By Dr. John Bacher, (PhD)

1.Overall-No increased protection from EIS
At the outset what is worst about the EIS is that it does not recommend as it has the power to do, an increase in the extent of the area which is prohibited from development. These areas are exactly the same as those put forward on the concept plan after the developer abandoned offsetting. The protected wetlands are simply to be linked by open space zoning, where activities that can damage wildlife habitat such as the construction of storm water management ponds can take place.  This means that two-thirds of the 500-acre site would be paved over, destroying both mature forests and a complex and biologically diverse savannah.  The EIS can protect these areas by increasing the area  designated Environmental Protection Area. (EPA).  Essentially the EIS has the power to change the weak Environmental Conservation Area (ECAs) into strong EPAs.  Dougan has decided not to use this power in a way offensive to his client.
What is outrageous about the Dougan report’s assumptions is that it is saying that the forests of the Environmental Conservation Areas, (ECAs), can be all cut down for development without loss of ecological function. What makes this so wrong is that so much of the functions identified in the report, ie. Habitat for forest interior birds, is a product of the relatively unbroken block of habitat. This will be disrupted by the cutting down of so many trees and paving over of other habitats that wildlife need to live. It also reveals for the first time that protected wetlands will be destroyed for roads required for development. (this is permitted under provincial law through a full environmental assessment).

2.New Information on Extent of Old Growth Forest (p2)
One valuable piece of information that was not in the November 2015 “Characterization” report is on page 2 and concerns the extent of old growth forests. It spells out correctly that half the site was forested in 1934 and that air photos reveal that all these mature forests remain intact today. No use of this information however, was made to determine the extent that old growth forests are found outside the currently protected wetlands.

3.Salamanders (pp. 4-6, 15,16)
What the EIS says about the Blue-Spotted Salamander is simply carried over from the Characterization report. It is all verbatim copying. No additional research or mediation on the input they received from me and possibly others was done.
It is important and helpful for preservation that the EIS does confirm the presence of the Blue-Spotted Salamander, (this was one of the basis for making the part of the area a Provincially Significant Wetland (PSW-protected) in 2010). If in sometime in the future the salamanders were to disappear the entire wetland could be developed under current provincial law through a down rating process.
The only places where any search for salamanders were undertaken were all north of the drain in the middle of the property. (Conrail drain). (see pages 15, 16 and Table 7) In correspondence with the city that was shared with Dougan I made it clear that a Blue Spotted Salamander in its larval
stage (with gills) identified by biologist Dr. Mike Dickman was seen on Ramsay Road between Dorchester and the bridge over a vernal pool.  This location is identified in the report as part of Polygon 15, “, Mineral Cultural Woodlot.” (MCW) No vernal pools are recognized as being here.
Nothing was done in response to my critique of the EIS by Dougan. This is important to note since at the OMB it is typical for the pro-development side to say, “they would not share their information with us.”  Doing this is not good science in the eyes of the potential adjudication body, the Ontario Municipal Board. (OMB)
After the completion of the EIS on July 1, 2016 three adult Blue-Spotted Salamanders were identified by A. Willems in Polygon 16 in the vicinity of Ramsey Road. This documents how the regionally rare species occupies virtually all of the potential development site.
Regarding Salamanders (the same point also applies to frogs to some degree), there are two points I brought to Dougan’s attention at the public meeting.   One is that salamanders (frogs do as well), migrate from the dry forest adjacent to the Power Canal to the wetlands east of Dorchester in the development area. No attempt was made after they were informed of this fact to see if my information was correct.
The mention of Salamander movement is important in that it brings out another point I made available to the consultants via the city planning department. This is that the salamanders do not spend all of their lives in protected wetlands. They breed in them, but they require drier habitats in different stages of their life cycle.
The EIS has ignored the findings of the respected scientists James P. Gibbs and Michael Reed point out in “Population and Genetic Linkages of Vernal Pool Associated Amphibians”, published in Aram J.K. Calhoun and Phillip G. deMaynadier, “Science and Conservation of Vernal Pools in Northeastern North America) (New York: CRC Press, 2008) The critical point is made in Color Plate 17 of this study. It points out that the migration range of the Spotted Salamander is 390 feet, while the range of the Jefferson Salamander, with which the Blue Spotted frequently hybridizes, is 633 feet.
