph in reference to phosphorus loading being kept to a minimum - The
Guidelines should provide some “guidelines” on how to manage nutrient uptake
(possibly a wetland design is needed)
SECTION 2.3.3
25. 2nd paragraph, 3rd sentence with respect to the requirement of the use of multi-draw or
blended outlets with cooling trenches. Not sure how we can provide this or achieve this
within our limited ROW unless we can provide outlet swales or ditches as cooling
trenches. Such a requirement would have an impact on urban cross section boulevards
26. 3rd paragraph, 1st sentence with respect that the road design should be “done in such a
manner that the need for excess salt use is minimized. Not sure how we can achieve
this. Not practical given the nature of our roads. Could have impact on public safety.
Due to the excessive costs involved in purchasing and applying road salt on road the
Region uses the absolute minimum required without sacrificing public safety
27. 3rd paragraph, 2nd sentence with respect to snow storage location. In most cases we
have boulevard/ ROW space for snow storage
28. 3rd paragraph, 2nd sentence with respect to permeable pavement and rougher pavement.
Not possible/practical for our arterial roads due to inferior performance and reduced road
lifespan
SECTION 2.3.4
29. 1st paragraph, 3rd/4th sentences reference the use of “SWM wet ponds, cooling trenches,
underground cooling chambers to assist with thermal mitigation”. We have constraints
with available ROW space and/or with existing and proposed infrastructure we need to
provide. (Not transferable to roads.)
30. 1st bullet – “minimum length to with ratio” should be replaced with width ratio
31. 2nd bullet - Submergent wetland plants require full sun for optimum growth. Consider
adjusting perimeter shading requirement to only a portion of the facility to screen midday
sun
SECTION 2.3.5.1 – OIL, GREASE AND GAS
32. Last sentence – with respect to oil-grit separators not being permitted as a standalone
control. For the majority of our urban projects this is our only option given limited ROW
space. Would a series of OGS units be acceptable as a standalone control? (Should be
based on WQ.)
March 15, 2016
DETAILED COMMENTS: draft LSRCA Tech Guidelines for SWM Submissions
Page 4
33. Double repeat of section 2.3.5.1 – Heavy Metals. Please make this section 2.3.5.2 to
reduce confusion
SECTION 2.5
34. As part of a SWM plan, the WHPA-Q2 is referenced along with the SGBLS SPP policy
on water balance. It is outlined within this policy that the proponent needs to be aware
of the fact that a water balance study may be required within the WHPA-Q2. The Region
supports the cross-reference to other requirements including the water balance study
35. 2nd paragraph, 1st sentence with respect to the “SWM plan must make every feasible
effort to maintain the pre-development infiltration and evapotranspiration rates and
temperatures to the receiving waterbody…” - Not sure if this is meant to be applied to
our road projects. If it is it would be very difficult to almost impossible to achieve given
our limited ROW space and the infrastructure we need to provide/accommodate.
36. 5th paragraph, 2nd sentence with respect to that “some existing approved plans of
subdivision may only require the infiltration of water from rooftops.” Please clarify if this
statement is suggesting the re-evaluation of approved plans
SECTION 3.0 – MODELING AND SWM FACILITY DESIGN
37. Page 18, 2nd paragraph, last sentence. Please note that only a P.Eng. can sign, not
CET, if risk to life is concerned
SECTION 3.3.1
38. Not sure if any of this section should be applied to our arterial road projects. Is this
section just for development areas and, if so, should it be defined that way?
39. Recommend moving the definition of LID moved to the Glossary
SECTION 3.3.2
40. Can you please clarify if this section, if any, applies to regional road projects?
41. Can you please clarify if the use of a sediment forebay was not considered as part of the
SWM facility requirements?
42. Vegetation Planting Plan – Consider rewording the 1st bullet to read “It is a requirement
to consider safety, aesthetics, species selection, shading and enhanced pollutant
removal when developing a planting plan.”
SECTION 3.3.3
43. Specific Design Requirements for Rooftop Storage – can you consider roof gardens as a
water reuse opportunity?
SECTION 3.3.4
44. Paragraph 5 with respect to Stage 1 and 2 reports being certified by NJDEP. Can
NJDEP be held liable if certified by them? Some clarification on this point would be
appreciated
SECTION 3.3.5
45. Last sentence with respect to a separate maintenance manual being provided. Please
note that any OGS units on our roads will be maintained by York Region and would not
require a separate maintenance manual. This would be completed as per the York
Region maintenance schedule
March 15, 2016
DETAILED COMMENTS: draft LSRCA Tech Guidelines for SWM Submissions
Page 5
46. This section should be expanded to reflect the importance of this activity and provide
greater guidance on the performance objective that the maintenance is expected to
achieve. In addition, the output of this requirement should include a detailed schedule of
specific activities. It may be helpful to list the maintenance requirements and when they
are required for ease of implementation.
47. Consideration should be given to providing guidance on procedures for sampling
accumulated sediment/soil (and possibly underlying soils from LID measures) with a
view to provide for suitable disposal and/or to schedule major maintenance activities
SECTION 3.4 – STORMWATER MANAGEMENT REPORT SUBMISSION
48. There is a reference to “standard engineering practices”. It should be defined or further
clarified what constitutes “standard engineering practices”.
