Globe and Mail Comes to Defense of Wetland Destruction, Dr. John Bacher

August 7, 2017 Les Stewart Original writing

The Media Co-op
August 6, 2017

Globe and Mail Comes to Defense of Wetland Destruction
Dr. John Bacher

On Thursday, July 20th, 2017 the Ontario government finally showed the courage to say no to developer lobbyists when it finally said no to five years of pressure to gut wetland protection policies that have been in place since 1991. It rejected proposals to permit “bio-diversity offsetting” that would permit the destruction of provincially significant wetlands which are an important refuge for endangered wildlife.

Vernal pool in wetland upgraded to protected status. – Photo credit: Adrin J Willems

Five days after the province firmly defended wetlands on Tuesday, July 25 after failing to publicize the wetland policy review the Globe and Mail leaped to the defense of developers who had advocated offsetting. It published an article by Jill Mahoney, “Fight for Wetland Stalls large Niagara Falls Development.” The particular development had offered itself as a pilot project for bio-diversity offsetting.

Mahoney‘s account was most bizarre that while ignoring the ultimately failed attempts by developers to change wetland rules through offsetting, it was full of angry quotations by the Mayor of Niagara Falls, James Diodati.. He denounced how, “The rules are being changed as the game is being played out.” This was a reference to a decision, following existing rules by the Ministry of Natural Resources and Forestry, (MNRF), to increase in October 2016, the area of wetland protected from development.

Upgraded wetland in Thundering Waters Forest. – Photo credit: Adrin J Willems

Mahoney focused on the opposition to the project came from the foreign owned nature of the current version of the threat to the Thundering Waters Forest. Her article only had one quote from an ecologically minded opponent of the development, retired Canadian forces captain, Edward Smith.

Based on a three hour interview Smith’s quote was narrowly limited to his concerns about foreign ownership. This ignored how he is being subject of a law suit based on his concerns for firings at the Niagara Peninsula Conservation Authority, (NPCA) these were expressed in a document which it attributed to him titled, “A Call for Responsibility.” The firings, although motivated by efforts of NPCA staff to protect the Thundering Waters Forest, took place before the property was transferred to its current owners.

Wetland upgraded after peer review of draft environmental impact study (EIS). – Photo credit: Adrin J Willems

Nine years ago when I and Jean Grandoni opposed the destruction of the Thundering Waters Forest at Niagara Falls City Council we were faced with a strange argument by the developer’s solicitor. This was that the scheme should be supported because of the prominence of the various local families behind it. Their support resulted in an appeal by me of the council’s decision to the Ontario Municipal Board. (OMB)

Following filing an appeal to the OMB I was contacted by the developer’s solicitor who asked me to engage in a mediation process. After several meetings, he agreed that the then Ministry of Natural Resources (MNR) would be given access to the site, if requested to do a wetland evaluation. On this basis I withdrew my appeal and minutes of settlement were signed.

Unknown to the solicitor, when we signed the Minutes of Settlement a Pelham area environmentalist, John Lynn, had contacted brave staff persons at the NPCA, urging them to help me with my OMB appeal. Lynn is the only surviving individual who was part of the core group of eco-justice activists who in 1959, led by future Ontario legislator Mel Swart, persuaded the provincial government to create the NPCA.

NPCA staff was overjoyed when following signing of the Minutes of Settlement; MNR invited them to accompany them on the evaluation. They took part in the discovery of two previously unidentified species that were not recorded when the owners denied MNR access to the site. These were the Black Gum, an endangered tree, and the regionally significant, Blue Spotted Salamander. The findings resulted in the protection as significant wetlands, of 281 acres of the 484 acre site.

The process of the wetland re-evaluation was quite laborious stretching from 2008 to 2010. The slow process was required by the legal need for the ecological advisers of the owners, Lisa Campbell and Richard Brady, to be present on the site visits. I learned about the victory through reading a Niagara Falls Planning Department report filed at a City Council meeting.

The rescue of the Thundering Waters Forest ignited a storm of protest from developers. Sympathy for their complaints among the Niagara Regional Councilors that control the NPCA board, triggered NPCA staff firings legitimated through a planning exercise known as its Strategic Plan.

On Strategic Plan advisory boards key figures involved in attempts to develop Thundering Waters served, notably the developer’ solicitor, Lisa Campbell and Richard Brady. This resulted over six years in the firings of 21 NPCA staff documented into an appendix to “A Call for Responsibility.” These firings also eventually resulted in the unionization of the NPCA through the Ontario Public Service Employees Union, (OPSEU)

During the carnage of firings at the NPCA a new threat to wetland protection emerged because of lobbying efforts by the Fort Erie Chamber of Commerce. These sought to remove wetland protection within Fort Erie’s urban boundaries.

What triggered the Fort Erie Chamber’s indignation about wetland protection was a large old growth swamp forest, dominated by oaks and hickories, known as the Thompson Road woodlot. It shades the mouth of Frenchman’s Creek and the Niagara River. This makes it an important refuge for waterfowl such as herons.

Both the Thompson Road Woodlot and the similar wetland forest Thundering Waters were recommended for protection from development in a 1980 study of ecologically sensitive areas of Niagara known as the Brady report. This continues to be the only comprehensive study of land use planning based on the need to protect threatened eco-systems in Niagara that are hot spots of bio-diversity. An attempt by the NPCA to update the Brady report did not look at the entire City of St. Catharines. Recently Lisa Campbell has penned another report justifying deforestation in St. Catharines in an environmentally sensitive area identified in the Brady report as the Escarpment-De Cew Forest.

Unfortunately, the Brady report has not been well reported on in the Niagara area corporate controlled media. Few know of its pleas to protect Thundering Waters (originally called Ramsey Road Woodlot), the Thompson Road Woodlot, the Brock Decew Forest and the Irish Grove Woodlot. (A Grimsby Forest threatened by a road). This widespread ecological literacy provided a favorable opportunity during for the Fort Erie Chamber of Commerce to attack provincial wetland policy in an all candidates meeting held during a provincial by-election. This sparked a review of provincial paper which featured a discussion re paper of biodiversity offsetting. It was during this period of policy review that the Thundering Waters forest was sold to foreign investors.

After the sale of the Thundering Waters Forest, the new owners came forward with a development proposal that was originally based on bio-diversity offsetting. This was the first time since 2010 that a specific development proposal had been made. The original focus of development, an old growth forest immediately south of Oldfield Road, had now become a protected wetland. After two demonstrations at the Niagara Region and Niagara Falls City council, development on the basis of offsetting was dropped.

