HomeMy WebLinkAbout01 - CAO 44-16 - Small Craft Harbours - Harbour Lands Divestiture
REPORT
CAO
TO: Mayor & Members of Council
FROM: Paul Shipway, CAO
DATE: July 21, 2016
REPORT: CAO-44/16 SUBJECT: SMALL CRAFT HARBOURS (SCH) – HARBOUR LANDS DIVESTITURE
On June 16, 2016 the Council of the Corporation of the Municipality of Bayham passed the
following resolution:
THAT the Council of the Corporation of the Municipality of Bayham
direct staff to submit a request to the Port Burwell Provincial Park for a
permanent easement over Part 1 and Part 2 of Plan 11R990, as
required, to provide access to the West Pier Boardwalk;
AND THAT staff be directed to post a historical overview report, and
relevant studies, of the federal harbour divestiture process;
AND THAT the staff report and relevant studies be posted on the
Municipal Website under ‘Studies’ when prepared;
AND THAT the historical overview report be within the July 21, 2016
Council Agenda for information purposes.
On June 17, 2016 staff sent formal correspondence to the Port Burwell Provincial Park requesting
consideration of an easement over the provincially owned lands providing access to the West Pier
Boardwalk as an attempt to legally and formally provide access over the same. Further
background pertaining to the historical access rights is included within this report.
This report has been prepared in an attempt to provide a holistic assessment of available
information pertaining to Small Craft Harbours (SCH) Divestiture discussions to date utilizing
available information. The historical information also includes facts about assets surrounding
and associated with the harbour lands.
In 1995 the federal government made port and harbour divestiture an official policy.
The Canada Marine Act received Royal Assent in 1998, and implemented the National
Marine Policy, which introduced commercial principles for managing marine
infrastructure to achieve greater efficiencies. The goal of divestiture was designed to
improve the efficiency of Canadian marine transportation by rationalizing port systems
and placing decision-making in the hands of users and local interests best placed to
operate them. Since implementing the National Marine Policy, the federal government
has attempted to strengthen the public port and harbour system by transferring
management and operation of major ports to not-for-profit organizations. The Canada
Marine Act allowed for divestiture of public port facilities to local interests, provincial or
municipal governments, allowing communities to own and control local facilities and
determine appropriate levels of service and maintenance. In the absence of any local
interest in taking over public port facilities, the Canada Marine Act allowed the
government to terminate its’ interests in these facilities.
SMALL CRAFT HARBOUR DIVESTITURE PROGRAMME
Fishing has historically been very important to the Canadian economy and culture. As
such, the DFO-SCH programme operated and maintained >1000 harbours
(comprising of 900 fishing and 135 recreational harbours) across Canada to provide
commercial fishers and recreational users with safe and accessible facilities.
Mandated in 1973, in accordance with the Fishing and Recreational Harbours Act, the
DFO-SCH programme maintained harbours “critical to commercial fisheries at an
acceptable standard”. Prior to the implementation of the National Marine Policy and
Port Divestiture Programme (PDP), the federal government began transferring
ownership of recreational and fishing harbours with minimal activity to community-
based groups. The DFO-SCH programme retained only essential harbours to the
commercial fishery and expanded private sector involvement in the management of
core harbours. The DFO-SCH programme mandate is to maintain harbours open and
in good repair, and is managed by five regions across Canada: Newfoundland and
Labrador; Maritimes and Gulf; Quebec; Central and Arctic; and Pacific.
Each year the Canadian government spends significant funds on harbour
maintenance and upgrades, including sediment dredging to maintain navigable
access. The current vision for DFO-SCH is to maintain only a network of essential
harbours, and to transfer ownership of all non-essential harbours through divestiture:
“Port divestiture improves the efficiency of Canadian marine transportation
by rationalizing the port system and placing decision making and
operations in the hands of users and local interests”1.
CHRONOLOGICAL PORT BURWELL HARBOUR BACKGROUND
The origin of Port Burwell is closely linked to harbour facilities and was established as a small
fishing wharf in 1833. Lumber was harvested from the area and exported from the harbour to
the United States during the 1900's. The 1900’s also saw major improvements to the wharf for
coal shipping and the harbour was used largely as a commercial fishing and bulked goods (coal,
potash and fuel oil) trans-shipment point 2.
1 Harbour Divestiture in Canada: Implications of Changing Governance – Journal of Marine Policy, Walker et al.
August 2015
2 Staff Report D-03/99 - Municipality of Bayham, March 10, 1999
In 1906 the Ashtabula railroad car ferry was launched, providing daily service between Port
Burwell and Ashtabula, Ohio. Canadian Pacific Railway (CPR) tracks and related rail
infrastructure were built to serve the ferry dock on the east side of the harbour, as seen on
aerial imagery from 1956 shown on Appendix ‘A’3.
The community of Port Burwell was part of Bayham Township as a Police Village until 1949
when the community was incorporated as a Village. This separation was the result of a
referendum held in 1948 sparked by a desire for local autonomy and procurement of water and
sewer services for the community. The Village flourished until the 1960's when the need for
coal diminished as a result of the demand for natural gas, electricity and oil. By 1964 the coal
shipping was transferred to Port Stanley4.
In 1948 Graham Oil constructed two, 700,000 litre (600,000 imperial gallons) oil tanks off-site
visible on aerial imagery from 1973 shown on Appendix ‘B’. The 1950’s see a fire within the
area of an 8,000 ton (8,130 MT) coal pile 5.
In 1958 the Ashtabula ferry sinks in Ashtabula Harbour, and the railcar ferry service is
discontinued. Dredging of the harbour to 24 feet (7.3 metres) is discontinued sometime
between 1962 and 1970. The turning basin begins to fill with sediment.
In 1976 transfer of the Harbour Lands from Public Works and Government Services Canada
(PWSGC)/Transport Canada (TC) to the Department of Fisheries and Oceans (DFO) Small
Craft Harbours (SCH) is completed. Port Burwell was designated as a Commercial Harbour
under the jurisdiction of TC until the transfer when SCH assumed authority and the designation
was changed to a Recreational Harbour. The change in designation meant that TC no longer
operated the harbour. The operation of the harbour was offered to the Village and the harbour
was required to operate with monies generated from leases, user charges and levies. Dredging
of the harbour by the Federal Government ceased to be carried out in 1973 6.
On March 23, 1977 the Village of Port Burwell passed By-law No. 301 authorizing the
construction of the East Beach Breakwall, built under the Shore Protection Works Program -
1800 & 600 Feet (1974 & 1978).
As a result of local political pressure, in 1977, an agreement with the Federal Government was
reached whereby the Federal Government purchased an $180,000 dredge in order to reduce
the financial burden of harbour operations. In return for the equipment, the Village would be
responsible for providing the expertise and labour for dredging activities. The dredge was
burned beyond repair in 1983 and as a result dredging stopped until 1989. As part of the
original provision of the dredging equipment, DFO indicated that a stipulation for the purchase of
the equipment was that the Village would make no further requests for dredging funding to the
Federal Government.
Again, increased political pressure led to an annual cost sharing of dredging fees on a 50/50
basis to a maximum of $30,000 per year between DFO and the Village of Port Burwell. The
dredging cost each year had exceeded $30,000. Donations from a few users, Federal grants
and some licence fees and recreational marina operations assisted in covering the Village’s
3 Remedial Options Analysis and Remedial/Risk Management Action Plan – Stantec Engineering. 2015
4 Staff Report D-03/99 - Municipality of Bayham, March 10, 1999.
5 Gartner Lee Limited, 1997
6 Staff Report D-03/99 - Municipality of Bayham, March 10, 1999
share of the costs, however, the majority of the Village’s funding came from the municipal tax
base 7.
The Village of Port Burwell first adopted an Official Plan in 1988 which contained strong
acknowledgements of the need for an operational harbour and a long term solution to costly
annual dredging activity by building an outer harbour facility. The Village of Port Burwell
commissioned a Tourism and Recreation Study and Master Plan (Hanscombe Report) which
was adopted in 1991. A background report was prepared in 1989 by Johnson Sustronk
Weinstein & Associates (JSW) entitled ‘Port Burwell Outer Harbour Study’. The Port Burwell
Outer Harbour Study recommended an Outer Harbour Facility at an estimated cost of
$8,135,000 as the inner harbour was subject to continuous silting while the near shore is subject
to an active littoral drift 8.
A financial partnership between various levels of government was recommended. Prior to this
development, the Village of Port Burwell had tried to sell dredged material to the United States
Army Corps of Engineers to re-nourish the beaches along the south shore of Lake Erie,
however due to environmental concerns, a sale could not be made.
The JSW study included analysis for maritime development and provided a comprehensive
review of recreational and commercial boating activity within the Lake Erie Basin and the
economic benefits resulting from the construction and operation of a harbour facility.
In 1991 at the peak of recession, Port Burwell attempted to attract a private
developer for the Outer Harbour Development. This process consisted of
requests for proposals of which only one was received. The developer was
an architect who modified the project and proposed a complex $110,000,000
development consisting of hotels, condominiums, commercial buildings and a
300 berth marina…an agreement was immediately executed between the
developer and the Village of Port Burwell. In 1992, the dream of a large
Outer Harbour was tied to a bid to have Ontario's first gambling casino. The
bid was apparently one of three seriously considered. However the licence
was given to the City of Windsor. Financing of large projects had now
become difficult and caused the project to be shelved permanently. Both the
JSW and the Hanscombe Reports contemplated implementing their programs
for improvements by obtaining Provincial and Federal grants.
On May 22, 1991 the Village of Port Burwell executed Contract No. CO-023, with DFO, to build
a Boardwalk on Federal Lands. This Boardwalk was authorized under Section 11 of an
Operating Lease Agreement between the Village of Port Burwell and DFO (multiple, identical,
yearly operating contracts existed. The final operating contract was authorized by Municipality
of Bayham By-law No. 1999-077, which ended May 31, 2000 as a decision of DFO). Funding for
construction of the Boardwalk was provided by DFO, Employment & Immigration Canada –
Canadian Jobs Strategy and the Village of Port Burwell. The completion date of the Boardwalk
project was July 26, 1991. Further, in relation to the West Bank Parking (Provincial Park
Parking Lot), which provides access to the Boardwalk, there was discussions about a
permanent granted use over the lands, however an agreement or easement was never
finalized, confirmed or registered during closure of Chatham St. and during new Provincial Park
7 Staff Report D-03/99 - Municipality of Bayham, March 10, 1999
8 Remedial Options Analysis and Remedial/Risk Management Action Plan – Stantec Engineering. 2015
entrance discussions. As such, access across the lands is at the leisure of the
Province/Provincial Park.
Additionally, the Village of Port Burwell also subleased land and items known as the Boat
Launch, Black Docks and Finger Docks (Plan 11R-990 Parts 7,8,9 – Federal Lands), attached
hereto as Appendix ‘C’, as a component of Agreement No. 0069.
On April 23, 1993 The Village of Port Burwell acquired Parts 1, 2 and 3, Plan 11R-5136 and
Parts 1 and 2, Plan 11R-5137 from SCH in the amount of $37,000. These acquisitions included
the East Pier and lands indicated in Appendix ‘D’ attached hereto.
In 1993 fog horns were removed from all ports in Lake Erie contrary to protests from
municipalities. The Canadian Coast Guard is responsible for navigation aids and mariner
information with respect to safe harbours and they had concerns with the Port Burwell Harbour.
Canadian Coast Guard did not want boaters attracted to unsafe harbours because of the lack of
depth and navigational markers. Various weather conditions can cause the Port Burwell
Harbour to ‘fill in’ causing boats to run aground. There are several regulations regarding
navigational aids and harbour conditions. These aids were historically continually being
removed from the bodies of water or being 'downloaded’ to municipal governments to look
after 9.
From 1994-2000 the Municipality of Bayham was a partner in the Lower Big Otter Remedial
Action Project which focused on tree planting, erosion mitigation and education in efforts to
lessen the siltation issues within the Big Otter. ALUS has effectively taken over the initial
concept of the Lower Big Otter Remedial Action Project.
In 1994 and 1995, a ‘Tri-Party Memorandum of Understanding (MOU)’ had been prepared by
the Canadian Coast Guard, but was never executed as the Village of Port Burwell did not satisfy
the MOU requirements. The parties involved were DFO, Canadian Coast Guard, and the
Village of Port Burwell. The MOU had been prepared in view of the limited safe access from
Lake Erie to the harbour. The Coast Guard was willing to undertake the continued provision of
its services only if the conditions allowed for safe navigation of small craft. DFO advised that
they took back the lights and only obstruction lights existed which warn mariners of obstructions.
In 1995, Pembina Resources Limited (Talisman Energy Inc.-Dundee Energy) purchased, from
the Village, approximately four acres along the mouth of the Big Otter Creek at a price of
$160,000 as a result of their concerns for access to the inner harbour and the central location of
the community to its existing gas wells in Lake Erie. A visual of the land is attached hereto as
Appendix ‘E’ (Part Lot 11, Concession 1, Part 3, RP 11R-5136). A draft Memorandum of
Agreement between the Village and the gas company requiring the gas company to provide a
minimum of $7,500 per year towards dredging activities existed but was never executed or
formalized. It is assumed it was drafted in lieu of the property purchase.
In an attempt to recover costs associated with harbour maintenance and operation, on June 24,
1996, the Council of the Village of Port Burwell gave first and second reading to a User Fee By-
law which was subject to significant opposition from marina operators and commercial
fishermen. As a result, the by-law did not receive a third reading and Council agreed to permit
harbour users to instead make donations for maintenance. The total sum of funds received by
9 Staff Report D-03/99 - Municipality of Bayham, March 10, 1999
donations was $600 from the commercial fishermen. The defeat of the by-law and significant
shortfall in donation revenue contributed to a Village of Port Burwell municipal year end deficit of
$52,000 10.
In 1996 an inspection of the harbour was conducted by Public Works and Government Services
Canada (PWGSC) for SCH, which found the harbour to be considered in ‘fair condition'.
Additionally in 1996 Aquafor Beech completes a study of the potential effects of plough dredging
at Port Burwell (Aquafor Beech Limited, 1996), and determines that the methodology, as well as
dredging and in-water disposal in general, is acceptable at the Port Burwell Harbour.
Numerous techniques have been developed to dredge sediments from the
bottom of a creek or a lake. The amount of resuspension associated with each
method is variable and certain techniques tend to minimize the amount of
resuspension while others are more disruptive. Prop washing is one of the most
disruptive techniques currently used as the method is intended to hydraulically
push the material away from the boat propeller (prop.)
The method known as "Plow-dredging" is an experimental method of using a
large plow attached to the stern of a tugboat. Due to the close proximity of the
plough to the prop, a significant amount of material is re-suspended with this
method. However, it was expected that less material would be re-suspended
than solely using prop washing. In addition, the plough methodology provides
better control of the accuracy of the depth of dredging. A combination of this
method and prop washing was conducted on June 4-6, 1996 by Dan Minor &
Sons. This experiment was met with initial objections from the Ministry of
Environment and Energy who concurred only for this experiment. In a letter
dated May 31, 1996, they cautioned that any future dredging using this
technique will be evaluated at that time based on the monitoring results from this
experiment. The Ministry of Natural Resources was cautious about the
experimental technique and are not in agreement with prop washing in the inner
harbour.
They commented on behalf of the Lake Erie Management Unit and the Long
Point Area Team (Aylmer District) on aspects of the monitoring study which dealt
with the potential impacts on fish and the aquatic organisms and habitats on
which they depend. For this method to proceed, the Village of Port Burwell was
required to hire a consulting firm to monitor the process and its effectiveness.
Aquafor Beech prepared a monitoring study at a cost of $22,000.