SECTION 3.4.1
49. It is unclear whether Stage 1 and 2 reports would be required on our road projects. Can
you please clarify?
SECTION 3.5 – CLIMATE CHANGE
50. Since this is an important impetus for the Guidelines, it may be better located in the
Introduction to set the foundation of the document
SECTION 5.0 – REFERENCES
51. The 4th credit cited for Clarifica; should it not be VH Otthymo Version 4.0?
APPENDIX A – STORMWATER MANAGEMENT REPORT CHECKLIST
52. Section 1c) – consider renaming it from “Figures” to “Drawings” to capture what is really
being requested
53. Section 2a) Oil-Grit Separators – part of the treatment train (not standalone). This may
not be attainable on certain road projects. It should be based on water quality at the
outlet, not requirements of treatment train (standalone may be sufficient)
54. Section 2 b) through d) - These do not apply to our road projects. (Checklist appears to
focus on large development and not linear road projects for mitigation.)
55. Section 7 – 1st bullet – We are not familiar with the 6 and 12 hr SCS Type II design
storms. Do these storms exist?
56. Section 7 – 10th bullet – We believe that “recession constant” is missing from the list
57. General:
a. Additional items for consideration to be included in the checklist:
i. how much nutrient loading is expected and what is the discharge levels to
receiving stream. This will identify if more than one feature is needed in
series to address the discharge target limits.
ii. a maintenance plan to discuss frequency, types of cleaning, wetland
harvesting and replanting
iii. monitoring plan on how well the system is performing
APPENDIX B – PEAK FLOW CONTROL CREDITS – INFILTRATION SYSTEMS
58. Step 2 – Monitoring Plan by a Qualified Individual – The “qualified individual” should be
defined or further clarified
March 15, 2016
DETAILED COMMENTS: draft LSRCA Tech Guidelines for SWM Submissions
Page 6
APPENDIX C – TYPICAL HYDROLOGIC VALUES AND REFERENCES
59. 3rd Paragraph with respect to the SCS Type II storm. This section should be
reconsidered. Not correct SCS Type II storm development?
60. 4th Paragraph – The drainage area is not a factor for application of the rational method.
61. 4th Paragraph on Page C5 with respect to “IDF Parameters”. Is “parameter’ the correct
word?
62. Section C.2-Imperviousness - Does HYMO use 2 parameters for imperviousness? We
are not familiar with this. In the second paragraph it states that “gravel surfaces must be
assumed to be impervious (such as asphalt)”. We are not sure if this represents
standard practice or if it’s being excessive and would appreciate some clarification
around this
63. Section C.2 - Infiltration Approach (bottom of page C7) the reference from “aerial” should
be “areal”
64. 2nd last paragraph (C8) – This paragraph needs some rewording. CN should not be
used without appropriate watershed analysis
65. Section C.2 – Hydrograph Computation, paragraph 3, makes reference to “typical
methods for determining slope length”. It should reference “parameters” not “methods”
66. Section C.2 – Channel Routing – paragraph 3, makes reference to “smallest channel
section”. It should read “shortest” instead of “smallest”
67. Section C.3 – Software Recommendations, paragraph 1 – The Signing Engineer should
confirm which software packages are acceptable for modelling, not LSRCA
68. Section C.4 – Intensity-Duration-Frequency (IDF) Curves. Can it be confirmed that this
is MCS/AES or is it Bandyopadhyay (the version used in Canada)?
69. Section C.4, paragraph 2, What “Regional IDF curves” are being referred to? Please
clarify
70. Section C.10 SCS Type II Mass Storm Distribution with respect to 6 and 12 hour
durations. This was not included in the original SCS Type II storm event
71. Table C.13 Typical TIMP and XIMP Values. Consider need to actually calculate the IMP
areas
72. Section C.14 CN* Calculation Methodology with respect to modified curve number CN*.
Disagree that what is shown is the CN method. Please refer to Paul Wisner’s Otthymo
User’s Manual ‘83
APPENDIX D – OIL/GRIT SEPARATORS
73. 2nd Paragraph, 1st sentence states “oil grit separators are not accepted as standalone
devices in relation to the Authority’s requirements for 80% total suspended solids”. As
previously stated, this may be problematic for our road projects due to limited ROW
without additional property acquisition
74. 3rd Paragraph, 1st sentence states “The maximum flow directed into an oil/grit separator
must be no greater than the 2 hour 1:2 year pre-development peak flow (greater flows to
bypass the OGS)”. Is this attainable under all road conditions?
APPENDIX E – PHOSPHORUS LOADING
75. 1st Paragraph in reference to the typical phosphorus reductions for various types of
BMPs and all bullet points. Not sure how we can achieve any of these reduction levels
within a road project. It would be very difficult to provide any of the listed facilities within
our limited ROW, without significant property acquisition
March 15, 2016
DETAILED COMMENTS: draft LSRCA Tech Guidelines for SWM Submissions
Page 7
APPENDIX F – CRITERIA FOR STREAM EROSION CONTROL STUDY
76. Unsure if this would apply to all our road projects that cross a watercourse. If it is
required, would a separate study be needed for each crossing? Why would this be
needed if we have to control the water quantity to pre-development conditions?
