January 4, 2016
Project No. 1717
April Nix
Environmental Planner
1 Carden Street
Guelph, Ontario
N1H 3A1
Dear April Nix
Re:
Potential Impacts to Off-site Significant Landform
132 Clair Road West Guelph, Ontario
NRSI was retained to provide ecological services in relation to the Draft Plan of Subdivision
23T-15501 and Zone Change ZC1510 applications. Part of this retainer has included reviewing
the Environmental Impact Study (EIS) prepared by North-South Environmental for 132 Clair
Road West in Guelph, Ontario. The EIS Terms of Reference were provided to the City and
presented to the Environmental Advisory Committee (EAC) and comments were included in a
Staff Report prepared by Ms. April Nix (City Environmental Planner), dated August 8, 2014.
Significant Landform, as identified in the Guelph Official Plan Consolidation dated September
2014 is present to the south of the proposed development area within additional lands owned by
the applicant.
The Significant Landform comments provided in the Staff Report (August 8, 2014) are as
follows:
 The TOR does not identify all known natural heritage features and areas, all known
features and areas should be identified in the TOR to inform the scope of the EIS being
proposed.
 More specifically the TOR should recognize Significant Landform as a known natural
heritage feature and establish the process in which negative impacts will be identified
and addressed. This would include impacts to the hummocky topography of the
Significant Landform, or to its ecological or hydrologic functions as per the requirements
under the Natural Heritage System policies (6A.2.8 of OPA 42). Also, please note that a
professional geoscientist (P. Geo), or a qualified professional with equivalent expertise is
required to confirm boundaries of Significant Landform.
The Terms of Reference were revised and appended to the draft EIS (dated August 28, 2015).
A preliminary review of the EIS by staff of NRSI, and discussions with Ms. Nix on December 16
and 17, 2015, confirmed that the EIS does not address Significant Landform in a substantive
manner. This letter addresses the issues associated with the Significant Landform and provides
information to satisfy the conditions of the City of Guelph’s Official Plan Amendment No. 42, as
detailed in the Significant Landform Policy section of this letter..
This letter has been prepared by Ms. Nyssa Clubine and Mr. David Stephenson of NRSI. Ms.
Clubine has extensive experience with Ontario landforms based on her educational background
and particularly her involvement in the delineation and policies associated with Significant
Landform in Guelph. Her involvement in this matter included active participation in Ontario
Municipal Board (OMB) mediation for several properties in southern Guelph. She worked
225 Labrador Drive, Unit 1, Waterloo, Ontario, N2K 4M8
Tel: (519) 725-2227
Web: www.nrsi.on.ca
Email: [email protected]
closely with landowners, City staff, as well as consultants hired by both the City and
landowners. Her work included participation in mapping of landforms using various map bases,
especially detailed topographic maps, on-site meetings to review landform delineations, and
participation in preparation of mediation materials and experts meetings. Mr. Stephenson also
participated in policy-level discussions and mediation associated with Significant Landforms,
and has extensive experience with EIS’s in the City and elsewhere.
In preparing this letter, NRSI reviewed the following documents to inform the discussion:
 Staff Report: 132 Clair Road West, Environmental Advisory Committee – August 8, 2014
 Environmental Advisory Committee Meeting Minutes – August 13, 2014
 132 Clair Road West, Guelph – Scoped EIS, North-South Environmental Inc. – August
28, 2015
 Planning Report – 132 Clair Road West, Guelph, Astrid J. Clos, Planning Consultants –
August 26, 2015
 Site Servicing and Stormwater Management Report – 132 Clair Road West, Guelph, GM
Blue Plan Engineering – August 2015
 Hydrogeological Investigation EIS Proposed Development 132 Clair Road West, Guelph
Technical Memorandum, Banks Groundwater Engineering Limited – July 17, 2015
 Watermain Easement and Limits of Significant Landform, Clair Road and Gordon Street,
Guelph, Water’s Edge Ltd. – August 12, 2013
 Official Plan Amendment No. 42 – City of Guelph – June 4, 2014
In order to evaluate the Significant Landform within the study area and identify potential impacts
to the natural feature, several steps were taken:
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
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The location of the natural feature was determined by an appropriate professional.
Adjacent Lands, as per OPA 42, were identified,
The current topography, and ecological and hydrological functions of the feature were
determined, and
Impacts to the landform including the ecological and hydrological functions of the
landform were assessed.
