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Interesting project observed. Louisette Lanteigne assumes no liability for any inaccurate, delayed or incomplete information, nor for any actions taken in reliance thereon. All information should be verified independently before being used and relied on.

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Attachment a

  1. 1. Response to City of Waterloo Planner Mr. Mounsey’s July 27, 2009 correspondence re: Ira Needles Commercial Centre By Louisette Lanteigne July 30 2009.
  2. 2. Background Information• On July 15th 2009, I presented a list of questions to City of Waterloo Planner Ryan Mounsey regarding the proposed Ira Needles Commercial Centre.• On July 27th a written reply was sent from Mr. Mounsey in regards to the list of questions.• This presentation is to outline the remaining issues and concerns (not exhaustive) regarding the response and planning processes for the Ira Needles Commercial Centre.
  3. 3. Concern #1: City Planning Staff have the belief that:“The City of Waterloo is not responsible for Water Resource Protection”
  4. 4. The July 27th reply from Planner Ryan Mounsey states:
  5. 5. To state that source water protection is not the city’s responsibility conflicts with the following:• Information on the City of Waterloo Website• The City of Waterloo’s Official Planning Policy• The City of Waterloo’s Environmental Strategic Plan 2002
  6. 6. Example 1 The City of Waterloo’s Website states:• The City of Waterloo is responsible for water efficiency, water resource protection and sewer-use control programs, and has won several awards for this work.
  7. 7. Example 2 Official Plan of the City of Waterloo Planning Area 1990:The Goal of the Plan To provide protection and enhancement of the fishery habitat through such means as maintaining the connective process between groundwater and baseflow to streams.
  8. 8. Example 2, Official Plan Cont.2.3.3 It is the policy of this Plan to discourage development inEnvironmental constraint Areas that would detract from the functionsperformed by the natural environment such as groundwaterrecharge, erosion control, wildlife habitat, or where environmentalconstraints exist. Developments may be permitted where it can bedemonstrated to the satisfaction of Council, the RegionalMunicipality of Waterloo, the Grand River Conservation Authorityand any other public agency having jurisdiction, that the proposalwill not adversely affect the Environmental Constraint Area. Suchappropriate statements as Environmental Impact Statement or anEnvironmental Analysis Report as set out in the Regional OfficialPolicies Plan or an Environmental Study as set out in Section2. of this Plan shall be required to support the developmentproposal.
  9. 9. Example 2, Official Plan Cont.4.1.11 Area Municipalities will in Consultation with the MNR or it’s delegate, establish policies in it’s’ Official Plans to:a) achieve no net loss of the productive capacity of the fish habitats by requiring that: i) The applicant assess the impact of the new development on designated fish habitat; ii) The quality and quantity of water which sustains fish communities and fish habitats is not adversely affected.
  10. 10. Example 3 The City of Waterloo’s Environment Strategic Plan 2002• 3. Water Resources Monitoring In order to make appropriate management decisions with respect to land use and development, it is necessary to understand the current state of the watershed and to identify changes as they occur. The establishment of a monitoring program that measures appropriate water quality, quantity, and aquatic habitat parameters is an essential component of water resource protection.
  11. 11. Issue #2The City of Waterloo approved the removal of the proposed Ira Needles Commercial Centre from the Laurel Creek Watershed Policy
  12. 12. OFFICIAL PLAN AMENDMENT 74 AND ZONE CHANGE for DS-09-34 June 22, 2009 Waterloo City CouncilAs the Zone Change was approved for the Ira Needles CommercialCentre, Waterloo City Council also agreed to remove this area fromthe Laurel Creek Watershed Policy to be relocated into the HenrySturm Subwatershed area.
  13. 13. This correspondence inspired the change of Subwatershed
  14. 14. Issues regarding the change of subwatershed• The City of Waterloo’s planners initiated the removal of the Ira Needles Commercial Centre area from one Subwatershed study to another in spite of the fact the lead planner wrote that water resource protection is not the City’s responsibility.• The stamp states the Stantec letter was received on May 4 2009 and the vote was on June 22nd. The letter sent from Stantec does not state it was directed to either GRCA or Regional Staff, but there was adequate time for the city to consult with these agencies prior to the rezoning of the proposal. If the lead planner wrote that the Region has the responsibility of water source protection, then why didn’t the city contact the Region’s Water Resources Staff to get them involved with the planning of this proposal prior to the rezoning and the Official Plan amendment?
  15. 15. Change of watershed cont.• The Henry Sturm subwatershed policy did not include this property into the area of study so the report lacks site specific data regarding various natural features.• No data has been presented to indicate what ramifications this change would have upon the existing Watershed Studies.• By removing the property from the Laurel Creek Subwatershed Study there are now less ecological constraints for this property.
  16. 16. For example: With the Laurel Creek Watershed Study this area had impervioussurface coverage limits but with the Henry Sturm criteria it does not have limits.
  17. 17. These dots are cars. .
  18. 18. Questions• road salts issues in this area can have serious impacts to our municipal wells and aquifers.• What happens with the leaking landfill when there is less water diluting the contamination issues?• The landfill is already experiencing water issues. There are areas to wet to remove the methane. What about risks of explosion?