APPENDIX G – EROSION AND SEDIMENT CONTROL STANDARDS
77. General Note to Appendix G - Some ESC measures listed are outdated and should be
updated to more recent measures
78. Section 6a) - The volume is the same as the requirements for a temporary ESC pond as
stated in subsection 5.b. Is this correct? The volume seems excessive
79. ESC Plan Notes (LSRCA ESC-1), Note 19. There is conflict with this note as the actual
site trailer location is not known until after the Contractor has been hired, which is after
the LSRCA permit has been issued
80. Temporary Sediment Basin and Outlet Details (LSRCA ESC-7) - Given our limited ROW
space this Temporary sediment basin would be difficult to provide on almost all of our
road projects without additional property acquisition or permanent easement
APPENDIX H – PLANTING REQUIREMENTS
81. General Note to Appendix H - Not sure if most of this section applies to our road
projects. If it does, it is unclear if it’s feasible to accommodate i.e. given our limited
ROW space
82. Trees and Shrubs, 1st bullet – It is recommended listing that cultivars, hybrids and
varieties are not acceptable to the list
83. Trees and Shrubs, 4th bullet – Consider increasing the spacing to 6 metres minimum for
trees
84. Stocking, 1st bullet – It is suggested to increase to 6 metres from the permanent edge
based upon the statement regarding aquatic plants requiring full sun
85. Stocking, 4th bullet – More detail should be provided as some proponent may abuse the
privilege of using smaller caliper or bare root stock in order to decrease project costs.
Provide clear parameters such as stating a slope of 2:1
86. Topsoil – Consider expanding this section to include specification for Terrestrial Soil and
Aquatic Soil
87. Acceptable Floral Species for SWM Pond Planting:
a. Please clarify if the planting list is for erosion and bank stabilization or for nutrient
and quality enhancement, or both
b. Recommend removing all references to ash trees from the list
c. Under the heading “Tree”, on page H7, some of these are shrubs and not trees
so the list should be updated to reflect this
d. Please note the botanical names for: Gray Dogwood (Cornus racemosa) and Stiff
or Swamp Dogwood (Cornus foemina)
e. For the tree “Ilex verticillata” it is recommended adding a footnote requiring both
male and female plants need to be planted as this is a dioecious species
APPENDIX I – TYPICAL HYDRAULIC VALUES AND SOURCES
88. Section I.1.1, Paragraph 4 in reference to the Steady and Unsteady state models. It is
recommend that someone else’s model should not be used and would suggest requiring
a letter from LSRCA saying it’s okay to use the model
89. Cross-Section Data in reference to “geo-referenced coordinates. It is our understanding
that we do not need geo-referenced coordinates for HEC-RAS
March 15, 2016
DETAILED COMMENTS: draft LSRCA Tech Guidelines for SWM Submissions
Page 8
90. Section I.2 Hydraulic Modeling, 1st paragraph - Is the description correct?
91. Section I.2 Hydraulic Modeling, 2nd paragraph - For accuracy, the “Managing Drainage
Manual” should be referred to as the “Drainage Management Manual”
92. Section I.2 Hydraulic Modeling, last paragraph – Existing models should only be used as
background information. This is not a recommended practice
93. Section I.3 Software Recommendations – Please clarify the version: 1D vs 2D? 2D has
not been released
March 15, 2016
DETAILED COMMENTS: draft LSRCA Tech Guidelines for SWM Submissions
Page 9
Planning and Economic Development
Corporate Services Department
May 25, 2016
Planning and Development
Lake Simcoe Region Conservation Authority
120 Bayview Parkway
Newmarket, ON L3Y 3W3
To Mr. Rob Baldwin:
Re:
Draft Version 2 – LSRCA Technical Guidelines for Stormwater Management
Submissions
Please accept this letter as York Region staff’s response to the LSRCA’s version 2 of the draft
Technical Guidelines for Stormwater Management Submissions, as circulated via e-mail for
comment. It is noted that many of the comments provided to LSRCA on version 1 were
incorporated into the Guidelines.
One area of concern that was raised as part of the initial review is how linear roads are treated
within the Guidelines and the implementation impacts to Regional projects. Upon review of
version 2 of the Guidelines, staff has questions regarding several of the Transportation
Department’s comments which remain unaddressed. The Region requests a meeting between
our Transportation Department staff and LSRCA to discuss our concerns.
Please contact Jennifer Best, Senior Planner, Long Range Planning by e-mail
[email protected] or phone at (905) 830-4444 ext. 76118 to coordinate a meeting with
Regional Transportation staff and the LSRCA.
Sincerely,
______________________________
Jennifer Best, MCIP, RPP
Senior Planner
Long Range Planning
Planning and Economic Development
MINISTRY OF ENVIRONMENT AND CLIMATE CHANGE COMMENTS
MOECC Staff Coordinated Document Review:
DOCUMENT TITLE: “LSRCA Technical Guidelines for Stormwater Management Submissions”
DATE OF DOCUMENT: February 12, 2016
It should be understood that these are not MOECC comments. They are coordinated comments of
MOECC staff that participate in the Stormwater Management Working Group for the LSRCA’s
consideration.
