We are writing today to express concern about a development proposal for the property known as the Dallan Lands (151, 205 and 253 Clair Road East).
We have been commenting on and following this proposal since May, 2008, on behalf of the Guelph Field Naturalists.
Our primary concern is the likelihood of isolating the wetland along Clair Road that is identified as part of the Hall’s Pond Provincially Significant Wetland (PSW) Complex, resulting in the eventual loss of biodiversity, specifically the present amphibian population. We believe that the proposed ecological linkage is inadequate and improperly located. The Dallan Lands EIS Addendum Report (2009) prepared by Stantec Consulting Ltd., describes the amphibian population documented at the Clair Road PSW as “vibrant”. The species of amphibians found there spend the majority of their life cycle in the wooded lands to the south and east, returning to the Clair Road PSW to breed in the spring.
The current design and location of the proposed ecological linkage to those woodlands is based on recommendations in the Stantec EIS Addendum report. However, these recommendations are not supported by the two other environmental reports that were sponsored by the City: The Natural Heritage Strategy (NHS) Report (2009) and the Hanlon Creek Watershed Study (1993) – both of which recommend a significantly wider and more centrally/directly located linkage. We understand that the Dallan Lands development application pre-dates the NHS and is therefore not subject to its policies. Nonetheless, the biological data and scientific literature review that form the basis of those policies should have been included in the Dallan Lands EIS Addendum report because it was available at the time. In addition, two other relevant studies done for a similar moraine landscape would support the City reports rather than the recommendations of the Stantec EIS Addendum report. They are:
1. Natural Heritage Planning for Amphibians and Their Habitats with reference to populations on the south slope of the Oak Ridges Moraine, by N. Helferty, 2002.
2. Natural Heritage Systems in Urbanizing Settings: Sustainable Practices for the Oak Ridges Moraine, by Diamond et al., 2002.We sent digital copies of these two studies to city staff last January, 2010.
The Stantec report does not document the migration route being used by the amphibians to and from the Clair Road PSW. It is logical to assume, however, that the amphibians utilize a more-or-less direct route across the open landscape between the wetland and the wooded lands to the south and east, likely using the small kettle wetlands in this area as “stepping stones”. Amphibians calling from the PSW would attract others from the wooded lands directly across the open landscape, most likely on wet, rainy nights in early spring. The small kettle wetlands have not been identified as part of the Hall’s Pond PSW Complex. The Ministry of Natural Resources’ rationale for including small wetlands in wetland complexes appears to be inconsistent across the province. The Aurora District Office of the MNR would likely have included these small wetlands in the PSW complex in a moraine landscape (see Rationale below).
As per the Ontario Provincial Policy Statement (PPS) (2005), the Stantec EIS Addendum report identifies the Clair Road PSW as “Significant Wildlife Habitat” (Seasonal Concentration Area). The report fails, however, to include the vital migration route of the amphibians as part of this habitat. As you are aware, the PPS contains specific language with respect to Natural Heritage including “diversity and connectivity”, “long-term ecological function” and “recognizing linkages between and among natural heritage features and areas”. The two Guelph environmental reports noted above recommend a significantly wider and more centrally/directly located linkage for the Clair Road PSW and the two relevant studies’ findings would support such a linkage. The Stantec EIS Addendum report recommends a significantly narrower linkage along the western boundary of the property, and it appears to be located there for reasons other than environmental ones.
The City’s Environmental Advisory Committee voted on a resolution at its June meeting to accept the Dallan Lands proposed development with its inadequate wildlife corridor. Five EAC members were present, one of whom declared a conflict of interest. Of the remaining four members who voted on the resolution, only one was a biologist/ecologist. In our opinion, this does not qualify as an adequate environmental review from a committee whose mandate is to advise the City on environmental matters.
Gord Miller, Ontario’s Environmental Commissioner, wrote an article that appeared in the Guelph Mercury earlier this year, commenting on the need to protect biodiversity in the province (“We can no longer ignore our bio-diversity crisis”, Guelph Mercury, Jan. 26, 2010) and noting this is the International Year of Biodiversity as declared by the United Nations. He made specific reference to Guelph including appropriate subdivision planning if we are sincere in halting the loss of biodiversity.
The Dallan Lands proposed development will be the first high-density, residential development on the Paris-Galt Moraine within the City south of Clair Road. It could very well set a precedent for future development on the Moraine, particularly with respect to ecological linkages and their ability to maintain ecological functions and wildlife populations for the long-term. If the current proposed ecological linkage for the Clair Road PSW is approved, it opens the possibility that all future corridors and ecological linkages that are identified in the City’s Natural Heritage System can be adjusted and minimized for other future proposed developments.
We note that in the latest version of the City’s Natural Heritage System shown on Draft Schedule 2: Land Use Plan (April, 2010) as part of the Official Plan Update, the design has already been changed from the wider, centrally-located linkage on earlier versions to show the narrower ecological linkage along the western boundary of the Dallan property. We understand that City Council will be voting on the NHS as part of the Official Plan Update later this month including this change, despite the fact that the Dallan Lands proposed development plan has not been approved. If this change is approved as part of the NHS/Official Plan Update, it certainly paves the way for the current proposed Dallan Lands development to be approved.
We believe that City council needs to be aware that approving the current proposed Dallan Lands development plan with its inadequately-sized and inappropriately-located ecological linkage along the Dallan Lands western property boundary will very likely result in the eventual loss of the existing “vibrant” amphibian population at the Clair Road PSW. The two city-sponsored environmental reports confirm this and the scientific literature supports this conclusion. If this occurs, we believe the specific policies of the PPS will not be met, nor will that part of the City’s Mission Statement which concerns environmental planning, stewardship and sustainability.
We respectfully request that more consideration be given to the design and location of the ecological linkage for the proposed Dallan Lands development plan to ensure the long-term sustainability of the Clair Road PSW biodiversity.
Sincerely,
Guelph Field Naturalists
MNR Aurora’s Rationale for Inclusion of Wetlands under 0.5 ha in Size*
Wetlands are uncommon on the Oak Ridges Moraine, covering only 2% of its surface. Most of the wetlands on the Moraine are small kettle wetlands or small headwater wetlands under 2 hectares in size. Large wetlands are restricted to major discharge zones and to its kettle lakes. Wetlands under 0.5 hectares thus constitute a large portion of wetlands on the Moraine. These small wetlands are included for any of the following reasons:
• Support wetland types not well represented elsewhere in the wetland complex
• Sustain significant species
• Are amphibian breeding ponds
• Function as migratory waterfowl stopovers
• Are headwater sources or contribute base flows
• Are hydrologically connected to larger wetlands
• Provide intervening wetland habitat between larger wetlands
• Occur along corridors
• Are kettle wetlands, an uncommon wetland that is restricted to moraines such as the Oak Ridges Moraine* Rationale is taken from 3rd Edition Wetland Evaluations located at the Ontario Ministry of Natural Resources Aurora District Office