In June of 2016 an attempt was made to justify development of the 203 acres of the Thundering Waters Forest which were not provincially significant wetlands. This was attempted through a draft Environmental Impact Study (EIS). It was prepared by Dr. Stephen Hill, of the consulting firm, Dougan Associates. It helped to set in motion a native led protest, organized by an Oneida resident of Niagara Falls, Karl Dockstader.

Prior to the release of Hill’s report a deluge of requests were made by concerned Niagara Falls residents to the Niagara Falls Planning Department that whatever its findings, the EIS, commissioned and paid for by a developer, be subjected to an independent peer review. What makes this particular aspect of the struggle to save Thundering Waters so revealing was that it was led by Linda Babb, whom the Globe and Mail interviewed at length, but was never quoted from. As a result of this input, as provided for in the Niagara Region’s and City of Niagara Falls official plans, an independent peer review of Hill’s report was made.

The peer review was conducted by North-South Environment by an Ecologist, Leah Lefler. The most important part of her critique was an observation on page 3 that at this stage of the development process, according to the Ontario Wetland Evaluation System, (OMERS) that additional lands should be examined for wetland evaluation.

Lefler stressed that OMERS required that the unprotected wetlands at Thundering Waters should “be evaluated” to see if they should be protected “as part of “the Niagara Falls Slough Forest Wetland Complex Provincially Significant Wetland.” She also stressed that existing provincial and municipal policy required that all wetlands on site “greater than 2.0 hectares” should be designated as an Environmental Protection Area” (EPA) in the Niagara Falls Official Plan and protected from development. She also demanded that acoustic surveys of the breeding habitats of endangered bat species be conducted.

Although the City of Niagara Falls kept Lefler’s report secret (it was revealed only after an access to information act request by Ed Smith), its key recommendation was acted upon. As the Globe and Mail reported a wetland evaluation visit was made in late September 2016. As a result of the site the area of protected wetland was increased to 335 acres. The developable acreage has now shrunk to 149 acres, much of which is further restricted by buffering constraints.

The Globe and Mail failed to comment on the ecological significance of the additional acreage protected through the application of the OMERS methodology and the comments of the peer reviewer. Some details of the significance of these lands are clear from Hill’s own draft EIS.

Hill’s June 2016 draft EIS revealed three areas of what were then unprotected wetlands with old growth forest characteristics. These areas having trees with cavities and grooved bark are important for roosting habitat for the endangered Little Brown, Northern Myosis and Tri-Colored bats. Under Hill’s EIS, which was discredited through Lefler’s peer review, these areas were targeted for what Hill termed a “Tree Saving Plan.” This called for saving individual old growth trees while permitting development around them.

One of the old growth areas north of the rail line which runs through the middle of the Thundering Waters Forest was identified by Hill as a Fresh-Moist Oak-Maple Hickory Deciduous Forest. Hill admitted it is “notable for the size distribution of mature trees”. His EIS found that this area also provides breeding habitat for two Species at Risk birds. These are the Eastern Wood Pewee and the Wood Thrush. Both species are experiencing serious declines because of deforestation.

Another area of old growth forest rescued by the increased area of protected wetlands is a block of Oak Mineral Deciduous Swamp. This Hill admitted was “an exceptional example of Carolinian slough forest, containing high diversity of native species and a variety of vegetated habitats.” Here are found rare Buttonbush communities. This forest contains numerous vernal pools. They provide breeding habitat for the Blue Spotted Salamander and various frog species. It is also habitat for a rare plant, Shreber’s Aster.

A block of Old Growth Oak Mineral Deciduous Swamp which was upgraded to protected status is south of the rail line near the earlier protected wetland that is home to a spectacular White Oak giant known as the Thunder Oak. It contains rare Rufous Bulrush and Buttonbush communities. This newly protected forest also has vernal pools important for breeding amphibians and nesting areas for Wood Thrush. A less ancient block of mature forest south of this area was protected. It has Wood Thrush . breeding habitat and vernal pools.

Through the wetland review protection was also extended to a large block of mature forest adjacent to Dorchester Road and the Chippewa Parkway along the Welland River. This has vernal pools that provide amphibian habitat. The swamp also provides nesting for the Eastern Wood Pewee.

The wetland review also protected a number of pockets of Willow Mineral Deciduous Swamp. Currently dominated by Black Walnut and Eastern Cottonwood, these pioneering woodlands are succeeding into a Pin Oak forest. They also have important amphibian breeding habitat.

Ecological studies reveal that there are severe constraints to even the 149 acres of the site that are not protected wetlands. Hill’s own draft EIS reveals that most of this area provides breeding habitat for Wood Thrush and the Eastern Wood Peewee. They also provide important foraging habitat for another Species at Risk, the Barn Swallow.

Repeating the mantras about job loss, the Globe and Mail did nothing to deal with the reasons for the opposition, based on concerns to the threat of habitat loss of endangered species. It is a text book example of the mentalities that are creating an extinction crisis.

Dangerous Environmental Consultations Result in Conservationist Victories, Dr. John Bacher

August 5, 2017 Les Stewart Original writing

The Media Co-op
August 3, 2017

Dangerous Environmental Consultations Result in Conservationist Victories
Dr John Bacher

Niagara Falls wetlands protection was increased in the wetlands at Thundering Waters Forest.

On July 20, 2017 the release of the “Ontario’s Wetland Conservation Strategy” marked a major conservation victory. It was the happy ending of a five year battle that pitted conservationists against land development lobbies, marked by two public consultations requested by developers. One was a review of the Conservation Authorities Act. The other was a review of Ontario Wetland policy.

The intent of the two reviews was to weaken Ontario’s wetland protection system. It is the strongest and most scientifically driven aspect of southern Ontario’s land use planning system. Wetland protection safeguards the habitats of endangered species threatened by urban sprawl. Shaped by scientifically trained wetland evaluators, it is not subject to the intrigues of municipal councils and the machinations, dependent on the availability and qualification debates over proffered expert witnesses, of the Ontario Municipal Board (OMB).

Unlike looser land use planning controls in other parts of Ontario, in the southern parts of the province, outside of the Canadian Shield, once identified Provincially Significant Wetlands (PSWs) become protected from site alteration (i.e. urbanization). These protected wetlands are mapped by public servants working for the Ministry of Natural Resources and Forestry (MNRF).

In developing wetland scoring what is critical to MNRF’s 600 point scoring system are various features to protect bio-diversity. One is the presence of Species at Risk. Another is the presence of rare ecological communities.

