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Report To: Special Council
Date of Meeting: August 19, 2026 Report Number: PDS-078-26
Authored By: Darryl Lyons, Deputy CAO, Planning and Infrastructure
Submitted By: Darryl Lyons, Deputy CAO, Planning and Infrastructure
Reviewed By: Mary-Anne Dempster, CAO
By-law Number:
File Numbers:
Report Subject:
Resolution Number: C-237-26
COPA-2026-0004 (x-ref ZBA2022-0026, and SC-2022-0015)
Applications for an Official Plan Amendment, Zoning By-law
Amendment and Draft Plan of Subdivision to Remove a Wetland
Feature to Facilitate the Proposed Development within the Brookhill
Neighbourhood Secondary Plan Area
Recommendations:
1.That Report PDS-078-26, and any related delegations or communication items, be
received;
2.That the Official Plan Amendments attached to Report PDS-078-26, as Attachment
1 be approved; and,
3.That all interested parties and any delegations be advised of Council’s decision .
Municipality of Clarington Page 2
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Report Overview
d agreements to the Municipality’s
Clarington’s retained technical expert, Aquafor
Council’s
urrent wetland’s
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compensation study and Implementation plan to be completed. Once the future
Compensation Report and Implementation Plan is approved by the Deputy CAO, Planning
and Infrastructure with appropriate securities in place, only then can the subject wetland
feature be removed.
Municipality of Clarington Page 4
Report PDS-078-26
1. Application Details
1.1 Owner: Tribute Tercot Brookhill 2 Inc.
1.2 Applicant: Biglieri Group Ltd.
1.3 Proposal:
Clarington Official Plan Amendment
The Official Plan Amendment application proposes to introduce a site-specific
amendment for the removal of an identified natural heritage feature (wetland feature) in
order to facilitate the proposed development. It also introduces policies for natural
heritage feature removal and compensation which would be specific to this application.
Brookhill Neighbourhood Secondary Plan Amendment
The Brookhill Neighbourhood Secondary Plan Amendment proposes to amend the
Environmental Constraints Overlay by adding a site-specific policy which will allow for
the removal of a wetland feature if supported by an Environmental Impact Study. It also
introduces ecological compensation policies for consideration.
The applicant has also submitted applications for Zoning By-law 84-63 Amendment and
an application for Draft Plan of Subdivision for the subject lands. The Zoning By-law
amendment will be presented to Council for approval in the future and would be
informed by the decision on this Official Plan Amendment. The Plan of Subdivision
process is delegated to the Deputy CAO, Planning and Infrastructure for approval.
1.4 Area: 11.15 hectares (27.5 acres)
1.5 Location: 2499 Nash Road, 2538 and 2494 Bowmanville Avenue in Bowmanville (see
Figure 1)
1.6 Roll Numbers: 1817-010-030-00500, 1817-010-030-00600, 1817-010-030-00700
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Figure 1 – Proposed Residential Concept Plan
2. Background
History of Applications
2.1 On December 12, 2022, Tribute Tercot Brookhill 2 Inc. submitted applications for a draft
plan of subdivision and rezoning to permit the development of 285 residential units
consisting of singles, semis, street townhouse and stacked townhouses. The subject
lands are located within the Brookhill Neighbourhood Secondary Plan Area (Figure 1).
2.2 A public meeting was held on January 20, 2025, for the draft plan of subdivision and
rezoning applications.
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2.3 Through the review of the applications, Clarington Staff identified that the proposal did not
conform to the Clarington Official Plan which requires protection of wetland features
greater than 0.5ha in size. The submitted Environmental Impact Study identified a Red -
osier Dogwood Thicket Swamp Type community totaling 0.87 ha in size (SWT2-5
classification).
2.4 An Official Plan Amendment application was received for both the Clarington Official Plan
and Brookhill Neighbourhood Secondary Plan on February 10, 2026. A Public Meeting
was held on April 20, 2026, for the Official Plan Amendment application.
2.5 Tribute Tercot Brookhill 2 Inc. is also now proposing a secondary school on the lands in
the northeast corner of the development east of Street C and north of Street A.
2.6 Since the second Public Meeting, Staff have had several meetings with the applicant to
explore the technical review of the wetland, compensation plan criteria and discuss the
applicants’ proposed sites for the offsetting. On May 13, 2026, the applicant submitted a
Technical Memo and supporting Restoration Plan proposal for Staff and Central Lake
Ontario Conservation Authority (CLOCA) to review. Staff also obtained Aquafor Beech
Ltd. to peer review the supporting information and provide comments. A summary of the
peer review comments is provided in the discussion of this report.
3. Land Use Characteristics and Surrounding Uses
3.1 The subject lands are located on the west side of Bowmanville Avenue and south of Nash
Road in the Bowmanville Urban Area. The lands are currently vacant with identified
natural heritage features and portions of the site are also used for agricultural purposes.
The subject application comprises three parcels of land which have frontage on Nash
Road and Bowmanville Avenue; however, a segment of Nash Road is proposed to be
removed after Clarington Boulevard is extended north to Nash Road (Concession 3).
3.2 The surrounding uses are as follows:
North: Nash Road, a single detached dwelling and the Bowmanville Creek.
East: Bowmanville Avenue and vacant agricultural lands. Applications have been
submitted by Tribute Tercot Brookhill 1 Inc. for an Official Plan Amendment,
Zoning By-law Amendment, and Draft Plan of Subdivision for the lands east of
Bowmanville Avenue. The Official Plan and Zoning By-law Amendments have
been approved.
South: Single detached dwellings on large lots and agricultural lands. Longworth Avenue
is proposed to be extended from Bowmanville Avenue to Green Road.
West: Predominantly vacant agricultural lands proposed for redevelopment to
residential uses.
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4. Provincial Policy
Provincial Planning Statement (PPS 2024)
4.1 The Provincial Planning Statement, 2024 (PPS) encourages planning authorities to
create healthy, livable, and safe communities by accommodating an appropriate range
and mix of housing types, including affordable housing and shall promote development
patterns that efficiently use land and infrastructure.
4.2 The PPS policies direct growth to settlement areas and promote compact development
forms. The subject lands are located within the Bowmanville Urban Settlement boundary.
Planning authorities are to facilitate a variety of housing forms and promote resident ial
intensification to achieve efficient development patterns, especially along public transit
and active transportation routes.
4.3 Section 4.1 of the PPS directs that natural features and areas shall be protected for the
long term. Natural heritage features and areas is defined as:
“means features and areas, including significant wetlands, significant coastal wetlands,
other coastal wetlands in Ecoregions 5E, 6E and 7E, fish habitat, significant woodlands
and significant valleylands in Ecoregions 6E and 7E (excluding islands in Lake Huron and
the St. Marys River), habitat of endangered species and threatened species, significant
wildlife habitat, and significant areas of natural and scientific interest, which are important
for their environmental and social values as a legacy of the natural landscapes of an
area.