Although not explained in the EIS a critical ecological function of the site is its habitat for the Blue Spotted Salamander. A key reason why the PSW is protected is that this species, which itself plays important functions for forest health such as maintaining good soils, (assists in increasing soil nutrients by delaying decomposition through predation) is considered regionally rare in both Niagara and Hamilton. Therefore, the EIS should determine if proposed development encroaches upon unprotected lands that salamanders need to survive. If it does, development should be prevented by designating the lands as EPA.
Using the ranges for the closely related Jefferson Salamander the approach that should have been used by Dougan is clear. All of the vernal pools used by Blue Spotted Salamanders (not just those north of the Conrail drain) should have been identified. An outward radius of 633 feet should have then be established to protect the critical ecological function of protecting the habitat of this species of concern in the wetland evaluation.  The EIS then should have required that the permissive ECA designations here should have been changed to the more restrictive EPA, which prohibits site alteration.
Dougan also ignores the sound direction of another article published in “The Science and Conservation of Vernal Pools” by Bryan Windmiller and Aram. J. K. Calhoun. It words should have been used by the Dougan team to expand EPA protection. This is that, “The primary strategy for pool conservation should be to direct development away from vernal pools and the adjacent terrestrial habitat.”  Such terrestrial habitat should be concerned should be protected “through a concentric-circle surrounded by radial management zones at distances established from data on pool-breeding amphibian movement patterns.” (the same point made in the previous paragraph)
The only pages where salamanders are explicitly discussed in the EIS are on pages 4 to 6. It is true that there are many other parts which may group them in with amphibians, (frogs), but here in contrast to the numerous frog species, they are not discussed.
The closest that the area where the possible impact of the Blue Spotted Salamander is discussed in in section of Table 11 that deals with “Amphibian Breeding Habitat.” Here is it is stated (although this is for frogs, not salamanders), that “small vernal pools exist across the property outside the PSW property”, which are important for amphibian breeding. 
The vernal pools outside of the protected wetland are not all small. There is quite a large vernal pool below Ramsey Road beneath a concrete bridge where Blue Spotted Salamander egg masses were identified and filmed by A. Willems. This is in the unprotected Polygon 13. 
Although the EIS does not mention salamanders specifically, what it suggests regarding breeding areas outside the protected wetlands is similar to the recent proposal to move, or offset, wetlands. It is suggested that there are “opportunities for enhancement of existing habitat” and “opportunities for habitat recreation.”
It is simply unrealistic to assume that a developer is going to be seriously in the business of enhancing habitats for the regionally rare Blue-Spotted Salamander. This could have been done by developers in the past by removing toxic material that gets dumped in the vernal pools they own. This has not been done and debris has piled up during the long period after the Thundering Waters Secondary Plan was launched to facilitate development in 2008. Note the comments on page 15 of the EIS.  It states that, “numerous canisters, fuel drums, and other debris were dumped…which may have inhibited the suitability of the pond for breeding Blue-Spotted Salamanders.”  The same situation is present in the large vernal pool beneath the bridge on Ramsey Road.
Unless ownership of the protected wetland is transferred to a conservation body, there will be continual temptations to damage it, so that the area can be down rated and then opened to development. This was the pattern for twenty years in quite similar Pin Oak dominated wetland with vernal pools in North Tonawanda that was for twenty years known as the Kydel Wetlands. (after the Canadian developer). Here many previously protected wetlands were opened up for development in two decades of bitter disputes.  This pattern did not stop until the area was acquired by the Audubon Society to become a well managed wildlife sanctuary.
The current concept plan endorsed by the EIS does not provide for a link to facilitate salamander (and also other wildlife movement), between the OPG lands and the protected wetlands through a protected EPA designation.  The EIS should require at least one corridor, through the designating of additional land in EPA protection between the PSW area and Dorchester Road. Under the current concept plan, endorsed by the proposed EIS, Dorchester would be wall of concrete creating a bad habitat island between the forests owned by OPG and those of the PSW. The OPG forest now part of a big 1,300-acre natural habitat chain stretching to the Niagara River, would be fragmented and isolated connected only by what is described on page 39 of the EIS as “a Storm water management block interface with Dorchester Road.” This means that amphibians moving between the OPG and the protected wetlands south of Oldfield Road could be poisoned by polluted storm water.
Most of the intent on pages 15 and 16 of the EIS is to build a biased lawyer’s case that the documented Blue Spotted Salamander population, should not be considered as Jefferson Salamanders. Recently the federal government’s committee on endangered wildlife put Jefferson dependent unisexual hybrid salamanders on the endangered species list. This can change the situation in terms of endangered species, where the EIS on page 15 does acknowledge that there are unisexual hybrid salamanders or LLJ.