The third and more traditional, but costly approach to dredging is referred to as
‘Dragline’ which is a method by which the silt is physically removed from the bed
of the harbour. Testing of the sediment samples and approvals for disposal must
be to the satisfaction of Long Point Region Conservation Authority, the Ministry
of Natural Resources and the Ministry of Environment.
Maintenance dredging requires approval of the Department of Fisheries and
Oceans which relies on approval from the Ministry of Natural Resources since
they manage the Federal Fisheries Act, Long Point Regional Conservation
Authority, Canadian Coast Guard and the Ministry of Environment. The Long
10 Staff Report D-03/99 - Municipality of Bayham, March 10, 1999
Point Regional Conservation Authority is concerned with the flood plain
management issues and The Ministry of Environment is concerned with respect
to the disposal of the dredging material on land 11.
Department of Fisheries and Oceans have concurred with information contained
in a document prepared by the former Village of Port Burwell Clerk-Administrator
that on average, depending on the type of vessel, commercial fishing boats
require a depth of 6 feet. The single commercial harbour user, Talisman energy
have several boats needed to access and service existing gas wells in Lake
Erie. Their boats require a depth of 9 feet. The majority of recreational boats
are power boats which require a depth of between 2 and 4 feet. Sail boats
typically require a depth of 6 feet. Fixed keel sail boats have been discouraged
by the Canadian Coast Guard from entering the harbour because of the
fluctuations in depth of the inner harbour
During 1997 Gartner Lee conducted a Phase I Property Transfer Assessment (Gartner Lee
Limited, 1997) for DFO to support transfer of harbour lands to the Village of Port Burwell. The
report concludes that there are no significant environmental issues with the Site, however
Gartner Lee Limited recommend soil sampling to determine if the coal handling operations may
have resulted in soil impacts.
On December 29, 1997 the Village of Port Burwell passed By-law No. 1997-021, being a by-law
to authorize an agreement in principle with DFO pertaining to the future ownership of the
harbour lands. On March 5, 1998, the Council of the Corporation of the Municipality of Bayham
passed the following resolution voiding the potential agreement as an action out of line due to
amalgamation:
THAT the Fisheries and Oceans Canada Agreement in Principle endorsed by
the former Corporation of the Village of Port Burwell dated December 29,
1997, be received
In March, 1998, Council members and staff met with representatives of the Department of
Fisheries and Oceans (DFO), Small Craft Harbours (SCH) to discuss the issues involving the
proposed transfer of SCH holdings in Port Burwell to the Municipality. SCH provided the
following information:
Dwayne Blanchard of the DFO has confirmed that there is absolutely no
federal funding available for dredging and that harbour fees are no longer
specified because of de-regulation. Market rates must now be applied and
they have no record of area rates. He noted that the Big Otter Marina can't
be charged except for berthing rights in the harbour. Further, he noted that
Port Burwell is a derelict fishing harbour and with the current water levels, the
deeper the channel is dug, the faster it fills in with silt. He suggested
following up with Ministry of Natural Resources about restrictions for
disposing of removed silt and sand. He added that a 300-400 berth outer
marina is the only long term solution, but would still require about $50,000
annually to dredge by the private sector. To dredge now with floating
equipment would cost approximately $100,000 to $200,000 to maintain a 6-
10 foot depth. For a 20 foot depth, the cost would be about $300,000.
11 Aquafor Beech - Port Burwell Harbour Dredge Monitoring Study, dated July, 1996
Therefore, the federal government couldn't afford the dredging costs for
commercial fishing vessels. Notwithstanding past practices and situations,
this year has been unique with the speed of drop in depth.
1980 DFO CORRESPONDENCE TO MINISTER OF AGRICULTURE
‘A marina development should be able to ensure its viability
without reliance upon continued maintenance dredging at public
expense, especially at the exorbitant cost such as proposed in
Port Burwell.’
Dwayne Blanchard stated that if the Municipality is no longer interested in
leasing or acquiring the harbour, they would attempt to market it, however,
they would be prepared to discuss the future ownership with other parties.
They are anxious to receive a written response from the Municipality about
intention of future ownership.
On March 10, 1999 the Council of the Corporation of the Municipality of Bayham considered the
following options:
Option No. 1 - Municipal Ownership Supported by Municipal Levy
This option would require the Municipality to accept ownership of the harbour
and structures currently under the control of the Federal government and
develop a long term plan for the operation and maintenance of the entire
harbour to be funded by the municipal tax base. The Municipality would
maintain control of the facility and set the service levels. However, the
question of whether all ratepayers should be required to fund the costly
dredging projects for a limited number of users must be considered. There is
also the question of liability, long term maintenance of structures and
administration which needs to be taken into consideration.
Option No. 2 - Municipal Ownership Supported by User Charges and/or
Donations
This option does not warrant serious consideration given the recent
discussions with the users of the harbour. There are a Iimited number who
have indicated their level of business couldn't support this option and would
force them to either relocate or close their business. When a scenario of
seeking donations was undertaken in 1996, a total of only $600 was received.
There is still the question of long term maintenance of the structures, liability
and administration.
Option No. 3 - Municipal Ownership - Abandonment of Harbour to Develop as
a Natural Habitat
This option would have the Municipality assume ownership of the harbour
lands from the Federal government and cease dredging activities or attract
boaters. The watercourse would be allowed to naturalize into a fish and wild
life habitat.
Option No. 4 - Municipal Ownership and Purchase of Dredging Equipment
This option would have the Municipality assume ownership of the harbour
lands from the Federal government and take on full responsibility for the costly
dredging and long term maintenance of structures and liability. With the
purchase of dredging equipment and hiring of expertise, the dredging could be
continuous, but determination of how the acquisition would be funded,
maintained and operated would need careful and detailed analysis before
serious consideration.
Option No. 5 - Municipal Ownership With Harbour Being Operated by a
Committee
This option would have the Municipality assume ownership of the harbour
lands from the Federal government and appoint a committee or board to take
on the responsibility of long term maintenance of structures and dredging
activities. The Municipality would still have to address liability issues, a
financing structure and would still be ultimately responsible for ensuring all
issues are identified and addressed appropriately.
Option No. 6 - Private Ownership
This option would see the Department of Fisheries and Oceans transfer
ownership to the private sector eliminating municipal involvement in all areas.
While there would be the hope that there is a market for the private sector to
assume ownership, they would also require the funds, resources and
capabilities of returning the harbour to a viable port of entry for at least small
commercial vessels and recreational boats.
Option No. 7 - Establishment of a North Shore Lake Erie Harbour Authority
On March 26, 1996, the Village of Port Burwell enacted a resolution to explore
the option of establishing such an authority to address specific concerns with
respect to maritime activities to various provincial and federal ministers toward
cost effective and efficient solutions. The resolution requested that other Lake
Erie North Shore communities consider the appointment of a political or
administrative representative to an inter-municipal committee to address
specific concerns.
The resolution was circulated to the following and listed are their responses:
a. Eastern Lake Erie Fishermen's Association
i. Response was positive, they expressed an interest in
learning more about the proposal.
b. Township of Norfolk
i. A resolution was passed in support.
c. City of Port Co/borne
i. A resolution was passed to endorse Port Burwell’s
resolution.
d. Village of Port Stanley
i. A Councillor was appointed to attend and represent the
Village at the initial meeting of an inter-municipal
committee.
Council ultimately passed the following resolution:
THAT Staff be directed to research the approval process for dredging the
harbour using the drag-line process;
AND THAT Staff obtain three quotes from excavators for Council's
consideration at the meeting scheduled for April 1, 1999, for work to be
performed this spring;
AND THAT Staff arrange a meeting with the businessmen having an interest
in the Port Burwell Harbour.
As previously stated the Federal Government leased the harbour to the Village and
subsequently after amalgamation, the Municipality, which is restricted by Provincial legislation
including the Municipal Act, Wharves and Harbours Act, Occupational Health and Safety Act,
Territorial Division Act, Environmental Protection Act, etc. Federal legislation includes the
Fisheries and Harbours Act, Great lakes Fisheries Convention Act, Harbour Commissions Act,
Department of Fisheries and Oceans Act, Public Harbours and Port Facilities Act and the Public
Works Act.
As a note there is a common law right extending back to 1806 that no entity, whether private or
public may fully obstruct waterways. This common law right has been abrogated in a number of
ways recognizing modern society including damming creeks on farmland, diverting water for
public hydro-electric utilities, etc. As a result, the federal government, as the Crown, has sought
to codify navigable water rights through statute.
The Municipality was also a silent party in a three party lease agreement for the Big Otter
Marina. As per a Memorandum from LPRCA to Big Otter Marina, dated May 13, 1999, the
Municipality of Bayham was released from the Big Otter Marina land lease agreement:
IT IS HEREBY ACKNOWLEDGED AND AGREED that the annual rental rate
for the lease of the Port Burwell Conservation Area (Big Otter Marina &
Campgrounds) property will be $3,750.00 for the period January 1, 1999 -
December 31, 2003 inclusive, payable in two semi-annual installments of
$1,875.00, due on July 15 and December 15, AND FURTHER that the
Municipality of Bayham (formerly Village of Port Burwell) is hereby released
from the lease agreements.
In 2000 Dillon Consulting prepares the ‘Port Burwell Assessment and Management Strategy’ for
the Municipality of Bayham (Dillon Consulting Limited, 2000), a planning document that
recommends conditional transfer of SCH lands to the municipality assuming a partnership with
SCH, and a commercial marina built outside of Big Otter Creek to avoid ongoing dredging
expenses, in partnership with the Province of Ontario.
In 2001 Environment Canada completes an assessment of Lake Erie tributaries, including
sediment analyses from Port Burwell. Further in 2001 MacViro prepares an enhanced Phase I
ESA. One surface soil sample finds metals concentrations below applicable Ontario Ministry of
Environment (MOE) criteria. Concentrations of polycyclic aromatic hydrocarbons (PAHs) in
excess of Canadian Council of Ministers of the Environment (CCME) interim sediment quality
guidelines, as well as concentrations of metals, nutrients and pesticides in excess of MOE
guidelines, are identified from six sediment samples collected. The study recommends further
delineation of sediment impacts. A review of the Phase I ESA is completed by Murray
Brooksbank at Environment Canada (Environment Canada, 2001) – Murray Brooksbank notes
that sediment quality is relatively good at Port Burwell and comparable to background conditions
within Lake Erie.
On February 6, 2003 Council is presented with an offer from SCH to transfer ownership of all of
their current holdings and facilities in the Port Burwell Harbour area, in return for a one-time
capital contribution of $1,000,000. The offer is conditional on the Municipality maintaining the
harbour at generally its current state for a minimum of five years.
On February 21st, 2003 the Council of the Corporation of the Municipality of Bayham
passed the following resolution:
THAT Council consider acceptance of the offer received from Mr. Dwayne
Blanchard on behalf of Small Craft Harbours, conditional on the following:
i. Establishment of an appropriate Reserve Fund for capital contribution,
with requirements that interest revenue only be utilized for current
maintenance/operations, and capital amount only for Harbourfront
development supporting an outer harbour marina development;
ii. Clarification, to the satisfaction of Council, of the level of maintenance
required for the five-year requirement of DFO;
iii. Confirmation of insurance ramifications;
iv. Investigation of inclusion of hold harmless provisions in any transfer from
Environmental Liability.
On March 24, 2003 the Municipality received a legal review of a proposed transfer
agreement which provided recommended language changes and the following
comment pertaining to environmental liability:
This writer would urge great caution in connection with the environmental
aspects of this transaction. The Phase 1 investigation prepared by Public
Works and Government Services Canada does indicate some areas of
concern. It is recommended that this environmental site assessment be
reviewed by an independent environmental testing company experienced in
this type of work for their views. In addition, some form of indemnification from
the transferor to the Municipality ought to be included in the Agreement
relating to environmental contaminants that may be discovered on the subject
property in the future.
On March 28, 2003 the Council of the Corporation of the Municipality of Bayham
passed the following resolution:
THAT Council advise Mr. Dwayne Blanchard of SCH that its position remains
as previously outlined February 21, 2003, namely that Council will consider
acceptance of the conditional offer received, conditional on the following:
i. Establishment of an appropriate Reserve Fund for capital contribution,
with requirements that interest revenue only be utilized for current
maintenance/operations, and capital amount only for Harbourfront
development supporting an outer harbour marina development
ii. Clarification, to the satisfaction of Council, of the level of maintenance
required for the five-year requirement of DFO.
iii. Confirmation of insurance ramifications.
iv. Investigation of inclusion of hold harmless provisions on any transfer
from Environmental Liability.
In 2008 SCH produced a letter report summarizing the impacts of the Species at Risk Act
(SARA) on Port Burwell operations (SCH, 2008). SCH identifies two fish species that may be at
risk, and outlines the habitat compensation requirements for future dredging work, a copy of
which is attached hereto as Appendix ‘F’.
In 2005 and again in 2010 the Municipality, in partnership with proponents conducted Ferry
Feasibility Studies. The Municipality went so far as to sign a Memorandum of Cooperation with
the Village of Grand River as authorized by By-law No. 2006-070. In both cases no tangible
actions resulted from the studies.
In 2010 a qualitative assessment of the sedimentation problem at Big Otter Creek is completed
by Shoreplan Engineering (ShorePlan Engineering Ltd., 2010). The study concludes that regular
dredging is likely the most cost-effective solution for maintaining the harbour.
On December 8, 2010 the Council of the Corporation of the Municipality of Bayham was
presented with a Port Burwell East Pier Report from CJDL Consulting Engineers estimated
required East Pier repairs ranging in cost from $49,000-$256,000.
On September 12, 2011, as a result of on-going discussions with SCH Council acted on the
determination of the need for a peer review and analysis of environmental risks for the Port
Burwell Harbour. In lieu of providing any firm transfer grant amounts, SCH determined it would
fund a peer review up to approximately $20,000. Stantec Consulting Ltd. was awarded the
project in the amount of $19,778 plus applicable taxes. The assessment concludes that data
gaps must be filled with a new Phase I Environmental Site Assessment (ESA) as well as a
Phase II ESA to support an eventual risk assessment for the Site.
THAT Stantec Consulting Ltd be retained to conduct a peer review for the Port
Burwell harbour area, as outlined in their proposal dated September 9, 2011,
subject to confirmation of funding from Small Craft Harbours.
On September 29, 2011, pertaining to East Pier repairs the Administrator advised Council as
follows:
The lowest reasonable construction cost of $318,420+HST is considerably over
the budgeted amount of $252,000 and does not include engineer costs. He
added that there is no advantage to delay the project to spring. Should the
project proceed, it was recommended that the difference be financed over a 2 to
3 year term rather than use capital reserves for the shortfall. Delay in
commencement of the work may limit the ability to complete this fall.
On October 6, 2011 Council passed By-law No 2011-089 authorizing Agreement No. 0082 for
East Pier repairs to be completed in the amount of $320,072.50+HST
As a note, the actual costs of the 2011 East Pier works were not fully accounted for until 2016
when Council allocated funds in the amount of $81,673.44 for unfinanced East Pier repair work.
In 2012 the Municipality of Bayham prepares the Official Plan (Municipality of Bayham, 2012).
This includes a Specific Policy Area (No.2), Mapping of Hazard Lands and Zoning information is
attached hereto as Appendix ‘G’.
3.3.2 Specific Policy Area No. 2 - Port Burwell Harbour
In addition to the policies of Section 6.1, the lands within the "Hazard Lands"
designation in Port Burwell which are generally situated south of Robinson
Street, and east of the Big Otter Creek and extending into Lake Erie, are
designated as "Specific Policy Area" on Schedule "D" to this plan and may be
used to develop a marina and ancillary facilities. These lands will remain in a
holding zone until such time as the conditions regarding development as
outlined in Section 6.1 of this Plan can be accommodated to the satisfaction
of the Municipality, in consultation with the Province and the Conservation
Authority.