4.4 The PPS provides a higher standard of protection for provincially significant features and
enables municipalities to determine the appropriate level of protection for regionally
significant and local features such as the wetland subject to this application and as such,
a decision to enable compensation for this locally significant wetland feature is consistent
with the PPS.
4.5 Compensation frameworks have also been developed by other agencies such as Lake
Simcoe Region Conservation Authority and Aquafor Beech Ltd has provided staff with
guidelines and advice regarding what should be included in a compensation plan for this
matter. CLOCA has also advised that they would actively participate and support
development of the compensation plan.
5. Official Plans
Durham Region Official Plan (Envision Durham)
5.1 Envision Durham provides a long-term policy framework that is used to manage Durham
Region’s growth and development. The intent of Envision Durham is to manage
resources, direct growth and establish a basis for providing Regional services in an
efficient and effective manner.
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5.2 The Durham Region Official Plan (Envision Durham) designates the subject lands as
“Community Areas.” Community Areas are to be planned for a variety of housing types,
sizes, and tenures, including townhouse dwellings. These areas can also include
population-serving uses and shall be developed in a compact form through higher
densities and by intensifying and redeveloping existing areas.
5.3 Envision Durham has not identified the subject wetland as part of the mapped Major
Open Space System. Envision Durham policies rely of the local municipalities regarding
the Natural Heritage System. Similar to the Clarington Official Plan, Envision Durham
prohibits development within natural heritage features.
5.4 Since January 1, 2025 Envision Durham was deemed to be an Official Plan of Clarington
by the Minister. The Official Plan Amendment needs to amend Envision Durham, the
Clarington Official Plan and the Brookhill Neighbourhood Secondary Plan to introduce the
site-specific compensation approach. This duplication of policy writing will need to
continue until the Clarington’s Official Plan review process is complete and there is a
single Official Plan.
Municipality of Clarington Official Plan (COP)
5.5 The Clarington Official Plan designates the site Urban Residential and is within the
Bowmanville Urban Area. A variety of densities, tenure and housing types are
encouraged, generally up to six storeys in height along Local Corridors and up to three
storeys internal to neighbourhoods. Detached dwellings, semi-detached dwellings, and
townhouses are also permitted.
5.6 The subject wetland is not shown on Map D ‘Natural Heritage System’ of the Clarington
Official Plan however policy (3.4.3 and 3.4.12) requires their evaluation. Wetlands
included in the natural heritage system are at least 0.5 hectares in size as per the
wetland definition in the Clarington Official Plan. They also require a minimum 30 metre
vegetation buffer or minimum vegetation protection zone (MVPZ).
5.7 An Environmental Impact Study (EIS) was prepared by SLR Consulting Ltd. (formerly
Palmer), given the natural heritage features identified on the subject site. The EIS was
prepared to evaluate the significance of the features and demonstrate conformity with
Clarington’s Official Plan policies.
5.8 The Municipality retained Aquafor Beech Ltd (Aquafor) to conduct a peer review of the
EIS and Hydrological Report given that the identified environmental featu res on the
property are proposed to be removed. Through the review, it was determined that the
wetland community (SWT2-5), located on the southwest portion of the subject lands,
meets the definition of a wetland as per Clarington’s Official Plan. The propo sed
applications are not in conformity with the Clarington Official Plan and therefore a site -
specific Official Plan Amendment was submitted.
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Brookhill Neighbourhood Secondary Plan
5.9 Within the updated Brookhill Neighbourhood Secondary Plan (BNSP), the subject lands
are designated ‘Low Density Residential’, ‘Medium Density Residential’, and ‘Medium
Density Local Corridor’. A Parkette and elementary school symbol are also shown on
Land Use Schedule A, as well as an Environmental Constraint overlay. A trail is also
proposed to the north of the subject lands, on the south side of the Bowmanville Creek
valley.
5.10 Schedule A includes an Environmental Constraint overlay on the subject lands. The
associated policies within Section 11.9 of the BNSP state:
“The areas with an Environmental Constraints Overlay as shown on Schedule A have
been identified as having the potential for environmental significance and the underlying
designation cannot be achieved until an EIS has been prepared and the limits of the
NHS confirmed to the satisfaction of the Municipality and the Central Lake Ontario
Conservation Authority (CLOCA).
The presence and precise delineation of these features and areas and the level of
development acceptable shall be determined through an EIS prepared to the
satisfaction of the Municipality and the Central Lake Ontario Conservation Authority
(CLOCA), as jurisdictionally appropriate, as part of the review of deve lopment
applications in accordance with the policies of the Clarington Official Plan.
If the study establishes that development can proceed, then the underlying designation
shall apply over those lands. Further, it may be determined that only a portion o f the
lands within the Environmental overlay may be available for development.”
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Schedule A of the BHSP
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At the time of developing the Environmental Protection Area (EPA) designation, typically
through aerial interpretation and other sources of information available, the precise
limits of the features in this particular area where not known. The features appear to be
a patch which is fragmented from the greater natural heritage system and needed
further evaluation before determining if it should be included in the EPA designation.
Further study was required before development can proceed with the underlying
designations. A study was completed to evaluate such significance, and it was found
that the wetland feature meets the Clarington Official Plan definition of a wetland. The
policies in the BNSP indicate that the policies of the Clarington Official Plan are still
applicable should such feature meet the criteria for protection.
5.11 The applicant has proposed an Amendment to the Secondary Plan policies to enable
the removal of the wetland and introduce compensation policies within the Brookhill
Neighbourhood Secondary Plan for this specific site.
6. Public Notice and Submissions
6.1 Two Public Meetings were held for this development proposal. One on January 20,
2025, and one on April 20, 2026. The first public meeting was held for the proposed
Zoning By-law Amendment, and the second meeting was for the Official Plan
Amendment, which was submitted after the initial applications were made. Public
Notice was given in accordance with the Planning Act including being sent to the
interested parties.
6.2 Two public meeting signs were installed on the subject lands, fronting Bowmanville
Avenue and Nash Road. Details of the proposed application were also posted on the
Municipality’s website, and in the Clarington Connected e -newsletter.
6.3 As of writing this report, staff have received 20 public submissions concerning the
proposed development, four of which were related to the proposed natural heritage
removal, and three members of the public came out to express their concerns at the
Public Meetings. The following concerns have been raised regarding the proposed
development:
a) Transportation impacts including:
o Traffic Impact Study should look at all developments within the area
comprehensively;
o Traffic impacts with the realignment of Longworth Avenue;
o Concern with limited sight lines on Bowmanville Ave at the intersection of
Street A;
o Concerned with the Nash Road realignment.