I became convinced of the value of the current wetland protection system as a result of my nine year battle to protect the 484 acre Thundering Waters Forest in Niagara Falls. Through a 2008 appeal to the Ontario Municipal Board (OMB), we were able to trigger a process which led to much of the Thundering Waters Forest becoming a protected PSW. This was largely because of the presence of the provincially threatened Black Gum and the then regionally rare Blue-spotted Salamander. While MNRF was responsible for the wetland re-evaluation, they were assisted by quite brave ecologists working for the NPCA. There are also provincially rare Buttonbush and Rufus Bull Rush ecological communities which boosted point scoring.

The odious agitation led by developers was unleashed following the 2010 wetland re-evaluation that rescued Thundering Waters Forest. First there was a firing of NPCA staff who worked with MNRF in the wetland re-evaluation, a process justified by its Strategic Plan. Then the business community of Fort Erie, led by its Chamber of Commerce, launched a campaign for the elimination of PSW protections within urban boundaries.

Pressure from developers and their municipal council allies, who controlled the NPCA board, resulted in a review of the Conservation Authorities Act and the provincial Wetland Policy. This sought to weaken wetland protection. It was hoped that protected PSWs in Niagara Falls and Fort Erie, largely Pin Oak dominated swamps, full of vernal pools, which provide critical habitat for species such as the declining Western Chorus Frog, would be opened up for development. During this time of policy debate the Thundering Waters Forest was sold by Mountain View Homes to the Chinese owned GR Canada Investments.

A critical element of the developers’ strategy was securing changes to the Conservation Authorities Act. What was sought was a change in law that would allow the conservation authorities to conduct wetland evaluations. It was hoped by developers that this would get protective PSW designations changed by the harassment of conservation authority staff bullied by municipal politicians. Such bullying has caused the Ontario Public Service Employees Union (OPSEU) to describe the work environment of these agencies as toxic.

Developers failed totally in their schemes to change the Conservation Authorities Act. Powers to conduct wetland mapping and evaluation remained in the hands of MNRF.

The only changes that are being made to the Conservation Authorities Act as a result of public consultation are those which will increase provincial oversight of authority boards. These are spelled out in draft legislation called the Building Better Community and Conserving Watersheds Act. The legislation was provoked by outrage over efforts to reduce wetland protection by municipally controlled conservation authority boards. One of its key features is giving MNRF power to enact bylaws to compel authorities to disclose information related to their programs.

Developers failed also to gut wetland polices to subvert the strict no site alteration provisions for PSW lands. This was proposed in a public discussion paper to modify wetland policy through what was termed, “Bio-Diversity Offsetting.” Under this proposal previously protected wetlands could be destroyed if claimed to be replicated, or “offset” elsewhere.

What helped increase opposition to offsetting protected wetlands was a proposed “pilot” project in Thundering Waters. These protected wetlands are predominately an old growth swamp oak forest. They are the most challenging type of wetland to replicate. The slow growing nature of oaks has resulted in many failures to offset such wetlands in the United States.

The proposed pilot project resulted in two massive protests. These filled the council chambers of the Niagara Region and the City of Niagara Falls. As a result proposed council motions that suggested the province endorse the pilot project were withdrawn. The maladroit effort also encouraged massive public input into both the wetland policy and conservation act governance consultations, which had previously drawn little public attention.

The reaffirmation of the wetland policy was done through a government news release that accompanied it on the subject of “Conserving Wetlands to Fight Climate Change.” The key language of affirmation is there, even if buried on page 48 of the PDF version and page 42 of the printed version. It pledges that the government will be “Providing provincial oversight to improve conservation authorities while not reducing protection for those wetlands already protected by provincial policy (e.g. provincially significant wetlands, coastal wetlands protected by the PPS, 2014)”

Comments on Proposed Agricultural and Natural Heritage Mapping For Growth Plan Area, Dr. John Bacher

July 30, 2017August 7, 2017 Les Stewart Original writing

Another original article by Dr. John Bacher, first published on JohnBacherPhD.ca.

JohnBacherPhD.ca
July 26, 2017

Comments on Proposed Agricultural and Natural Heritage Mapping For Growth Plan Area by Preservation of Agricultural Lands Society.
Dr. John Bacher PhD

1. Agricultural and Natural Heritage Mapping Should More Deliberately Seek to Build Upon Existing Municipal Plans.
PALS’ is concerned that a rather abstractionist approach has been taken to the challenge of developing mapping for natural heritage and agricultural areas in the Growth Plan. Instead of starting from scratch as is being proposed, the existing municipal plans need to be carefully complied and studied to determine possible deficiencies which would then be corrected through the Growth Plan. The mapping needs to reinforce not undermine, existing good mapping for agriculture and natural heritage in the municipal plans within the Growth Plan area.

2. Goal of Growth Plan Is To Set Higher Standards for Land Use Planning
It has been PALS’ experience that the Growth Plan has encouraged better land use planning. In this regard our most positive experience with the Growth Plan came about from its disallowance by the province of proposed amendments, through sustained appeals to the Ontario Municipal Board, (OMB) of the Niagara Region and Niagara Falls official plans. These amendments were intended to facilitate the subdivision of both farms and natural areas into rural estates to be serviced by sceptic systems on lots with a minimum size of five acres.

3. Agricultural Designations Should be Based on Capability not Economics
While the proposed mapping exercise cannot open up large new areas to estate development, PALS is concerned that the varied economic criteria for agricultural mapping for the usual three-zone approach in rural areas may result in inappropriate shifting of designations. These are “Specialty Crop”, “Good General” and “Rural.” These standards vary as to the permitted uses the designations allow. Golf courses for instance, are not a permitted use within Specialty Crop lands. “Rural” lands also are more permissive regarding residential severances.

Determination of the type of mapping should remain, as is currently spelled out in the Provincial Policy Statement (PPS) on land capability based on soils and climate. Economic criteria such as access to markets change more readily than factors imposed by nature.

One of the most vivid examples of PALS’ experience of the centrality of soil and climate is the Chateau des Charmes Estates winery in Niagara on the Lake. During the 1970s the land which was in an urban shadow caused by close proximity to two expressways, but with excellent air drainage and soil, had been abandoned from any agricultural use. This situation changed and the winery is now one of Canada’s most prestigious agricultural operations.

4. PALS Has One Request to Correct Longstanding Error in Agricultural Designation
PALS has one specific request to modify an agricultural mapping designation through this mapping exercise. This is to designate all of the rural lands north of the Welland River, in the municipalities of Thorold and Niagara Falls as “specialty” crop lands.

The area north of the Welland River has similar capabilities in terms of soil and climate as the currently designated specialty crop lands which now extend only to Mountain Road in Niagara Falls. There is no distinctive soil and climate type bordered by this road, and there is now an estate winery located in Niagara Falls on Lundy’s Lane, right in the middle of the area we are seeking to expand the “specialty” crop designation into .