4.Frogs (6, 16, 27, 28  34, 39 and Table 11)
Many of the comments critiquing the EIS regarding enhancing vernal pools to compensate for their destruction and the problem of the proposed wall of concrete along Dorchester Road relate equally to frogs as to salamanders. Another is the problem of the range of vernal pool obligate species. These species present in the proposed development area are the Gray Tree Frog, the Wood Frog, Spring Peeper, Western Chorus Frog and the Leopard Frog.
One of the important ecological functions of the Niagara Falls Slough Forest PSW is to protect the habitat of the frog species that breed in vernal pools. Unlike the situation with salamanders the EIS admits that some of these species are found outside the protected wetland area. The suggestion that this will be compensated for by the developers cleaning up the vernal pools in the protected wetlands is unrealistic. It is similar to the failure of many offsetting schemes to be actually implemented after the development which is to be offset is actually built.  Moreover, it is disturbing that the one measure that would protect these areas, fencing to restrict the dumping of garbage, is nowhere proposed in the report.
One of the reasons that fuller coverage was obtained for frogs than salamanders is that call stations were interspersed throughout the property. This contrasts vividly with the trapping of salamanders. They were trapped for only in the northerly protected wetland south of Oldfield Road.
One of the vernal pool forest obligate species, the Wood Frog, tends to be intolerant of urban conditions. According to the Niagara Peninsula Conservation Authority, (NPCA)’s biodiversity inventory, it is not found in Niagara in urban areas.  This situation is quite vividly illustrated in its range requirement, the greatest for the vernal pool obligate species of eastern North America. According to Color Plate 17 previously mentioned it is 633 feet. The EIS should keep development out of a radius of this distance to ensure the continued ecological function of the wetland in an urbanized environment.
Not all the frog species which are present on the subject lands are vernal pool obligate. They have however, there own specific habitat requirements which need to be addressed in the EIS. The time period for calls captured the species listed. However, there is a different calling period for Green Frog and Bullfrog.
While Bullfrogs are absent from the vernal pools there are permanent ponds in the southern protected wetlands where their calls have been heard. Such as large pond has been identified as possible habitat for the Snapping Turtle in the EIS.   Although these areas are protected the bullfrogs may range outside them.
Green Frogs are commonly observed on the site, although properly not considered vernal pool obligates. This is because of their ability to live in more robust conditions, utilizing marginal habitats such as roadside ditches in contrast to forest shaded vernal pools. This similar to the urban tolerant, American Toad, also found on the subject lands and identified in the EIS.
The relationship between Green Frogs and American Toads and the urban environment is complex and subject to scientific debate.  One thing is clear however, is that they are easily displaced from it. This is best illustrated in the fluctuations in Green Frog populations in the City of Toronto. Once virtually extirpated from urbanized areas as a result of the good management of ravine lands they have begun to recover lost territories.
Green Frogs can be found throughout the five hundred acres of the proposed Paradise development. They are not common however, if at all present, in urbanized areas of the City of Niagara Falls, even in parklands, most of which lack any wetland features.
While examining the development I walked throughout the only severely degraded area of the 500-acre site, Polygon 25. It is identified as a CUM-Dry Moist Oldfield Meadow, an environment which covers only five per cent of the site in five different polygons. (9.76 hectares) Surprisingly however, for all its bleakness this area still supports a viable population of the regionally rare native plant, the Wooly Sedge.
Polygon 25 has serious problems of an absence of vegetative cover, being in some areas a virtual desert.  Although completely omitted from any description in the Characterization report, it is described on page 10 of the EIS as “a large open filled area.” Surprisingly, for all this area’s degradation, encouraged by an easy entry point for off road vehicles off of the Chippewa parkway road, it contains a healthy population of Green Frogs. It was surprising to see one merrily jump in what appeared a first to be a sterile muddy puddle.
Although the problem can be corrected if the landowner was simply to blockade a narrow access point for all terrain vehicles, the degradation of Polygon 25 is real. It appears to be the only part of the entire 500-acre site where the natural environment is not healing, essentially since the drivers of all terrain vehicles will not let it.
What makes the omission of the mention of the real degradation of Polygon 25 so disturbing is that there are incorrect assumptions about such problems even to the extent of requiring site alteration as opposing to trash removal, regarding habitats in the provincially significant wetlands.