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Environmental impacts including:
o Concern with removal of the NHS to allow for development;
o Concern with roads bisecting wetland features;
o Not supportive of wetland removal as there is a need to preserve our
sensitive environment and needs to be protected;
o Protection of wildlife and environmental features;
o Not supportive of compensation policies;
o Concerns with ground water impacts;
o Concerned with loss of habitat, especially for the wild turkeys.
b) Ensure pedestrian and cycle connections are provided along Bowmanville
Avenue and Longworth Avenue;
c) Erosion of Bowmanville’s small-town character and charm, as well as loss of
greenspace and farmland;
d) Impacts on local infrastructure and public services;
e) Concern with building communities with subdivision patterns that are neither
sustainable nor conducive to healthy and walkable; and
f) Potential well interference that could impact existing residents;
7. Department and Agency Comments
7.1 Various agencies and internal departments were circulated for comments on the
applications. Attachment 2 to this report is a chart which provides the list of circulated
parties. Of particular importance for this Official Plan Amendment are CLOCA’s
comments. A further discussion of CLOCA’s comments can be found in Section 9 of this
report.
8. Summary of Background Studies
8.1 The following studies have been submitted in support of the Official Plan Amendment,
zoning by-law amendment and draft plan of subdivision applications.
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Urban Design Brief, Biglieri Group, December 2022
Sustainability Report, GHD, December 2022
Functional Servicing and Stormwater Management Report, David Schaeffer
Engineering Ltd., December 2022
Landscape Analysis Brief, Biglieri Group, December 2022
Traffic Impact Study, TYLin, December 2022
Phase One Environmental Site Assessment (ESA), Soil Engineers Ltd.,
September 2021
Phase Two Environmental Site Assessment (ESA), Soil Engineers Ltd., October
2021, and
Stage 1 & 2 Archaeological Assessment, Parslow Heritage Consultancy Inc.,
November 2019.
Technical Memorandum (Compensation) SLR Consulting, May 13, 2026
Technical Memorandum (Hydrology) SLR Consulting, August 7, 2026
8.2 The following studies, of particular importance to the Official Plan Amendment (removal
of the wetland) are summarized as follows:
Planning Rationale Report, Biglieri Group, December 2022, revised February 2026 and
April 2026
8.3 The Planning Rationale Report submitted in December 2022 was prepared in support of
the applications for a Zoning By-law Amendment and Draft Plan of Subdivision to develop
approximately 11.15 hectares of agricultural land into a residential community.
8.4 The Rationale Report was revised in February 2026 and April 2026 to focus on the
proposed Official Plan Amendment to permit the removal and compensation of the
wetland feature identified on the subject lands. The report claims that the 0.69 ha SWT2-
5 wetland located on the subject lands (the full area of the feature is approximately 0.87
hectares) can be removed because it is isolated, has limited ecological and hydrological
function, and is not part of the identified Natural Heritage System.
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8.5 The report proposes a site-specific Official Plan Amendment allowing ecological
compensation and wetland replacement (minimum 1:1 ratio) and explains that retaining
the wetland would significantly affect the planned road network, including Clarington
Boulevard and internal collector roads, as well as reduce the development potential
envisioned by the Brookhill Secondary Plan. Overall, the 2026 report builds on the
planning rationale established in 2022 by providing the environmental, policy, and
compensation justification needed to facilitate development of the site as originally
proposed.
8.6 The April 2026 report was revised to include a site-specific Official Plan Amendment and
Secondary Plan Amendment and a site-specific compensation policy.
Environmental Impact Study, SLR (formerly Palmer), November 2022, Revised Sept 2025
8.7 The Environmental Impact Study (EIS) submitted in support of the proposal undertook a
field investigation of features on the subject lands. The features include a woodlot,
thickets and wetlands. The report recommends removal of all identified natural heritage
features on the subject lands given that no species at risk habitats were identified on the
site, although some species such as Barn Swallow, Eastern Meadowlark, and Snapping
Turtle were observed. The report concludes these features have limited ecological
function and are not part of the regional natural heritage system. With recommended
mitigation measures, including timing restrictions for vegetation removal, erosion controls,
wildlife protection measures, and wetland compensation at a minimum 1:1 ratio, the study
concludes that the proposed subdivision feasible, conforms to applicable policy
requirements, and is not expected to result in negative impacts on the natural
environment.
8.8 The report was updated in September 2025 to address comments peer review comments
from Aquafor (the Municipality’s Consultant) and Municipal Staff, which included
additional field work investigations, woodland reassessment, bat species at risk
investigations, and a detailed wetland compensation strategy.
Technical Memo SWT2-5 Wetland Creation and Restoration Plan for Brookhill West,
SLLR, May 13, 2026
8.9 The technical memorandum supports the proposed removal of the 0.87 ha SWT2 -5
wetland as part of the Brookhill West development and outlines a preliminary wetland
compensation strategy. The consultant concludes that the existing wetland is isolated,
provides limited ecological and hydrological functions, and would become further
degraded as surrounding development proceeds.
8.10 To achieve compensation, the proponent proposes creating and restoring approximately
1.46 ha of wetland habitat in two restoration areas adjacent to the Maple Grove Wetland
Complex, supported by approximately 0.75 ha of enhanced buffers, invasive species
management, native planting, habitat enhancements, and five years of monitoring. The ir
plan is based on a 3:1 compensation ratio and proposes that the remaining compensation
requirement (1.15 ha) be addressed through a cash -in-lieu payment.
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8.11 The memo acknowledges that further field investigations, wetland boundary staking,
ecological surveys, detailed design, and consultation with CLOCA and the Municipality
are required to verify existing conditions, confirm restoration opportunities and
compensation areas, and finalize the restoration plan and offsetting requirements.
Hydrogeological Assessment, Palmer, December 2022, revised July 2026
8.12 The Hydrogeological Report assessed the hydrogeological conditions for the proposed
residential development. The 2026 update includes groundwater level measurements
through September 2025 and confirms the overall groundwater flow direction toward
Bowmanville Creek. Construction dewatering assessment was added, and the report
concludes that an Environmental Activity and Sector Registry (EASR) registration will
likely be required due to the anticipated pumping rates.
8.13 The report also identifies 17 domestic wells within 500 m of the site and notes that five
wells are located near the site boundaries and are likely still in use given the rural setting.
Although the report concludes that no long-term impacts to private wells are expected
because recharge mitigation (LID measures) will be implemented and groundwater
impacts are anticipated to be low, it specifically recommends that prior to construction, a
water well survey should be completed and the five wells adjacent to the site should be
offered well monitoring.
8.14 The report notes that during field investigations the two wetlands at the south end of the
site did not contain persistent standing water and were interpreted as seasonally
inundated features rather than groundwater dependent wetlands.
9. Discussion
9.1 Wetland features are important because they provide a wide range of environmental
benefits, including groundwater recharge, flood control, water quality improvement,
habitat for wildlife, climate mitigation, and most importantly they deliver ecosystem
services that would be costly to replace through engineered solutions.
9.2 The removal of a wetland feature should only be considered once all other options have
been considered and only where equivalent or greater ecological functions are
demonstrated through compensation, restoration, or enhancement measures. Although
the applicant has submitted environmental studies and a proposed Restoration Plan,
further work is required to demonstrate a greater or equivalent, offset for the proposed
wetland loss.
