Ecological concerns with Stittsville quarry expansion proposal

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One of our EcoYouth Council members, Maggie Hanna, submitted a letter to the City concerning a quarry expansion proposed in the Stittsville area. As Maggie outlines, there are a number of serious environmental concerns associated with this proposal. We hope that these concerns are resolved before any further action is taken on this proposal.

Want to take action? Let your councillor know your thoughts, as well as the project manager Jasdeep Brar. This proposal will come to Council's Agriculture and Rural Affairs committee—and hopefully also the Environment and Climate Change Committee, given the considerable ecological aspects, as described below. Feel free also to contact councillors on either committee. For updates on this file, please subscribe to our newsletter or follow us on social media (@ecologyottawa)!

Please read Maggie's letter below!

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Dear Jasdeep Brar, 

We are writing to express our deep concerns regarding the recent proposed expansion of the Tomlinson Stittsville Quarry Operation (Application # D01-01-24-0019). After thoroughly reviewing the application documents, we have identified several critical issues that we believe must be addressed before any further action is taken.

The expansion plan involves extracting over three million tonnes of aggregate through bedrock blasting, resulting in the destruction of 15.3 hectares of wetlands and 30.3 hectares of woodlands, impacting ecologically specific species and habitats, including:

• Threatened species under the Species at Risk Act (SARA): Eastern Whip-poor-will and Western Chorus Frog (Environmental Impact Statement, Sections 5.5.2 and 5.5.1)
• Species of Special Concern under SARA: Monarch Butterfly (Environmental Impact Statement, Section 5.5.4) 
• Provincially Rare and regionally significant plant species: Prairie Dropseed (Environmental Impact Statement, Sections 5.4.3)
• Significant Woodlands: The woodlands within (A, B, C and D) within the expansion site are classified as Significant Woodlands under the City of Ottawa’s criteria due to their large size, essential ecological functions (such as water protection and biodiversity support), presence of rare and provincially significant vegetation, and substantial economic and social value (Environmental Impact Statement, Section 6.4)

We believe that The Tomlinson Group’s proposed Rehabilitation Plan is inadequate. It primarily involves backfilling the 109.8-hectare extraction area with soil and planting vegetation. Of this, only 66.3 hectares are designated for ecological restoration - 19.5 hectares for a “wetland feature” and 46.8 hectares for restored woodlands - while the remaining 43.5 hectares (nearly half of the extraction site) will only be temporarily restored to cultural meadows, but are ultimately reserved for future development. 

The Planning Report Addendum states that the rehabilitation will result in “improved ecological woodland, wetland and wildlife habitat functions over existing conditions”. However, this assertion is deeply flawed for several reasons:

1. Recreated wetlands do not have the same environmental value as natural wetlands: Wetlands are characterized by rich organic soils that develop over thousands of years and highly specific hydrological regimes. The Association of State Wetland Managers, Inc (ASWM) states that “total restoration of a wetland in a manner that ‘totally duplicates’ all aspects of a naturally occurring wetland including soils is impossible in a short period of time.” 
2. The Rehabilitation Plan does not address additional complexities: The ASWM notes that there should be additional considerations taken when recreating a wetland if there are invasive species present, if there are endangered plant and animal species present and if the wetland is forested. A site survey has confirmed the presence of invasive phragmites and glossy buckthorn (Environmental Impact Statement, Section 5.4.2), yet the Rehabilitation Plan does not account for these species at all.
3. Absence of long-term monitoring and scientific expertise: Effective wetland restoration requires long-term protection, monitoring and adaptive management before and after construction. The ASWM also cites the lack of adequate expertise as a common reason for failures of wetland recreation and restoration. The current rehabilitation plan lacks a long-term monitoring strategy and does not propose collaboration with scientific experts, environmental agencies, or conservation organizations to guide and oversee the restoration process.
4. The Rehabilitation Plan does not address consequences of future development: The rehabilitation plan designates 43.5 hectares (nearly half the extraction site) for only temporary restoration, ultimately reserving this land for future development. The plan fails to address the long-term ecological consequences of permanently losing this land to development, as well as how future development could impact the rehabilitation progress of the wetlands and woodlands they claim they will restore. 

Given these significant deficiencies, we demand that:

1. No further action be taken on this expansion until these concerns are addressed.
2. The Rehabilitation Plan be amended to incorporate:
   1. A long-term monitoring and adaptive management plan for the recreated wetland feature.
   2. A clear strategy to address how invasive species will be carefully managed in the restoration process.
   3. Direct collaboration with scientific experts, conservation agencies or environmental organizations to ensure a successful restoration.
3. The city require a clear plan addressing the fate of the 43.5 hectares reserved for future development, including:
   1. An assessment of the ecological consequences of future development on this land.

The destruction of established, natural wetlands and significant woodlands in exchange for a poorly planned restoration is unacceptable. We urge the City of Ottawa to take these concerns seriously before proceeding with any further actions.

Sincerely, 

Maggie Hanna, Ecology Ottawa Youth Council

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