To justify the destruction of frog breeding areas such as vernal pools and overall habitat the EIS talks about targeting what Table 11 calls “Enhancement areas within PSW boundaries”. Here it is proposed to “recreate vernal pools”, which in order to be accomplished would require excavation that could disrupt existing valuable natural habitats.  Likewise, on page 39 it is advocated that, “Enhancement of degraded provincially significant wetland areas” be undertaken “through recreating vernal pool habitats.”
The idea of parts of the protected wetlands as being “degraded” is nonsense. These areas habitats simply need to be better protected through keeping out all terrain vehicles and removing garbage, not by excavating new vernal pools. Such disruptions could well encourage the actual degradation of these areas by not only by harming existing healthy native vegetation but by encouraging the spread of exotic and invasive species.
On pages 27 and 28 there is considerable discussion about the absence of fish habitat in the report. The absence of fish habitat however, points to the value of the 500-acre parcel for amphibians. These water courses essentially play a valuable function for breeding amphibians similar to forested vernal pools. In this regards they are similar to the wetland forests and vernal pools associated with the Ten Mile Creek, which were recently protected from urban expansion in part because of an acceptance of this important ecological function of the relevant ECAs (Ten Mile Creek and an linked forest) by the Ontario Municipal Board. (OMB)
Frog habitat will also be impaired through road construction associated with the development which is planned to disrupt provincially significant wetlands. According to the page 25 of the EIS this will impact the protected wetland on both Polygon 27 and 32. This destruction of wetland involves 0.7 hectares in Polygon 27 and another .6 hectares in Polygon 32. It is reflective of the determination of the authors of the EIS not to increase the protected area is that there is no suggestion that 1.1 hectares be added to EPA designations to reduce the impacts of this destruction by protecting more swamp forests.
Instead of increasing the size of the protected area in response to road construction on protected wetlands   reference is made to the planting of shrubs in buffer areas. Such an approach is not being done through  road improvements currently impacting the protected wetland south of Oldfield Road. The barren nature of this wetland buffer is a testament to the reality to how the development will unfold, if permitted. This situation recently has been further exacerbated by the situation of utility poles on the very sort of road buffer lands which the EIS purports, will in the future be carefully protected by native shrubs.
Nowhere in the EIS is the impact of road mortality on amphibian species discussed. If it were properly recognized, such an analysis could have contributed to a recognition of the need to have more areas withdrawn through the expansion of EPA designations.
In the EIS a proposed double standard is proposed regarding the protection of vernal pools. It is suggested on page 27 that, “The 230m (metre) critical terrestrial habitat zone will be protected for vernal pools that are located in the interior areas of the PSW/EPA. For other ponds located near the edge of the protected wetlands, the 230m management zone extends into the development blocks.”  If the ecological function of the “critical terrestrial zone” is valid for the interior of protected areas, the concept should also be applied to vernal pools in edge areas, through an expansion of EPA designations by the recommendations of the EIS.
One of the biggest problems with the EIS is its admitted failure to identify the vernal pools within the Secondary Plan area that are used by obligate species. On page 34 it is admitted that although the unprotected wetland area where these pools are present has been identified, it is sill a mystery as to “the specific area of pool habitat that is present within these areas.” This confession reveals many issues. One is that these non-PSW wetlands need to be re-evaluated, since they contain more vernal pools than were identified when the evaluation was made. Secondly, it reveals that the EIS is incomplete, since it has failed to identify all the vernal pools which are important for the breeding requirements of obligate species that need them for their survival. This expose also reveals how environmental standards in Ontario are lower than those of New England states with similar post-glacial ecosystems in which vernal pools play a critical role. Here municipalities are legally required to map and certify all such ecosystems.

5.Old Growth Forests
The earlier reality of the extent of half of the site being in old growth forest cover is expressed in the report through its recommendations regarding Polygons 6, 12 and 29. It recommends that these areas be subject of what are called “Tree Saving Plans.” These are to protect individual trees that are deemed by future study to be important for old growth, mature trees, and mast (acorns and nuts) from oak and hickory trees, which are important to feed wildlife.
Polygon 6 is classed as a Green Ash Mineral Deciduous Swamp and is contiguous to the large oak dominated protected wetland south of Oldfield Road. Polygon 12 is designated as an Oak Mineral Deciduous Swamp and was part of this big block of old growth wetland forest until the monstrous Conrail Drain was dug in the 1970s. Polygon 29 is also and Oak dominated forest swamp and is contiguous forest to the large block of protected wetland south of the rail line.