Justification provided by Applicant in support of Removal of the Wetland Feature
9.3 The EISs and Hydrogeological Studies submitted for the subject lands claim that the
wetland proposed for removal is isolated, has limited ecological and hydrological function,
and does not support significant wildlife habitat, species at risk, amphibian breeding
habitat, or connectivity to the Natural Heritage System.
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9.4 Based on the above conclusion, the applicant has submitted a proposed Official Plan
Amendment to introduce site-specific policies to enable the removal of the wetland if
supported by the EIS. The proposed Official Plan Amendment also speaks to mitigation
measures, such as ecological compensation as a viable last-resort option to conserve
and enhance the natural heritage system. It then introduces Ecological Compensation
policies to be considered.
9.5 Among the introduced policies, is a suggested that Compensation Report and Plan be
provided, demonstrating how environmental impacts can be mitigated through the use of
best ecological offsetting practices, and any other practices or measures, to the
satisfaction of the Municipality and CLOCA. This would include:
Ensure no net loss of ecological function
Strengthen the broader environment by enhancement of the system
Provide compensation that is acceptable to the Municipality and Conservation
Authority, using recognized ecological offsetting approaches such as restoration,
naturalization, enhancement, replacement, or cash -in-lieu, in accordance with
approved compensation criteria.
Peer Review Response
9.6 Aquafor has completed a peer review of the Environmental Impact Study for 2400 Nash
Road and 2538 and 2494 Regional Road 47, Municipality of Clarington (Palmer, 2022),
the Restoration Plan as well as Technical Memorandum titled "Opinion on Wetland
Ecological, Hydrogeological and Recharge Function" (dated August 7, 2026), prepared
by SLR Consulting (Canada) Ltd. (SLR).
9.7 In their August 13, 2026, memorandum to staff (See Attachment 3) Aquafor concurs with
SLR’s hydrogeological assessment that wetland “SWT2-5” does not perform significant
groundwater recharge nor groundwater discharge functions with the local or regional
groundwater system, nor does it appear to have direct surface water connection(s) to
local surface water features.
9.8 From an ecological perspective, Aquafor agrees that the “SWT2-5” wetland is not unique
in terms of observed flora and fauna, although it does provide some value to generalist
wildlife, and may also be considered SAR bat maternity roost habitat (habitat of an
endangered species, protected under the NHS designation).
9.9 Aquafor has also indicated that they generally agree with the applicants EIS that if the
wetland is retained, including a 30m buffer, but surrounded by development it will
eventually result in degradation.
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9.10 As outlined in their peer review, is Aquafor’s professional opinion that
“Wetland removal and compensation should generally be considered only as a last resort
on a site-specific basis through detailed technical analysis indicating an opportunity for an
ecological net gain. However, Aquafor also acknowledges that the “SWT2 -5” wetland is a
common wetland form that has a reasonable chance of successful replication if done
correctly, and that a unique situation exists in this circumstance in which compensation of
the wetland elsewhere could be overall beneficial to the local ecosystem, provided
stormwater management at the Nash Road property can be effectively compensate for
lost hydrologic function within the proposed development site, and the offsite wetland
compensation can demonstrate a net gain to the system in terms of ecological form and
function.”
9.11 As outlined in the memorandum, Aquafor recommends that additional work be
completed in support of the detailed design for wetland compensation including
characterization of the hydrologic characteristics of the wetland, determination of
appropriately sized buffers and additional amphibian and b ird surveys.
Agency response
9.12 CLOCA staff have reviewed the application and have provided comments that in
principle, support the proposed removal and compensation for th is wetland.
9.13 CLOCA Natural Heritage Staff concur with SLR and Aquafor that the long-term isolation
of the retained wetland feature following the proposed development is not desirable and
therefor removal and compensation for the wetland feature may be appropriate.
9.14 In addition, CLOCA staff concur with SLR and Aquafor that additional environmental
investigations will be needed with respect to the development of the restoration plan.
Staff response
9.15 Staff have reviewed this application for an Official Plan Amendment to permit the removal
of wetland on the subject lands and have considered the expert opinions of the applicants
Consultants, the Municipality’s peer reviewer, Aquafor and CLOCA and concur that
removal of the wetland and compensation that includes a net gain elsewhere in the
Bowmanville Creek watershed is supportable.
9.16 Attachment 1 contains the recommended Official Plan Amendment in support of the
application.
9.17 The recommended Official Plan Amendment, like the applicant’s proposal, has included
the requirement for mitigation using best ecological offsetting practices and a
Compensation Report. However, as noted previously in this report, further environmental
investigations shall be completed and included as appropriate, in the Compensation
Report and Implementation Plan prior to approval of same.
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9.18 Staff have also included a policy to require a net gain to the Bowmanville Creek
Watershed Natural Heritage System both in terms of feature size (3:1) and functions. As
provided for in our newer Secondary Plans, unauthorized removal of features must be
compensated for at a ratio of 3:1. It stands to reason that authorized removals should
also require this level of net gain.
9.19 The recommended policies also provide that any compensation requirements, including
financial securities, outlined in the Compensation Report and Implementation Plan shall
be included as conditions of any future zoning by-law amendment and/or draft plan of
subdivision approvals for the subject lands. Including this policy is intended to safeguard
that the compensation requirements are implemented.
10. Financial Considerations
10.1 Not Applicable
11. Strategic Plan
11.1 The recommendations in this report are generally in keeping with Clarington’s Strategic
Plan.
11.2 As opined in the applicant’s EIS, and supported by Clarington’s peer reviewer and
CLOCA, retaining the existing wetland in situ but surrounded by future development, will
eventually degrade the wetland. The recommended approach will provide for
compensation and a net gain to the Bowmanville Creek watershed natural heritage
system. G.4.3 of the Strategic Plan states Protect and enhance Clarington’s natural
heritage. Although the recommended approach enables removal of a local feature of
limited ecological value and no ground water connection, the recommended policy would
enable enhancement (net gain) to the NHS.
12. Climate Change
12.1 This report supports Clarington's climate change objectives by recognizing the important
role wetlands have to the climate. Wetlands help store and sequester carbon, reduce
flood risks by retaining and slowly releasing stormwater, improve water quality, support
groundwater recharge, and increase the resilience of natural and urban systems to more
frequent extreme weather events associated with climate cha nge. Although this wetland
will not be protected in situ, the compensating wetland will provide the climate change
benefits as described.
13. Concurrence
13.1 Not Applicable.
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14. Conclusion
14.1 Staff have evaluated the proposed application by Tribute Tercot Brookhill 2 Inc. to
amend the Clarington Official Plan and the Brookhill Neighbourhood Secondary Plan to
permit the removal of wetland on the subject lands and have considered the expert
opinions of the applicants Consultants, the Municipality’s peer reviewer, Aquafor Beech
and CLOCA and concur that removal of the wetland and compensation that includes a
net gain elsewhere in the Bowmanville Creek watershed is supported in this site specific
instance and recommend the Official Plan Amendment contained in Attachment 1.