Item
Paragraph
General
Comment
1.0
Introduction
1.0
Introduction
1.0
Paragraph 3
1.1
General
Comment
2.0
Paragraph 2
2.0
Bullet 3
2.0
Bullet 3 Sub 4
2.0
Bullet 5 Sub 1
2.1
Second
paragraph
Comment
Suggest a uniform approach to cross referencing the LSPP
policies. Some sections have cross references whereas others
do not. This is may be confusing to the reader.
Consider referencing the need for Class EA and MOECC
approvals by outlining when in the process the LSRCA
submission would occur and that comparable information is
needed for those processes.
Consider adding a caveat at the end that says the proponent is
still required to obtain any other necessary approvals or
permits from the relevant government agencies (e.g. MOECC,
MNRF, MTO, municipality, etc)
“SWM submissions” the discussion in the proceeding sentence
is wrt Provincial documents. Consider adding LSRCA “SWM
submission”
It should be indicated that environment planning should be
consistent with and support municipal land use planning, e.g.,
OP, secondary plans, by-laws. It may be helpful to indicate the
valuable role that a municipal-scale stormwater infrastructure
master plan can provide.
Suggest the following clarification: “Better Site Design involves
techniques applied early in the planning and design process
...”
Consider accounting for wide spectrum of runoff events
ranging from high intensity short duration summer events to
low intensity long duration snowmelt/rain on snow events.
Suggest recognizing porous/pervious pavement (concrete,
asphalt, pavers) as alternative to impervious cover.
“- Plant vegetation” ..suggest adding … that is salt-tolerant,
especially where de-icing agents are heavily used.
“..absolute minimum..” suggest language change kept to an
amount that does not exceed natural background rates/loads
of sediment release.
“..all SWM submissions must” …suggest for statement to also
include future documents, otherwise may have to revise these
guidelines whenever a new guideline is released (ie MOECC
LID manual)
Page
1
1
1
2
3
3
3
4
5
2.1
General
Comment
linked to
section 3.5
Consider refering to climate change adaptation early and at
appropriate points in the guideline – instead of mainly at the
end. For example, consider some guidance and, as
appropriate, links to criteria in sections 2.2.1, 2.2.2.1, 2.2.3,
and 2.5.
2.1
Table X
5
2.1
General
Comment
2.1
Conveyance
Controls
2.2
General
Comment
2.2.1
4th bullet
2.2.1
General
Comment
Box 1,2,3
Can some consideration be given to the format of Table #.
Perhaps if the Objective was stated first and the criteria in the
second column. Cross references to the relevant sections for
each criteria would also help make connections between
content. E.g. Peak flow linkage in Table to Section 2.2.1 (page
6)
Observation it is likely implied through the list of documents
following Table X. Is there value in explicit stating the need to
consider catchment characteristics and receiver
characteristics? I recall that being a take away from the SWI
SWM Retrofit Tech project that looked at the effectiveness of
various design and technologies used at retrofit sites. This was
an interesting take away albeit related to the idea of a
treatment train approach.
The table could indicate that additional objective for “Water
Quantity”, specifically for volume control, is to protect water
quality of the receiver since reduced contaminants loadings
can be expected as a result of achieving significantly reduced
run-off.
Rain gardens and reuse can be implemented on the road
ROW. Suggest adding a new bullet: Capture and management
systems with LIDs.
Suggest that each subsections of section 2.2 take on a similar
structure. List and label the Rational, Objective, performance
goal… I was not always certain which considerations were
listed as performance goals. Which complicates matters as
the document develops
Suggest making it clear that quality control is still expected for
sites directly adjacent to Lake Simcoe if that is the case.
Do you want to mention the duration of the peak flows?
Why only impervious areas? urban pervious area does not
have same drainage characteristics as non-urban pervious.
The text boxes appear to be contradictory to statements on
page 2 which states “Better Site Design Techniques are to be
used ... Better Site Design focuses on utilizing and treating
rainfall as soon as it hit hits the ground.” The stormwater
volume control performance goals on page 8, however, seem
to apply only the fraction of the rain that falls on impervious
areas. Also, landscape areas are likely to contribute more to
phosphorus loading into Lake Simcoe.
8
2.2.2.1
2.2.2.1
Performance
goals
5
6
5-8
7
6-7
8
The performance goals described in the text boxes are unclear.
The following are also suggested: an explanation, before the
text boxes, of what is meant by “sites without restrictions”;
diagrams that illustrate the 3 text boxes.
2.2.2.2
2.2.2.2
The first boxes states “run-off volume … from run-off of 25
mm of rainfall” while the second box requires “runoff from a
25 mm rainfall event”. Is the difference intentional, if so,
please make clear their meaning. Also, how does this apply to
rain events < 25 mm or rain events > 25 mm?
General
Suggest listing the three (3) alternatives earlier in this
Comment
subsection, then the process and then the factors to be
considered.