In 2013 Terrapex conducted a Phase I/II ESA on behalf of DFO (Terrapex Environmental Ltd.,
2013). The report defines three areas of potential environmental concern (APECs)) located
both on and off-site. The Subject Lands are all associated with Terrapex's APEC 1. Three
monitoring wells are installed and three sediment sampling locations are placed within the
harbour lands, in addition to three additional background sediment sampling locations outside of
the harbour lands. Analytical results for soil indicated the presence of petroleum hydrocarbons
(PHC) petroleum hydrocarbons fraction 2 (F2) in one sample and polycyclic aromatic
hydrocarbons (PAHs) in three samples that exceed the applicable Federal and/or Provincial
guidelines. Groundwater in three locations exceeded the applicable guidelines for arsenic and
iron. In sediment, PHC F3 and F4, PAHs and pesticides exceeded the applicable guidelines in
up to five locations, including background sampling locations. An NCSCS score of 56.8 for the
land lot portions of the Site (CS0001) categorizes the Site as ‘Class 2: Medium Priority for
Action'. For the water lot portions (CS0002), the Federal Contaminated Sites Action Plan
(FCSAP) aquatic sites classification system (ASCS) is applied and a score of 79.4 is assigned,
corresponding to 'Class 1: High Priority for Action'.
The study recommends additional soil sampling, including vertical delineation, as well as a
round of groundwater sampling from all monitoring wells, in support of a Preliminary
Quantitative Risk Assessment (PQRA) and Screening Level Ecological Risk Assessment
(SLERA) for the land lot portions. For the water lot portions, supplemental surficial sediment
sampling, toxicology assessment and benthic survey are recommended to support a risk
assessment.
In 2014 IBI Group prepares a waterfront master plan study for Port Burwell (IBI Group, 2014).
The report focuses on the valued economic and tourism aspects of the area although may not
be in line with the economic realities of the Municipality of Bayham or Port Burwell.
In 2014-2015 SNC-Lavalin completes a soil and groundwater assessment of the Canadian
Coast Guard (CCG) automation building (previously referred to as the PWGSC automation
building by others) located on the west shore of Big Otter Creek (SNC Lavalin, 2015). PAHs,
arsenic or selenium are observed in soil in excess of Federal and/or Provincial criteria in 4 of 7
sampling locations, while PAHs are observed in groundwater in excess of Federal and/or
Provincial criteria in 3 of 3 monitoring wells.
In 2015 SCH provided the Municipality with the following studies and corresponding
summarized findings:
i. Final Remedial Options Analysis & Remedial-Risk Management Action Plan - Sediments
ii. Final Remedial Options Analysis & Remedial-Risk Management Action Plan - Soil &
Groundwater
iii. Site-Specific Human Health & Ecological Risk Assessment of Sediment at Port Burwell
iv. Preliminary Quantitative Human Health Risk Assessment & Screening Level Ecological
Risk Assessment of Soil & Groundwater at Port Burwell
FINAL REMEDIAL OPTIONS ANALYSIS & REMEDIAL/RISK
MANAGEMENT ACTION PLAN - SEDIMENTS
ADMINISTRATIVE MONITORING
The risk management plan for the Site while under Federal ownership would
consist of administrative monitoring of land use changes by internal DFO staff
to ensure that the risk assessment exposure and receptor assumptions are
maintained. The identified contaminants that exceed guideline values at the
site are considered unlikely to trigger remediation or additional risk
management measures in the future, given the Site's restricted land use
potential.
A change in land use triggered by a change in jurisdiction (i.e., federal to
provincial transfer) has an uncertain outcome with respect to risk assessment
results, and new or additional assessment, and remediation and/or risk
management work may need to be completed under a new land use
scenario. If the property is divested to the Municipality of Bayham, the land
use is expected to remain the same, although the jurisdiction would change.
As a result of the jurisdictional change, the risk assessment may need to be
re-evaluated to screen in parameters that specifically exceed provincial
criteria, which have not been considered in the SSRA. If risk was identified as
a result of this re-evaluation, further investigation and/or development of
remediation/risk management options may be warranted. The administrative
and operational considerations involved in the transfer of an active port and
associated facilities from SCH to the Municipality of Bayham are considered
outside the scope of this Remedial Options Analysis and Remedial/Risk
Management Action Plan.
PORT MAINTENANCE
Port Burwell Small Craft Harbour is likely to continue providing dockage and
marina services to recreational and commercial fishing vessels regardless of
future ownership. Siltation of the harbour due to the accumulating sediment
load from Big Otter Creek will require regular dredging in order to maintain
small craft access. Past dredging works at the Site have used a direct in-
water sediment disposal approach, as historically approved by the MOECC
based on project-specific sediment analyses (Riggs Engineering Ltd., 2011).
The results of the core sampling conducted as part of the SSRA indicate that
concentrations of COPCs (i.e., PAHs and DDTs) vary with the depth of the
sediment but at their maximum are not significantly different from the surface
sediments. The results from the three cores do not indicate a consistent
pattern with one showing a significant increase of COPC concentrations with
depth; the other showing a decrease and the third showing no change. These
apparent contradictions are likely the product of the heterogeneity associated
with historical sediment deposition, making it difficult to predict the quality of
the sediment at any particular location or depth; however, since the COPC
concentrations at depth were not found to be greater than those assessed in
surface sediments, if buried material was disturbed and brought to the
surface during dredging activities, it is unlikely to represent a significant
concern.
Due to the limited number of cores collected and the observation that in one
location the COPC concentrations increased with depth, dredging activities
should be accompanied by monitoring of COPC concentrations in sediment in
order to provide the information necessary to properly manage any material
that contains significantly elevated concentrations (i.e., above the sediment
quality standards). It is recommended that future dredging works for the
purpose of maintaining port access should include the following elements to
support the administrative monitoring approach and ensure that it remains
protective of human health and the environment:
i. Dredging design, sediment sampling/analysis plans and MOECC in-
lake disposal approvals to be submitted to and reviewed by all site
stakeholders.
ii. Dredging works must maintain appropriate silt containment measures
(e.g. silt curtains).
iii. As-built dredging and disposal plans (including bathymetry of dredged
channel and disposal area relative to IGLD 85) to be provided to all site
stakeholders.
FINAL REMEDIAL OPTIONS ANALYSIS & REMEDIAL/RISK
MANAGEMENT ACTION PLAN - SOIL & GROUNDWATER
RISK MANAGEMENT PLAN
The risk management plan for the Site while under Federal ownership will
consist of administrative monitoring of land use changes by internal DFO staff
to ensure that the risk assessment exposure and receptor assumptions are
maintained. The impacts above AGRC at the Site are considered unlikely to
trigger remediation or additional risk management measures in the future
given the Site's restricted land use potential within a flood zone. The
administrative and operational considerations involved in the transfer of an
active port and associated facilities from SCH to the Municipality of Bayham
are considered outside the scope of this Remedial Options Analysis and
Remedial/Risk Management Action Plan.
PRELIMINARY QUANTITATIVE HUMAN HEALTH RISK ASSESSMENT &
SCREENING LEVEL ECOLOGICAL RISK ASSESSMENT OF SOIL &
GROUNDWATER AT PORT BURWELL
RISK CHARACTERIZATION
In surface soil, maximum concentrations of benzene, toluene, molybdenum
and select PAHs (i.e., 1-methylnaphthalene, 2-methylnaphthalene, total
methylnaphthalene, naphthalene and phenanthrene) exceeded ecological
guidelines protective of aquatic life.
Additionally, in groundwater, maximum concentrations of arsenic, iron,
manganese and select PAHs (i.e., anthracene, benzo(a)anthracene,
benzo(a)pyrene, benzo(g,h,i)perylene, chrysene, fluoranthene,
phenanthracene and pyrene) exceeded guidelines protective of aquatic life.
TERRESTRIAL ENVIRONMENT
None of the COPCs identified in surface soil were found at concentrations
that exceeded guidelines protective of terrestrial life. This includes plants, soil
invertebrates, birds and mammals. All of the exceedances noted during the
COPC screening were of guidelines protective of aquatic receptors (i.e.,
protective of the soil to groundwater to surface water exposure pathway).
More specifically, the maximum concentrations of benzene and toluene were
less than the CCME soil contact guidelines for the protection of plants and
invertebrates and were less than the MOECC component guidelines
protective of terrestrial receptors (i.e., plants, soil organisms, mammals and
birds). Similarly, maximum concentrations of molybdenum, naphthalene and
phenanthrene were less than the MOECC soil guidelines protective of
terrestrial receptors (i.e., plants, soil organisms, mammals and birds).
For 1-methylnaphthalene, 2-methylnaphthalene and total methylnaphthalene,
guidelines for the protection of terrestrial receptors were not available from
the CCME or MOECC. However, the maximum concentration of all low
molecular weight PAHs (3 aromatic rings) was 8.3 mg/kg which was less
than the ecological guideline of 29 mg/kg from the USEPA (2007) , which is
based on the lowest guideline for the protection of soil invertebrates and
avian and mammalian wildlife.
Therefore, it is not anticipated that benzene, toluene, molybdenum, 1 -
methylnaphthalene, 2- methylnaphthalene, total methylnaphthalene,
naphthalene or phenanthrene pose a significant risk to terrestrial receptors
(i.e., birds, mammals, soil invertebrates, terrestrial plants) at the Site. This
includes species of conservation concern.
AQUATIC ENVIRONMENT
Concentrations in soil of benzene, toluene, molybdenum and select PAHs
(i.e., benzo(g,h,i)perylene, 1 -methylnaphthalene, 2-methylnaphthalene, total
methylnaphthalene, naphthalene and phenanthrene) exceeded guidelines
protective of aquatic life. However, given the long-term nature of Site
activities, it is reasonable to assume that the soil and groundwater has
reached a steady-state in which groundwater concentrations are
representative of leaching from soil. As such, the assessment of potential
risks to the aquatic environment at the Site focused on COPC concentrations
in groundwater.
Therefore, although concentrations of benzene, toluene and naphthalene in
soil exceeded the CCME groundwater check values for protection of aquatic
life, concentrations of these COPCs in groundwater were less than
guidelines, indicating that these COPCs do not pose a risk to aquatic
receptors. This also includes species of conservation concern at the Site.
Similarly, although soil concentrations of molybdenum,
1-methylnaphthalene, 2-methylnaphthalene and total methylnaphthalene
exceeded MOECC guidelines protective of aquatic life, concentrations of
these COPCs in groundwater were less than guidelines. Therefore, it is not
anticipated that these COPCs pose a significant risk to aquatic receptors,
including species of conservation concern, at the Site.
In groundwater, maximum concentrations of arsenic, iron, manganese,
anthracene, benzo (a) anthracene, benzo(a)pyrene, benzo(g,h,i)perylene,
chrysene, fluoranthene, phenanthracene and pyrene exceeded guidelines
protective of aquatic receptors. However, for PAHs, all exceedances of
CCME and MOECC groundwater guidelines were sampled in the vicinity of
the vacant automation building, which is located greater than l00 m from the
water’s edge. Given the distance from the aquatic environment and the small
number of exceedances (i.e., 4 out of 13 samples), it is considered unlikely
that PAHs in groundwater pose a significant risk to aquatic receptors,
including species of conservation concern, at the Site.
For arsenic, the maximum concentration exceeded the CCME guideline, but
all arsenic concentrations were below naturally occurring background
concentrations in Ontario (i.e., 13 µg/L; Table l Full Depth Background Site
Condition Standards). Therefore, arsenic is considered unlikely to pose a
significant risk to aquatic receptors, including species of conservation
concern, at the Site.
Although an essential element required by all living organisms, high iron
concentrations in well- aerated aquatic environments can result in the
formation of a precipitate that can smother benthic organisms (e.g., benthic
plants, benthic invertebrates, fish eggs). All samples exceeded the guideline;
however, observations made during field sampling of sediment and benthic
invertebrates in support of the assessment of the aquatic environment
(conducted by Stantec under separate cover), did not find any evidence of
iron precipitate. Therefore, it is not anticipated that iron poses a significant
risk to aquatic receptors, including species of conservation concern, at the
Site.
For manganese, only one out of nine samples exceeded the freshwater
chronic guideline for the protection of aquatic life from the BC MOE. Given
that manganese is an essential nutrient required by all living organisms and
is only slightly-to-moderately toxic to aquatic organisms (BC MOE, 2015), it
is not anticipated that manganese poses a risk to aquatic receptors, including
species of conservation concern, at the Site. In summary, it is not anticipated
that COPCs identified in soil or groundwater pose a significant risk to aquatic
or terrestrial receptors, including species of conservation concern, at the Site.
SUMMARY
The purpose of the human health preliminary quantitative risk assessment
(PQRA) and screening level ecological risk assessment (SLERA) was to
identify the presence or absence of impacts to soil and groundwater at the
Port Burwell Small Craft Harbour (the "Site") in Port Burwell, Ontario, to
determine whether or not concentrations of contaminants of potential concern
(COPCs) pose unacceptable risk to human or ecological receptors. The
PQRA /SLERA was completed using soil and groundwater data collected by
Terrapex in 201 2, SNC in 2014, and Stantec in 2015.
For the human health preliminary quantitative risk assessment (PQRA),
benzene, toluene, ethylbenzene, and total xylenes exceeded risk based
guidelines for commercial land use, for direct contact with soil and were
carried forward into the PQRA. Groundwater is non-potable and not used as
a source of drinking water, therefore it was not carried forward for further risk
assessment. The results of the PQRA suggest that there are no risks to any
of the four human receptors (Toddler Site Visitor , Adult Site Visitor,
Landscape Worker and Construction Worker) due to direct exposure
pathways (i.e., soil ingestion, soil dermal contact, inhalation of suspended soil
particulate); exposure to all identified non-carcinogenic COPCs from soil
resulted in HQs less than 0.2. Additionally, for the Adult Site Visitor and
Landscape Worker receptors, average daily ingestion, dermal contact and
inhalation exposure to benzene in Site soils resulted in a cancer risk that was
less than 1 in 10 million. These results indicate that, as per Health Canada
and MOECC guidance, the cancer risk associated with exposure to benzene
at the Site can be considered to be "essentially negligible".
For the SLER A, benzene, toluene, molybdenum, 1 - methylnaphthalene,
2- methylnaphthalene , total methylnaphthalene , naphthalene and
phenanthrene in soil, and arsenic, iron, manganese, anthracene ,
benz(a)anthracene, benzo(a)pyrene , benzo(ghi)perylene , chrysene ,
fluoranthene , phenanthrene, and pyrene in groundwater, were carried
through for risk assessment. However, the results suggest that there are
no significant risks to aquatic or terrestrial receptors at the Site, including
species of conservation concern.
The results of the site-specific risk assessment (SSR A) of the aquatic
environment (Stantec, 2015) determined that there were no human health
risks to the selected human receptors due to applicable exposure pathways
(i.e., inadvertent ingestion and dermal contact with Site surface water, and
consumption of fish caught at the Site) for all non-carcinogenic and
carcinogenic COPCs. Similarly, the results of the ecological risk assessment
suggested that, based on a weight- of-evidence approach, which used
surface water chemistry, sediment chemistry, fish tissue residues and benthic
community analysis, the COPCs identified within the surface water and
sediment did not appear to pose an unacceptable risk to the viability of the
aquatic community within Big Otter Creek and Lake Erie.
Overall, these results suggest that there are no risks to any of the four human
receptors due to direct exposure pathways (i.e., soil ingestion, soil dermal
contact, inhalation of suspended soil particulate), and no risks to ecological
receptors due to COPCs identified in soil and groundwater at the Site.
However, should potable drinking water wells be proposed in the future, the
groundwater should be resampled and reassessed for potential human health
risk, prior to consumption by any individuals.
