Walter
T. Pereyra
City of
488 –
RE:
The following comments are
provided in response to the Environmental Checklist prepared by the City for
the proposed development of
From my review of this
checklist and appropriate documents, and participation in a community meeting
on the proposed park, I have concluded that the development of Ebright Park as proposed will
adversely impact Ebright Creek and its fauna and
environment as well as my property and in particular my home. Developed ball fields are not suitable for
this site and should be eliminated from the park design.
1.
BACKGROUND
I have lived on Ebright Creek for 30 years.
My property is bisected by Ebright Creek
downstream from the proposed park site.
My home, which was built in 1936, is situated 20-feet from Ebright Creek. I am
intimately familiar with Ebright Creek and its
environs.
As
has been pointed out in the checklist, Ebright Creek
is a high quality, Class II salmonid stream
supporting cutthroat trout and rainbow trout, and spawning populations of kokanee salmon, coho salmon and
sockeye salmon. The kokanee salmon in Ebright Creek were recently determined to be part of the
dwindling run of native kokanee from
2.
ENVIRONMENTAL IMPACTS
The development of Ebright Creek as proposed will increase discharge into Ebright Creek and thus adversely impact the creek, its environment and its
fish and fauna.
Runoff from the
The increased runoff was
verified by the city’s consulting engineer from Gray & Osborne present at
the public hearing and is further detailed in the Stormwater
TIR prepared by them for this development.
Although remedial measures are proposed to address the expected impacts
from increased peak flows to Ebright Creek, the fact
remains that the volumes of water
passing into Ebright Creek will be increased. These increased flows to Ebright
Creek, primarily during the rainy winter season, will flow downstream through
the known Ebright Ravine, a critical steep-sloped
area subject to an SO-190 designation due to its potential erosion
hazards. Increased flows means increased
erosion which equates to increased negative impacts to kokanee
and salmon spawning in Ebright Creek and their
subsequent production plus the trout populatins
native to the creek.
3. REDUCED
AQUIFER RECHARGE
Increased
runoff from the proposed site will reduce the important recharge of the aquifer
supplying Ebright Creek during the critical summer
period.
The acceleration of
water off the park site in the form of increased runoff can only reduce the
amount of recharge of the important aquifer for Ebright
Creek. This is particularly important
during the summer months when Ebright Creek becomes
totally dependent upon subsurface flows from this aquifer for its
maintenance. With flows at my home
averaging only 0.5 cfs, any reduction in summer flows
is critical to the carrying capacity of the creek.
4. CHEMICAL
POLLUTANTS
The use
of fertilizers and other field maintenance products on the proposed ball fields
will potentially add phosphorous and other pollutants to Ebright
Creek and
The maintenance of the
ball fields will most likely require the application of fertilizers, herbicides
and pesticides. Even with the most
judicious application, some of these chemicals will eventually end up into Ebright Creek due to runoff and flow patterns on the site, and
the relatively close proximity of the ball fields to Ebright
Creek and wetland areas. There is no
question that such chemical contamination will have a deleterious impact to the
fish, fauna and environment of Ebright Creek and
eventually
5. FLOODING
IMPACTS
Increased
runoff from the park site can only add to the flooding impact to my home during
periods of extended high flows in Ebright Creek
As pointed out above, my home
is sited on Ebright Creek, just 20-feet from its
southern bank. In recent years I have
noticed increased flows in Ebright Creek during the
winter months. Ebright creek itself has flooded my house and
property on three occasions. There are strong indications that increased
development on the Plateau is responsible for these increased flows and their
damaging effects. The consulting
engineers for the City have indicated that proposed development of the site
with a multi-purpose ball field will increase the runoff from the park
site. Even though peak flows may be
attenuated through proposed mitigation measures, the fact remains that the
total volume of water flowing off the park site will increase. These increased volumes of water can only add
to the risk of flooding of my property and particularly my home.
And what happens if the
engineering solutions for handling the increased runoff fail to mitigate against increased peak flows? Will the park be “undeveloped”? NO.
Will the risk of flooding of my home increase? YES.
This then becomes my problem and the costs of development have once more
been externalized. This risk and end
solution is unacceptable.
The City certainly should not
be contributing to this increasing
cumulative impact to Ebright Creek and my
property by further developing lands in the immediate watershed of Ebright Creek. To the contrary the City should be doing
everything possible to mitigate the damage that has already been caused by the
reduction of permeable land on the Plateau.
In summary the City should make a determination of significance (DN) for the
proposed park site. I feel the
environmental impacts from the proposed development of the
In my mind it is totally
unconscionable for the City to propose developing the sensitive lands of the
Thank you for allowing me to provide these comments in response to the
Environmental Checklist. I look forward
to the evaluation by the City of these and other comments on this Checklist and
the final determination of significance in response to these comments.
Sincerely,
Walter T. Pereyra, Ph.D.