Staff Contact: Thom Hunt, Director of Planning, THunt@clarington.net or Darryl Lyons, DCAO,
Planning and Infrastructure, dlyons@clarington.net
Attachments:
Attachment 1 – Recommended Official Plan Amendments
Attachment 2 – Agency and Department Comments
Attachment 3 – Peer Review Memorandum, Aquafor Beech
Interested Parties:
List of Interested Parties available from Department.
Attachment 1 to Report PDS-078-26
The Corporation of the Municipality of Clarington
Official Plan Amendment Number 156 to the
Clarington Official Plan
Purpose: The purpose of this amendment is to amend the Brookhill Neighbourhood
Secondary Plan to include a policy to allow for the removal of a 0.69-hectare wetland and
to require compensation to be provided to mitigate the removal of a natural heritage
feature.
Location: The Subject Lands are municipally addressed as 2494 and 2538 Regional Road
57 (Bowmanville Avenue), and 2499 Nash Road. These are legally described as Part Lot 15,
Concession 2, Former Township of Darlington, Parts 1, 2 & 3 on Reference Plan 40R29634,
now in the Municipality of Clarington. The Subject lands are located directly
west/southwest of the intersection between Bowmanville Avenue and Nash Road, north of
the Future Longworth Avenue extension and realignment, and have a total area of 11.15
hectares. The subject wetland is generally located north of Longworth Avenue and east of
Clarington Boulevard and as depicted with the Environmental Constraint overlay on
Schedule A Land Use, Transportation, Parks and Open Space to the Brookhill
Neighbourhood Secondary Plan.
Basis: This Amendment is based on an application and supporting studies prepared on
behalf of the owner Tribute Turcot Brookhill 2 Inc. in support of the application which may,
following a future development application approval, facilitate future development. The
following Studies have been submitted in support of the application:
• Urban Design Brief, Biglieri Group, December 2022
• Sustainability Report, GHD, December 2022
• Functional Servicing and Stormwater Management Report, David Schaeffer
Engineering Ltd., December 2022
• Landscape Analysis Brief, Biglieri Group, December 2022
• Traffic Impact Study, TYLin, December 2022
• Phase One Environmental Site Assessment (ESA), Soil Engineers Ltd., September
2021
• Phase Two Environmental Site Assessment (ESA), Soil Engineers Ltd., October 2021,
and
• Stage 1 & 2 Archaeological Assessment, Parslow Heritage Consultancy Inc.,
November 2019.
• Planning Rationale Report, Biglieri Group, December 2022, revised February 2026
and April 2026
The following studies have also been submitted in support of the Official Plan Amendment
and have been peer reviewed by the Municipality’s consultant:
• Environmental Impact Study, SLR (formerly Palmer), November 2022, Revised Sept
2025
• Technical Memo SWT2-5 Wetland Creation and Restoration Plan for Brookhill West,
SLR, May 13, 2026
• Technical Memorandum titled Opinion on Wetland Ecological, Hydrogeological and
Recharge Function, dated August 7, 2026, prepared by SLR Consulting on behalf of
Tribute Tercot Brookhill 2 Inc.
• Hydrogeological Assessment, Palmer, December 2022, revised July 2026.
Actual Amendment: The Brookhill Neighbourhood Secondary Plan is hereby amended as
follows:
1. A new Section 13.3 Exceptions and subsections are added as follows:
“13.3 Exceptions
13.3.1 Notwithstanding any other provision of this Plan, a wetland with a size greater than
0.5 hectares located on those lands municipally addressed as 2494 and 2538 Bowmanville
Avenue and 2499 Nash Road ( Assessment Roll Numbers 181701003000500,
181701003000600, and 181701003000700) may be removed subject to the
recommendations of the Environmental Impact Study (Environmental Impact Study, SLR
(formerly Palmer), November 2022, Revised Sept 2025) and an acceptable Compensation
Report and Implementation Plan that has been approved by the Deputy CAO Planning and
Infrastructure.
a. The Compensation Report and Implement Plan shall demonstrate how the removal of
the wetland will be mitigated using best ecological offsetting practices, and any other
practices or measures, to the satisfaction of the Municipality.
b. The Compensation Report and Implement Plan shall provide a net gain to the
Bowmanville Creek Watershed Natural Heritage System in terms of both features size (3:1)
and functions,
c. The additional environmental investigations as outlined in the Peer Review Memo
prepared by Aquafor Beech, Review of Technical Memorandum titled “Opinion on Wetland
Ecological, Hydrogeological and Recharge Function, in Support of the Removal of the Nash
Road SWT2-5 Wetland Feature (SLR, August 7, 2026) shall be completed and included as
appropriate in the Compensation Report and Implementation Plan prior to the approval of
the Compensation Report and Implementation Plan to the Municipality’s satisfaction, and
d. The compensation requirements as described in the approved Compensation Report
and Implementation Plan, including any financial securities, shall be included as a
condition of a future zoning by-law amendment and/or draft plan of subdivision approvals
for the subject lands.”
Implementation: The provisions set forth in the Municipality of Clarington Official Plan
regarding the implementation of the Plan, shall apply in regard to this amendment.
Interpretation: The provisions set forth in the Municipality of Clarington Official Plan
regarding the interpretation of the Plan, shall apply in regard to this amendment.
Amendment Number 4 to the
Durham Region Official Plan
Purpose: The purpose of this amendment is to amend the Durham Region Official Pan to
include a site specific policy to allow for the removal of a 0.69 hectare wetland and to
require compensation to be provided to mitigate the removal of a natural heritage feature.
Location: The Subject Lands are municipally addressed as 2494 and 2538 Regional Road
57 (Bowmanville Avenue), and 2499 Nash Road. These are legally described as Part Lot 15,
Concession 2, Former Township of Darlington, Parts 1, 2 & 3 on Reference Plan 40R29634,
now in the Municipality of Clarington. The Subject lands are located directly
west/southwest of the intersection between Bowmanville Avenue and Nash Road, north of
the Future Longworth Avenue extension and realignment, and have a total area of 11.15
hectares. The subject wetland is generally located north of Longworth Avenue and east of
Clarington Boulevard and as depicted with the Environmental Constraint overlay on
Schedule A Land Use, Transportation, Parks and Open Space to the Brookhill
Neighbourhood Secondary Plan.
Basis: This Amendment is based on an application and supporting studies prepared on
behalf of the owner Tribute Turcot Brookhill 2 Inc. in support of the application which may,
following a future development application approval, facilitate future development. The
following Studies have been submitted in support of the application:
• Urban Design Brief, Biglieri Group, December 2022
• Sustainability Report, GHD, December 2022
• Functional Servicing and Stormwater Management Report, David Schaeffer
Engineering Ltd., December 2022
• Landscape Analysis Brief, Biglieri Group, December 2022
• Traffic Impact Study, TYLin, December 2022
• Phase One Environmental Site Assessment (ESA), Soil Engineers Ltd., September
2021
• Phase Two Environmental Site Assessment (ESA), Soil Engineers Ltd., October 2021
• Stage 1 & 2 Archaeological Assessment, Parslow Heritage Consultancy Inc.,
November 2019
• Planning Rationale Report, Biglieri Group, December 2022, revised February 2026
and April 2026
The following studies have also been submitted in support of the Official Plan Amendment
and have been peer reviewed by the Municipality’s consultant:
• Environmental Impact Study, SLR (formerly Palmer), November 2022, Revised Sept
2025
• Technical Memo SWT2-5 Wetland Creation and Restoration Plan for Brookhill West,
SLR, May 13, 2026
• Technical Memorandum titled Opinion on Wetland Ecological, Hydrogeological and
Recharge Function, dated August 7, 2026, prepared by SLR Consulting on behalf of
Tribute Tercot Brookhill 2 Inc.