Should the land use of the Site change, or should any camping facilities or
buildings be constructed on the Site, further environmental assessment may
be required to confirm the absence of risks (i.e., to confirm acceptable soil
and/or groundwater quality).
SITE-SPECIFIC HUMAN HEALTH & ECOLOGICAL RISK ASSESSMENT
OF SEDIMENT AT PORT BURWELL
RISK CHARACTERIZATION UNCERTAINTY EVALUATION
The risk characterization step in the risk assessment integrates the
information from the Problem Formulation, the Exposure Assessment and the
Toxicity assessment. As a result, it is subject to all of the uncertainties
already discussed. However, the use of multiple lines of evidence to
investigate a causal relationship between the sediment quality and indices of
environmental quality rely on a number of assumptions which also contribute
to the uncertainty. These assumptions include the following:
i. The TRVs act as an accurate benchmark for the effects noted with the
benthic indices.
ii. The reference stations provide a suitable benchmark for evaluating the
benthic characteristics quantified within the Site area.
iii. The physical and chemical characteristics of the sediment were
complete in representing the contributing factors to the state of the
benthic community.
iv. The COPCs do not interact, other than within their own chemical
classes (i.e., the toxic potential of manganese does not contribute to
that of the PAHs or DDT (and metabolites)).
Additional samples would reduce the uncertainty with most of these
assumptions, but the study area is relatively large and diverse with each
sediment sampling station having its own dynamic. Effort was made to
accommodate this during the field program and subsequent analysis but a
number of factors including sediment type and time of the year influenced
how representative the data was. In many respects, the sampling program
provided only a "snapshot". However, the potential toxicity of sediments
predicted to be of concern were identified based on the presence of chemical
parameters that exceeded either the ISQGs or the PELs. As previously
discussed, the uncertainty and inherent conservatism in both of these
environmental quality values results in the possibility that toxicity will not be
observed even when chemical concentrations are found above their
respective benchmarks. The fact that there was no clear relationship between
the predicted toxicity and any observed adverse effects to the benthic
community structure in samples collected within the Port Burwell study area,
suggests that the chemical quality of the sediment is of minor importance and
the results reflect other causal factors (e.g., physical/nutrient conditions of the
sediment).
CONCLUSIONS AND RECOMMENDATIONS
The results of the ERA indicate that there are no unacceptable risks to semi-
aquatic receptors from surface sediment and surface water at the Site. These
results are also considered protective of terrestrial receptor exposure through
the ingestion of surface water. Given that the results of the assessment of the
terrestrial environment (provided by Stantec under separate cover)
determined that there were no risks to terrestrial receptors from soil or
groundwater at the Site, it is not anticipated that the Site poses unacceptable
risks to terrestrial or semi-aquatic birds or mammals from soil, groundwater,
sediment or surface water.
The viability of the aquatic health community was assessed using a weight-of-
evidence approach. Taking into consideration the results of the surface water
chemistry, sediment chemistry and benthic community analysis, two of the
three lines of evidence indicate that there are no significant effects on the
aquatic life community. Based on a comparison of the sediment physical
characteristics with the COPC toxic potential and benthic community indices,
the strongest influence on potential adverse effects appears to be substrate
composition, mainly the proportion of clay and silt, and the concentration of
TOC. Consequently, the COPCs identified at the Site are not expected to
pose unacceptable adverse effects to the viability of the aquatic community
within Big Otter Creek and Lake Erie within the study area.
SUMMARY
The purpose of the site-specific human health and ecological risk assessment
(SSRA) was to identify the presence or absence of impacts to sediment and
surface water at the Port Burwell Small Craft Harbour (the "Site") in Port
Burwell, Ontario, to determine whether or not concentrations of contaminants
of potential concern (COPCs) pose unacceptable risk to human or
ecological receptors. The SSR A was completed using sediment, surface
water, benthic invertebrate, and fish data collected by Terrapex in 2012, and
Stantec in 2015.
For the human health risk assessment (HHRA), thallium, zirconium, and
benzo (a) pyrene exceeded the guidelines for inadvertent ingestion and
dermal contact with surface water, and cobalt, iron, and uranium exceeded
selected guidelines in fish tissue. In addition, acenaphthylene, and pyrene in
sediment exceeded the selected sediment guideline for potential
bioaccumulation in fish tissue. These COPCs were carried forward into the
HHRA. The results of the HHRA suggest that there are no risks to the
selected human receptors (Toddler Site Visitor, and Adult Site Visitor) due to
inadvertent ingestion and dermal contact with Site surface water, and
consumption of fish caught at the Site; exposure to all identified non-
carcinogenic COPCs from soil resulted in HQs less than the target
benchmark of 0.2. For the Adult Site Visitor, chronic inadvertent ingestion of
surface water, chronic dermal contact with water, and ingestion of fish
from the Site resulted in an estimated cancer risk greater than 1-in-100,000,
the risk level considered to be "essentially negligible" by Health Canada. The
fish consumption pathway was the primary exposure pathway for this
estimated cancer risk. However, given the numerous conservative
assumptions necessary in the exposure and risk estimation process, Stantec
anticipates that actual on-Site risks posed by benzo(a)pyrene are negligible.
Overall, the results suggest that there are likely no risks to human receptors
due to exposure to sediment, surface water, or consumption of fish at the
Site.
For the ecological risk assessment (ERA), manganese, select PAHs and DDT
(and metabolites) in sediment, and zinc in surface water were carried through
for risk assessment. The results of the ERA indicate that there are no
unacceptable risks to semi-aquatic receptors from surface sediment and
surface water at the Site. This includes the potential for DDT and its
metabolites to biomagnify in the food chain, thus resulting in a higher level of
exposure for the top predators. Concentrations measured in fish tissue did
not represent a concern to piscivorous birds and mammals. The results of the
ERA are also considered protective of terrestrial receptor exposure through
the ingestion of surface water. Given that the results of the assessment of the
terrestrial environment (provided by Stantec under separate cover)
determined that there were no risks to terrestrial receptors from soil or
groundwater at the Site, it is not anticipated that the Site poses unacceptable
risks to terrestrial or semi-aquatic birds or mammals from soil, groundwater,
sediment or surface water.
The viability of the aquatic health community was assessed using a weight-of-
evidence approach. Taking into consideration the results of the surface water
chemistry, sediment chemistry and benthic community analysis, two of the
three lines of evidence indicate that there are no significant effects on the
aquatic life community. The bioaccumulative potential of the COPCs was also
assessed within fish but the results were more relevant to the assessment of
birds and mammals than to the fish themselves as tissue-based toxicity limits
were not available.
Based on a comparison of the sediment physical characteristics with the
COPC toxic potential and benthic community indices, the strongest influence
on potential adverse effects appears to be substrate composition, mainly the
proportion of clay and silt, and the concentration of TOC. Consequently, the
COPCs identified at the Site are not expected to pose unacceptable adverse
effects to the viability of the aquatic community within Big Otter Creek and
Lake Erie within the study area.
The results of the Preliminary Quantitative Human Health Risk Assessment
and Screening Level Ecological Risk Assessment (PQRA/SLERA) of the
terrestrial environment (Stantec, 2015) determined that there were no human
health risks to the selected human receptors due to direct exposure pathways
(i.e., soil ingestion, soil dermal contact, inhalation of suspended soil
particulate) for all non-carcinogenic and carcinogenic COPCs. Similarly, the
results of the SLERA suggested that there are no significant risks to aquatic
or terrestrial receptors at the Site, including species of conservation concern,
from soil or groundwater at the Site. Therefore, it is not anticipated that the
Site poses unacceptable risks to terrestrial or semi-aquatic birds or mammals
from soil, groundwater, sediment or surface water.
Overall, these results suggest that there are no human health risks to any of
the human receptors due to inadvertent ingestion and dermal contact with
Site surface water, and consumption of fish caught at the Site, and no risks to
ecological receptors due to COPCs identified in sediment and surface water
at the Site. Based on the results of the SSRA and the current land use, no
further work and no remedial actions are currently being proposed for the
Site. However, should the land use of the Site change, further environmental
assessment may be required to confirm the absence of risks (i.e., to confirm
acceptable sediment and/or surface water quality).
The below chart provides a description of previously identified APECs at the Site with respect to
the land parcels described in the 1998 land survey of the Subject Lands and surrounding
properties (Kim Husted Surveying Ltd., 1998).
DISCUSSION
FINANCIAL BACKGROUND
As has been noted numerous times, including within the 2016-2026 Capital Budget Report, the
Municipality utilizes a mix of reserves, grant funding and tax levy to fund operations and capital
projects. The Capital Budget does not rely on debt financing due to the financial realities of the
Municipality and the need to preserve debt capacity. The Treasurer has attempted to minimize
the capital impact on the levy by creating a dynamic reserve funding scheme. This scheme
suits the Municipal financial reality and provides the greatest opportunity to minimize the impact
of levy increases, however it is not considered a risk adverse scheme, and unplanned capital
requirements have the capability to cause complications and financial strain within the 2016-
2026 capital funding model.
In plain language the Municipality incorporated OMPF reductions, OPP cost increases, Ojibwa
debt payments and associated legal through two methods:
1) Internal staff operating efficiencies;
2) Significantly reducing the annual Capital Levy
The current funding strategy, which is the staff recommended funding strategy, requires
adherence to core infrastructure funding and a dedicated path to restore capital funding,
which over time, when funding has obtained semi-sustainable levels, would mitigate the
risk of the strategy as it is currently funded. The above is the same reason staff have
recommended Council consideration of asset portfolio reductions as at current funding
levels the Municipality cannot adequately fund all assets, which results in a growing
spectrum of liability.
The above strategy coupled with the fact that the Municipality of Bayham has not
historically held a normalized and stable capital levy increase, results in staff
recommendation for Council to avoid any ventures, where possible, which are not risk
averse as the Municipality has limited financial resources to allocate.
Capital Levy 2011-2016
2011 $762,465
2012 $973,302
2013 $801,000
2014 $825,000
2015 $597,851
2016 $289,141
In addition to the chart above and below, which demonstrates the annual underfunding of
the Capital Levy, staff also attach additional charts hereto as Appendix ‘H’, which
visualize the historic capital underfunding and sporadic nature in which asset categories
have been historically funded as per Financial Information Return (FIR) data.
Municipality of Bayham - Capital Levy
Capital Tax Levy 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 Average
2015 Levy $597,851 $615,787 $634,260 $653,288 $672,887 $693,073 $713,865 $735,281 $757,340 $780,060 $803,462 $705,930
2015 Levy -
Corrected $933,180 $961,175 $990,011 $1,019,711 $1,050,302 $1,081,811 $1,114,266 $1,147,694 $1,182,125 $1,217,588 $1,254,116 $1,101,880
Five Year Historical
Average $791,924 $815,682 $840,152 $865,357 $891,317 $918,057 $945,599 $973,967 $1,003,186 $1,033,281 $1,064,280 $935,088
2016-2025 Capital
Budget $473,507 $1,780,594 $1,327,581 $1,107,024 $1,049,054 $1,039,535 $817,936 $1,018,541 $940,484 $1,190,000 $1,074,426
Deficit -$335,329 -
$345,389 -$355,751 -$366,423 -$377,416 -$388,738 -$400,400 -$412,412 -$424,785 -$437,528 -$450,654 -$395,950
The Municipality is in deficit of funding in the amount of $395,950 annually on capital
programs over the 10 year capital levy for an aggregate total of $3.95 million as noted
above. The Municipality has several large life cycle asset replacements, betterments and
rehabilitations over the next ten years both in linear assets, equipment and infrastructure
which will be challenging to complete based on the current financial implications.
Deferring the capital programs and replacements in the years projected only increases
the funding deficit as the replacement or rehabilitation costs will inflate annually and
make the capital deficit increase. In addition to funding capital programs as required,
proper financial management requires the reserves to be replenished to be able to fund
needs/events outside of the capital budget scope. The 2016-2018 years of the capital
budget do not sustainably fund reserves for future years (i.e. unexpected asset failures)
based on current projections and current asset conditions.
The above is relevant in the context of harbour divestiture discussions and any asset acquisition
discussions as historical capital funding, underfunding and Ojibwa and related liability
requirements would dictate staff to strongly recommend Council not take on any additional
liabilities unless said asset or venture has tangible benefits which outweigh the risks in the
determination of Council.
DIVESTITURE
This report has been prepared, at the direction of Council, in an attempt to provide a holistic
assessment of available information pertaining to Small Craft Harbours (SCH) Divestiture
discussions to date. In assessing the historic actions, by the Municipality, pertaining to harbour
divestiture and associated properties, it is evident that the process has been repetitive. The fact
remains that the Council of the Corporation of the Municipality of Bayham has continually
explored the concept of harbor divestiture, from SCH to the Municipality, largely predicated on
the considerations of Council in 2003:
THAT Council advise Mr. Dwayne Blanchard of SCH that its position remains
as previously outlined February 21, 2003, namely that Council will consider
acceptance of the conditional offer received, conditional on the following:
v. Establishment of an appropriate Reserve Fund for capital contribution,
with requirements that interest revenue only be utilized for current
maintenance/operations, and capital amount only for Harbourfront
development supporting an outer harbour marina development
vi. Clarification, to the satisfaction of Council, of the level of maintenance
required for the five-year requirement of DFO.
vii. Confirmation of insurance ramifications.
viii. Investigation of inclusion of hold harmless provisions on any transfer
from Environmental Liability.
Described in further detail those conditions include:
1) Environmental Liability
a. The environmental studies conducted to date by SCH have been based on
Federal environmental standards where the Municipality would be held to Ontario
Provincial environmental standards.
i. ‘The administrative and operational considerations involved in the transfer
of an active port and associated facilities from SCH to the Municipality of
Bayham are considered outside the scope of this Remedial Options
Analysis and Remedial/Risk Management Action Plan’
This condition is about risk avoidance. Proceeding without specific language and protections
possesses too great of unknown financial and environmental liabilities and risks given the
financial realities of the Municipality. PSAB 3260 Liability of Contaminated Sites, which requires
environmental degradation of land to be reported and accounted for on financial statements,
reinforces this position.
2) Public Use Provisions
a. Clarification, to the satisfaction of Council, of the level of maintenance
required for the five-year requirement of SCH.
b. Detailed accounts of funds expended by SCH over the five years
proceeding potential transfer.
Given the limited capital resources of the Municipality and the potential financial and
insurance implications of harbour activities detailed understanding of the above
provisions is required. This fact is furthered given the natural sedimentation forces and
historical evidence of the same, in Bayham.
Scholarly research from the peer reviewed Journal of Marine Policy reinforces the
careful consideration of the above conditions:
Because many of these divested harbours have legacy contaminant issues,
divestiture transfers a variety of potentially complex environmental liabilities to
new custodians, who may lack specific risk assessment experience or
financial resources to implement costly remediation or monitoring
programmes. For many federally owned harbours undergoing divestiture, the
choice of dredge disposal options is often limited, because sediment
contaminants often exceed sediment quality guidelines (SQGs). For
example, in Nova Scotia recent changes in provincial environmental
regulations related to disposal of dredge material under Division IV-Section
10 (1) (c) of the Environment Act, now means that some traditional land-
based disposal methods are no longer acceptable. Dredge disposal at
licensed waste disposal containment cell facilities (on land) or conventional
landfill sites are viable, but expensive options. Because of these issues, many
third party owners are reluctant to assume ownership due to liability concerns
related to environmental contamination 12.
3) Transfer Payment
a. An amount which would fully maintain all infrastructure or improve all
12 Harbour Divestiture in Canada: Implications of Changing Governance – Journal of Marine Policy, Walker et al.
August 2015
infrastructure for a specified period of time, as determined by a qualified
consultant, so that no levy requirements are utilized on the harbour lands.
