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

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


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