PALS Is Opposed to the Omission of Natural Heritage Areas from Urban Area
PALS understands that apart from situations where urban river valleys protected by the Greenbelt extend into urban areas, that it is proposed that the natural heritage system of the Growth Plan is not to include lands within urban boundaries. This suggestion appears to defy scientific logic. If for instance, a core area exists of 100 hectares or more in an urban area, (which is what is being proposed in Figure 2 for most of the Growth Plan area) there is no good scientific rationale why such a natural habitat should not be protected by the Natural Heritage System of the Growth Plan. Being within an urban boundary should give such lands greater protection as they are more under threat of development. Many tend to be located in zone 7E, the Carolinian life zone. It is Canada’s most important area of bio-diversity, with many rare species and habitats.

What is disturbing, is that through our participation in the now-completed review of Ontario wetland policy, which in the end rejected proposals to permit site alteration on designated PSW features, PALS became aware of where in Niagara many of these large natural areas of 100 hectares or more are located. These features, some of which are PSWs in Fort Erie and Niagara Falls, tend to be located on the fringe of the urban boundary. They are also linked to other natural areas through the Welland River and Frenchman’s Creek. Some of these PSWs, notably the Thompson Road Woodlot in Fort Erie straddling Frenchman’s Creek, buffer adjacent agriculturally- designated lands. Another PSW within urban boundaries, the Niagara Falls Slough Forest, (also known as the Thundering Waters Forest) contains important habitat for three species of endangered bats, since most of it is an old growth forest. It also provides critical habitat for vernal pool obligate species, such as the Blue Spotted Salamander, and the Gray Tree, Chorus and Wood frogs.

All the forested wetlands within the urban boundaries of Niagara Falls and Fort Erie have been found to contain breeding habitat for a Species at Risk, the Wood Thrush. This is a good indicator species to protect the imperiled natural heritage of the Growth Plan area. It requires large tracts of unbroken forest to survive. The proposed natural heritage mapping, by leaving large areas of southern Niagara within urban boundaries that would otherwise fit into its criteria for protection, out of its designations , puts this key indicator species at additional risk.

The omission of urban areas from the proposed natural heritage system appears to be compensation to the same development interests that conducted a lengthy campaign to permit offsetting of PSW lands. The negative consequences of this approach are spelled out through the facts, if not the commentary, on
Table 3 of the draft strategy methodology.

Table 3 shows that in the Growth Plan area 10 per cent of PSWs would not be protected by the proposed natural heritage mapping. In general 13 per cent of all wetlands would be left out. Eight per cent of the habitats of endangered species would be unprotected. This problem is triggered by the ignoring provincially significant woodlands in the criteria for protection through the proposed natural heritage mapping. This criterion is more inclusive of natural areas than the proposed 100 hectare minimum and does not distinguish between urban and rural areas.

5. City of Toronto’s Strong Policies to Protect Natural Areas Would Be Weakened By Proposed Mapping
Among municipalities in the Growth Plan, the City of Toronto has been a leader in developing a strong, protective natural heritage system. This system is described well by the authors, of “An Enduring Wilderness: Toronto’s Natural Parkland” Here in Appendix E, the authors note that there are 2,698 hectares protected through designated Environmentally Protected Areas (ESAs) in the City of Toronto’s official plan. This amounts to four per cent of Toronto’s land base. While most of these lands are publicly owned, the authors stress that “Some ESAs extend onto privately owned land.” These private lands are vulnerable to development through possible re-zonings.

Natural Heritage mapping for the Growth Plan should strengthen not undermine the City of Toronto’s ESA based natural heritage protection. Although the Green Belt does extend into the Toronto this is only on public lands, not private lands vulnerable to development.

Toronto’s existing natural heritage mapping protects 369 significant plant species. The term “significant” means that these native plant species are declining within Canada, or at least in the Toronto region. It also provides habitat for 128 species of breeding birds. The proposed Growth Plan natural heritage mapping puts this treasure of bio-diversity at increased risk.

6. Toronto’s Success is Both a Promise and a Warning in Terms of Bio-Diversity.
Toronto’s success in terms of developing a natural heritage system is both a promise and a warning. It is a success in that , largely through these policies and park naturalization, the Green Frog, has been able to recover some of its lost habitat in Toronto. Wildlife however, that requires more exacting, specialized, habitats, notably vernal pool obligate species, such as the Blue Spotted Salamander, Gray Tree Frog, Western Chorus Frog and Wood Frog, remain extirpated.

Despite protecting large areas in forested parklands, notably the Rouge and High Parks, the Wood Thrush has vanished as a breeding species from Toronto. Strong natural heritage mapping, which protects at least all the current areas of provincially significant woodlands, is needed to stop the disappearance of this critical indicator species from the parts of Growth Plan facing urbanization pressures underscored in Figure 2.

7. Ignored Provincially Significant Woodlands Should Provide Basis of Natural Heritage System
In the Natural Heritage mapping discussion paper there is no discussion of provincially significant woodlands. Such woodlands are for instance, omitted from features identified in Table 3, although there are important policies for their protection contained within the PPS. There is no estimate of what per cent of these woodlands form part of the proposed natural heritage mapping contained in Table 3.

PALS agrees strongly with the following passage from the Ministry of Natural Resources and Forestry, (MNRF) Natural Heritage Implementation Guidelines. This is that, “The protection of woodland cover in southern Ontario is an important concern. The loss of woodland habitat is one of the most serious threats to biological diversity.” The draft mapping proposals natural heritage for the Growth Plan do not adequately reflect this concern.

Rather than ignoring provincially significant forests, their protection, buffering and linkage should be the core of the Growth Plan’s Natural Heritage Mapping. The protection they provide is far greater than the 100 hectare core minimum size contained in the draft natural heritage strategy.

The Natural Heritage Mapping proposal for the Growth Plan describes a very different approach than that taken in MNRF’s implementation guidelines. The proposed mapping for the Growth Plan is based upon a minimum core of 500 hectares for relatively ecologically intact landscapes and a “minimum core size of 100 hectares …in areas with high levels of fragmentation and low percentage of natural cover.” In contrast MNRF’s implementation guidelines stress that, “In the absence of more complete information, the threshold should be reduced to include woodlands that would otherwise be missed. For example, where woodland cover is between 15 and 30 percent of the land base, woodlands close to 4 hectares, rather than 20 hectares should be considered significant.”

Figure 2 in the consultation document has a map of the proposed area of fragmentation where a minimum core size of 100 hectares is recommended. Based on the MNRF implementation guidelines, it would be appropriate that an area of 4 hectares was employed. For the more intact area of the Growth Plan, it appears the implementation guidelines recommend an area of 50 hectares. This is a vivid contrast to the proposed 500.