• Hydrogeological Assessment, Palmer, December 2022, revised July 2026.
Actual Amendment: The Durham Region Official Plan is hereby amended as follows:
1. A new subsection 10.3.4 is added to Section 10.3 Vibrant Urban System as follows:
“10.3.4 Notwithstanding any other provision of this Plan, a wetland with a size greater than
0.5 hectares located on lands municipally addressed as 2494 and 2538 Bowmanville
Avenue and 2499 Nash Road ( Assessment Roll Numbers 181701003000500,
181701003000600, and 181701003000700) may be removed subject to the
recommendations of the Environmental Impact Study (Environmental Impact Study, SLR
(formerly Palmer), November 2022, Revised Sept 2025) and an acceptable Compensation
Report and Implementation Plan that has been approved by the Deputy CAO Planning and
Infrastructure.
a. The Compensation Report and Implement Plan shall demonstrate how the removal of
the wetland will be mitigated using best ecological offsetting practices, and any other
practices or measures, to the satisfaction of the Municipality.
b. The Compensation Report and Implement Plan shall provide a net gain to the
Bowmanville Creek Watershed Natural Heritage System in terms of both features size (3:1)
and functions,
c. The additional environmental investigations as outlined in the Peer Review Memo
prepared by Aquafor Beech, Review of Technical Memorandum titled “Opinion on Wetland
Ecological, Hydrogeological and Recharge Function, in Support of the Removal of the Nash
Road SWT2-5 Wetland Feature (SLR, August 7, 2026) shall be completed and included as
appropriate in the Compensation Report and Implementation Plan prior to the approval of
the Compensation Report and Implementation Plan to the Municipality’s satisfaction, and
d. The compensation requirements as described in the approved Compensation Report
and Implementation Plan, including any financial securities, shall be included as a
condition of a future zoning by-law amendment and/or draft plan of subdivision approvals
for the subject lands.”
Implementation: The provisions set forth in the Durham Region Official Plan regarding the
implementation of the Plan, shall apply in regard to this amendment.
Interpretation: The provisions set forth in the Durham Region Official Plan regarding the
interpretation of the Plan, shall apply in regard to this amendment.
Attachment 2 to Report PDS-078-26
Attachment 4 – Agency and Department Comments
The following agencies and internal departments were circulated for comments on the
applications. Comments were due April 21, 2026 for the Clarington Official Plan
Amendment (COPA) submission. Below is a chart showing the list of circulated parties
and whether or not we have received comments to date.
Department/Agency Comments
Received
Summary of Comment
☒
☒
☒
Department/Agency Comments
Received
Summary of Comment
Notwithstanding the above, CLOCA Natural
Heritage staff concur with SLR and Aquafor
Beach that the long-term isolation of the
retained wetland feature(s) following the
proposed development is not desirable from
either a natural hazard perspective.
Accordingly, compensation for the affected
wetland feature(s) may be appropriate. At this
time, CLOCA Natural Heritage staff have no
concerns with the proposed restoration
location. However, consistent with the
conclusions presented in Section 2.3 of the
technical memorandum, additional
investigation will be required to confirm the
site's suitability for wetland restoration and
long-term success.
On the Hydrological report the MW21-1,
MW21-2, and MW21-4 were instrumented
with Solinst data loggers for continuous
groundwater level monitoring on January 22,
2021. CLOCA has not yet received the
technical memorandum presenting and
discussing the results of the monitoring
activities.
Clarington Staff note that at the time of writing
this report, an updated Hydrological Report
was received and circulated to CLOCA for
review. No comments have been received to
date.
The available subsurface information supports
the findings presented in Palmer’s EIS report
(2022) that the Willow Mineral Deciduous
Swamp (SWD4-1) and Red-Osier Mineral
Dogwood Thicket Swamp (SWT2-5) located
within the property are predominantly surface
water fed. These features do not contain
persistent standing water and are only
seasonally inundated. An increase in
impervious surfaces within the property could
adversely affect the long-term sustainability of
the on-site wetlands.
Department/Agency Comments
Received
Summary of Comment
Subject to confirmation by CLOCA and
Municipality of Clarington ecologists that the
subject wetlands do not meet the criteria for
regulated features, Staff have no objection to
their removal and relocation elsewhere,
provided that proposed compensation plan
and design are acceptable to relevant
authorities.
Kawartha Pine Ridge
District School Board
and Peterborough,
Victoria,
Northumberland,
Clarington Catholic
District School Board
☒ KPRDSB requested that the school site be
moved/adjusted so it is within one
development phase, instead of the current
proposal across two different property
owners.
They also stated that due to the uncertainty
related to an Environmental Constraint
overlay that establishes an area where further
study is required before development can
proceed, the approval of this application is
premature.
French Public Board:
Conseil Scolaire
Viamonde
☐ No comments.
French Catholic Board:
Conseil Scolaire
Catholique Mon Avenir
☐ No comments.
Clarington Engineering
Development Division
☒ No objection to the proposal.
.
Clarington Emergency
and Fire Services
☒ No objection to the proposal.
Clarington Building
Division
☒ No objection to the proposal.
Enbridge Gas ☒ No objection to the proposal.
Hydro One ☒ No objection to the proposal.
Bell ☐ No comments.
Rogers Cable ☒ No objection to the proposal.
Canada Post ☒ Canada Post has no objection. Canada Post
will provide mail delivery service to this
development through Community Mailboxes.
The location of the community mailboxes will
be determined at the detailed design stage of
the subdivision application.
August 13, 2026
Attn. Nicole Zambri, MCIP, RPP
Senior Planner, Planning and Infrastructure Services Department
Municipality of Clarington
40 Temperance Street
Bowmanville, ON L1C 3A6
Re: Review of Technical Memorandum titled "Opinion on Wetland Ecological,
Hydrogeological and Recharge Function, in Support of the Removal of the Nash Road
SWT2-5 Wetland Feature (SLR, 2026)
Aquafor Ref: 67700
Aquafor Beech Ltd. (Aquafor) has been retained by the Municipality of Clarington to provided
services for the review of the Environmental Impact Study for 2400 Nash Road and 2538 and
2494 Regional Road 47, Municipality of Clarington (Palmer, 2022). This has included a feasibility
analysis for the possibility of wetland compensation for the removal of “SWT2-5” at the Maple
Grove Wetland Complex, and most recently, a review of the Hydrogeological Investigation
Report (SLR, 2026) and associated documents.