While it is always worthy to save old growth trees individually, the presence of significant concentrations of them in Polygons 6, 12 and 29 illustrate why these areas should be designated as EPA and protected from development. They also are important for habitat for threatened species.
Polygon 6 has wetland vernal pools. It also provides significant breeding habitat for the Eastern Wood Pewee and the Wood Thrush. These are both forest interior species that require large tracts of intact forest habitat and would vanish if the subdivisions proposed by the unaltered concept plan were allowed to be constructed here.  Page 30 of the EIS admits that, “studies have confirmed that breeding densities of Wood Thrush are lower in forest patches within residential areas than in rural forests with no adjacent housing.” Likewise, on page 31 it is admitted that regarding the Eastern Wood Pewee, “forest stands adjacent to residential development including housing and roads tend to be used less often by these birds.”
Polygon 12 has rare vegetative habitats associated with vernal pools and is important for breeding amphibians.  It also contains an endangered plant species, Schreber’s Aster.
Polygon 29 is another treasure house of rare species. It has both the Schreber’s Aster and Wood Thrush habitat.
Table 11 discusses what are termed mitigation measures for old growth forest. In this regards however, it stresses, that in such circumstances the key principle should be “to avoid.”  They also admit that, “Compensation for old-growth forest is not feasible.”
Since the authors of the EIS were not prepared to recommend that the three old growth Polygons be designated as EPA they come up with a recommendation that here there should be “individual tree protection.” This concept is simply an excuse to avoid the obvious need for these three old growth swamp forests to be properly designated as EPAs through the EIS process.
One of the basic reasons that the tree saving idea was proposed for these areas was the importance of mast for wildlife. It is impossible to imagine this ecological function through the proposed protection of individual trees in a subdivision.  If they actually were to try to take advantage of such food sources turkeys for instance, would run the risk of being seen as nuisances and be removed.

The EIS admits that there is an abundance of cavity trees that should be important for bat habitat on the site. However, it concludes that the acoustic surveys needed to determine this have not been completed. This is the best reason for work on the EIS to be continued. Identifying important ecological functions such as bat habitat, which involves threatened species, notably the Brown Bat, is an important role for the EIS. Determining the boundaries of EPAs need to be guided by the EIS, not last minute permitting before subdivision registration.
The acoustic surveys need to be completed before the concept design can be used for any planning purpose. The rest of the process, such as the consideration of transportation and infrastructure which is the subject of an upcoming public meeting, should be suspended. If the developer complains about this situation the answer is clear-the rules about development on forested ECAs requiring an EIS have been long established in Niagara.

7.Bird Habitat
One of the most important ecological functions of the Thundering Waters area is its significance as a habitat for native birds. |This is not confined to the threatened Wood Thrush and the Wood Pewee.
The site is excellent for bird habitat because it is a combination of forests and savannahs. This is illustrated by the presence of the federally threatened Wood Thrush through the site, including the less sparsely forested savannahs.
The EIS disparages the savannah areas as mere “cultural habitats.” Although created by human actions these habitats are similar to conditions when forests became established following the retreat of glaciers. Such habitats were created by fires (some induced by native burning to improve bio-diversity), hurricanes, tornados and landslides before the past two centuries of Euro-Canadian dominance of the landscape.
The “cultural” habitats are quite unlike abandoned farmers’ fields. The area has had about six decades to recover from the dumping of Ontario Hydro associated with the power canal. This has caused the lands that were disrupted by past dumping to not be old fields, typical of abandoned agricultural areas  but savannahs, with an impressive coverage of native trees. One is the regionally rare American Plum, which was introduced to Ontario as a orchard species by native people.  Such circumstances provided good habitat for a variety of native breeding bird species, which on page 33 of the EIS are termed birds that benefit from “Shrub and Early Successional Bird habitat.”
The EIS notes that what are termed “early successional indicator bird species thrive in what it terms a “block of cultural thicket’, termed Polygon 16.  These species are the Brown Thrasher, the Black-Billed Cuckoo and the Field Sparrow.” They are found in a 15.7 hectare block of habitat. The EIS admits that the planned “removal of this area will result in displacement of the various bird species and other wildlife that use this habitat type.”
Instead of advocating that Polygon 16 be made an EPA designation, the EIS advocates that the habitat be replicated elsewhere on site. It fails to suggest that a block of comparably large habitat be created instead suggesting fragmented silvers of habitat, which appear not to add up to even half of what will be lost in Polygon 16.