The core area minimums for the Growth Plan should reflect the criteria of MNRF’s Natural Heritage Guidelines. These are in essence, 4 hectares for fragmented landscapes, 50 hectares for others. While in areas of less than five per cent forest cover, two hectares are considered appropriate for core size, the contrast between 4 and 100, and 50 and 500, give a good sense of the great variation between the approach taken by the MNRF implementation guidelines and the proposed natural heritage mapping strategy for the Growth Plan.

The consultations need to review how successful municipalities have been in undertaking this basic requirement of the PPS to identify and link provincially significant forests. The existing policies and mapping requirements mandated by the PPS need to be clearly spelled out for the next phase of public consultation. Where their plans have failed to follow provincial policy, they should be brought into conformity through the natural heritage mapping exercise. This should involve both the identification of significant woodlands and the necessary work to encourage corridors between them.

8. Consultation Document Provides Too Optimistic Evaluation of Proposed Strategy.
A number of aspects to the proposed natural heritage strategy have given a too-optimistic perception of the impact of the proposed strategy. This is based on the assertion that outside of urban boundaries, 45 percent of the landscape is covered. This appears to be boosted by the inclusion of large water bodies, most notably Lake Simcoe. If this is so, a separate estimate should be made for terrestrial landscapes.

From observing Figure 4 it appears that the majority of the proposed mapping for natural heritage is either in the Greenbelt Plan, or in lands that form part of the Canadian Shield in Simcoe County, Kawartha Lakes and Peterborough. In other areas there appears to be large swaths of peach colored lands with minimal green shaded natural heritage mapping. One vivid instance of this appears to be the municipal boundary line between Durham Region (within the Greenbelt) and the City of Kawartha Lakes. (Outside the Greenbelt) A similar contrast appears in the boundary lines between York Region and Simcoe County.

There are also large swaths of peach colored lands with a disturbing lack of green mapping in the western areas of Wellington County, Waterloo Region and Haldimand which all appear to be devoid of heritage mapping. Since forest cover is so low in these areas, they are examples of where the minimum two hectares should be used for core area mapping purposes. If this is not properly studied in existing municipal plans a separate process needs to be undertaken as part of this process.

To understand the adequacy of the proposed mapping outside the Greenbelt a single calculation needs to be made. What is the per cent of designated provincially significant woodland outside the Greenbelt that is captured by the proposed mapping outside of the large area of forest cover of the Canadian Shield? It also should be determined if existing mapped areas in official plans for corridors are reflected in the proposed mapping.

9. Growth Plan Mapping Should Compliment Not Undermine Existing Natural Heritage Mapping in Official Plans
In summary, the regional natural heritage mapping for the Growth Plan area should strengthen, not undermine, the existing mapping for this purpose already embedded in municipal plans. In this regard two urgent steps need to be taken. Within urban areas the mapping needs to include existing protections such as identified PSWs and other natural heritage identification contained in official plans. Outside of these areas and the Greenbelt, a separate review needs to be conducted in the heavily deforested area identified in the consultation paper in Figure 2. It should be seen if all the areas mapped in existing municipal plans here are included in the proposed strategy. If these plans do not meet the minimal standards of the PPS, the mapping examination of the Growth Plan should follow its guidelines regarding significant woodlands and connecting corridors.

Both the agricultural and natural heritage mapping in the Growth Plan need to give firm direction to land use planning. Compared to the perpetuation of the rural landscape and natural heritage, other land use planning debates are trivial. Clear identification of landscapes that need protection is crucial.

Reproduced with permission. JohnBacherPhD.ca

The Need for an Ontario Land Use Planning Board, Dr. John Bacher

July 11, 2017July 11, 2017 Les Stewart Original writing

Another original article by Dr. John Bacher, first published on JohnBacherPhD.ca.

Dr. John Bacher (PhD)
July 10, 2017

The Need for an Ontario Land Use Planning Board
The Preservation of Agricultural Lands Society
Dr. John Bacher

John Bacher, a researcher with the Preservation of Agricultural Lands Society, walks on farmland that he helped save from development in Niagara Falls, Ontario on Saturday, March 28, 2015. Environmentalists are cheering a decision at the OMB denying the urban boundary expansion of Niagara Falls. It was one of the biggest farmland protection cases at the OMB in Ontario history and is particularly significant in light of the greenbelt reviews currently underway. (Photo by Peter Power for The Toronto Star)

1. Province is to be Commended for Addressing Need to Reform Ontario Municipal Board (OMB)
The provincial government is to be commended for undertaking the difficult challenges of making improvements to legislation regulating the operations of the Ontario Municipal Board. (OMB) In general these reforms build on those introduced in 2005. Of these, most beneficial was the prohibition of an appeal a municipal council decision to prohibit the expansion of a human settlement area. PALS is of course pleased that this laudable reform was carried on in the proposed legislation. As expressed in our earlier comments, this needs to be further clarified. It seems strange that encroachments on designated environmental protection areas are not treated as expansions of the human settlement area.

2. PALS is Pleased with Most Proposed Changes to OMB
At the outset, PALS wishes to make it clear that we support all, with two exceptions, of the proposed changes to OMB. Changes to restrict appeals, have more transparent procedures, eliminate appeals of ministerial zoning orders, and provide financial, legal and planning support to appellants acting in the public interest in championing provincial policy are long overdue. PALS also supports the reform that instead of “good planning”, decisions of an appeal body should be based on lack of conformity to provincial policy.

PALS has been involved in the development of provincial policy since our founding in 1976. We have taken part in numerous public consultations regarding planning policies. Throughout that time our OMB appeals, most of them successful, have been provoked because of violations of provincial policy. These appeals have also become a discovery expedition into fields of provincial policy which often tend to be ignored by planners working for municipalities and the private sector.

3. PALS Believes Good Planning Means Conformity to Provincial Policy
The use of the term “good planning” by the OMB is essentially an archaism to the period before 2005 when the extent of provincial policy was much more limited than it is today. Earlier there was nothing comparable, for instance, to the 2005 Natural Heritage Implementation Guidelines, which can be if actually applied, a sound basis for good planning in both rural and urban areas. By protecting water quality these guidelines would safeguard as one of the most our most dedicated members, Jean Grandoni, has stressed, fish habitat. The protection of streams from storm water pollution due to urban sprawl which poisons aquatic life, is one of the most vivid ways in which all of our rural landscape is food lands.