Significant Landform Policy
The City of Guelph Official Plan Amendment No. 42 was reviewed and an excerpt from the
Guelph Official Plan Consolidation (September 2014) is provided here.
6A.2.8 Significant Landform
Objectives
a) To identify and protect the significant portions of the Paris Galt Moraine within the
City that play a role in contributing to:
i. important environmental services including, surface water features and
groundwater resources, providing wildlife habitat and linkages, and
supporting biodiversity; and
ii. the City‘s geologic and aesthetic uniqueness.
b) To protect vulnerable surface water and groundwater resources, maintain and
enhance linkages, connectivity and related functions between and among natural
heritage features and areas, surface water features and groundwater features
and related hydrologic functions within the Paris Galt Moraine.
Criterion for Designation
1. Hummocky Topography of the Paris Galt Moraine that exhibits slope
concentrations where the slope is 20% or greater, and located in association with
closed depressions identified by the GRCA, and in close proximity to other
Significant Natural Areas of the Natural Heritage System.
Policies
2. Development and site alteration shall not be permitted within the Significant
Landform except for uses permitted by the General Permitted Uses of Section
6.A.1.2.
3. Development and site alteration may be permitted on Adjacent Lands to
Significant Landform where it has been demonstrated through an EIS or EA to
the satisfaction of the City, in consultation with the GRCA where appropriate,
that there will be no negative impacts to the Hummocky Topography of the
Significant Landform, or to its ecological or hydrologic functions.
4. In addition to the General Permitted Uses of Section 6A.1.2, the following
additional uses may be permitted within the Significant Landform subject to the
requirements under 6A.1.2.8, where it has been demonstrated through an EIS or
EA to the satisfaction of the City, in consultation with the GRCA, where
appropriate, that there will be no negative impacts to the Hummocky Topography
of the Significant Landform, or to its ecological or hydrologic functions:
i) essential linear infrastructure and their normal maintenance;
ii) essential transportation infrastructure and its normal maintenance, provided
the Hummocky Topography is maintained outside the right-of-way to the
greatest extent possible; and
iii) municipal water supply wells, underground water supply storage and
associated small scale structures (e.g. pumping facility).
iv) essential stormwater outlets for appropriately treated and managed
stormwater discharge in accordance with policy 6A.2.8.6 and the Stormwater
Management policies of this Plan.
5. Essential linear infrastructure and underground water supply storage shall be
designed to ensure that:
i) the Hummocky Topography of the Significant Landform will be maintained or
restored to the greatest extent possible;
ii) hydrological regimes will be maintained or restored, and
iii) Connectivity within the Natural Heritage System will be maintained.
6. Essential stormwater management outlets permitted within Significant Landform
shall:
i) meet any applicable requirements of comprehensive environmental study(ies)
(such as a subwatershed plan) to be completed as part of the Clair Maltby
Secondary Plan;
ii) be designed to ensure that:
a. grading and alteration to the Hummocky Topography is minimized and
restored to pre-existing topographic conditions to the greatest extent
possible;
b. pre-development run-off volumes based on pre-development topography are
maintained;
c. best management practices and/or low impact development approaches are
implemented to ensure a high level of contaminant and sediment removal in
accordance with comprehensive and site specific
environmental studies; and
d. where feasible, winter bypass relief systems to alternate receivers are
used to minimize potential chloride (i.e., salt) loadings or alternate winter
management strategies are used in accordance with the comprehensive
and site specific stormwater and/or environmental studies; and
iii) require the implementation of a monitoring and contingency plan for potential
impacts to groundwater quality and quantity on receiving lands associated
with this use within the Significant Landform.
7. Notwithstanding policy 6A.2.8.6 ii b) above, stormwater runoff volumes from the
development area exceeding the pre-development runoff volumes may be
permitted to be released to and recharge within the Significant Landform where
there are limiting physical site characteristics, and in accordance with City and
Provincial requirements for Water Resources and Stormwater management
including comprehensive and site specific stormwater and/or environmental
studies.
8. Where a Significant Landform feature also provides the function of an Ecological
Linkage, the Ecological Linkage policies shall also apply.