Divestiture is a complex discussion and possibility with various associated opportunities, risks
and expenses. Council is proceeding, as it has over the past years, with extreme caution and
only down a path with clear, objective net benefits to the Municipality that does not add
additional risks to the current municipal risk portfolio.
Report CAO 44/16 re Small Craft Harbours – Harbour Lands Divestiture has been prepared, at
the direction of Council, utilizing available information for public information purposes.
RECOMMENDATION
1.THAT Report CAO-44/16 re Small Craft Harbours – Harbour Lands Divestiture be
received for information.
Respectfully Submitted by:
Paul Shipway
CAO
l egend
TerreslriolSile Areo () Stantec E:SJ Aquatic S~e Area
D Properly Boundary
Noles
1. Cootdinote System: NAO 1983 UlMZone 17N
2. h'lage Source; Notional Air Photo library. 11956). Pott Burwel! Air Ptioto,
September 25, 1956. I :10,000. A 1555 1. Pho to 18. O ttawa. ON:
Deporlmenl of Energy. Mines and Re1ou1ces.
3. Properly Boundary: Kim Husted SUfveying Ud. (!998). Pion 11R·6760,
Projecl97-45621. Reference HF 1. February 17, 1998. Tillsonburg, ON .
Ci ent/Projecl
Deportment of Fisheries and Oceans Canada
Remedial Options Analysis and
Remedial/Risk Management Action Pion
Port Burwell Small Croft Harbour. Ontario
Fig1.1eNo .
A.4
Tille
Port Burwell in 1956
APPENDIX 'A'
l e g e nd
Appro.>lmote Terres trid Site Area ()stantec i;;::::sJ Appro:itirnote Aquatic Sil e Area
~ P1operly Boundary
No l es
\.Coordinate S~tem: NAO 1983 UTMZone 17N
2. :rnoge Source: National A~ Photo Library. [1973). Port Surwe~ Aii Photo.
Mot 19.1973. 1:30,000. A:r.3285 . Photo 196. Ottawa, ON: Deportmen! of
Ehe1gy, Mines and Resource1.
3. Property Boundary: Kim Husted SUfveying Ud. (1998). Pion l \R·6760.
Project 97-45621, Referenc e HF 1, February 17, 1998. Tilli.onburg, ON .
CGenl/Project
Deportment of Fisheries and Oceans Canada
Remedial Options Analysis and
Remedial/Risk Management Action Pion
Port Burwell Small Craft Harbour. Ontario
FigueNo.
A.5
Tille
Port Burwell in 1973
APPENDIX 'B'
APPENDIX 'C'
AP
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APPENDIX 'E'
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Official Plan of the Municipality of Bayham
Revised 2012
Page 3-13
3.3.1 Specific Policy Area No. 1 – Elliott Road
Notwithstanding the “Agriculture” policies of this Plan to the contrary, the lands comprising approximately 43
hectares in Part Lot 15, Concession 10 of the Municipality of Bayham and bounded by Green Line to the north,
Provincial Highway 3 to the south, Elliott Road to the east and a wooded area to the west, and occupied by ten
(10) existing non-farm residential dwellings may accommodate a total of twenty (20) non-farm dwellings in the
area designated as “Specific Policy Area” on Schedule “A1” to this plan.
3.3.2 Specific Policy Area No. 2 – Port Burwell Harbour
In addition to the policies of Section 6.1, the lands within the “Hazard Lands” designation in Port Burwell which
are generally situated south of Robinson Street, and east of the Big Otter Creek and extending into Lake Erie,
are designated as “Specific Policy Area” on Schedule “D” to this plan and may be used to develop a marina
and ancillary facilities. These lands will remain in a holding zone until such time as the conditions regarding
development as outlined in Section 6.1 of this Plan can be accommodated to the satisfaction of the
Municipality, in consultation with the Province and the Conservation Authority.
3.3.3 Specific Policy Area No. 3 – Chateau Wyndemere
The re-development of the former church retreat lands comprising 22.1 hectares of land located south of Nova
Scotia Line in Part Lot 6, 7, 8, Concession 1, will require an Official Plan and Zoning By-law amendment prior
to any development. The approval authority will identify the required studies, through pre-consultation, prior to
any amendment to this Plan, which shall include, at a minimum, the following.
a)Studies completed to the satisfaction of the Ministry of Environment and the
Municipality with respect to the proposed sewage and water services in accordance
with Sections 3.1.3.2 and 5.1 of the Official Plan;
b)Completion of an Environmental Impact Study (EIS) in accordance with Section
2.2.3.3 of the Official Plan;
c)Cultural and An archaeological assessments to be completed to the satisfaction
of the Ministry of Tourism and Culture as per Section 2.6.3 of the Official Plan;
d) An agricultural impact assessment, to be completed to the satisfaction of the
approval authority.
e)Adequate and appropriate access to a public road.
f) A development agreement entered into between the developer and the
Municipality, which shall address, but is not limited to, vehicular access to the
lands
APPENDIX 'G'
Official Plan of the Municipality of Bayham
Revised 2012
Page 6-1
SECTION 6 NATURAL HAZARD LANDS
6.1 HAZARD LANDS DESIGNATION
6.1.1 General
6.1.1.1 The “Hazard Lands” designation applies to areas which exhibit or potentially exhibit a hazardous
condition as a result of their susceptibility to flooding, erosion, dynamic beach hazards, subsidence,
slumping, inundation or the presence of unstable soils, unstable bedrock, or steep slopes.
6.1.1.2 In the Municipality of Bayham the boundaries of the “Hazard Lands” designation have been
generalized on Schedule “A2”, “B”, “C”, and “D” to follow the regulation limit determined by the Long
Point Region Conservation Authority due to the absence of detailed engineered flood line mapping
in the Municipality. These areas may be used for any of the uses permitted in the underlying land
use designation found on the map. In all cases the location of buildings and structures for purposes
other than flood or erosion control will be regulated through the provisions of the Zoning By-law after
Municipal Council has consulted the Conservation Authority where applicable.
6.1.1.3 The “Hazard Lands” designation within Port Burwell, adjacent to Big Otter Creek was determined
through the simulation of the 100-year hydraulic flood as established by the Conservation Authority.
The lands within the “Hazard Lands” designation represent the engineered Flood plain for the Big
Otter Creek. Bridges, culverts, hydro structures and boathouses without residential quarters, are
permitted.
6.1.2 Buildings and Fill
No buildings and structures shall be permitted in the “Hazard Lands” except where a permit or written
clearance is obtained from the Conservation Authority or where such buildings, structures or fill are intended
for flood or erosion control and are approved by the Municipal Council and/or the Conservation Authority.
6.1.3 Flood Control Work
Whenever any flood control or other works are undertaken which result in changes in any area designated as
“Hazard Lands”, such changes will be incorporated into the appropriate Land Use Plan, by an amendment to
this Plan.
6.1.4 Land Dedication Under the Planning Act
Where new development is proposed on a site, part of which is designated as “Hazard Lands” in the plan, then
such lands shall not necessarily be acceptable as part of the dedication for park purposes as required under
the Planning Act. All lands dedicated to the Municipality shall be conveyed in a physical condition satisfactory
Official Plan of the Municipality of Bayham
Revised 2012
Page 6-2
to the Municipality.
6.1.5 Setbacks and Lotlines
Building setbacks will be imposed from the margins of hazard lands in relation to the kind, extent and severity
of the existing and potential hazards after consultation with the Conservation Authority.
6.1.6 Consideration of Amendments
6.1.6.1 Where any land designated as “Hazard Lands” is under private ownership, the Plan does not intend
that this land will necessarily remain as hazard land indefinitely, nor shall it be construed as implying
that such land is free and open to the general public or that the land will be purchased by the
Municipality or any other public agency. Applications for the redesignation of “Hazard Lands” for
other purposes may be considered by the Municipal Council after consultation with the Conservation
Authority and various Ministries or agencies and after consideration of the following:
a) The existing physical hazards;
b) The potential impacts of these hazards;
c)The proposed methods by which these impacts may be overcome in a manner
consistent with accepted engineering techniques and resource management
practices; and,
d)The costs and benefits in monetary, social and biological value in terms of any
engineering works and/or resource management practices needed to overcome
these impacts.
6.1.6.2 There is no public obligation, however, either to redesignate or to purchase any area designated
“Hazard Lands” particularly if there is an existing or potential hazard that would be difficult or costly
to overcome, and furthermore, any studies or plans required by the Municipality or the Conservation
Authority must be prepared by the applicant/landowner at his own expense.
6.1.7 Valley Walls and Top of Bank
6.1.7.1 Valley walls and banks adjacent to the actual flood plain or valleylands system in the “Hazard
Lands” designation may be subject to erosion or instability due to soil and slope characteristics. In
many cases, these lands also possess unique physical features, which further warrant their
preservation.
6.1.7.2 Valley walls and the top of bank shall be considered to extend from the flood plain to a distance of
30 metres from the top of bank of all flood plain areas. Valley walls are the area of lands between
Official Plan of the Municipality of Bayham
Revised 2012
Page 6-3
the watercourse and the top of bank. The top of bank is defined as the highest point of the valley
walls as determined by a 3:1 (run:rise) elevation, which begins 15 metres back from the toe of bank
of the watercourse.
6.1.7.3 Lands within the valley walls and top of bank areas are intended primarily for the preservation of the
natural landscape. Such uses as agriculture, outdoor recreation, nursery gardening, forestry, public
or private parks, or other outdoor recreation functions, may be permitted.
6.1.7.4 The erection of buildings, grading, or any other construction may be undertaken in this area
provided that:
a) Engineering reports are prepared at the cost of the owner/applicant to ensure that
the proposed construction will not be endangered by possible erosion or land
slippage and that adequate tableland exists to ensure proper sewage servicing.
b) The development is compatible with the natural landscape and does not adversely
alter the valley features or result in extensive clearing of wooded areas.
c) Written permission is received from the Conservation Authority and the Ministry of
Natural Resources.
6.1.8 Lake Erie Shoreline
6.1.8.1 The Lake Erie shoreline area is a strip of land immediately adjacent to Lake Erie that is influenced
by flooding, erosion, and dynamic beach hazards and may present a hazard to any structures within
this area. For the purpose of the Official Plan the “Hazard Lands” will begin at the furthest landward
limit of these three shoreline hazards.
a) The flooding hazard limit will extend for a distance determined by the following
formula:
100 yr.
flood level
+ 15 metres (engineered flood allowance for wave
uprush and other water related hazards)
b) The erosion hazard limit will extend for a distance determined by the following
formula:
D = 3h + 100r (or) 30 metres (whichever is greater)
Where
D =
Setback (metres) measured from toe of bluff
h = Difference in elevation between top of bluff and toe of bluff which
Official Plan of the Municipality of Bayham
Revised 2012
Page 6-4
may or may not be below or above lake level elevation
Note: Lake level is elevation 173.85 metres ASL (GSC datum) (average
for last ten (10) years during November to March period)
100 = Constant representing 100 years of protection
r = Rate of erosion in metres per year at the point under consideration,
as determined by the appropriate Conservation Authority.
c) The dynamic beach hazard limit will extend for a distance determined by the
following formula:
flooding hazard limit as
determined by subsection 6.1.8.1
a)
+ dynamic beach allowance
of 30 metres
6.1.8.2 The policy of this Official Plan is to allow structures within this area only if the erosion at the building
site in question has been decreased to zero by a stabilization project. Such stabilization project
must be:
a) Designed and supervised by a registered Professional Engineer;
b) Approved by the appropriate Conservation Authority, Municipal Council and the
Ministry of Natural Resources.
6.1.8.3 In some cases, buildings and structures may be erected closer to the waterline than the distance
calculated through the application of the formula in subsection 6.1.8.1 a) of this Plan. Such
buildings and structures may be associated with water-related uses such as marinas, docks and
boathouses, and in all cases, the erection or expansion of all such buildings and structures shall be
subject to the approval of the appropriate Conservation Authority.
6.1.8.4 For areas that are exposed to the 1:100 year lake level and wave uprush as defined by the Ministry
of Natural Resources, new development, and additions to, or relocations of existing structures, shall
incorporate floodproofing measures and shall be subject to the approval of the Municipal Council,
Ministry of Natural Resources and the appropriate Conservation Authority.
6.1.9 Development Policies
6.1.9.1 The following policies will apply for any proposed development within the “Hazard Lands”
designation:
a) Development within the defined portion of a dynamic beach, or in areas which will
initiate or increase existing flooding hazards, erosion rates, or dynamic beach
Official Plan of the Municipality of Bayham
Revised 2012
Page 6-5
processes along areas of the Flood plain, valley walls and Lake Erie shoreline will
not be permitted.
b) On the Lake Erie shoreline, the approval of the Ministry of Natural Resources will
also be secured before Council gives favourable consideration to any shoreline-
related development.
c) Vehicular and pedestrian mobility to and from sites within the “Hazard Lands”
designation must be ensured during times of emergency (ie. flooding, erosion etc.).
d) No new development of buildings or other structures will be permitted on the toe of
slope if it is unstable and susceptible to erosion. Slope stabilization measures shall
be undertaken in accordance with the advice of the appropriate Conservation
Authority.
e) No development involving institutional uses, essential emergency services, or
involving the disposal, manufacture, treatment, or storage of hazardous substances
will be permitted.
6.1.10 Docks and Waterfront Structures
6.1.10.1 Docks, waterfront and marina structures on property abutting water shall:
a) Be subject to the approval of the appropriate Conservation Authority, and where title
to the bed of the waterway is vested with the Crown, the Ministry of Natural
Resources;
b) Be designed, constructed and maintained in a manner that contributes to the amenity
of the Municipality;
c) Be capable of withstanding damaging storms, ice and high water conditions, or
alternatively be designed to be removed during winter months. Seasonal structures
are to be removed prior to winter freeze-up;
d) Not contain sanitary facilities unless connected to municipal sewers;
e) Be located so as not to interfere with navigation or aids to navigation;
f) Be constructed and placed so as to minimize the impact on natural vegetation and
topography;
g) Not contain any residential accommodations.
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OFFICIAL PLAN OF THEMUNICIPALITY of BAYHAM
SCHEDULE 'D'
PORT BURWELL:LAND USE and CONSTRAINTS
1:10,000
0 250 500125Metres
C o n s t r a i n t s
C o n s t r a i n t s
Sewage Treatment Facilities
Hazard Lands
L a n d U s e
L a n d U s e
Residential
Commercial
Multi Unit ResidentialHarbour Residential / Commercial
Open Space
InstitutionalIndustrial
Specific Policy AreasConservation Lands
SPECIFIC POLICYAREA NO. 2
B a s e F e a t u r e s
B a s e F e a t u r e s
Local RoadsCounty Roads
Existing Petroleum Wells
3.3 Holding Zones
In any zone which is accompanied by the holding symbol “h”, the uses normally
permitted by that zone for lands, buildings or structures may only be allowed when the
holding symbol is removed by amendment to this By-law or any subsequent holding by-
law. Permitted uses, when the holding symbol (h) is applied, are limited to those that
existed on the date when the holding by-law was passed. The purpose of individual
holding zones is as follows:
a)h1 Purpose: To ensure public health and safety, an agreement with the
Municipality, or the satisfying of conditions of severance, which address impacts of
new development to the applicable proposed water supply system and/or sewage
treatment and disposal system; and which may include issues relating to water
capacity, water quantity, water quality, and financial costs will be required prior to
the removal of the “h1” zone symbol.
b)h2 Purpose: To ensure orderly development, a subdivision agreement with the
Municipality, which addresses financial and servicing impacts of new development to
the Municipality, will be required prior to the removal of the “h2” zone symbol.
c)h3 Purpose: To ensure the mitigation of impacts to natural heritage features and their
ecological functions, an Environmental Impact Study will be required prior to the
removal of the “h3” zone symbol.
d)h4 Purpose: To ensure parcels of land do not become landlocked, proof of access to a
public right-of-way by the proponent will be required prior to the removal of the “h4”
zone symbol.