One of the basic principles of the Natural Heritage Implementation Guidelines is the protection it gives to the headwaters of streams. This also should protect considerable areas of rural land from urban expansion. PALS’ has found however, that the attitudes of municipalities have made this policy a ‘dead letter’.

The challenges of protecting stream headwaters is shown by PALS’ experience in a 2014 OMB hearing regarding the Ontario Motor Speedway in Fort Erie. This was a difficult experience for us, since our proffered expert witness, Dr. Hugh Gaylor, was not permitted to give opinion evidence as a planner because of his one-year membership in PALS. More seriously however, the headwaters of Miller’s Creek were permitted to be turned into a massive parking lot, since the planning instruments were manipulated so the motor raceway was not an urban expansion but a “special policy area.”

Long after the hearing was concluded, PALS’ learnt that there is a provision for special policy areas in the Provincial Policy Statement (PPS). It has nothing to do with putting parking lots over headwaters on agriculturally zoned and designated lands. The term applies to areas which are in floodplains but are already urbanized.

Before the current guidance of provincial policy, it was understandable why the OMB had to in effect invent its own policy to ensure good planning. For many decades, even after the devastation and loss of human life in floodplains caused by Hurricane Hazel, there was no formal policy to compel zoning to prevent development on these hazardous lands. Despite formal policies that exist today however, threats to such areas persist.

4. Large Swaths of Provincial Policy Not Embedded in Municipal Plans
What is of great concern to PALS, is that while the basic concepts of good planning are well embedded in provincial policy, they are not well reflected in land use planning guidelines approved by municipalities. One disturbing aspect of this failure, is to properly protect the headwaters of streams as mandated by provincial policy. While decades old policies to protect fish habitat are slowly creeping into official plans, the same cannot be said for policies mandated by the most recent version of the PPS. These are policies to ensure adaptation and mitigation for climate change and to protect imperiled bio-diversity.

PALS’ took part recently in extensive Niagara Region public consultations in its mandated five year review of its official plan. During this period there was no discussion of the need to update the plan to implement these new policies of the PPS.

Some may suggest that for both climate change and bio-diversity, what is needed is simply to follow older policies of the PPS and protect large blocks of forested habitat and rural land from sprawl. This approach however, is inadequate. Many threatened wildlife species, have more specific habitat needs.

For instance, PALS’ has become familiar with the habitat requirements of vernal pool obligate species, such as the Western Chorus which in Ontario, is experiencing a marked population decline. Many forested areas which provided habitats for these frogs in the past, now fail to do so because of drainage. Municipal plans need to implement the new PPS plans for bio-diversity, which have been effectively shelved.

5. New Policies for Intervenor Funding Show Need for Ontario Land Use Planning Board
Given the stubborn refusal of municipalities to implement PPS policies on biodiversity and climate change, and the welcome new provisions for intervenor funding, PALS expects that many appeals will be made to what is planned to be called the Local Appeals Tribunal (LAT). The proposed new name for the tribunal however, LAT, does not give sufficient dignity to the important matters it will be adjudicating. A more appropriate one would be the Ontario Land Use Planning Board.

The term OMB has its origins before the Planning Act of 1946. For almost four decades, its adjudications based on land use planning were confined to the municipalities, (entirely urban), that had special provincial legislation to conduct land use planning. Even after the Planning Act of 1946, land use planning did not get going in predominately rural areas until the passage of the comprehensive zoning by-law of Thorold Township in 1959, when it was approved by the OMB, following appeals,. A critical role in the passage of- this by law was played the Township’s Reeve, a subsequent founder in 1976 of PALS, Mel Swart.

Swart’s success in using Planning Act controls to restrict quarries played an important role in the creation of the Aggregate Policy of the Planning Act. Subsequently, both he as an Ontario Legislator and PALS played a major role in securing the agricultural policies of the act.

PALS’ deep involvement in land use planning and the OMB shows us why an appeal tribunal should clearly have an expression of the importance of land use planning in the long- term interest of future generations in its name. This would be most clearly expressed as the Ontario Land Use Planning Board.

6. Decisions of Ontario Land Use Planning Board Should be Final
PALS’ is opposed to the proposal in the draft legislation that alterations by a provincial appeals tribunal to a municipal council land use planning decision should , if a council continues to object after ninety days, require a second hearing in order to be upheld. In this regard our views are shaped by the OMB rejection of a proposed urban boundary expansion in the City of Niagara Falls in the watershed of the Ten Mile Creek. The council of Niagara Falls even had the temerity to appeal our OMB victory to the courts, which resulted in a cost award to PALS and Jean Grandoni. This appeal by the city is illustrative of the profound contempt municipalities in Ontario have for provincial policy. If found to be in violation of policy by a provincially appointed planning board , municipalities should not have a second hearing to argue their case.

An important role in our OMB victory was played by our lawyer, David Donnelly, who acts in effect as a policy advisor to many Ontario environmental groups. He has warned that the proposed double hearing process could turn the proposed LAT into a rubber stamp for municipal councils.

The victory of PALS and Jean Grandoni at the OMB was based on a number of violations of provincial policy. Critical to the victory was the testimony given under subpoena from PALS, of Mark Christie, a senior planner with the Ministry of Municipal Affairs and Housing. (MMAH) The essence of his testimony was that the urban expansion was not needed as it has been provincial policy since the 1980s that calculations of residential land supply should be made on an upper tier, (regional) basis. In opposition to PALS, the City of Niagara Falls and the Niagara Region argued that excessive land supplies in Port Colborne and Fort Erie should not be used to prohibit an urban boundary expansion in Niagara Falls.

Christie’s expose was one of many violations of provincial policy uncovered at the hearing. One was a failure to follow the protocols of the Canada Land Inventory, which require on-site soil tests when soil mapping results are challenged. It was also demonstrated that the agricultural policy was violated by the failure to consider lands of lesser capability in southern Niagara Falls. Another was to ignore the Niagara Region’s Official Plan’s implementation of provincial policy to protect natural heritage. An onsite visit by experts of all parties confirmed that the subject lands are a deer migration corridor. It also demonstrated that a forested area contained a vernal pool, which in violation of storm water management guidelines of the province, was proposed to become a storm water pond.

7. PALS Proposals are Modest Additions to Proposed Reform Package
In conclusion, PALS wishes to stress that our two proposed legislative alterations are reasonable and modest alterations to well-intended reforms. Municipalities’ failure to respond for many years to PPS policies and more recently policies for climate change, to curtail urban expansions, and the protection of bio diversity, show the need for an Ontario Land Use Planning Board whose decisions should be final.

