Concerns regarding a large mall project along Ira Needles next to the Erb St. landfill. Impacts to a large wetland complex and concerns for local water risks. Shared with City of Waterloo and Regional council.

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. 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. Concern #1:
City Planning Staff have the belief that:
“The City of Waterloo is not responsible for Water Resource Protection”

4. The July 27th
reply from Planner Ryan Mounsey states:

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. 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.
http://www.city.waterloo.on.ca/DesktopDefault.aspx?tabid=172

7. Example 2
Official Plan of the City of Waterloo Planning Area 1990:
The Goal of the Plan
1.7.3.9. To provide protection and enhancement of the fishery
habitat through such means as maintaining the connective process
between groundwater and baseflow to streams.

8. Example 2, Official Plan Cont.
2.3.3 It is the policy of this Plan to discourage development in
Environmental constraint Areas that would detract from the functions
performed by the natural environment such as groundwater
recharge, erosion control, wildlife habitat, or where environmental
constraints exist. Developments may be permitted where it can be
demonstrated to the satisfaction of Council, the Regional
Municipality of Waterloo, the Grand River Conservation Authority
and any other public agency having jurisdiction, that the proposal
will not adversely affect the Environmental Constraint Area. Such
appropriate statements as Environmental Impact Statement or an
Environmental Analysis Report as set out in the Regional Official
Policies Plan or an Environmental Study as set out in Section
2.3.1.4.3. of this Plan shall be required to support the development
proposal.

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. 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. Issue #2
The City of Waterloo approved the removal of the proposed Ira Needles
Commercial Centre from the Laurel Creek Watershed Policy

12. OFFICIAL PLAN AMENDMENT 74 AND ZONE CHANGE for DS-09-34
June 22, 2009 Waterloo City Council
As the Zone Change was approved for the Ira Needles Commercial
Centre, Waterloo City Council also agreed to remove this area from
the Laurel Creek Watershed Policy to be relocated into the Henry
Sturm Subwatershed area.

13. This correspondence inspired the change of Subwatershed

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. 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. For example: With the Laurel Creek Watershed Study this area had impervious
surface coverage limits but with the Henry Sturm criteria it does not have limits.

17. These dots are cars. .

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. Issues #3:
Insufficient supporting documentation regarding hydrogeology of
in regards to the Ira Needles Commercial Centre

20. In the July 27th
letter from the City states:

21. The February 14, 2001 correspondence from Peto
MacCallum Ltd. states the following:

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. The Peto MacCallum Ltd. states:

24. Examine the bore hole depth, the number of holes, the time of year for
testing and the years they worked.

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. 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. 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. Further Information
Written on Jan. 20, 2013

29. Google Earth map showed a large vernal pond that was
located by Ira Needles and University Ave.

30. Ira Needles pond habitat:
This large vernal pond was home to beavers, migratory
birds, raccoons, foxes, and turtles, etc.
A Blandings was found in Westvale during the pond
removal phase. The MNR stated the turtle found was a pet
Blandings because it was “tame.” Angela Schoen from
Turtle Haven rescue centre, stated the turtle came from the
wetlands “beside the dump”. She also stated that Blandings
were found in previous years to the north in close proximity
to this area.

31. The pond was drained.

32. They drained the creek dry.

33. Videos of Ira Needles Pond being drained
This is a video of the wetland soon after they drained it:
http://www.youtube.com/watch?v=Z-J3WNysFu8
This is a video of the pump used to drain the wetland, visit here:
http://www.youtube.com/watch?v=QaIwvZxQ0kI&feature=related

34. GRCA forms states there was no
wetland or habitats at all. Pg 1 top

35. Page 1 bottom

36. Page 2 top

37. Page 2 bottom

38. The Boardwalk Mall is in the red area with
within 500m of the landfill.

40. Figure 33: Region of Waterloo Landfill schematic showing the relationship of garbage, the respective
liners and protection areas and the leachate gathering system.
Source: http://www.geoscapegrandriver.ca/waste_and_recycling.html

41. 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.

42. 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.)

43. Topography isn't enough to delineate
watersheds or prevent water risks.
(cross section of the Waterloo Moriane)

44. 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.

45. 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
hrussell@nrcan.gc.ca or by phone at 613-
992-4374