3.4 Application of Regulations
No person shall within any zone use any land or erect, build, construct, reconstruct,
relocate, excavate for, alter, add to, enlarge, extend or use any building or structure,
except in conformity with this By-law for the zone in which such land, building, structure
or use is located.
3.5 Defined Areas
All zones may be subdivided into one or more defined areas within which greater or
lesser restrictions shall apply. These defined areas shall be designated by reference to the
symbol of the zone within which each such defined area is located together with a
number so as to differentiate different defined areas within a zone from each other and
from other areas within the zone.
3.6 Exceptions for Defined Areas
Within any zone there may apply exceptions with respect to a defined area and, in
addition to such exceptions, all provisions of this By-law including the general use
regulations and the special use regulations applicable to the zone within which the
defined area is located shall apply to the defined areas; provided that, unless a contrary
intention appears from the exceptions, the following shall apply:
a)If the exceptions establish regulations different from the general provisions of this
By-law, including the general use regulations and special use regulations applicable
to the zone within which the defined area is located, the exceptions shall supersede
and prevail over such corresponding regulations of this By-law.
Z611-2012
3-3
b) If the exceptions establish one (1) or more specifically permitted uses of the defined
area, such permitted use or uses shall be the only purpose or purposes for which land,
buildings or structures within the defined area may be used; and
c) If the exceptions specifically permit one (1) or more uses in addition to those
otherwise permitted in the zone within which the defined area is located, any and all
of the other exceptions applicable to the defined area shall also apply to the
additional permitted use or uses and not only to the uses not otherwise permitted in
the zone.
3.7 Multiple Zones
Where a lot is subdivided into more than one zone, the regulations applicable to these
zones shall apply to the respective areas so zoned, and the zone lines shall be deemed to
be lot lines for the purposes of this By-law.
3.8 Interpretation of Zone Boundaries
Where any uncertainty exists as to the location of the boundary of any of the said zones
as shown on the zoning maps, the following shall apply:
a) Unless otherwise shown, the boundary of the zones as shown on the zoning maps are
the centre lines of the road allowance or lot lines and the projection thereof
b) Where a zone boundary is indicated as approximately following lot lines, such lot
lines shall be deemed to be the said zone boundary;
c) Where a zone boundary is indicated as approximately parallel to the line of any road
and the distance from such road is not indicated, such zone boundary shall be
construed as being parallel to such road and the distance therefrom shall be
determined by the use of the scale shown on the zoning maps;
d) Unless otherwise indicated, a road, railway right-of-way, or watercourse included on
the zoning maps is included within the zone of the adjoining lands on either side
thereof; and where such road, right-of-way, or watercourse serves as a boundary
between two or more different zones, a line midway in such road, street, lane, right-
of-way, or watercourse and extending in the general direction of the long division
thereof is considered the boundary between zones unless specifically indicated
otherwise;
e) In the event a road, street, lane or railway right-of-way shown on the zoning maps is
closed, the land formerly in said road or right-of-way shall be included within the
zone of the adjoining land on either side of the said closed road or right-of-way, and
the zone boundary shall be the former centre line of the said closed road or right-of-
way;
f) Where any zone boundary is left uncertain after application of the preceding
provisions, then the boundary line shall be determined according to the scale on the
zoning maps in the office of the Municipality.
3.9 Conservation Authority Regulation Limit
3.9.1 Any zone which is accompanied by the hatch/shading symbol identified as “conservation
authority regulation limit”, the uses normally permitted by that zone for lands, buildings
or structures may only be allowed when written approval is obtained from the
Conservation Authority. Permitted uses, when the “conservation authority regulation
limit” symbol is applied, are limited to those that existed on the date when the holding
by-law was passed.
3.9.2 The conservation authority regulation limit does not delimit the extent of all the areas
regulated by the Regulation (Ontario Regulation 178/06). Mapping will be periodically
updated by the Conservation Authority as more detailed information becomes available.
The areas described in the text of the Regulation prevail over the delineated boundary or
where a line is absent.
4-21
By-law shall apply to prevent the continued use of the lot as reduced as if no such
acquisition had taken place, provided that:
a)No further change is made in the dimensions, area or any other characteristics of
the lot as reduced, subsequent to the date of such acquisition, that would increase
the extent of the said non-conformity; and
b)No building or structure or addition thereto is erected on the lot as reduced,
subsequent to the date of such acquisition, except in accordance with all the
provisions hereof for the zone in which such lot is located.
4.52.2 In the case of a road widening dedication, the land that has been or will be dedicated shall
be included in any calculation for the purpose of determining lot area, coverage, height,
parking, landscaped open space, floor area, floor area ratio, and the location of any
permitted building or structure relative to the required side or rear yards, provided any
building or structure is located wholly within the boundary of the land remaining after the
dedication.
4.53 Ancillary Sale of Automobiles
Sales of automobiles ancillary to a motor vehicle service station, public garage, or motor
vehicle body shop shall be limited to maximum of six (6) automobiles being stored, kept
or displayed for sale on the site at anytime.
4.54 Adult Entertainment Parlours
4.54.1 Notwithstanding any other provision of this By-law, an Adult Entertainment Parlour shall
be prohibited in any zone or on any site or location that is situated less than 500 metres
from an existing residential or institutional use.
4.54.2 An Adult Entertainment Parlour shall also be prohibited in any zone or on any site or
location that is situated less than 500 metres from any zone that permits residential or
institutional uses.
4.55 Minimum Distance Separation Formulae
4.55.1 The Minimum Distance Separation Formula I shall be applied to any proposed
development in all zones, excluding any hamlet or village zones.
4.55.2 The Minimum Distance Separation Formula II shall be applied to any new or expanding
livestock or poultry facility.
4.56 Conservation Authority Regulation Limit
Notwithstanding any other provisions of this By-law, where lands are located within the
defined area labelled as “conservation authority regulation limit” on any schedule to this
By-law, no development shall be permitted without written approval from the
conservation authority. Development shall mean the construction, reconstruction,
erection or placing of a building or structure of any kind; any change to a building or
structure that would have the effect of altering the use or potential use of the building or
structure; increasing the size of the building or structure or increasing the number of
dwelling units in the building or structure; site grading; or the temporary or permanent
placing, dumping or removal of any material, originating on the site or elsewhere.
11-1
SECTION 11 VILLAGE RESIDENTIAL (R2) ZONE REGULATIONS
11.1 Permitted Uses
No land shall be used and no buildings or structures shall be erected, used, or altered in
the Village Residential (R2) Zone except for the following purposes:
Double duplex dwelling;
Multi-unit residential use;
Triplex dwelling;
Townhouse and rowhouse dwelling;
Apartment building;
Boarding house or rooming house;
Senior citizen home;
Group home;
Home occupation;
Accessory buildings and structures.
11.2 Permitted Buildings and Structures
Buildings and structures for the permitted uses;
Accessory buildings and structures for the permitted uses.
11.3 Minimum Lot Area
Triplex, double duplex,
townhouse, or rowhouse
dwellings:
Port Burwell, Vienna: 340 m2 per dwelling unit
Straffordville: 400 m2 per dwelling unit
Apartment buildings or
multi-unit dwellings:
10 units or less:
325 m2 for each of the first four
(4) dwelling units and 93 m2 for
each additional dwelling unit
thereafter
More than 10 units: 340 m2 per dwelling unit
Boarding or rooming house, senior citizens home,
nursing home or group homes:
557 m2 for the first ten (10)
rooms capable of being
occupied and 46 m2 for each
additional room thereafter.
11.4 Minimum Lot Frontage
Triplex, double duplex, townhouse, or rowhouse dwellings: 25.0 metres
All other dwellings: 10.0 metres. per dwelling unit or 40.0 metres., whichever is less
11.5 Maximum Building Coverage
50 %
11.6 Minimum Floor Area
Triplex, double duplex dwelling units: 80.0 m2
Apartment building units: 50.0 m2
Boarding or rooming house, senior citizens/nursing home or group homes: 40.0 m2
11.7 Minimum Front Yard Depth
6.0 metres.
11.8 Minimum Side Yard Width
Dwelling with an attached garage or
carport:
1.2 metres plus 0.5 metres for each additional
or partial storey above the first storey
Dwelling without an attached garage
or carport:
1.2 metres plus 0.5 metres for each additional
or partial storey above the first storey for one
side and 3.0 metres on the other side
Dwelling situated on a corner lot: 4.5 metres on the side abutting a public street
and a minimum of 1.5 metres on the other side
11.9 Minimum Rear Yard Depth
9.0 metres. or one-half the height, whichever is greater.
11.10 Regulations for Accessory Buildings
Notwithstanding the provisions of Section 4.2, the following shall apply:
a)Notwithstanding the provisions of paragraph a), no accessory building shall be
located within 6.0 metres of a public street.
b)Maximum Height - 3.5 metres.
c)Maximum Floor Area - 18.5 square metres.
11.11 Exceptions - Village Residential (R2) Zone
11.11.1
11.11.1.1 Defined Area
R2-1 as shown on Schedule “H” to this By-law.
11.11.1.2 Permitted Uses
Dwelling, Four-Unit
Restaurant, drive-in or take-out, as an accessory use.
11.11.1.3 Permitted Buildings and Structures
Existing buildings and structures for the permitted uses.
11.11.1.4 Minimum Floor Area
55.0 square metres per dwelling unit.
Previous
Section
11.11 a)
removed by
Z556-2008
19-1
SECTION 19 TOURIST COMMERCIAL (C3) ZONE REGULATIONS
19.1 Permitted Uses
No land shall be used and no buildings or structures shall be erected, used, or altered in
the Tourist Commercial (C3) Zone except for the following purposes:
Bed and Breakfast Lodging or Tourist Home;
Bus depot;
Commercial fishing operations, excluding any commercial processing operations;
Hotel, motel;
Marina and accessory uses, including boat storage and repairs;
Restaurant;
Retail service shop;
Tavern;
Travel trailer camping park;
Accessory use including one dwelling unit as an accessory use;
19.2 Minimum Lot Area
Public sanitary sewage disposal service, but no public water supply: 900m²
Public water and sanitary sewage disposal services are available: 555m²
Tourist commercial uses providing lodging / accommodations: 555 m2 for the first ten
(10) rooms capable of being occupied and 46 m2 for each additional room thereafter
19.3 Minimum Lot Frontage
15.0m
19.4 Maximum Lot Coverage
50%
19.5 Maximum Building Height
12.0m
19.6 Minimum Floor Area
Commercial Use: 10m²
Accessory dwelling units: In accordance with Section 4.45
Accessory single detached dwelling: 65m²
19.7 Minimum Front Yard Depth
6.0 metres
19.8 Minimum Side Yard Width
4.5m
19.9 Minimum Rear Yard Depth
10.0m
19.10 Buffer Strip
Where a C3 Zone abuts a Residential, Institutional or Open Space Zone, a buffer strip
shall be provided along the abutting lot lines having a minimum width of 2.0 metres.
19.11 Regulations for Travel Trailer Park
Regulations related to the establishment and operation of a travel trailer park shall be as
set down by the Tourism Act, and regulations thereto as amended from time to time.
19.12 Dwelling Units
No commercial building wherein gasoline, petroleum products, paint or any other highly
flammable, toxic or explosive products are handled in quantity shall have accessory
dwelling units. Where such dwelling units exist and the use of the commercial building
changes to a use involving the aforementioned products, the said dwelling units shall
cease to be occupied as dwelling units.
19.13 Exceptions - Tourist Commercial (C3) Zone
R1
I
R1I-2
I
R1
OS2
R1
R1
R2C2
R1-7
M4
MH
I
R1(h2)R1(h2)
R2(h2)
C3
OS2
OS1
OS1 R1(h2)
C2C2
OS1
C3(h2)
OS2
C2
R1 C3
C3(h2)
R1(h2)
OS2-5(h2)
R1
R2(h2)
OS2-9
OS2
R1
R1
R1
I
SEE INSET MAP
ASHLEYAVE
CH
A
T
H
A
M
S
T
VI
C
T
O
R
I
A
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T
LIBBYE ST
NO
V
A
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A
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R O B I N S O N S T
SEE SCH EDULE A -MAP No.13
SEE SCHEDULE A -MAP No.14
MUNICIPALITY OF BAYHAMSCHEDULE IPORT BURWELL 0 200 400100
Metres
Legend
LPRCA Regulation Limit
R1-7
I
I
MH
I
R2
I C1
R2
II
C1
R2
OS2
R2 R2
C2
C2
R1
MH
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R1-10
R1
R1
R1
R1
EL
I
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A
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E
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ER
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T
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WATERLOO ST HANNAH ST
VI
C
T
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INSET MAP
20
0
9
A
n
n
u
a
l
Am
o
r
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z
a
t
i
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n
20
0
9
C
a
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B
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t
20
0
9
C
a
p
i
t
a
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e
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Pe
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a
g
e
(
%
)
o
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Fu
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/
A
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s
20
0
9
C
l
o
s
i
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g
Ne
t
B
o
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k
V
a
l
u
e
Percentage (%) of Net Book Value/Asset Class
Ge
n
e
r
a
l
G
o
v
e
r
n
m
e
n
t
$1
4
,
4
8
8
$4
0
,
6
5
0
$3
2
,
0
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%
$775,202 1.45%
Pr
o
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s
Fi
r
e
$6
5
,
2
8
4
$3
3
0
,
6
7
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$3
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,
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48
%
$1,219,492
Pr
o
t
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n
a
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l
$3
,
5
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$0
$0
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$21,149
Em
e
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$0
$0
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B
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$6
8
,
7
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6
$3
3
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,
6
7
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%
$1,240,641 2.33%
Tr
a
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s
p
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$6
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,
1
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2
$3
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7
,
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$4
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,
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6
9
7%
$26,958,379
Ro
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-
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n
p
a
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d
$3
6
,
7
4
8
$1
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,
6
0
0
$1
9
,
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52
%
$648,121
Ro
a
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s
-
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r
i
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a
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u
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s
$2
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8
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$0
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$125,721
Ro
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a
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&
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$1
9
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3
4
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$0
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$640,742
Wi
n
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,
P
a
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s
$1
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7
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$0
$0
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$11,730
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r
k
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g
$5
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$0
$0
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$509
St
r
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l
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g
$2
,
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4
$2
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%
$23,057
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h
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$1
1
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4
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0
0
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$2
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%
$955,347
SU
B
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$8
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6
,
5
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$7
9
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%
$29,363,606 55.04%
En
v
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$15,106,601
Wa
s
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&
d
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$7
2
,
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$0
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0%
$1,932,366
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b
a
n
s
t
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$0
$0
$0
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$0
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r
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$1,938,050
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t
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$2
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$2,033,235
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$3
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9
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,
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$21,010,252 39.38%
He
a
l
t
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s
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%
$3,352
Ce
m
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t
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s
$0
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,
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$19,932
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h
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r
$0
$0
$0
0%
$0
SU
B
T
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L
$2
5
7
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6
,
0
9
3
$1
6
,
0
9
3
62
6
2
%
$23,284 0.04%
Re
c
r
e
a
t
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o
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a
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t
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r
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l
s
e
r
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s
Pa
r
k
s
$1
4
,
0
2
9
$7
,
8
8
6
$7
,
8
8
6
56
%
$494,878
Ha
r
b
o
u
r
/
B
e
a
c
h
$0
$1
3
,
9
7
2
$1
3
,
9
7
2
NA
$0
Re
c
.
F
a
c
.