Reproduced with permission. JohnBacherPhD.ca

Secret Peer Review of Botched Environmental Assessment, Dr. John Bacher

July 11, 2017July 11, 2017 Les Stewart Original writing

Another original article by Dr. John Bacher, first published by Mediacoop.ca:

The Media Co-op
June 15, 2017

Secret Peer Review of Botched Environmental Assessment
Freedom of Information Act Request Reveals Secret Peer Review of Thundering Waters Forest Development Scheme.
Dr. John Bacher

In the afternoon of July 7, 2016 in front of Niagara Falls City Hall native people and environmentalists from across Niagara gathered at a rally to call for the protection of the threatened Thundering Waters Forest. Here the Cayuga elder Alan Jamieson remarked how, “You have enough shopping centers.” in a plea to rescue the refuge. The Oneida environmental champion Karl Dockstader lamented how the planned “deforestation is an affront to the traditional indigenous leadership.”

“This is a no-brainer. “We the people” want to save the Thundering Waters forested wetland from development.” – Carla Rienzo

Following the indigenous rally many protestors went to attend a public participation session held in the basement of Niagara Falls City Hall. One of the most important bits of information to be disclosed there was that a peer review was underway of the draft Environmental Impact Statement (EIS) prepared by Dougan Associates for the proponent of the Thundering Waters development, GR Canada Investments. It was revealed that the environmental consulting firm doing the report was North/South Environmental.

What is quite bizarre was that although the North/South Peer Review was completed about a week later on July 15, 2016 its contents were not released to the public until ten months later. The 14 page report remained secret until a Freedom of Information Act request was filed by Ed Smith with the provincial government. Access fees of $350 dollars were paid for by various events in August 20016, such as a fund raising concert by citizens working to rescue the Thundering Water Forest from development.

The secret report was authored by ecologist Leah Lefler. It had considerable impact in shaping the comments about the draft EIS by Ian Thornton, of the Ministry of Natural Resources and Forestry, (MNRF). However, so far no Niagara politicians have acknowledged it exists.

Thornton found North/South’s peer review to be “Very thorough”, taking a position which “closely aligns with our comments.” It informed his conclusions conveyed to the Niagara Falls City Council just before its August 23rd meeting.

Lefler’ s criticism which stressed the need to study currently unprotected wetland areas for possible expansion and conduct acoustic surveys of the mature and old growth forested habitats used by endangered roosting bats, reinforced MNRF’s own analysis. This properly guided the Niagara Falls’ Planning Department’s advice to Niagara Falls City Council to delay the Public Meeting under the Planning Act legally required for any re-zonings to take place.

While Thornton’s advice properly suspended the momentum to destroy the Thundering Waters Forest on August 23, the process should have been terminated five weeks earlier. The Planning Act meeting should have never been scheduled. The North/South peer review clearly demonstrated that the recommendations of the draft Dougan EIS were not adequate to meet the requirements of Ontario and municipal law to protect natural habitats, wetlands and wildlife.

The key clash between the Dougan reported, authored by Stephen Hill, and Lefler was the issue of the need to expand the designations of provincially significant wetlands (areas protected from development), which at the time (the designations since have been expanded), comprised only a third of the 484 acre site. Lefler argued that adjacent then unprotected wetlands “should be evaluated…to determine if they should be complexed as part of the Niagara Falls Slough Forest Wetland Complex.”

Other documents obtained by the same access request show Niagara politicians denouncing the expansion of the Niagara Falls Slough Forest Complex as apparently arbitrary. These ignored however, the reality that this was done on the basis of research mandated by the City of Niagara Falls and the Niagara Region’s own policies for peer review of EIS documents.

Lefler also clashed with Hill over the need to protect dry forests in Thundering Waters. He stressed that provincial, regional and city policies all stressed that, “Development is not generally permitted” within such areas unless “no negative impact can be demonstrated.”

Lefler found that assumptions minimal impacts could not be justified without additional research. He calculated that the development would trigger the removal of “approximately 93 hectares of natural vegetation, including wetland, woodland and meadow vegetation.” There was however, in Hill’s EIS no discussion of the possible “impacts related to the removal of features, such as changes to wetland hydrology, loss of habitat, edge impacts, etc.” Lefler discovered that there was also silence “on how the proposed land use plan will maintain the existing water balance and hydrology” in the protected wetlands. He found that with such omissions “it is impossible to determine whether or not environmental impacts will occur and to what extent they are expected to occur.”

Lefler indicated that more work needed to be done for an adequate “Assessment of Significant Wildlife Habitat.” In this regards what was especially important for the peer reviewer was the habitats of endangered bats. He urged that to protect bats “tree cavity surveys should be completed” and that “acoustic surveys be completed.”

Considerable attention in Lefler’s critique was directed towards the future destruction caused by roads and traffic. In this regards Lefler noted that road construction was proposed through parts of the otherwise protected provincially significant wetland. He found that Hill ignored “the impacts to the features and ecological function” of these wetlands “from the construction and use of the proposed road network.”

Lefler detailed how not only roads through otherwise protected wetlands, but throughout the threatened Thundering Waters Forest would have terrible consequences for wildlife. Her peer review detailed how, “Roads are a major cause of mortality to small mammals, amphibians and reptiles.” One example cited show horrific devastation in 2014 on a 250 meter segment of road brought about the deaths from collisions of most of the 1,200 amphibians who attempted to cross it. “

Another clash between Lefler and Hill took place over the issue of what is an adequate width of a buffer. Hill’s report attempted to justify a minimal 15 meter buffer. In response the peer reviewer replied that, “In general, a wider buffer will better achieve the intended functions than a narrower buffer. In our opinion, a 30m buffer is necessary when wetlands or treed wetlands become surrounded with development in order to mitigate the increased stresses with urban land uses, particularly residential development.”

Lefler went into considerable detail to innumerate the extensive threats from residential development near treed wetlands. These included “encroachment, dumping of yard waste, invasive plant spread, domestic pets preying on birds and small mammal populations” and ad-hoc trails. He also stressed that without adequate buffers trees were vulnerable to being blown down by wind.

In addition to his “major comments” Lefler added 68 “minor or editorial comments.” One was that no studies for salamanders were on within the southern half of the property. Another concerned the approach towards the endangered Chimney Swift. Studies taken on the Eastern Whip-poor-will were found not to meet species at risk protocols. He identified a failure to assess vernal pools for “Significant Wildlife Habitat for Woodland Amphibian Breeding Habitat.” The denial of the presence of breeding habitat for the endangered Acadian Flycatcher was challenged.

The most revealing of the peer reviewers minor comments relate to a vernal pool obligate species, the Gray Treefrog. Lefler caught how while Hill’s text “states that only a couple of Gray Treefrogs were detected”, Appendix F in the EIS indicated, “that a total of 6 Gray Treefrog individuals were heard calling, which is more than a couple.”

