Below are Sierra Club’s concerns with respect to this development proposal:
1. The plan does not provide an adequate amphibian migration corridor/linkage
a. EIS indicates wetland contains “a vibrant amphibian community with exceptionally strong choruses”
b. Vast majority of amphibians at this site (spring peepers, gray tree frogs) spend most of their lives in wooded areas, not in or around wetlands
c. Hanlon Creek Watershed Plan (HCWP) identifies most of site as “primary linkage”
d. GRCA recommended buffer and linkage guidelines in HCWP “should be followed as closely as possible” (December 16, 2009 letter to City of Guelph)
e. No amphibian surveys were done to determine the location of amphibian migration corridor, as was done with the Southgate development.
f. Developer proposing 25 metre corridor at western edge of property
g. GRCA recommended 125 metre corridor (December 16, 2009 letter)2. Surveys for Jefferson Salamander are inadequate. Ministry of Natural Resources Species at Risk Specialist, Karolyne Pickett, says “I categorically reject any conclusion based on this 2010 survey that Jefferson Salamander does not occur in the surveyed ponds.” (pers. comm. 1 April 2011)
3. Loss of 5 temporary wetlands
a. GRCA says the small kettle wetlands should be protected from development and that removal would diminish ecological connectivity on the subject lands and beyond (November 10, 2009 Internal Technical Review)
b. The EIS for this project acknowledges that the proposal to remove these wetlands violates GRCA policy (pg. 3.11)4. Wetland buffers are inadequate.
a. Hanlon Creek Watershed Plan recommends 120 metre buffers. This plan proposes 30 metres.
b. GRCA says that “a 30 m buffer would protect less than 50% of the breeding population of most species” inhabiting the large wetland (November 2009 Internal Technical Review)5. Summary of impacts:
a. Violates Provincial Policy Statement by allowing negative impacts on wetland function–impacts on amphibians and their habitat
b. Violates Hanlon Creek Watershed Plan, which designates most of site as “primary linkage” and recommends 120 metre buffers
c. According to MNR, Jefferson Salamander surveys inadequate
d. GRCA recommendation of 125 metre corridor not implemented
e. Destroys 5 small wetlands, contrary to GRCA policy and recommendation
f. Inadequate buffer to protect 50% of amphibians per GRCA document
g. Environmental connectivity on this land and beyond negatively impacted per GRCA document
h. Development would destroy at least 500 trees5. Deficiencies in the application that should be addressed:
a. Require amphibian migration survey using pitfall traps to determine proper location of corridor; require 125 metre corridor as recommended by GRCA
b. Require increased wetland buffer consistent with Hanlon Creek Watershed Plan (120 metres)
c. Require additional Jefferson Salamander surveys
d. Reduce density per recommendation of Hanlon Creek Watershed Plan–very low level of imperviousness (10%), rural residential/cluster development “with very large pervious infiltration buffers around them.” (page 183) It is our understanding that this proposal is for a density that exceeds the average recommended for greenfield areas.
e. NOTE: The Provincial Places to Grow Act directs that if there is a conflict between it and the Provincial Policy Statement (i.e. the requirement that there be no negative impact on wetland features or functions) then the policy direction “that provides more protection to the natural environment or human health prevails (Section 14.4)JM