Most recently, Aquafor has reviewed the Technical Memorandum titled "Opinion on Wetland
Ecological, Hydrogeological and Recharge Function" (dated August 7, 2026), prepared by SLR
Consulting (Canada) Ltd. (SLR) on behalf of Tribute Tercot Brookhill 2 Inc.
It is understood that this memo was written to provide local hydrogeological context of the
“SWT2-5” wetland in response to a request by Central Lake Ontario Conservation Authority
(CLOCA). Specifically, CLOCA requested confirmation on whether the "SWT2-5" wetland
performs a significant groundwater recharge function or a direct hydraulic connection that
would classify it as a hydrogeologically regulated feature under regional planning framework.
The SLR memorandum summarizes the physical, ecological, and hydrogeological
characteristics of the wetland, relying on multi-year ecological field surveys (2016–2025), site
borehole logs (2021), in-situ hydraulic testing, and continuous groundwater level monitoring
data (June 2020 through December 2025).
SUMMARY OF HYDROGEOLOGICAL FINDINGS
Based on our review, SLR’s memorandum provides a reasonable characterization of the local
hydrogeological regime. Key findings regarding the value of “SWT2-5” to the site and the
broader Bowmanville Creek subwatershed include:
Attachment 3 to Report PDS-078-26
August 13, 2026
1) Surface Water Connections: Based on the information provided, the wetland appears
to be hydrologically isolated and sustained by direct precipitation and localized surface
runoff accumulating in a shallow topographic depression. The contributing catchment
area, though not delineated or quantified, appears to be small and not extend much
beyond the subject property.
2) Groundwater Discharge into the Wetland: The standing water within the wetland
during seasonal wet periods does not include contributions from groundwater
discharge as the local groundwater level has been shown to remain at least 0.5 m
below ground (spring 2022) and more typically approximately 1 m below ground
(spring of 2021, 2023, 2024, and 2025) during annual high periods.
3) Groundwater Recharge from the Wetland: Hydraulic testing of the Sandy Silt Till and
Sand and Silt Till layer underlying the “SWT2-5” are noted as being relatively low-
permeability glacial till deposits indicating that the wetland feature is not associated
with significant groundwater recharge. The previous site specific Hydrogeological
Investigation Report (SLR, July 2026) further identifies soils more conducive to
infiltration further east on the subject site, outside of the wetland area.
The above findings characterize the “SWT2-5” wetland as not having a direct hydrologic
(surface water connection) to downstream surface water features and not performing any
significant role in groundwater discharge or groundwater recharge within the Bowma nville
Creek Subwatershed.
HYDROLOGIC SENSITIVITY & DEVELOPMENT IMPACTS
Surface water-fed isolated depressional wetlands like “SWT2-5” are extremely sensitive to
land use changes within their contributing catchment because they rely almost entirely on
direct precipitation and localized overland flow rather than a reliable groundwater baseflow.
While surface water contributions would need to be maintained to support the wetland,
changes to inflow volumes, flow rates, and water quality would impact the overall
productivity of the wetland. As such, the proposed development of upland areas within the
catchment is expected to impact seasonal inundation (hydroperiod), response to rainfall
events, and long-term water quality. This impact has not been quantified but it is expected to
be significant. Upstream stormwater controls (including LIDs) and standard 30 m buffers can
mitigate but not eliminate the impact of development on this type of wetland.
ADDITIONAL ECOLOGICAL CONTEXT
Throughout the various iterations of the Nash Road EIS, and in a statement made in the 2026
Hydrology Memo, SLR is of the opinion that “detailed ecological investigations completed
August 13, 2026
between 2016 and 2025 concluded that the “SWT2-5” feature provides relatively limited
ecological functions”. Aquafor notes the following.
From an ecological perspective, Aquafor considers the surveys done as part of the 2022 and
2025 EIS iterations to be sufficient in determining the habitat across the site. Per the 2025 EIS,
there are no amphibian breeding stations directly in the wetland (the next closest is targeting
the “SWD4-1” community), and breeding bird surveys were conducted using a roving area
method across the subject lands. While not specific to the “SWT2-5” wetland, and with the
understanding that species occupancy can vary year to year, information regarding these
wildlife categories have been captured during the course of the field investigations. It should
also be noted that specific to amphibians, SLR noted a lack of standing water in the “SWT2-5”
during survey events, which would exclude amphibians from breeding in this feature,
particularly in the later, drier months. However, if additional information is desired for the
wetland in particular, both amphibian call survey and breeding birds survey points could be
stationed directly in the wetland, which would target key wildlife species specific to the
“SWT2-5” wetland.
Aquafor also notes that migratory bats (Eastern Red, Hoary Bat, and Silver-haired Bat) were
listed as Endangered in 2025 under the repealed Endangered Species Act, and remain
protected under the Species Conservation Act (in force as of March 2026). While no formal
survey protocol exists for the newly listed bats, Aquafor has been made aware of instruction
from the MECP regarding habitat to include live or dead trees >10 cm in DBH, as well as those
exhibiting exfoliating bark, cracks, knots, holes, and cavities, and shrubs >1 m in height, as
these may provide roosting habitat for SAR bats. This aligns with habitat guidance published
by COSEWIC for these species.
Habitat for SAR bats should be considered in the context of the wetland (and other wooded
areas generally, including any community codes of FOD, SWD, CUW, SWT or CUT), as these
features may now be considered habitat of Endangered Species, as supported by t he
documented presence of Endangered Eastern Red Bat, Hoary Bat, and Silver -haired Bat
(confirmed through 2025 acoustic monitoring) in the study area. Specific to the “SWT2-5”
wetland, dense native shrub vegetation is valuable for Eastern Red Bat in particular, which is
known to prefer dense foliage, and may roost close to the ground. This habitat is protected
under both the Species Conservation Act, as well as under the Municipality’s Official Plan as
part of the Natural Heritage System (Natural Heritage Features category – habitat of
endangered and threatened species). Per provincial legislation, destruction of endangered or
threatened species habitat may go forward, but must follow correct procedure under the
SCA. It is otherwise at the discretion of the municipality as to whether removal of parts of the
NHS is permitted on a case-by-case basis. In the instance that wetland removal and
compensation goes forward, shrub and tree plantings as part of that compensation can be
expected to provide replacement habitat for these species.
August 13, 2026
ROLE OF BUFFERS IN WETLAND IMPACT AND PRESERVATION
Throughout the course of this Peer Review exercise, Tribute/SLR has maintained that despite
the application of a 30 m buffer to the feature, development surrounding the “SWT2-5”
wetland (if retained) will eventually result in its degradation. Aquafor generally agrees with
this statement from an ecological and hydrological perspective, and this has been used by
Tribute/SLR as one of the primary justifications for its removal, with proposed wetland
compensation elsewhere as a means of offsetting the loss.