$6
,
8
6
7
$1
5
,
0
0
0
$1
5
,
0
0
0
21
8
%
$207,852
Li
b
r
a
r
i
e
s
$3
,
7
7
8
$0
$0
0%
$51,348
Mu
s
e
u
m
s
/
C
u
l
t
u
r
e
$7
,
3
4
7
$2
1
,
6
6
2
$2
1
,
6
6
2
29
5
%
$184,061
SU
B
T
O
T
A
L
$3
2
,
0
2
1
$5
8
,
5
2
0
$5
8
,
5
2
0
18
3
%
$938,139 1.76%
TO
T
A
L
(
E
x
c
l
u
d
i
n
g
W
a
t
e
r
/
W
a
s
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e
w
a
t
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r
)
$9
6
2
,
0
8
2
$1
,
2
4
1
,
5
3
8
$2
5
0
,
1
1
4
26
%
$53,351,124 100%
$1
,
3
4
4
,
0
4
6
$4
,
0
8
4
,
1
2
1
$2
5
0
,
1
1
4
$6
7
$53,351,124 $1
NO
T
E
S
Re
l
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d
H
e
a
v
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l
y
o
n
2
0
0
8
Un
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x
p
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n
d
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C
a
p
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t
a
l
($
6
0
0
,
0
0
0
+
)
,
t
h
u
s
b
a
s
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c
a
l
l
y
n
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ca
p
i
t
a
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l
e
v
y
i
n
2
0
0
9
a
n
d
t
h
a
t
wo
u
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d
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d
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i
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p
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a
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2
0
0
8
APPENDIX 'H'
20
1
0
A
n
n
u
a
l
Am
o
r
t
i
z
a
t
i
o
n
20
1
0
C
a
p
i
t
a
l
B
u
d
g
e
t
2
0
1
0
C
a
p
i
t
a
l
L
e
v
y
Pe
r
c
e
n
t
a
g
e
(
%
)
o
f
L
e
v
y
Fu
n
d
i
n
g
/
A
s
s
e
t
C
l
a
s
s
20
1
0
C
l
o
s
i
n
g
Ne
t
B
o
o
k
V
a
l
u
e
Percentage (%) of Net Book Value/Asset Class
Ge
n
e
r
a
l
G
o
v
e
r
n
m
e
n
t
$
1
3
,
0
9
3
$
2
5
,
5
0
0
$
2
5
,
5
0
0
1
9
4
.
7
6
%
$
7
6
2
,
1
0
9
1
.
4
0
%
Pr
o
t
e
c
t
i
o
n
s
e
r
v
i
c
e
s
Fi
r
e
$6
9
,
5
5
2
$8
6
9
,
0
0
0
$1
7
0
,
5
0
0
24
5
.
1
4
%
$1,314,135
Pr
o
t
e
c
t
i
v
e
i
n
s
p
e
c
t
i
o
n
a
n
d
c
o
n
t
r
o
l
$2
,
2
9
9
$6
,
0
0
0
$6
,
0
0
0
26
0
.
9
8
%
$31,850
Em
e
r
g
e
n
c
y
m
e
a
s
u
r
e
s
$0
$0
$0
0.
0
0
%
$0
SU
B
T
O
T
A
L
$7
1
,
8
5
1
$8
7
5
,
0
0
0
$1
7
6
,
5
0
0
24
5
.
6
5
%
$1,345,985 2.47%
Tr
a
n
s
p
o
r
t
a
t
i
o
n
s
e
r
v
i
c
e
s
Ro
a
d
s
-
P
a
v
e
d
$5
4
4
,
1
8
7
$8
1
1
,
2
2
0
$3
0
9
,
9
0
0
56
.
9
5
%
$26,590,776
Ro
a
d
s
-
U
n
p
a
v
e
d
$1
9
,
9
3
8
$9
2
,
0
0
0
$0
0.
0
0
%
$628,183
Ro
a
d
s
-
B
r
i
d
g
e
s
a
n
d
C
u
l
v
e
r
t
s
$3
,
8
3
7
$3
3
,
0
0
0
$0
0.
0
0
%
$198,884
Ro
a
d
w
a
y
s
-
T
r
a
f
f
i
c
O
p
e
r
a
t
i
o
n
s
&
R
o
a
d
s
i
d
e
$1
2
,
6
8
2
$0
$0
0.
0
0
%
$647,014
Wi
n
t
e
r
C
o
n
t
r
o
l
-
E
x
c
e
p
t
s
i
d
e
w
a
l
k
s
,
P
a
r
k
i
n
g
L
o
t
s
$1
,
0
1
3
$0
$0
0.
0
0
%
$10,717
Pa
r
k
i
n
g
$7
6
$0
$0
0.
0
0
%
$433
St
r
e
e
t
l
i
g
h
t
i
n
g
$1
,
6
7
8
$1
5
,
0
0
0
$5
,
0
0
0
29
7
.
9
7
%
$21,379
Ot
h
e
r
$2
6
,
1
8
9
$3
1
1
,
0
0
0
$0
0.
0
0
%
$984,911
SU
B
T
O
T
A
L
$6
0
9
,
6
0
0
$1
,
2
6
2
,
2
2
0
$3
1
4
,
9
0
0
51
.
6
6
%
$29,082,297 53.30%
En
v
i
r
o
n
m
e
n
t
a
l
s
e
r
v
i
c
e
s
Wa
s
t
e
w
a
t
e
r
c
o
l
l
e
c
t
i
o
n
/
c
o
n
v
e
y
a
n
c
e
$2
0
4
,
8
0
6
$5
0
8
,
8
4
3
$0
0.
0
0
%
$14,955,772
Wa
s
t
e
w
a
t
e
r
t
r
e
a
t
m
e
n
t
&
d
i
s
p
o
s
a
l
$7
7
,
9
3
8
$0
$0
0.
0
0
%
$2,435,120
Ur
b
a
n
s
t
o
r
m
s
e
w
e
r
s
y
s
t
e
m
$0
$0
$0
0.
0
0
%
$0
Ru
r
a
l
s
t
o
r
m
s
e
w
e
r
s
y
s
t
e
m
$0
$0
$0
0.
0
0
%
$0
Wa
t
e
r
t
r
e
a
t
m
e
n
t
$5
2
,
2
4
4
$0
$0
0.
0
0
%
$1,888,468
Wa
t
e
r
d
i
s
t
r
i
b
u
t
i
o
n
/
t
r
a
n
s
m
i
s
s
i
o
n
$4
1
,
9
9
5
$1
,
2
4
9
,
1
0
0
$0
0.
0
0
%
$2,972,000
SU
B
T
O
T
A
L
$3
7
6
,
9
8
3
$1
,
7
5
7
,
9
4
3
$0
0.
0
0
%
$22,251,360 40.78%
He
a
l
t
h
s
e
r
v
i
c
e
s
Pu
b
l
i
c
h
e
a
l
t
h
s
e
r
v
i
c
e
s
$1
9
3
$0
$0
0.
0
0
%
$3,159
Ce
m
e
t
e
r
i
e
s
$0
$1
0
,
0
0
0
$1
0
,
0
0
0
NA
$19,932
Ot
h
e
r
$0
$0
$0
0.
0
0
%
$0
SU
B
T
O
T
A
L
$1
9
3
$1
0
,
0
0
0
$1
0
,
0
0
0
51
8
1
.
3
5
%
$23,091 0.04%
Re
c
r
e
a
t
i
o
n
a
n
d
c
u
l
t
u
r
a
l
s
e
r
v
i
c
e
s
Pa
r
k
s
$1
6
,
0
6
3
$9
0
,
0
0
0
$2
0
,
0
0
0
12
4
.
5
1
%
$668,452
Ha
r
b
o
u
r
/
B
e
a
c
h
$0
$8
8
,
9
0
0
$8
8
,
9
0
0
NA
$0
Re
c
.
F
a
c
.
$8
,
4
3
6
$1
9
3
,
0
0
0
$7
8
,
0
0
0
92
4
.
6
1
%
$199,416
Li
b
r
a
r
i
e
s
$1
,
7
8
7
$2
5
,
0
0
0
$2
5
,
0
0
0
13
9
8
.
9
9
%
$49,561
Mu
s
e
u
m
s
/
C
u
l
t
u
r
e
$4
,
2
3
1
$2
2
,
6
6
5
$2
2
,
6
6
5
53
5
.
6
9
%
$179,830
SU
B
T
O
T
A
L
$3
0
,
5
1
7
$4
1
9
,
5
6
5
$2
3
4
,
5
6
5
76
8
.
6
4
%
$1,097,259 2.01%
TO
T
A
L
(
E
x
c
l
u
d
i
n
g
W
a
t
e
r
/
W
a
s
t
e
w
a
t
e
r
)
$7
2
5
,
2
5
4
$2
,
5
9
2
,
2
8
5
$7
6
1
,
4
6
5
10
4
.
9
9
%
$54,562,101 100.00%
$1
,
1
0
2
,
2
3
7
$4
,
3
5
0
,
2
2
8
$7
6
1
,
4
6
5
$6
4
$54,562,101 $1
NO
T
E
S
20
1
1
A
n
n
u
a
l
Am
o
r
t
i
z
a
t
i
o
n
20
1
1
C
a
p
i
t
a
l
B
u
d
g
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t
2
0
1
1
C
a
p
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t
a
l
L
e
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Pe
r
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(
%
)
o
f
Fu
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d
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/
A
s
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l
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s
20
1
1
C
l
o
s
i
n
g
Ne
t
B
o
o
k
V
a
l
u
e
Percentage (%) of Net Book Value/Asset Class
Ge
n
e
r
a
l
G
o
v
e
r
n
m
e
n
t
$
1
1
,
7
1
3
$
5
1
,
0
0
0
$
5
1
,
0
0
0
4
3
5
.
4
1
%
$
7
6
3
,
1
2
7
1
.
4
1
%
Pr
o
t
e
c
t
i
o
n
s
e
r
v
i
c
e
s
Fi
r
e
$7
1
,
3
0
8
$1
,
0
8
9
,
3
0
0
$1
6
4
,
5
0
0
23
0
.
6
9
%
$1,295,092
Pr
o
t
e
c
t
i
v
e
i
n
s
p
e
c
t
i
o
n
a
n
d
c
o
n
t
r
o
l
$1
,
5
8
5
$6
,
0
0
0
$6
,
0
0
0
37
8
.
5
5
%
$12,355
Em
e
r
g
e
n
c
y
m
e
a
s
u
r
e
s
$2
,
1
8
0
0.
0
0
%
$15,730
SU
B
T
O
T
A
L
$7
5
,
0
7
3
$1
,
0
9
5
,
3
0
0
$1
7
0
,
5
0
0
22
7
.
1
1
%
$1,323,177 2.44%
Tr
a
n
s
p
o
r
t
a
t
i
o
n
s
e
r
v
i
c
e
s
Ro
a
d
s
-
P
a
v
e
d
$6
8
2
,
4
0
2
$7
4
8
,
8
2
2
$2
4
5
,
0
0
0
35
.
9
0
%
$25,908,374
Ro
a
d
s
-
U
n
p
a
v
e
d
$1
2
,
8
4
1
$4
1
,
5
6
3
$0
0.
0
0
%
$615,342
Ro
a
d
s
-
B
r
i
d
g
e
s
a
n
d
C
u
l
v
e
r
t
s
$4
,
1
2
8
$0
$0
0.
0
0
%
$544,198
Ro
a
d
w
a
y
s
-
T
r
a
f
f
i
c
O
p
e
r
a
t
i
o
n
s
&
R
o
a
d
s
i
d
e
$0
$0
$0
0.
0
0
%
$647,014
Wi
n
t
e
r
C
o
n
t
r
o
l
-
E
x
c
e
p
t
s
i
d
e
w
a
l
k
s
,
P
a
r
k
i
n
g
L
o
t
s
$1
,
0
1
3
$0
$0
0.
0
0
%
$9,704
Pa
r
k
i
n
g
$0
$0
$0
0.
0
0
%
$433
St
r
e
e
t
l
i
g
h
t
i
n
g
$1
,
3
7
4
$1
0
,
0
0
0
$0
0.
0
0
%
$20,005
Ot
h
e
r
$0
$6
0
9
,
0
0
0
$0
NA
$1,045,561
SU
B
T
O
T
A
L
$7
0
1
,
7
5
8
$1
,
4
0
9
,
3
8
5
$2
4
5
,
0
0
0
34
.
9
1
%
$28,790,631 53.20%
En
v
i
r
o
n
m
e
n
t
a
l
s
e
r
v
i
c
e
s
Wa
s
t
e
w
a
t
e
r
c
o
l
l
e
c
t
i
o
n
/
c
o
n
v
e
y
a
n
c
e
$2
0
3
,
9
4
8
$3
0
4
,
7
4
3
$0
0.
0
0
%
$14,751,379
Wa
s
t
e
w
a
t
e
r
t
r
e
a
t
m
e
n
t
&
d
i
s
p
o
s
a
l
$8
0
,
5
4
6
$0
$0
0.
0
0
%
$2,354,574
Ur
b
a
n
s
t
o
r
m
s
e
w
e
r
s
y
s
t
e
m
$0
$0
$0
0.
0
0
%
$0
Ru
r
a
l
s
t
o
r
m
s
e
w
e
r
s
y
s
t
e
m
$0
$0
$0
0.
0
0
%
$0
Wa
t
e
r
t
r
e
a
t
m
e
n
t
$5
3
,
0
7
5
$4
5
0
,
0
0
0
$0
0.
0
0
%
$1,908,508
Wa
t
e
r
d
i
s
t
r
i
b
u
t
i
o
n
/
t
r
a
n
s
m
i
s
s
i
o
n
$6
0
,
7
1
9
$0
0.
0
0
%
$2,711,213
SU
B
T
O
T
A
L
$3
9
8
,
2
8
8
$7
5
4
,
7
4
3
$0
0.
0
0
%
$21,725,674 40.14%
He
a
l
t
h
s
e
r
v
i
c
e
s
Pu
b
l
i
c
h
e
a
l
t
h
s
e
r
v
i
c
e
s
$1
9
3
$0
$0
0.
0
0
%
$2,966
Ce
m
e
t
e
r
i
e
s
$0
$3
,
0
0
0
$3
,
0
0
0
NA
$19,932
Ot
h
e
r
$0
$0
0.
0
0
%
$0
SU
B
T
O
T
A
L
$1
9
3
$3
,
0
0
0
$3
,
0
0
0
15
5
4
.
4
0
%
$22,898 0.04%
Re
c
r
e
a
t
i
o
n
a
n
d
c
u
l
t
u
r
a
l
s
e
r
v
i
c
e
s
Pa
r
k
s
$2
3
,
1
7
4
$1
0
7
,
9
2
5
$6
5
,
9
2
5
28
4
.
4
8
%
$645,278
Ha
r
b
o
u
r
/
B
e
a
c
h
$5
,
8
6
7
$2
7
4
,
8
0
0
$1
3
1
,
9
0
0
22
4
8
.
1
7
%
$419,822
Re
c
.
F
a
c
.
$5
,
7
4
4
$1
7
4
,
0
0
0
$9
1
,
5
0
0
15
9
2
.
9
7
%
$205,000
Li
b
r
a
r
i
e
s
$1
,
7
8
7
$4
0
,
0
0
0
$0
0.
0
0
%
$47,774
Mu
s
e
u
m
s
/
C
u
l
t
u
r
e
$2
,
7
0
4
$5
5
,
5
0
0
$5
5
,
5
0
0
20
5
2
.
5
1
%
$177,126
SU
B
T
O
T
A
L
$3
9
,
2
7
6
$6
5
2
,
2
2
5
$3
4
4
,
8
2
5
87
7
.
9
5
%
$1,495,000 2.76%
TO
T
A
L
(
E
x
c
l
u
d
i
n
g
W
a
t
e
r
/
W
a
s
t
e
w
a
t
e
r
)
$8
2
8
,
0
1
3
$3
,
2
1
0
,
9
1
0
$8
1
4
,
3
2
5
98
.