9. For the purposes of 6A.1.1.17, the boundaries of Significant Landform must be
confirmed on a site-specific basis by a professional geoscientist (P. Geo.), or a
qualified professional with equivalent expertise, using topographic mapping
completed by an Ontario Land Surveyor (at a contour interval of 1m or less).
10. Modifications to the boundaries of the Significant Landform may be made without
an amendment to this Plan provided it is demonstrated through an EIS or EA to
the satisfaction of the City, that:
i) alternate areas of Hummocky Topography that are at least of equal
hectarage will be protected as Significant Landform. Such areas may be
Areas;
ii) the alternate areas identified for protection are in close proximity to other
Significant Natural Areas of the Natural Heritage System and are adjacent to
and maintain linear continuity of the Significant Landform;
iii) the modification(s) does not result in loss of connectivity within the Natural
Heritage System;
iv) the alternate areas of landform identified for protection consist of Hummocky
Topography of the Paris Galt Moraine; and
v) the modified boundaries of the Significant Landform have been confirmed in
accordance with the requirements of 6A.1.1.17 and 6A.2.8.9.
For the purposes of 6A.2.8.10 i), alternate areas of Hummocky Topography shall be located on
the subject property, unless the EIS or EA is part of a comprehensive development application
involving multiple properties, in which case the alternate areas may be located on any one or
more of those properties.
If it can be demonstrated to the City’s satisfaction that there are no alternate areas of
Hummocky Topography within Ecological Linkages or outside of other Significant
Natural Areas, the alternate areas identified for protection may overlap with other
Significant Natural Areas in accordance with the provisions of 6A.2.8.9.
All lands identified as alternate landform pursuant to provisions 6A.2.8.10 shall be
deemed to be Significant Landform and shall be subject to all policies relating to
Significant Landform.
Once an EIS or EA is accepted by the City, the modified Significant Landform
boundaries will be deemed to be consistent with the policies of this Plan and have
the effect of modifying the designations and mapping on Schedules 1, 2, 10 and
10D.
Location of the Significant Landform
The Significant Landform was staked in the field and confirmed by City of Guelph staff as well
as Mr. Ed Gazendam, P.Geo, in 2013 (Water’s Edge 2013), Some minor revisions to the
boundary shown in the mapping associated with OPA 42 were made in the field and the final
Significant Landform boundary was mapped as part of a site alteration permit for the Watermain
Easement extending from Poppy Drive to Gosling Gardens. The boundary of the Significant
Landform was further revised in OPA 42 settlement mapping and is shown on Figure 1 and 2
below, as Significant Natural Areas and Natural Areas.
Ms. Clubine reviewed detailed topographic mapping, and with Mr. Stephenson, toured the site
on December 23, 2015 to review site conditions including topographic features associated with
the landform boundaries as per OPA 42 mapping. Ms. Clubine agreed with the boundaries of
the landform in the settlement mapping.
Figure 1 – Current Guelph Official Plan Natural Areas Mapping
Source: Clos, Astrid J. 2015. Planning Report – 132 Clair Road West, City of Guelph
Figure 2 – Official Plan Amendment No. 42, Minutes of Settlement Excerpt from Attachment V-2
Source: Clos, Astrid J. 2015. Planning Report – 132 Clair Road West, City of Guelph
Adjacent Lands
According to the City of Guelph, Official Plan (Consolidation September 2014), no buffer is
required for Significant Landform features; however the adjacent lands area is 50m from the
field verified edge of the natural feature (City of Guelph 2014). Based on the mapping of the
proposed development area prepared by GM BluePlan, the 50m adjacent lands to the
Significant Landform overlaps with the approved alignment of Poppy Road shown in the Guelph
Official Plan and the location of the watermain easement. Preliminary grading of the road has
been completed and the watermain that will feed the Bird Landing Subdivision to the east has
been installed. This grading was undertaken in compliance with a Site Alteration Permit issued
by the City of Guelph and a Permit issued by the GRCA. The Significant Landform designation
in the Official Plan coincides with the 30 m wetland buffer.