It is worth noting that removal of a wetland feature in favour of compensation elsewhere
should not be considered the only solution to the issue of wetland degradation. Should
development be expected to result in negative impacts to the wetland, and all parties
generally agree that stormwater management strategies cannot adequately address this, then
this indicates that the minimum 30 m buffer prescribed in the Official Plan is insufficient to
protect the wetland. As such, a formal review of general wetland buffer policies considering
the feasibility of more technically-based, site-specific buffers may be a worthwhile future
environmental planning initiative.
RECCOMENDATIONS FOR FURTHER CHARACTERIZATION
While the August 7th memo provides a characterization of the wetland from a hydrogeologic
perspective, additional characterization is recommended to holistically understand the
relationship between local wetland hydrology and the supported ecological system. Aquafor
recommends that the Municipality of Clarington request the following additional
characterizations to holistically support site development planning, stormwater management
LID design, and off-site wetland compensation design:
a) Characterization of the hydrologic characteristics of the wetland is limited. The
following should be considered for further hydrologic characterization:
• Through Ontario GeoHub, LiDAR data is available at a greater vertical accuracy
than the 1.0 m contours provided in the memo. These data can be used to further
verify hydrologic isolation from downstream surface water features as currently
determined via wetland perimeter staking.
• Catchment area delineation should be undertaken to understand the extents of
drainage area contributing to the “SWT2-5” wetland. LiDAR data available through
Ontario GeoHub may be useful for this delineation.
• The seasonal hydroperiod associated with the “SWT2-5” wetland has not been
well established. Surface water loggers in shallow monitoring wells or drive-point
piezometers within the deepest portion of the wetland basin equipped with
August 13, 2026
automated pressure transducers can help understand the seasonal hydroperiod
and capture flash responses to precipitation and gradual recessions.
• Wetland feature specific water balance should be undertaken to quantify key
hydrologic parameters within the wetland on a seasonal or annual basis. Any
analysis of this nature should consider inflows from the surrounding catchment.
b) As SLR maintains that impacts to the “SWT2-5” wetland (if retained) cannot be
avoided with the current proposed development design, the application of an
increased wetland buffer (e.g. >30 m wide) should be explored as part of design
alternatives to determine if these effects can be adequately mitigated.
c) Surveys completed by SLR throughout the course of the EIS are generally thought to
be sufficient to characterize the site. If desired however, additional Wildlife Surveys
could be considered that are targeted specifically to the “SWT2-5” habitat feature.
These include:
• Additional amphibian surveys - an amphibian survey point directly within the
wetland, although Aquafor notes that standing water has not been documented in
this feature, and therefore, the likelihood of amphibian breeding in this wetland is
low.
• Additional Breeding Bird Surveys – rather than a roving area method utilized
during previous field investigations, a targeted breeding bird survey point could
be located in the wetland feature. This would dedicate a full 10-minute window
over two survey events to documenting bird breeding evidence directly in the
wetland, and supplement existing bird data on the site generally. Considering the
small size and conditions of the wetland however, it is unlikely that additional
surveys will record any area sensitive swamp thicket species that have not already
been documented on the site generally.
d) Habitat on the site generally (inclusive of the “SWT2-5” wetland) should be re-
evaluated in terms of its value for SAR bats. While formal survey guidelines for newly
listed migratory bats have not been published to date, industry standard now
considers all woody vegetation as having maternity roosting potential , supported by
COSEWIC habitat guidance. Implications of this project on SAR bat habitat should be
reviewed accordingly.
August 13, 2026
CLOSING STATEMENT S
Aquafor concurs with SLR’s hydrogeological assessment that wetland “SWT2-5” does not
perform significant groundwater recharge nor groundwater discharge functions with the local
or regional groundwater system, nor does it appear to have direct surface water
connection(s) to local surface water features. Aquafor acknowledges that with the minimum
30 m buffer, it is likely that ecological form and function will degrade in the wetland, once
encapsulated by development especially given the expected imperviousness within the small
contributing catchment area.
To ensure the municipal and conservation authority objectives are fully met, we recommend
that the applicant address the recommended surface water characterizations of “SWT2-5”
(LiDAR catchment delineation, hydroperiod assessment, and feature water balance) as part of
the detailed design for off-site wetland compensation and site-wide stormwater
management. We remain available to discuss these comments with municipal staff and
CLOCA as needed.
From an ecological perspective, Aquafor agrees that the “SWT2-5” wetland is not unique in
terms of observed flora and fauna, although it does provide some value to generalist wildlife,
and may also be considered SAR bat maternity roost habitat (habitat of an endangered
species, protected under the NHS designation). Additional surveys targeting amphibians and
birds directly in the wetland may supplement existing data, but based on the habitat
described by SLR, are unlikely to document additional sensitive wildlife that would trigger
protection above and beyond what is already known for this feature.
As discussed in various Aquafor memos, and throughout several meeting discussions between
Aquafor, Clarington, Tribute and SLR, successful wetland compensation is difficult to achieve ,
with a documented history of low success. Wetland removal and compensation should
generally be considered only as a last resort on a site-specific basis through detailed technical
analysis indicating an opportunity for an ecological net gain. However, Aquafor also
acknowledges that the “SWT2-5” wetland is a common wetland form that has a reasonable
chance of successful replication if done correctly, and that a unique situation exists in this
circumstance in which compensation of the wetland elsewhere could be overall beneficial to
the local ecosystem, provided stormwater management at the Nash Road property can be
effectively compensate for lost hydrologic function within the proposed development site,
and the offsite wetland compensation can demonstrate a net gain to the system in terms of
ecological form and function. Aquafor agrees with CLOCAs assessment that a 3:1 wetland
compensation properly sited and designed with consideration for sustainable ecological and
hydrologic principles offers an opportunity to enhance and expand the existing NHS, and may
be the preferred option in this specific case, provided it takes place outside of the limits of the
existing NHS. This should not be considered a general rule for all situations however, as each
wetland is unique and are generally understood to be best retained in place.
August 13, 2026
Given the unique planning framework associated with this site, the reproducible/common
wetland form, relatively low-value of the wetland recharge/discharge regime to the regional
groundwater system, and observed lack of surface water connections to local surface water
features, Aquafor agrees that removal and compensation can be considered a viable strategy
for “SWT2-5”. To support this strategy, additional wetland characterization of “SW T2-5” is
needed to ensure compensation can replicate and enhance lost ecological value and
development-level stormwater controls can mimic pre-development water balance to the
greatest extent possible. Projects across the municipality should be evaluated on a case-by-
case basis going forward, and should not look to this development as a precedent by which to
allow wetland removal in favour of development.
Sincerely,
AQUAFOR BEECH LIMITED
Peter Hebert, B.Eng.
Water Resources Coordinator
P: (226) 343-0646
E: hebert.p@aquaforbeech.com
Natalie Doerr, B.Sc.
Senior Terrestrial Ecologist
P: (519) 362-1527
E: Doerr.n@aquaforbeech.com