70 Waverley Drive Proposed Zoning Amendment

I acknowledge that this comment comes late in the process of review of this planning item. I learned about the application on May 2nd. 2007. I outline below several aspects of the proposed project that I see require considerably more attention before the application is ready for decision by City Council.

(1) Relationship of the Proposed Project to future use of lands of Guelph Country Club.

The Guelph Country Club has provided recreational benefits to the City of Guelph for over 75 years. The original extent of Guelph Country Club land has been reduced by a series of at least four severances each of which was justified as providing money to the Country Club to allow it to remain viable, thus avoiding a closure of the club and redevelopment of the green space land to building lots. .

As part of its consideration of the present application Guelph City Council needs to be convinced that the application does not involve a first step in the conversion of the remaining Country Club property from a golf course to housing. If there is a strong possibility that the Country Club land is to be redeveloped in the near future then the present application should be denied. It is not good planning practice to approve a severance such as proposed which would encumber the planning of conversion of the remaining Country Club Land.

A related issue is whether or not the proposed application would preclude the extension of Stevenson Street north unto the Country Club Lands if this was desired in the future. On Schedule 1 (Location Map) a lot is shown directly north of Stevenson , the most easterly of a series of lots along Waverly and with slightly less depth than the other lots. The future of this lot directly bears on the future extension of Stevenson northward. This lot is not part of the subject lands for this application. This lot is currently fenced as part of the Country Club lands and is adjacent to an existing green. What is the intended use of this lot ? I believe that a decision on the future use of this lot should be made coincident with the current application
I am also puzzled by the comments by engineering that road access to the Country Club Land from Waverley could be provided further west. What location of connection is referred to ?

(2) Improvements to the Stormwater System for the Upper portion of the Stevenson Street Sewer

The stormwater aspect of this application is much more complex than the usual consideration of treatment of stormwater generated on the proposed building lots. The principle feature that needs to be recognized is the opportunity provided by this application to institute improvements in the stormwater system at the upper end of the Stevenson Street system. Let me first provide some background.

The upper portion of the Stevenson Street stormwater system was built in the 1970’s when efficient removal of stormwater from urban property was the only design consideration. This type of design has subsequently been recognized as causing environmental damage to receiving water though the transmission of frequent high flow peaks to the receiving water in summer storms and through transmission of pollutants to the receiving water.

As an interim corrective to these problems stormwater detention ponds were introduced into stormwater planning for new developments. In the last few years a different approach to stormwater control has been introduced involving disbursed control elements and different street layouts. In Canada and the United States this is called Low Impact Development while in Australia it is called Water Sensitive Urban Design. In several Ontario cities retrofits of older stormwater systems have been carried out to correct problems caused by the older portions of the stormwater system. These retrofits have involved both stormwater ponds and some distributed LID elements and practices.

As part of the environmental approvals the City of Guelph received from the Ministry of the Environment for the now completed expansion of the sewage treatment plant the City promised to make retrofit improvements to the city’s older stormwater system in order to improve water quality in the Speed and Eramosa Rivers. So far the city has not done any of this promised work. The Ministry of the Environment can be expected to include a review of the city’s performance as regards stormwater retrofits as a consideration in the future review of further applications by the city to further expand discharges from the sewage treatment plant. Failure to honour past commitments is a barrier to approval of future expansion.

Improvements in the upper Stevenson stormwater system would thus provide environmental and regulatory benefits to the city and should be considered in the context provided by this application. The proponent has recognized some of these potential benefits through the sketch of a sediment basin, naturalized channel segment and on-line storage pond to replace the existing open-channel section of the stormwater system in Windsor Park. This is a promising approach but it not included in the documentation provided for council’s consideration and is not required by any of the proposed conditions. In any case the city has a general policy that the stormwater system is entirely under city ownership. I support this policy and any exceptions to it require the demonstration of very specific benefits to the city and the environment from allowing some element of private ownership and/or control of stormwater systems.