When there are examples of retail site that can on-site
Flexible
manage to 1 in 100 year return event, and LID street systems
Treatment
Alternatives for with minimal run-off, 12.5 mm and 5 mm volume reduction
appears too relaxed. However, it is recognized that alternative
Restriction
may need to be considered on a case specific basis.
8-9
8-9
Alternative #2 with minimum 5 mm volume reduction seems
too relaxed. Are significant benefits expected from 5 mm
volume reduction, and if not, is there a need for alternative
#2?
2.2.2.2
2.2.3
2.3.1
Box alternative
#1 and #2
Under alternative #3, item iii could be limited to the same
tributary but anywhere upstream or alternatively anywhere is
the same storm sewer catchment area. Item iv (anywhere in
Lake Simcoe watershed) seems too broad, contrary to LSRCA’s
Better Site Design principle and as such may be perhaps
inappropriate.
I may be misunderstanding this, but Alternative 1 is saying a
minimum of 12.5 mm volume reduction on-site. What about a
combination of Alternative 1 and 3? - Total of 25 mm volume
reduction, but 12.5 mm on-site and 12.5 mm off-site.
Same with alternative #2.
Major Minor
Please make clear if a major system is required guidance from
System
LSRCA perspective for neighbourhoods where there are minor
systems.
Final paragraph Should make reference to Table 3.2's footnote that states the
table does not include every available SWM practice type. If a
practice can be demonstrated to the ministry to meet the
required long-term suspended solids removal, it is acceptable
for water quality objectives.
May want to reference title of document “ Stormwater
9
9
11
2.3.1
Phosphorus
2.3.2
Paragraph 1
2.3.2
2.3.2
Paragraph 2
Paragraph 3
2.3.2
Paragraph 5
2.3.5
Paragraph 1
2.3.5
Paragraph 2
General
2.3.5.1
Paragraph 1
sentence 3
2.4
2.4
Paragraph 1
2.5
Paragraph 2
2.5
Paragraph 4
3.0
Paragraph 2
General
management and design manual (March, 2003) for greater
certainty about the source document. Hyper
link https://www.ontario.ca/document/stormwatermanagement-planning-and-design-manual
The annual phosphorus load reduction applies to impervious
surface only. However, landscape areas are also sources of
phosphorus loading into Lake Simcoe, e.g. sediment, animal
feces, fertilizer.
Phosphorus Loading Study – The first paragraph uses language
which is different than LSPP Policy 4.8. “Phosphorus Loading
Study” vs “SW plan”
Target is “zero increase” vs LSPP 4.8(e)“shall be minimized”
Is P loading higher during the spring/snowmelt season? If so,
suggest note be added that designs of practices should
accommodate this season's runoff/soil characteristics in order
to truly reach an annual reduction in TP load of 80%
I found Appendix E to be more informative than this
paragraph. Suggest dropping the cross reference to the tool in
favour of listing the table of values.
Suggest moving the introduction to this section up to the start
of the Water quality section and bumping the clauses listing
contaminants up to subsections so that they flow better.
Is there value in discussing water quality in the receiving
body?
There seems to be a change in the document from
considerations to supporting documents. Suggest inserting
transition language.
“,…OGS units can be used..” - suggest to put an add-on to this
sentence stating that frequent maintenance is required,
otherwise the trapped sediment can be flushed out in large
storms.
Is the test a proposed ‘development’ or ‘major development’
This subsection is seemingly disconnected from the design
requirements of the other sections. Perhaps it is the subject
matter.
The last sentence makes reference to a consultant. No other
section uses this language.
The final two sentences seem incomplete and may contain the
author’s notes.
First time the terms ‘qualified professional’, ‘licensed
professional’ have been used. The additional terms ‘such as’
make this a confusing requirement.
Assess the value and potential of a submission’s checklist or
quick reference guide, particularly to help developers
understand the expectations. A checklist could list the various
steps and assessments, when they could be applicable and
guideline’s section for reference.
11
11
11
11
11
13
13
13
14
14
15
15
18
18 or
later in
Appendix
General
3.3
General
3.3.1
Third
paragraph
3.3.1
Forth
paragraph,
Third sentence
Section 3.2 and 3.3 seem to be unique ideas. Suggest there is
a need for some language to help the reader transition from
supporting studies to the design of the works.
There does not appear to be any actual verification that SWM
facility (after build) is working as designed. Modelling and
predicting the performance of a proposed design is valuable,
however, some form of science based verification of volume
control and phosphorus reduction achieved is needed for as
long as the design is being relied upon.
“water quality credit…” – this idea needs to be described in
greater detail. Recommend adding some text to specify by
whom? credit issued by LSRCA?
The document should make clear that guidance about water
quality credits and LID credits are LSRCA guidance. The LSRCA
document must not presume MOECC decision outcomes.
“..LSRCA is to be preconsulted..” can we also include
preconsultation also with MOECC
Assess the value and potential of a submission’s checklist or
quick reference guide, particularly to help developers
understand the expectations. A checklist could list the various
steps and assessments, when they could be applicable and
guideline’s section for reference.
3.4
General
A transition to the approval process should be better
described ahead of the Subsection.