One concern regarding buffer areas is that such lands as is currently demonstrated on Oldfield Road on the northern edge of the Thundering waters planning area have other demands upon them such as the placement of utility poles.  Such disturbed sites can also become disrupted by exotic Buckthorn. The lands associated with the Conrail Drain the railway are quite tiny compared to Polygon’s 16’s 15.7 hectares. They   moreover pose serious challenges to ecological restoration because of the presence of invasive Phragmities. These are very difficult to remove and the widespread disruption of habitat through site alteration if the Paradise project proceeds will inevitably cause them to spread.
One of the odd recommendations of the EIS is that the savannahs be replicated in Blocks 12 and 13. According to the EIS these are essentially Brownfield sites. Such areas are described on page 9 as marked by the presence of “industrial waste….including piles of garbage and concrete.” Lands which would have been more appropriate for brownfield clean up for development, are instead going to become where regionally rare plant species are going to be relocated to.
The three birds identified in the EIS as requiring being significant species of early successional habitat are declining in populations throughout North America and Ontario. According to the Environment Canada’s website, the Field Sparrow’s decrease has been stimulated by “urban expansion.”  The Brown Thrasher’s decline has made it a vivid symbol for the loss of thicket habitat in Eastern North America. The Yellow-Billed Cuckoo’s presence, much like that of the Blue Spotted Salamander, is related to the health of the forest. This is a declining species which is a candidate species for assessment by the Committee on the Status of Endangered Wildlife in Canada. It is important as a consumer of noxious insects during pest outbreaks. One of these species is a serious threat to forest health in other areas of Ontario, the Forest Tent Caterpillar.
A recent article in the American environmental protection magazine Audubon, “How One Under-appreciated Habitat is a Boon for Birds”, highlights the value of what the EIS is content to have destroyed. It stresses that the thicket habitats scorned by the EIS are in reality “one of the most critical habitats in Northeast” not only for species such as the American Woodcock and cottontail rabbit that live here year round “but also on millions of migratory songbirds that depend on their fruit rich largess every autumn.” While the EIS claims that the significance of the Acadian Flycatcher can be discounted, since there is no evidence that it breeds here, this observation points to the importance of even seasonal habitat for threatened birds.  The article points out that the United States’ Fish and Wildlife Service is seeking to create a Great Thicket National Wildlife Refuge.
Another deficiency in  the EIS is that it restricts its discussion to forest obligate bird species to the threatened Wood Pee-Wee and Wood Thrush.  There are many other forest obligate species that will be harmed by the deforestation aspects of the project, most notably one dependent on tree shaded vernal pools, the Wood Duck, which is regionally rare. Other regionally rare  species vulnerable to proposed forest termination  include the the Scarlet Tanager , the Wild Turkey and the Red-Bellied Woodpecker. The EIS  fails to  identify the forest interior obligate species that are probable or possible breeders here.

8.Facts on the Ground Show that Virtually the Entire Site Should be Seen as Undevelopable
The facts as opposed to the interpretations of the EIS combined with field observations by others, reveal that according to Ontario law, virtually all of the site should be understood as undevelopable. This is most vividly illustrated from the EIS by the situation regarding the Wood Thrush.
The facts reveal that the Wood Thrush, which is regarded as a Species of Special Concern in Ontario and is designated as “Threatened” in Canada nests in most of the land that is being proposed for development. It is rather obvious therefore that this is an important ecological function and that therefore the EIS should require that 98.39 per cent of the site be designated as an Environmental Protection Area.  This is what is actually revealed through the facts of biology set forth in the EIS as opposed to the biased interpretations that flow from them.
A similar message from facts on the ground comes from the Snapping Turtle. It is said in the EIS to be confined to a pond in a southerly protected wetland near the Welland River. However, I accompanied by Joyce Sankey, who photographed one, viewed one on Ramsey Road near its bridge. Combined with the observations in the EIS it is likely that Snapping Turtles range over much of the site, much like the Wood Thrush.
According to the EIS only 3.62 hectares, an abandoned brownfield on the site can be seen as “anthropogenic” being cleared of natural vegetation. The rich habitats on the rest of the property illustrate why 98. 39 per cent of the rest of the site should be protected.  Tragically in Niagara huge brownfield tracts remain vacant while natural habitats continue to be eradicated. The proposed use of brownfields for rare plants displaced by the Paradise proposal  is terribly revealing of how bizarre the scheme is.

Review o Environmental Impact Statement (EIS) on Paradise
  June 30, 2016