Figure 3 – Existing Conditions
Characterization of the Significant Landform
The delineated Significant Landform in this area is one of the furthest northern extents of the
landform in the City. On the subject property, the Significant Landform is associated with the
ridges and depressions that show increasing definition as one goes towards the south. South of
the proposed development parcel, there are a number of topographic highs consisting of hills as
well as ridges. Depressional topography dominates the southern portion of the landform on the
property. These southern depressions currently sustain wetland vegetation communities. The
sloped topography associated with the northern boundary of the wetland marks the extent of the
Significant Landform closest to the proposed development. The landform in question is
adjacent to a man-made farm pond that has subsequently been evaluated and meets wetland
criteria. It is not a naturally formed depression as found in other portions of the lands located
between Clair and Maltby Roads.
The hydrological and hydrogeological characteristics of the area are detailed in the Site
Servicing and Stormwater Management Report (GMBP 2015) and the hydrogeological
Technical Memorandum (Banks Groundwater 2015). The depression features along the north
edge of the landform were found to have fairly small closed catchments.
The composition of surficial deposits is described in the Technical Memorandum prepared by
Banks Groundwater Engineering Ltd. (July 2015). The memorandum describes 4 different
deposits within the study area; all of which are well-drained and provide good groundwater
infiltration. Groundwater flow in the area occurs within the bedrock in a westerly direction, from
a regional groundwater high located to the east of the subject property, towards the Speed
River. Groundwater flow through overburden material is generally within the same direction as
surface drainage occurring within the Hanlon Creek subwatershed; from a groundwater high
southeast of the subject property to the west northwest and towards Hanlon Creek. Baseflow
within Hanlon Creek is sustained by groundwater recharge that occurs locally.
The groundwater monitoring showed downward gradients in the depressions indicating the
areas were recharge areas, not associated with groundwater discharge. As such, it is likely that
the study area provides a groundwater recharge function; particularly as no surface water
drainage features occur on site. No groundwater discharge areas are present within the study
area (Banks Groundwater 2015). However, the base of the depressions tended to be
dominated by relatively impermeable layers that lead to a water regime conducive of sustaining
the existing wetlands. The vegetation in the wetlands is dominated by species, such as cattails,
and reed canary grass, with areas of open water (the extent of which changes from season to
season), which are typical of sites with considerable water level fluctuations.
The August 2015 EIS provided details of the flora and fauna associated with the wetlands. The
majority of the lands around the wetlands, other than small fringes of upland meadow, are
actively tilled (corn in 2015). The reader is referred to the EIS for details about the ecological
function of the wetlands. It was concluded that the wetland to the south of the proposed
development parcel are part of the Provincially Significant Halls Pond Wetland Complex.
Impact Assessment
Potential impacts arising from the proposed development were determined by comparing the
details of the proposed development with the characteristics of the Significant Landform
including existing ecological and hydrologic features and functions. Several types of potential
impacts require assessment that may result when development occurs in the vicinity:
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Direct impacts to the features on the subject lands associated with disruption or
displacement caused by the actual proposed ‘footprint’ of the undertaking.
Indirect impacts associated with changes in site conditions such as drainage and water
quantity/quality.
Induced impacts associated with impacts after the development is constructed such as
subsequent demand on the resources created by increased habitation/use of the area
and vicinity.
Direct Impacts
The Significant Landform has been field verified and mapped, and does not occur within the
proposed development area. The Servicing and Stormwater Management Report provided
preliminary grading details for the perimeter of the development area. Grading will occur along
the north side of Poppy Road as well as the west side of Gosling Gardens and the western
boundary of the development area. The grading along Poppy Road is within the Significant
Landform adjacent lands; however the grading has already occurred associated with the
approved Poppy Road and servicing.
The proposed development is outside of the Significant Landform. Conditions north of the
Poppy Road alignment, within the proposed development area, do not reflect the definition of
hummocky topography as identified in OPA 42. As such, no direct impacts to the topography of
the Significant Landform will occur as a result of the proposed development.
The EIS prepared for 132 Clair Road West by North-South Environmental identified the potential
impacts to natural features within the proposed development area as well as the larger study
area that overlapped with the northern extent of the Significant Landform. These features
include a cultural meadow, a Provincially Significant Wetland (PSW), and cultural woodlands.
For more information on these features, refer to the EIS (NSE 2015). None of the natural
habitats overlap with the proposed development, and the proposed development is separated
from the natural habitats by the existing works associated with Poppy Drive. As such, no direct
impacts to the natural habitats will occur.