3.5
General
Climate Change Subsection seems to be hanging. This could
possibly be incorporated into another section so that it is seen
as a part of the design standards?
4.0
“Development” Note that this is different than the Provincial Plans
“Major
I made note that the SPP has a different definition from the
Development” LSPP. Is there need to clarify this or is the intent to use the
LSPP. Note the term development is cross referenced yet
distinct in section 4.0 vs the LSPP.
“Watercourse” For continuity suggest aligning with the term key hydrologic
features in LSPP. The proposed definition is quite broad and I
believe it may create challenges wrt to the definition of
sufficient outlet.
“Qualified
Suggest this term should be considered for a definition.
Person”/
Individual
Appendix STEP 1 Table
Low Infiltration Rate - What does this mean? If the infiltration
B
rate is less than 15, then no credit is given and they can't
proceed to Step 2?
While the 2003 manual states that infiltration practices may
not be suitable if there is an infiltration rate less than 15
mm/hr, it is a guideline and according to the LID Interpretation
19
19
20
20
20
27
28
30
30
30
B2
STEP 2 Table
Monitoring
Plan
Appendix Bullet f)
G
Appendix Headings
I
Paragraph 4
Bulletin (2015, Standards Branch), should be interpreted not
as a prohibition but a caution.
Why would you get a score of 1 for having no monitoring plan? B2
Shouldn't it be 0?
…”installed at all low…” – May be a typo
G3
Heading number structure may be incomplete after I.1.1
I5
Punctuation is highlighted in yellow
I5
CITY OF BARRIE COMMENTS (V1)
Project Review Comments
Item
1
2
3
4
Section
5
6
7
8
9
10
11
12
13
14
15
16
2.0
2.0
2.0
2.0
2.0
2
2
2.1
2.1
2.1
2.1
3
4
4
4
4
4
5
5
5
5
5
5
17
18
19
20
21
22
23
2.2.2.1
2.3.2
2.2.2.2
2.2.2.2
2.2.2.2
2.2.3
2.2.3
7
8
8
9
9
10
10
24
25
26
27
29
2.2.3
2.2.4
2.3.2
2.3.2
2.3.2
2.3.3
10
10
11
12
11
12
30
31
32
33
34
2.3.3
2.3.5
2.3.5.1
2.4
2.3.5.1
12
13
13
14
14
35
2.5
15
36
37
38
39
40
41
42
43
44
45
3
2.5
2.6.2
3.3.1
3.3.1
3.3.1
3.3.2
3.3.1
3.3.1
3.3.1
15
15
17
19
20
20
20
20
20
20
1.0
2.0
Page
1
1
3
3
Remarks
Hydro-Geological is one word
c and d could be combined
Remove reference to BMPs (re; standard language comment above)
provide Referance for "Better Site Design Techniques"
standardize terminology throughout document ie) Better Site design "techniques" at start of para and Better Site design "practices" at
end.
define ESC
When application has been made to capture and store runoff for irrigation MOECC will not permit (discussion)
Why is 2ha the required site plan?
Memo should be a requirement not "good practice"
The requirements for information prior to pre-submission be clearly outlined
The objectives in Table 1 should be more measurable, what are they based on? To what level should they be carried out?
"reduced lot grading" should read "reduce % grade of lot"
Table should be numbered and have a title
Why are Chlorides not included within this table?
The objectives should include conformance with ECA and lake Simcoe Act.
Why are the bulleted document not within the table above?
section is not clear - if what is in the boxes are performance goals - that should be stated as it indicates "the following stormwater
performance goals"
The terms "Linear projects" should be defined
The Alternatives on page 9 should be introduced prior to the discussion on page 8
vi. Should this indicate 30 m from a dug well? 15 m is from a drilled well? Also should highly vulnerable aquifers be included?
Additional guidance should be provided on the process of assessing and implementing off-site mitigation.
Regional storm even needs to be accommodated
The City doesn't secure ownership for Site Plan developments unless conveying enhanced drainage through the site.
Does this conform to the drainage act? "In the case of discharge to privately owned land, the proponent shall be required to obtain a
legal right of discharge registered on title"
Conveyance must be undertaken such that there is no increase in regulatory flood elevations
using "kept to a minimum" is too general - can a threshold be applied +5%
Define "acceptable third party"
Will phosphorus trading requirements apply if a site is not meeting the target "zero" increase in loading
Should mention of contamination of shallow aquifers that provide baseflow be included in this section?
The Source Protection Group is in support of encouraging the design of roads and parking lots to minimize the need for excess road
salt application. It is also recommended that the background in this section also speak to impacts to the groundwater system,
particulary the shallow aquifer systems that provide baseflow the streams. This section should also speak the use of the LIDs and road
salt. (e.g. unless clean roof-top runoff is to be infiltrated infiltration of salt laden run-off would not be permitted in WHPA-A-B, and A-C
in the ICA).
Can examples of acceptable treatment train be provided?
What else should be included to control Oil, Grease and Gas? Provide examples
define "known erosion area" and "first and second order headwater streams"
This paragraph states why Heavy Metals are of concern but provides no context to this manual or what is required to manage them
The Para outlines the requirement of a water balance assessment but then indicates that each consultant should contact the CA to
discuss - this should be standard criteria or part of the pre-consultation meeting - the purpose of guidelines is to ensure standards are
set.
