RE: Waterloo Airport Runway Project Métis Nation of Ontario Region 9 Consultation Committee Planning Phase Comments

Thank you for the information that was provided in the meeting with Region 9 Consultation Committee (R9CC) on March 24, 2021.  The objective of that meeting was to provide information to the R9CC regarding the Impact Assessment Agency of Canada’s (IAAC), impact assessment process and to discuss the R9CC’s concerns over the proposed expansion of the Waterloo International Airport.  The R9CC had provided an initial written letter outlining questions and concerns to the Waterloo International Airport (Waterloo) late in 2020 with a response received back from Waterloo on December 23, 2020.  While the R9CC appreciates the information provided in both examples, and understands that the IAAC is early in the assessment process, the following are a list of outstanding concerns and comments with respect to the proposed project and IAAC process.

As presented during the meeting on March 29^th, the wetland will be both ‘removed’ and ‘altered’ to accommodate the expansion of the runways to the northwest of the airport.  With this, there remain concerns over the impact and loss of the wetland complex.   As stated in the response table in the presentation, impacts will be mitigated with the creation of a new wetland at another location.  Wetland complexes such at these are valuable features on the landscape.  With the proximity of the Grand River and the tributaries including the Randal Drain, the connectivity of these features, we believe, are not able to be recreated.

Additionally, it is our understanding that the Randal Drain is a permanent flowing, cold-water tributary of the Grand River that also contributes to the wetland complex. In order to adequately assess the potential impacts of the project, the proponent will need to provide clarity on whether the runway expansion will result in relocation of the Randal Drain or paving over/enclosure of the watercourse.  As with the loss of the wetland complex, we are concerned that the loss of a valuable cold water stream on not only fish and fish habitat but a cold water stream will be a significant loss.

With both the wetland and tributaries including the Randal Drain, there are several species of plants and animals including fish that will be impacted.  Currently, the information provided in the presentation does not include enough information about species presence in these areas, and for species listed, mitigation does not address adequately how impacts to species will be addressed.  And while the R9CC has not had time to do an adequate survey of citizens and how the wetland may be used including the harvest of plants for food and medicine (e.g. wild leeks, watercress, fiddleheads, etc.), we are confident stating if the wetland is lost, so too are opportunities to harvest plants, and conduct or lead other Métis educational and outreach programs.

We are concerned over the impacts to Blanding’s and Snapping Turtles, both of which are listed as threatened/endangered by both the Species at Risk Act (SARA) and Endangered Species Act (ESA).  Similarly, the Monarch Butterfly is a federally listed species at risk.  Relative to the relocation of the wetland and/or Randal Drain, the R9CC believes that species such as turtles will be significantly impacted by the direct loss of habitat and connectivity/complexing with other habitats.  With an incomplete species list of the wetlands/drain, all species impacted are a concern to the R9CC for these same reasons.

We are aware that the Butterfly Conservancy has an educational facility in the proposed impact area.  And while the majority of the educational facility is within a building, they do also have viewing areas including walkways that extend into the wetland.  Currently some of our citizens use for viewing and enjoyment, that facility however, a few of our members also deliver outreach and education events from this facility and other locations on the wetland.  We are concerned over the loss of those opportunities to share knowledge of natural heritage features.

The R9CC, while concerned over the loss of natural heritage features, is also concerned over the increase in traffic as a whole; increased air and vehicle traffic.  The increased air traffic with expanded runway facilities puts air traffic more into residential areas meaning increased noise, possible odours (i.e. jet fuel fumes), and potential spill incidents.  Vehicle traffic includes increased use of roads for transport and personal vehicle use.  With little information on how the infrastructure that supports the airport will be developed, we have concerns over the impacts to R9CC citizen’s quality of life.

The R9CC understands that the expansion of the airport is valuable to the Waterloo and Region’s economy.  With this, the R9CC understands the project may push through if concerns can be mitigated.  The R9CC is very interested in leading, or at least, being part of a Stewardship Committee that will oversee all aspects of the project including mitigation and restoration activities.  With lived experience in the area and a vested interest, our citizens would be valuable in being part of this committee.  Membership could include: interested First Nation communities, all levels of government, and other public or stakeholder groups.

At this time, we are submitting the concerns discussed above to ensure these potential project impacts are adequately assessed as part of the environmental assessment process and receive thorough consideration. Given these concerns the R9CC will continue to be involved in all aspects of the assessment process, and may require capacity funding in order to do so effectively.

Sincerely,

Peter Rivers

Region 9 Provisional Council of the Métis Nation of Ontario Councillor & Chair of the Consultation Committee