Before the application is considered the city needs to develop a stormwater retrofit plan for the portion of the upper Stevenson Street system upstream of Windsor Park. The plan would include target reductions in flow peaks, in runoff volume, and in sediment and dissolved pollutant loading. Elements of the retrofit should include reconfiguration of drainage at the houselots, specifically disconnection of leaders carrying roof runoff from the stormwater system, replacing this treatment with rainbarrels and spreading of the roof water on lawns.

In addition storage should be added to the system to trap sediment and reduce flow peaks. Storage elements with infiltration (ponds, buried perforated pipes, infiltration galleries) would reduce flow volume. Various locations for storage elements should be considered including under the easterly portion of Windsor Park. The location for a channel/pond system sketched by the proponent is also a feasible alternative. This location would require a very ingenious landscape plan to overcome conflicts between a naturalized channel and perhaps pond (with riparian trees to provide shading) and the existing golf course fairway and green that is immediately adjacent.

The existing stormwater system at the start of the open-channel; segment in Windsor Park has a sustained flow showing that it is supported by discharging groundwater. As of today flow is present in the Windsor Park Creek at a time when the Speed and Eramosa Rivers have receeded to baseflow conditions. This confirms the groundwater-discharge component in the Creek. With added recharge to the shallow groundwater system upslope, as would occur with infiltration of roof water on the housing lots, the baseflow flowrate in the channel would be enhanced, although it is unlikely that it could be sufficient to become a perennial stream.

With suitable controls to divert runoff peak flows to storage and/or to a buried-pipe bypass there is the possibility of creating a naturalized stream channel in the easterly end of the subject property with nearly perennial flow. This would be a definite environmental plus.

Another benefit that should be included in stormwater consideration is the use of stored stormwater as a source of irrigation water by Guelph Country Club. The present source of irrigation is the Speed River through an intake opposite Riverside Park. During dry periods any withdrawl of water from the Speed River is undesireable as flowrate is already too small to maintain good water quality in the

(3) Enhancement of Natural Heritage Features

The existing stream channel segment in Windsor Park is judged not to be a significant Natural Heritage Feature but it nevertheless is a distinctive feature without parallel in the neighbourhood and has potential to be a valuable addition to the aesthetics of the park. The wooded area in the subject lands is large enough to show up clearly on the 1:10,000 Ontario basemaps although it too is judged not to be a significant Heritage Feature. There are several large white pine either on the subject lands or immediatey adjacent to it that I judge to be fine additions to the viewscape of the area. There is emphasis in the botanical assessment on invasive species such as the dreaded common buckthoprn, Manitoba maple and crack willow. These could all be removed and replaced by more desireable native trees if this was desired.

The objective of the city as regards the subject lands and Windsor Park should be to enhance both the active use portion of the park and a specially designated natural heritage area on the western portion of the park. The existing playground equipment in the park is located near the western edge of the mowed section of the park. If this equipment is moved to the eastern portion of the park this would allow an allocation of the western part of park as a natural area at least as large as the existing natural area A portion of the western portion of the mowed area could be transferred to the natural area. There is a parcel of land north of the eastern portion of Windsor Park, not part of the park, that is entirely fenced in and not obviously attached to any of the adjacent lots. If this parcel could be purchased by the city and added to the park this would enhance the size of the park and widen the choices for a suitable location for play equipment at the eastern end of the park.

To summarize I think the following actions are needed:

(1) Clarification of the relation between the current proposal and possible redevelopment of the Country Club Lands
(2) Agreement on a specific stormwater management system for the Windsor Park segment of the upper Stevenson stormwater system. The system should meet targets for reduction in stormwater volume and peak flowrate, and reduction in pollutants transferred to the Eramosa River. If at all possible the system should provide a source of irrigation water for the golf course, and a naturalized stream channel segment in a naturalized portion of Windsor Park All stormwater elements should be owned by the City of Guelph.
(3) Creation of a naturalized area of Windsor Park at least as large as the current western segment of the park currently zoned P5.        HW