3
5
%
$54,120,507 100.00%
$1
,
2
2
6
,
3
0
1
$3
,
9
6
5
,
6
5
3
$8
1
4
,
3
2
5
$3
1
$54,120,507 $1
NO
T
E
S
Re
l
i
e
d
H
e
a
v
i
l
y
o
n
2
0
1
0
Un
e
x
p
e
n
d
e
d
C
a
p
i
t
a
l
($
1
7
0
,
0
0
0
+
)
20
1
2
A
n
n
u
a
l
Am
o
r
t
i
z
a
t
i
o
n
20
1
2
C
a
p
i
t
a
l
B
u
d
g
e
t
2
0
1
2
C
a
p
i
t
a
l
L
e
v
y
Pe
r
c
e
n
t
a
g
e
(
%
)
o
f
Fu
n
d
i
n
g
/
A
s
s
e
t
C
l
a
s
s
20
1
2
C
l
o
s
i
n
g
Ne
t
B
o
o
k
V
a
l
u
e
Percentage (%) of Net Book Value/Asset Class
Ge
n
e
r
a
l
G
o
v
e
r
n
m
e
n
t
1
7
,
2
2
6
6
6
,
0
0
0
.
0
0
4
7
,
0
0
0
.
0
0
2
7
2
.
8
4
%
7
5
1
,
0
6
2
1
.
3
8
%
Pr
o
t
e
c
t
i
o
n
s
e
r
v
i
c
e
s
Fi
r
e
1
1
4
,
7
6
6
1
,
2
5
4
,
5
0
0
1
7
0
,
0
0
0
14
8
.
1
3
%
2,276,143
Pr
o
t
e
c
t
i
v
e
i
n
s
p
e
c
t
i
o
n
a
n
d
c
o
n
t
r
o
l
1
,
9
7
0
6
,
0
0
0
6
,
0
0
0
30
4
.
5
7
%
10,385
Em
e
r
g
e
n
c
y
m
e
a
s
u
r
e
s
1
,
7
9
6
0
0
0.
0
0
%
13,934
SU
B
T
O
T
A
L
1
1
8
,
5
3
2
1
,
2
6
0
,
5
0
0
1
7
6
,
0
0
0
1
4
8
.
4
8
%
2
,
3
0
0
,
4
6
2
4
.
2
2
%
Tr
a
n
s
p
o
r
t
a
t
i
o
n
s
e
r
v
i
c
e
s
Ro
a
d
s
-
P
a
v
e
d
6
8
9
,
4
9
5
4
0
6
,
0
0
0
0
0.
0
0
%
25,218,879
Ro
a
d
s
-
U
n
p
a
v
e
d
1
5
,
4
2
4
5
4
,
0
0
0
0
0.
0
0
%
599,918
Ro
a
d
s
-
B
r
i
d
g
e
s
a
n
d
C
u
l
v
e
r
t
s
1
9
,
5
5
8
0
0
0.
0
0
%
524,640
Ro
a
d
w
a
y
s
-
T
r
a
f
f
i
c
O
p
e
r
a
t
i
o
n
s
&
R
o
a
d
s
i
d
e
2
,
6
8
0
0
0
0.
0
0
%
644,334
Wi
n
t
e
r
C
o
n
t
r
o
l
-
E
x
c
e
p
t
s
i
d
e
w
a
l
k
s
,
P
a
r
k
i
n
g
L
o
t
s
1
,
7
3
6
0
0
0.
0
0
%
7,968
Pa
r
k
i
n
g
3
5
7
0
0
0.
0
0
%
76
St
r
e
e
t
l
i
g
h
t
i
n
g
2
,
3
6
3
1
0
,
0
0
0
1
0
,
0
0
0
42
3
.
1
9
%
17,642
Ot
h
e
r
9
3
,
8
1
8
5
7
4
,
0
0
0
2
7
0
,
0
0
0
28
7
.
7
9
%
1,198,661
SU
B
T
O
T
A
L
8
2
5
,
4
3
1
1
,
0
4
4
,
0
0
0
2
8
0
,
0
0
0
3
3
.
9
2
%
2
8
,
2
1
2
,
1
1
8
5
1
.
7
5
%
En
v
i
r
o
n
m
e
n
t
a
l
s
e
r
v
i
c
e
s
Wa
s
t
e
w
a
t
e
r
c
o
l
l
e
c
t
i
o
n
/
c
o
n
v
e
y
a
n
c
e
2
3
8
,
6
5
3
2
2
5
,
9
7
2
0
0.
0
0
%
14,512,726
Wa
s
t
e
w
a
t
e
r
t
r
e
a
t
m
e
n
t
&
d
i
s
p
o
s
a
l
9
6
,
8
9
1
0
0
0.
0
0
%
2,257,683
Ur
b
a
n
s
t
o
r
m
s
e
w
e
r
s
y
s
t
e
m
0
0
0
0.
0
0
%
0
Ru
r
a
l
s
t
o
r
m
s
e
w
e
r
s
y
s
t
e
m
0
0
0
0.
0
0
%
0
Wa
t
e
r
t
r
e
a
t
m
e
n
t
2
9
,
3
7
7
4
5
0
,
0
0
0
0
0.
0
0
%
1,968,039
Wa
t
e
r
d
i
s
t
r
i
b
u
t
i
o
n
/
t
r
a
n
s
m
i
s
s
i
o
n
1
0
0
,
7
2
1
0
0
0.
0
0
%
2,780,362
SU
B
T
O
T
A
L
4
6
5
,
6
4
2
6
7
5
,
9
7
2
0
0
.
0
0
%
2
1
,
5
1
8
,
8
1
0
3
9
.
4
8
%
He
a
l
t
h
s
e
r
v
i
c
e
s
Pu
b
l
i
c
h
e
a
l
t
h
s
e
r
v
i
c
e
s
2
5
8
0
0
0.
0
0
%
2,708
Ce
m
e
t
e
r
i
e
s
0
1
2
,
5
0
0
1
1
,
5
0
0
NA
19,932
Ot
h
e
r
00
0
0.
0
0
%
0
SU
B
T
O
T
A
L
2
5
8
1
2
,
5
0
0
1
1
,
5
0
0
4
4
5
7
.
3
6
%
2
2
,
6
4
0
0
.
0
4
%
Re
c
r
e
a
t
i
o
n
a
n
d
c
u
l
t
u
r
a
l
s
e
r
v
i
c
e
s
Pa
r
k
s
4
7
,
9
3
6
5
7
,
0
0
0
1
0
,
0
0
0
20
.
8
6
%
633,944
Ha
r
b
o
u
r
/
B
e
a
c
h
0
1
6
2
,
4
0
0
3
2
,
4
0
0
NA
419,822
Re
c
.
F
a
c
.
9
,
8
2
7
1
3
6
,
5
0
0
7
5
,
0
0
0
76
3
.
2
0
%
318,698
Li
b
r
a
r
i
e
s
3
,
7
8
9
1
0
0
,
0
0
0
0
0.
0
0
%
164,387
Mu
s
e
u
m
s
/
C
u
l
t
u
r
e
7
,
3
6
7
7
,
8
0
0
5
,
5
0
0
74
.
6
6
%
169,759
SU
B
T
O
T
A
L
6
8
,
9
1
9
4
6
3
,
7
0
0
1
2
2
,
9
0
0
1
7
8
.
3
3
%
1
,
7
0
6
,
6
1
0
3
.
1
3
%
TO
T
A
L
(
E
x
c
l
u
d
i
n
g
W
a
t
e
r
/
W
a
s
t
e
w
a
t
e
r
)
1
,
0
3
0
,
3
6
6
2
,
8
4
6
,
7
0
0
6
3
7
,
4
0
0
6
1
.
8
6
%
5
4
,
5
1
1
,
7
0
2
1
0
0
.
0
0
%
$1
,
4
9
6
,
0
0
8
$
3
,
5
2
2
,
6
7
2
$
6
3
7
,
4
0
0
$
5
1
$
5
4
,
5
1
1
,
7
0
2
$
1
NO
T
E
S
Re
l
i
e
d
o
n
2
0
1
1
U
n
e
x
p
e
n
d
e
d
Ca
p
i
t
a
l
(
$
8
0
,
0
0
0
)
20
1
3
A
n
n
u
a
l
Am
o
r
t
i
z
a
t
i
o
n
20
1
3
C
a
p
i
t
a
l
B
u
d
g
e
t
2
0
1
3
C
a
p
i
t
a
l
L
e
v
y
Pe
r
c
e
n
t
a
g
e
(
%
)
o
f
Fu
n
d
i
n
g
/
A
s
s
e
t
C
l
a
s
s
20
1
3
C
l
o
s
i
n
g
Ne
t
B
o
o
k
V
a
l
u
e
Percentage (%) of Net Book Value/Asset Class
Ge
n
e
r
a
l
G
o
v
e
r
n
m
e
n
t
1
4
,
1
2
6
7
3
,
5
0
0
.
0
0
4
5
,
0
0
0
.
0
0
3
1
8
.
5
6
%
7
3
6
,
9
3
6
1
.
3
7
%
Pr
o
t
e
c
t
i
o
n
s
e
r
v
i
c
e
s
Fi
r
e
13
1
,
3
1
7
19
8
,
5
0
0
18
3
,
5
0
0
13
9
.
7
4
%
2,144,826
Pr
o
t
e
c
t
i
v
e
i
n
s
p
e
c
t
i
o
n
a
n
d
c
o
n
t
r
o
l
1,
4
2
3
5,
0
0
0
5,
0
0
0
35
1
.
3
7
%
8,962
Em
e
r
g
e
n
c
y
m
e
a
s
u
r
e
s
2,
1
8
0
0
0
0.
0
0
%
11,754
SU
B
T
O
T
A
L
13
4
,
9
2
0
20
3
,
5
0
0
18
8
,
5
0
0
13
9
.
7
1
%
2,165,542 4.02%
Tr
a
n
s
p
o
r
t
a
t
i
o
n
s
e
r
v
i
c
e
s
Ro
a
d
s
-
P
a
v
e
d
70
6
,
5
4
7
21
2
,
9
9
0
0
0.
0
0
%
24,574,401
Ro
a
d
s
-
U
n
p
a
v
e
d
15
,
3
9
1
18
8
,
0
0
0
0
0.
0
0
%
1,009,092
Ro
a
d
s
-
B
r
i
d
g
e
s
a
n
d
C
u
l
v
e
r
t
s
19
,
5
0
4
15
,
0
0
0
0
0.
0
0
%
505,136
Ro
a
d
w
a
y
s
-
T
r
a
f
f
i
c
O
p
e
r
a
t
i
o
n
s
&
R
o
a
d
s
i
d
e
2,
6
8
0
0
0
0.
0
0
%
641,654
Wi
n
t
e
r
C
o
n
t
r
o
l
-
E
x
c
e
p
t
s
i
d
e
w
a
l
k
s
,
P
a
r
k
i
n
g
L
o
t
s
1,
7
3
1
0
0
0.
0
0
%
6,237
Pa
r
k
i
n
g
00
0.
0
0
%
76
St
r
e
e
t
l
i
g
h
t
i
n
g
1,
3
7
2
10
,
0
0
0
10
,
0
0
0
72
8
.
8
6
%
16,270
Ot
h
e
r
52
,
4
9
1
94
5
,
0
0
0
32
0
,
0
0
0
60
9
.
6
3
%
1,259,909
SU
B
T
O
T
A
L
79
9
,
7
1
6
1,
3
7
0
,
9
9
0
33
0
,
0
0
0
41
.
2
6
%
28,012,775 52.02%
En
v
i
r
o
n
m
e
n
t
a
l
s
e
r
v
i
c
e
s
Wa
s
t
e
w
a
t
e
r
c
o
l
l
e
c
t
i
o
n
/
c
o
n
v
e
y
a
n
c
e
23
7
,
0
1
4
62
,
3
0
0
0
0.
0
0
%
14,417,846
Wa
s
t
e
w
a
t
e
r
t
r
e
a
t
m
e
n
t
&
d
i
s
p
o
s
a
l
96
,
6
2
7
0
0
0.
0
0
%
2,161,056
Ur
b
a
n
s
t
o
r
m
s
e
w
e
r
s
y
s
t
e
m
00
0.
0
0
%
0
Ru
r
a
l
s
t
o
r
m
s
e
w
e
r
s
y
s
t
e
m
00
0.
0
0
%
0
Wa
t
e
r
t
r
e
a
t
m
e
n
t
6,
7
7
2
0
0
0.
0
0
%
1,961,267
Wa
t
e
r
d
i
s
t
r
i
b
u
t
i
o
n
/
t
r
a
n
s
m
i
s
s
i
o
n
12
7
,
3
7
2
18
,
0
0
0
0
0.
0
0
%
2,735,552
SU
B
T
O
T
A
L
46
7
,
7
8
5
80
,
3
0
0
0
0.
0
0
%
21,275,721 39.51%
He
a
l
t
h
s
e
r
v
i
c
e
s
Pu
b
l
i
c
h
e
a
l
t
h
s
e
r
v
i
c
e
s
25
7
0.
0
0
%
2,451
Ce
m
e
t
e
r
i
e
s
0.
0
0
%
25,584
Ot
h
e
r
0.
0
0
%
0
SU
B
T
O
T
A
L
25
7
0
0
0.
0
0
%
28,035 0.05%
Re
c
r
e
a
t
i
o
n
a
n
d
c
u
l
t
u
r
a
l
s
e
r
v
i
c
e
s
Pa
r
k
s
49
,
5
6
2
36
,
0
0
0
24
,
0
0
0
48
.
4
2
%
584,382
Ha
r
b
o
u
r
/
B
e
a
c
h
0
15
2
,
0
0
0
96
,
0
0
0
NA
419,822
Re
c
.
F
a
c
.
13
,
3
3
1
15
7
,
0
0
0
48
,
0
0
0
36
0
.
0
6
%
305,367
Li
b
r
a
r
i
e
s
7,
2
1
9
30
,
0
0
0
0
0.
0
0
%
157,168
Mu
s
e
u
m
s
/
C
u
l
t
u
r
e
7,
3
4
8
6,
0
0
0
2,
5
0
0
34
.
0
2
%
162,411
SU
B
T
O
T
A
L
77
,
4
6
0
38
1
,
0
0
0
17
0
,
5
0
0
22
0
.
1
1
%
1,629,150 3.03%
TO
T
A
L
(
E
x
c
l
u
d
i
n
g
W
a
t
e
r
/
W
a
s
t
e
w
a
t
e
r
)
1,
0
2
6
,
4
7
9
2,
0
2
8
,
9
9
0
73
4
,
0
0
0
71
.
5
1
%
53,848,159 100.00%
$1
,
4
9
4
,
2
6
4
$2
,
1
0
9
,
2
9
0
$7
3
4
,
0
0
0
$7
$53,848,159 $1
NO
T
E
S
20
1
4
A
n
n
u
a
l
Am
o
r
t
i
z
a
t
i
o
n
20
1
4
C
a
p
i
t
a
l
B
u
d
g
e
t
2
0
1
4
C
a
p
i
t
a
l
L
e
v
y
Pe
r
c
e
n
t
a
g
e
(
%
)
o
f
Fu
n
d
i
n
g
/
A
s
s
e
t
C
l
a
s
s
20
1
4
C
l
o
s
i
n
g
Ne
t
B
o
o
k
V
a
l
u
e
Percentage (%) of Net Book Value/Asset Class
Ge
n
e
r
a
l
G
o
v
e
r
n
m
e
n
t
$
1
1
,
7
8
3
$
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$2,026,599 3.79%
Tr
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SU
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TO
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NO
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