The missing four male Gray Treegfrogs illustrate a broader problem with the Thundering Water’s scheme than even Lefler was able to capture through his stinging rebuke. While driving around the perimeter of the threatened forest, Adrin Willems and I on the evening of June 12, 2017 were able to hear around two hundred individuals give their short flute like trills. This symphony at risk is a treasure beyond the abilities of the best peer reviewer to capture.

Reproduced with permission. JohnBacherPhD.ca

Canada’s Largest First Nations newspaper and the Midhurst sprawl plan’s “junk science”.

June 20, 2017June 20, 2017 Les Stewart Original writing

Ontario continues to encourage Simcoe County as the “wild west of development/sprawl”.

Free download here.

First Nations Drum
April 1, 2017

Ontario Planner Struggles to Save Huron-Wyandot Homeland

By Dr. John Bacher (PhD) & Danny Beaton (Mohawk, Turtle Clan)

Opinion

The Turtle Island region of Huronia – otherwise known by its archaic colonial name of Simcoe County – is under environmental assault by urban sprawl. A blockade to stop Dump Site 41, the occupation of Springwater Provincial Park, and sacred water walks along the shores of Lake Simcoe are tactics being used to rescue the traditional territories of the Huron-Wyandot.

Victor Doyle is a senior planner with the Ontario Ministry of Municipal Affairs and Housing, (OMMAH) and is inspired by the earth-respecting spiritual actions of various Ojibway communities and their many Mohawks allies. Doyle has been with OMMAH for three decades and is at the epicenter of ongoing battles to protect this sacred land with his fighting for provincially-directed land use planning to rescue wildlife, farms, forests and water from human greed.

Doyle’s most avid opponents are twofold – corporations, and the powerful minions of developers who run Simcoe County (politicians). Doyle’s determination to stand up against their pressure has earned him their enmity. One such politician is former Mayor Doug White of West Gwillimbury, who as far back as 2010 dismissed Doyle’s defense of Ontario’s land use policies as the mere rantings of “one unelected provincial bureaucrat.”

Waawaasaegaaming (Lake Simcoe) Water Walk 2015, The Narrows, Orillia, ON. Photo by Les Stewart

Chief Planner of Toronto, Jennifer Keesmaat, has made Doyle the public voice on the issue, commanding media attention on the research of agronomists, foresters, conservation biologists, land use planners, hydrologists and municipally-controlled conservation authorities. Though no official title accompanies Doyle’s point-man position, his stature and prominence should be effective in forestalling or preventing further encroachment.

Two brave conservationists, Wayne Wilson and Patti Young, are no longer with the Nottawasaga Conservation Authority due to their opposition to urban sprawl from the booming City of Barrie spilling over into its watershed and into the community of Midhurst in Springwater Township. In 2014, both Wilson and Young departed under the guise of an NVCA “efficiency audit.” Young vacated her position first with Wilson following suit.

While such relatively obscure figures cannot get the media’s attention, Doyle’s warnings about violations of provincial land use policy ravaging Huronia have been published in two of Canada’s leading newspapers, the Toronto Star and the Globe and Mail. Doyle’s first warnings about Huronia appeared in the December 12, 2009 edition of the Toronto Star. The newspaper characterized his warnings as “a damming memo from Ontario’s senior planner” that paints “a stark picture of unsustainable sprawl, congestion and skyrocketing infrastructure costs if the province proceeds with a controversial strategy to urbanize large swaths of Simcoe County north of the Greenbelt.”

Waawaasaegaaming (Lake Simcoe) Water Walk 2015, Tudhope Park, Orillia, ON. Photo by Les Stewart

When penning his 2009 warnings, Doyle worried about schemes promoted by corporations to turn the small hamlet of Bond Head, a village of 500 people served by septic tanks, into a city of 114,000 persons. This threat still endures, although now in a more modest scale of a 30,000 hectare proposal. A new danger emerging is the construction of 10,000 housing units in Midhurst. The biggest problem posed by this development is the polluted runoff spilling into Willow Creek, which is a major source of water flowing into the Minesing Wetlands. The wetlands are an important refuge for rare, endangered and ecologically significant wildlife including the endangered Hine’s Emerald Dragonfly, Sturgeon, Bald Eagle, Trumpeter Swan, Sandhill Crane, Blue Winged Warbler, and various turtles.

As Doyle took to writing his second citizen report this spring, Ontario’s land use planning system’s “Co-ordinated Review” appeared to be on the brink of collapse. A freeze on urban boundary expansions – a key principle of both the Greenbelt and the Lake Simcoe Protection Plan – was under attack by media, developers and municipalities.

The Toronto Globe and Mail provided a link to Doyle’s full 27 page report titled “The Growth Plan and the Greenbelt Plan: Settling the Record Straight” where he vigorously defends urban boundaries. This led to a modest expansion of the Greenbelt on urban river valleys and on grape and fruit tree growing lands in Grimsby. While “Setting the Record Straight” saved the Greenbelt, it has not yet rescued Huronia. The warnings in the report do show why Midhurst, Bond Head and all of its remaining rural land need the protection of the Greenbelt.

Nonsense used to justify the urbanization of Willow Creek, such as the claim urbanization does not harm streams, is junk science, and has been refuted by Doyle using data from the watershed report cards assembled by conservation authorities. Using a study by the Credit River Conservation Authority, Doyle demonstrates how surface water in urbanized areas is always rated, “Very Poor” or “Poor” and explains that damaged watersheds are without any native fish, turtles or frogs.

Doyle said the main threat posed to Minesing Wetlands wildlife refuge from urban sprawl is “the major issue of habitat loss, which, in turn, is the key loss of bio-diversity.” Doyle warns refusal to extend the Greenbelt into Simcoe County is causing a mass sale of farms purchased by land speculators. His report states, “development interests continue to be speculatively buying or securing huge land assemblies tens of thousands of acres beyond the green belt.” The speculation in Simcoe County has led to farmland to commonly sell for $54,000 dollars an acre. In contrast, in the better regulated Waterloo region, farmland cost $14,000 an acre.

Doyle’s report illustrates the necessity of the struggle to protect Huronia inside the Greenbelt – a struggle made more difficult by the hostility we received while walking around Lake Simcoe with Ojibway environmental leaders in the “Walk for the Water.” My experience includes a driver of an animal control vehicle angrily scowling at us for taking a rest near a bicycle trail.

Those in Huronia that care for the earth should not be treated with contempt, but with the honor given to one standing-up for the sake of the entire community and the life web supporting it. The province must rescue Huronia by extending the Greenbelt.