  19. 19. Issues #3:Insufficient supporting documentation regarding hydrogeology of in regards to the Ira Needles Commercial Centre
  20. 20. In the July 27th letter from the City states:
  21. 21. The February 14, 2001 correspondence from Peto MacCallum Ltd. states the following:
  22. 22. The data used by Peto MacCallum (and referred to by Stantec)• The PetoMacCallum Ltd. report titled: Preliminary Geotechnical Investigation Proposed industrial subdivision West Hill Drive and University Ave. Waterloo Ontario was produced in 1988.
  23. 23. The Peto MacCallum Ltd. states:
  24. 24. Examine the bore hole depth, the number of holes, the time of year for testing and the years they worked.
  25. 25. Issues and Concerns re: Geotechnical Data• The bore hole data is too shallow to reasonably assess hydrogeological risks associated with a large scale commercial centre.• There are not enough bore holes to accurately reflect the subsurface geology of the area.• This report only relates to approximately one month worth of analysis in a study conducted over 20 years ago.• There is no 12 month data to illustrate basic seasonal variants, ie: spring thaw water balances, flow rates etc.
  26. 26. re: Geotechnical Data cont.• There is insufficient supporting documentation to ascertain that the clean water collection system will either result in a similar distribution (laterally or vertically) or similar volume of recharge water as presently occurs.• There has been inadequate monitoring to accurately calculate existing runoff conditions, infiltration conditions and groundwater discharge.
  27. 27. re: Geotechnical Data cont.• Calculations and stream flow observations were not used to verify baseflow conditions. (Continuous streamflow measurements for a 12 month period would assist in the determination of volumes of runoff and volumes of groundwater discharge and groundwater recharge in/out of area creeks.)• Using bore hole data, outwash till formations can appear to reflect consistent clay coverage but this poses a serious risk to aquifer systems. GPR profiles can help mitigate the risks by illustrating the till areas in more detail and thereby providing a better view of the underlying sediment layout. This area’s topography indicates an outwash till system at this location.• Staff did not initiate a review of the hydrogeological data by Regional Water Services and do not feel it is their responsibility to do so as noted in the July 27th correspondence.• Pre-development onsite monitoring for a minimum 2 year period in accordance to water resource protection policies of the GRCA should be implemented in order to circumvent risks to aquifer and well systems.
  28. 28. Further InformationWritten on Jan. 20, 2013
  29. 29. Google Earth map showed a large vernal pond that was located by Ira Needles and University Ave.
  30. 30. Ira Needles pond habitat:This large vernal pond was home to beavers, migratorybirds, raccoons, foxes, and turtles, etc.A Blandings was found in Westvale during the pondremoval phase. The MNR stated the turtle found was a petBlandings because it was “tame.” Angela Schoen fromTurtle Haven rescue centre, stated the turtle came from thewetlands “beside the dump”. She also stated that Blandingswere found in previous years to the north in close proximityto this area.
  31. 31. The pond was drained.
  32. 32. They drained the creek dry.
  33. 33. Videos of Ira Needles Pond being drained This is a video of the wetland soon after they drained it: is a video of the pump used to drain the wetland, visit here:
  34. 34. GRCA forms states there was nowetland or habitats at all. Pg 1 top
  35. 35. Page 1 bottom
  36. 36. Page 2 top
  37. 37. Page 2 bottom
  38. 38. The Boardwalk Mall is in the red area with within 500m of the landfill.
  39. 39. Figure 33: Region of Waterloo Landfill schematic showing the relationship of garbage, the respective liners and protection areas and the leachate gathering system. Source:
  40. 40. Quote from Geoscape website:• In the region of Waterloo all waste is directed from satellite substations to the main landfill on Erb Street west of Waterloo. As seen in Figs. 33 and 36, this facility sits on top of the main drinking water aquifer and so care must be taken to protect the water supply from leachate contamination.
  41. 41. Regarding Landfills & Aquifers: Examine Waterloo Region!• The Waterloo Landfill is located in the extreme southwest corner of the City of Waterloo. The area is underlain by a major sand and gravel aquifer which supplies about 45 million gallons per day (mgpd) of groundwater to Kitchener Waterloo area. In fact, this is one of the most significant groundwater resources in Canada.• This passage is taken from page 231 of the following report: Hazardous waste risk assessment By D. Kofi Asante-Duah (A search of the title and author will lead you to the complete online report.)
  42. 42. Topography isnt enough to delineate watersheds or prevent water risks. (cross section of the Waterloo Moriane)
  43. 43. What goes in the ground will head to wells with draw down effects regardless of topography. Professor Mike Stone:chloride loadings to Waterloo Regional wells reveals this fact.
  44. 44. Example: The Arkell Research Station in Guelph • Using standard bore hole testing, this area appears to be covered in a consistent clay layer. • GPR profiles identifies this area as a shallow outwash aquifer. The clay is discontinuous. They are like shingles with many spaces of infiltration in between. • This area gathers up to 7% of Guelph’s potable water supply and it recharges cold water trout streams. • The GPR profiles for the Arkell Research Station were provided by Hazen Russell, Sedimentologist with the Canadian Geological Survey of Canada. For more information he can be reached by email at or by phone at 613- 992-4374