EBR Registry Number 013…

   EBR Registry Number 013-1014 – Growth Plan Natural Heritage System.  City of Kawartha Lakes comments:

 The City of Kawartha Lakes, in collaboration with the County of Peterborough, City of Peterborough, Ministry of Natural Resources and Forestry (MNRF), local Conservation Authorities, local First Nations, the Ontario Stone, Sand & Gravel Association (OSSGA), and numerous Non-Government Organizations (NGOs), have worked collaboratively using MNRF’s Marxan System to create a mapped Natural Heritage System (NHS) for our geographic areas of the Greater Golden Horseshoe (GGH), in accordance with the policies of the 2005 Provincial Policy Statement (PPS), and more recently, the 2014 PPS.  The collaborative effort is called Kawarthas, Naturally Connected (KNC).  The process included extensive consultation and months of work over a five year plus timeframe, and after completion of the mapping, has been substantially “ground-truthed” by numerous organizations with an expertise in biology.  The results of this collaborative effort are contained here: http://www.kawarthasnaturally.ca/.

 The new proposed NHS mapping subject to this EBR posting, which ignores the extensive collaborative efforts undertaken to create an NHS system (most notably across the northern and eastern sections of the City), is excessive and places an overwhelming burden on landowners to justify change.  This is the result of using the 500 hectare core areas and excessive linkage widths which were applied as the baseline for this area of the GGH.  This Provincial mapping has also not taken into account some projects which have already received various approvals, including approved pits and quarries and draft approved subdivisions.  It should also be noted that we do not have draft policies to review in the context of the proposed NHS.  This will be an important component of implementing any proposed NHS.

 This process of creating a blanket approach to cover the entire area has followed the regionally defined NHS already created by our collaborative approach.  In essence, this is now putting the cart before the horse: the Provincial mapping should have preceded the detailed KNC refined mapping.  The KNC mapping project has considered the purpose of the NHS – to maintain, restore, or where possible, improve the diversity and connectivity of natural features in an area, and the long-term ecological function and biodiversity of a natural heritage system.  Policy 2.1.3 of the 2014 PPS notes that NHS’s shall be identified, recognizing that they will vary in size and form in rural areas and prime agricultural areas.  The KNC project has also accounted for developments which are already approved and ensured that we still maintain an NHS which maintains long-term ecological functions and biodiversity.  The Provincial blanket approach has not taken these factors into account.  In addition, the KNC project provided overlap with abutting municipalities both in and out of the GGH, to ensure that our Regional NHS can be linked to our neighbours, including those to the north (outside the GGH).  This would satisfy the purpose of a continuous GGH NHS with our neighbours.

 In the southern and western portions of the City, the approach has failed to recognize the appropriate NHS as a result of the 500 hectare core areas, which are non-existent as a result of agricultural operations.  The KNC NHS mapping identified many lands in the southern portion of the City which would be protected, restored, and enhanced as a result of the Marxan mapping work KNC conducted.  We note that in the western portion of the GGH, the Province took a different approach to the NHS mapping methodology, using 100 hectare core areas.  The Province has shown that the approach to the NHS can vary based on locational factors but have not identified the natural heritage features that would lead to this conclusion.

 The map viewer on the EBR posting has been sufficient for identifying the areas subject to the proposed Provincial NHS.  However, the mapping does not identify how the NHS has been prepared. The mapping needs to be updated showing the breakdown of features within the NHS – for example, it should, at a minimum, identify the difference between core areas and linkage areas.  City staff cannot accurately assess if the mapping is correct or if there may be errors in the mapping, without assessing the background data.  We request that the Province releases its detailed mapping to allow verification of the data.

 As a result, we recommend that the Province modify the GP NHS mapping for the City of Kawartha Lakes and our neighbours (the County and City of Peterborough) and replace it with the Regional NHS mapping created by our local collaborative (KNC), and as shown on the website noted above.  This mapping will provide consistent and reasonable protection to natural heritage features across our City, and including the trans-boundary areas with our neighbours (the Counties of Peterborough, Simcoe, Northumberland, and Region of Durham).  The mapping is already supported by the large number of participants which were party to its development.

 If the Province is not supportive of this approach, then as a bare minimum, it should be acknowledged that the Provincial NHS will allow for scoped natural heritage evaluations (NHEs), based on its very broad mapping, and areas located within the accurately defined locally Regional NHS will required a more fulsome NHE study to ensure protection of the identified features.  In addition, the Province should provide detailed mapping (identification) of the level of features used to create the Provincial NHS, such as identifying cores, linkages, and additional natural features.

[Original Comment ID: 211096]