Last para indicates that some existing approved plans of subdivision may only require the infiltration of water from rooftops - when
does this apply? Why is it important to highlight?
Para 1 - City of Barrie Drainage policies require water balance for all Development proposals
discuss using wet pond or sediment ponds
Do we need to reference US EPA when we have so much information locally through LSRCA and CVC?
Section 2.2.1 is not below.
Are there credits available for a conveyance system?
within the table is the should 100-year and "Regional" be included?
Properly reference the CVC TRCA manual instead of calling it "this 2010" manual.
Section 2.2.1 is not below.
More information is required regarding the water quality crediting system - who will provide them, how will they be tracked?
46
47
48
49
3.3.1
3.3.2
3.3.2
3.3.3
20
20
22
23
50
51
52
53
54
55
56
3.3.3
3.3.3
3.3.3
3.3.4
3.3.4
3.3.4
3.3.4
23
23
23
25
25
26
26
57
3.3.5
26
58
59
60
61
3.3.5
3.4
3.4
3.5
26
27
27
29
62
63
64
65
66
67
68
69
70
71
72
4.0
4.0
4.0
4.0
4
4.0
2.0
2.0
2b
2.0
30
30
30
30
30
31
A2
A2
A2
A3-4
A5
73
74
75
76
77
3.0
4
4.0
8.0
8.0
A5
A6
A6
A8
A8
78
79
80
8.0
8.0
A8
A8
B1
81
82
83
84
85
86
87
88
89
1.1
90
91
92
93
94
1.1
General
General
General
95
General
96
General
B2
B2
B3
B4
B4
C10
C12
C3
C5
H1
I4
p
y
q
g
q
safety/failure factor?
define "facility" as it applies to SWM
Define where "freeboard" is measured from
Point 1 - max allowable ponding depth - is this measured from the top of 100 year overflow?
"The consultant is advised to consult with the governing municipality for guidance and details regarding parking lot and rooftop controls
within their jurisdiction" Why is this highlighted for parking lots and rooftops? Does this mean the CA is not going to comment on
these? should the consultant not consult with the municipality on all aspects of SWM? (discuss)
note that ICDs and orifices must be fixed to the structure
The City has a min allowable orfice drain (0.75m)
Oil and grit separators remove particulate "P" the city would like to see credit for these.
there is an OGS section 2.3.5.1 and 3.3.4 - perhaps they could be combined?
The Sentence "Be advised" could be better worded
Alternatively Municipalities could outline the approved OGS product and the CA could note that within this document.
Currently the City of Barrie is working on a Pilot project with the MOECC to combine ECAs - in doing this maintenance requirements
are being determind - it is important that these efforts are not duplicated (discuss)
The operation and maintenance manuals submitted should be inline with the requirements of the system wide ECA (under
development). (discuss)
consistency of language - why is the term charrette being used for the first time this far into the document?
define "qualified person"
bulleted list should be re-organized based on life safety risk
Further definition of a fully reconstructed impervious surface should be provided. Does this include 0.5 hectares of roadway being
reconstructed now requires the addition of a stormwater management component for volume control?
Why are we using Timmins storm event? Can that be mapped to show the relationship the watershed?
include definition of "SPP"
should be an acronyum section and a definition section
The Source Protection Plan definition of major development needs to be included within the glossary.
define " canopy interception" and "safe conveyance"
a) Location should include municipal address, Existing condition should include Natural Heritage and SWP info should be included
should SWP issues be included in the list?
b) should the document indicate that when applicable the ECA will account for the information outlined in 2.0?
Velocity would be a better Inlet and Outlet Design criteria
Could there be a section that includes Hybrid Wet Pond/Exfiltration Cell
Throughout the document pre-and post-development are discussed - perhaps there should be a paragraph that outlines how infill, city
and provincial projects will be considered if the same - state that once
Should the first bullet read Regional event and uncontrolled 1:100 year flood lines…
Refer to the LSRCA Hydrogeological Guidelines for details.
Design should include all background info that support design
When outlining survey information should specify details required (geo ref top of bridge deck and underside of bridge deck).
clairify meaning "In modelling files and documentation to maintain existing watercourse naming conventions were applicable" who has
the correct naming convention?
Info should be better organized ie that which is specific to model, survey, drawings in three groups.
More context around the credit system is required - who determines, how it works within the existing crediting systems? (discussion)
There may be other water quality constraints identified outside of a Source Protection Vulnerable Area that create an issue. For
example, a brownfield site not in a WHPA, or a rural nitrate plume.
Monitoring Plan credits need to consider the ECA process. (discuss)
the explanation of 5 should be clarified it seems that you are getting more points for failure
Is the calculation shown used to determine impervious area? If so state that.
table should have title (Step 3: Assumption)
What about SWMM in the list of software recommendations?
Can Green-Ampt be included?
rainfall distributions applied to a site… should be decided in conjunction with the subject Municipality and LSRCA.
What does the sentence "Climate adaptation of precipitation and rainfall is becoming a requirement by several Municipalites" mean?