Indirect Impacts
Potential indirect impacts to the Significant Landform may arise from changes to surface and/or
groundwater impacts, as well as potential modifications to site conditions affecting flora and
fauna (e.g. disruption, etc.). The following potential indirect impacts to the Significant Landform
were assessed:
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Changes to surface drainage patterns
Changes to groundwater regime
Changes to water quality
Impacts to local flora and fauna
Surface Water Regime
The proposed development will include commercial buildings and a parking lot with 2 linear
stormwater management bio-retention facilities. The Servicing and Stormwater Management
Report includes details regarding the proposed infiltration and design of the stormwater facilities
on site (GM Blue Plan 2015). The lands identified for the proposed development do not
currently contribute surface water to the wetland-dominated depressions to the south. As such,
the proposed development, including preliminary grading plans will not affect the surface
drainage patterns that contribute to the wetland water balance. The hydrogeology Technical
Memorandum stated that no surface drainage features are present within the study area. In
addition, the wetland is located at a higher elevation than the proposed development area.
Therefore, any surface drainage that enters the wetland will originate upslope from the wetland,
outside of the development area. Changes to surface drainage patterns within the development
area will not affect the wetland water balance.
Groundwater Regime
The use of bio-retention facilities for stormwater management on the development site will offset
any potential decrease in pervious area within the Significant Landform adjacent lands. Water
collected from Poppy Drive, Gosling Drive, and their rights of way will be directed towards the
onsite stormwater management facility, and will infiltrate, thus reducing the impact of the
impervious surfaces.
As noted in the hydrogeological assessment, the groundwater that currently infiltrates within the
development area generally flows in a northwesterly direction, away from the Significant
Landform and associated wetlands.
As such, the proposed development is not anticipated to influence the groundwater regime
within the Significant Landform.
Water Quality
The hydrogeology Technical Memorandum indicated that there are limited source water
protection implications within the proposed development area. Surface water runoff from the
site will be directed through a Stormceptor STC 4000, or other approved system, prior to
discharging into the bio-retention facility and infiltrating. This process will mitigate potential
impacts to ground water quality from chemicals originating within the development area and
from the roads.
In terms of the water quality in the Significant Landform, as noted above both surface and
groundwater flows will be directed away from the landform and associated natural habitats.
Flora and Fauna
The EIS, prepared by North-South Environmental indicated that the proposed development has
limited potential for indirect impacts on the natural heritage features within the study area or the
Significant Natural Areas and Natural Areas as defined by OPA 42. As the development area is
located within an agricultural area that is actively farmed and does not encroach on the natural
areas to the south, indirect impacts to the ecological function of the Significant Landform will not
occur with the proposed development. Potential indirect disturbance impacts such as noise,
dust and light can be mitigated though the use of measures such as construction timing,
revegetation of bare soils, and/or use of street lighting to avoid ‘light wash’. The natural features
to the south of the development area will be left to naturalize post-development, restoring some
of the ecological function of this area. The adjacent lands of the Significant Landform contain
the Poppy Road alignment as well as a watermain. The ecological function of the adjacent
lands is limited in its current state. Additional indirect impacts are not anticipated to occur with
the proposed development.
Induced Impacts
Induced impacts are described as those that are not directly related to the construction or
operation of the facilities in question, but rather arise from the use of the natural areas as a
result of the development. The simplest example is increased use of a natural area by
residents, feral domestic wildlife, and unauthorized trail/pathway construction.
As the proposed development is a corporate business park, induced impacts are anticipated to
be limited as user activity will be restricted to the commercial area during regular business hours
(NSE 2015)
Summary
The extent and characteristics of the Significant Landform located to the south of the proposed
development has been documented. It was found that although the actual landform and natural
habitats do not overlap with the proposed development, the adjacent lands zone of the
Significant Landform does include a minor overlap with Poppy Road. The proposed
development will not result in any modifications to the landform’s topography. No impacts
related to groundwater or surface water regime will occur. Indirect impacts to flora and fauna
are documented in the EIS, and are very limited and readily mitigated. The adjacent lands to
the Significant Landform will remain as they currently exist, with no additional modifications or
alterations.
In summary, the proposed development will not result in impacts to the Significant Landform or
its ecological or hydrological features or functions
Sincerely,
Natural Resource Solutions Inc.
_____
Nyssa Clubine
Stream Corridor & Environmental Analyst
______
David Stephenson
Senior Biologist