There are extensive differences between the City planting requirements; a summary of the differences have been included in the next
tab in this spreadsheet - for LSRCA's information. (discuss)
100 m is too large - 75m recommended.
Links to references should be provided when available
Section numbers and references within document should be reviewed for example 2.3.2 is followed by 2.2.2.2
More Context should be included regarding the application of these Guidelines - are they specific to the regulated area? (discuss)
Can there be clairification regarding the requirement that runoff from a 25mm design storm be detained? Why was this value chosen?
As this seems to be a conservative number are we also requiring a safety factor within the design? (discuss)
There are several areas, some of which are outlined within the comments where the Guideline conflicts with City standards, the city
would like to request a meeting to discuss the best method to clairify these differences to both the development community and
internal staff (City and CA).
CITY OF BARRIE - APPENDIX "H"
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Comment
The City’s density requirements appear to be different and are calculated through a density chart for each area such as upland and shoreline fringe.
There is a comment that planting layout should be random and natural where the City requires shrubs to be planted in masses for survivability against
herbaceous development. The City requirement is for mass plantings of a minimum of 15 shrubs.
The tree density should be dependent on size (Bare Root vs. Caliper) and species. Spacing can range from 2.5m to 9m for trees.
The City density ratios are different and allow for more flexibility on site dependent layouts based on our matrix and substitution rates. Our standard is a 50%
coverage. We also permit for the substitution of materials based on density such as the calculation of whip stock for trees, shrubs for trees or trees for shrubs
to be flexible and meet specific site requirements.
The City does not typically require or endorse in-water or aquatic planting outside of the establishment of rush species. The loss rate of material to ducks and
geese does not justify the benefit. Natural succession has also shown to be quite high in ponds. Also, we are finding that through the pond cleaning operations
the developer or Operations is more than likely to remove aquatic materials from the main cells through clean out operations. Planting within the fore bay is not permitted by the City.
The reference to stocking material should be as per industry standard where caliper is shown in mm. (50-60mm).
The City does not permit the installation of bare root material as the timing of installation is quite specific and is often a hindrance to the establishment of
planting.
Due to the nature of herbaceous growth, all shrubs must be a minimum of 60cm in height as a nursery standard.
H4 shows the profile for planting zones but does not show a description or address the requirements for each zone. It appears that this detail has been
redirected to show ‘Moisture Zones’ from its original purpose. This is covered by our current BSD-1318 that has also been used by the NVCA. The intent of this
detail should reflect the proper designation for each zone as Submergent, Aquatic Fringe, Shoreline Fringe, Flood Fringe and Upland
The Acceptable Floral Species for SWM Pond Planting title should not use the word ‘Floral’
In regards to the species listing for SWM Pond Planting please refer to the following:
The City of Barrie will not accept the use of Ash, Poplar, Aspen, Birch and Rubus (Raspberry). There are situations in urban environments (not in proximity to open space or EP designated lands where the selective use of some tree cultivars should be
considered for diversity. While this steers away from the “native” designation of ponds, the issue is that these cultivar trees are often found on the adjacent
street frontage or the rear yards of people backing onto the ponds. Some additional consideration for Aesthetics should be given for these situations where
native is not a critical element at the discretion of the municipality.
Hickory has not proven suitable for Barrie’s climate but would be fine in other parts of the LRSCA’s southern boundary zones. Black spruce is difficult to source and often is only available in small container sizes. Because of its slow growing nature it is also susceptible to being choked
out by herbaceous materials. There are restrictions on placement of materials adjacent to residential lots such as willow, basswood and silver maple due to the growth and rooting habit of
these trees.
Page H7 should show material listing as ‘Shrub’
While there is a warning on the listing for Ash, it should also be noted that other varieties of plant material may also be deemed acceptable by the municipality
based on site specific needs or conditions that are not contained within the planting list. Examples of shrubs for use not shown on the planting that may be acceptable:
 Cephalanthus Occidentalis – Buttonbush
 Elaeagnus Commutata – Silvervberry
 Hypericum Prolificum – Shruby St. John’s Wort
 Lindera Benzoin – Benjamine Bush
 Myrica Pensylvanica - Bayberry
 Myrica Gale – Sweet Gale
 Rhus – Sumac (fragrant, smooth and staghorn)
 Rosa Palustris – Swamp Rose
 Rosa Setigera – Prairie Rose
 Shepherdia Canadensis – Buffaloberry
 Spirea Tomentosa – Steeplebush
 Symporicarois Albus – White Snowberry
 Viburnum cassinoides – Witherod
One element that I did not see addressed was the application of seed and mixture rates. Currently the City of Barrie requires the application of the Native
Simcoe County Seed Mix and an Annual Rye nurse crop. This is often used in conjunction with a 1.0m wet meadow mix application around the water zones
although this material is not typically 100% native.
It is noted that in Section ‘G’ the details and standards shown do not necessarily comply with that of City Standards. Engineering standards are currently being
redeveloped and would be applied to any works within the Municipality and take precedence over those shown in this section. Specifically, the Sediment Control
Fence detail is not a robust as our current standard and does not address terminal posts, tensioning or fastening methods.