October 4, 2017…

   October 4, 2017

  Ala Boyd

 Manager Natural Heritage Section

 Ministry of Natural Resources and Forestry

 Policy Division

 Natural Resources Conservation Policy Branch

 300 Water Street

 Peterborough, Ontario K9J 8M5

   Thank you for the opportunity to comment on the draft Natural Heritage System for the Growth Plan. The following provides the Golden Horseshoe Food and Farming Alliance  summary and analysis of the proposed NHS for the Growth Plan in relation to its implications for the Agricultural System and the agricultural sector.

   Proposed Growth Plan NHS Methodology

  The methodology identifies the principles, criteria and methods used to develop the draft NHS map for the Growth Plan.  The mapping criteria and methods were selected to identify a system at a regional landscape scale for the Greater Golden Horseshoe and are not intended to identify or connect all natural areas and features that may be important at a smaller regional or local scale. 

 Based on the application of the criteria and the scale of the mapping, the Allliance notes that the methodology looks to have identified and mapped natural features within the NHS in the Prime Agricultural Area and Rural Lands, where they do not appear to exist on the landscape. Actual features are not identified on agricultural lands in  the Natural Heritage System and farmers need to be aware of features.

  Currently, for agricultural lands, mapping is contained on two maps – Agriculture Systems and Natural Heritage Systems and you need to look at 2 different website to access the information.  In reality, the Natural Heritage System should be an overlay to the Agricultural Systems mapping and available in one view.

  Although agricultural, agricultural-related and on-farm diversified uses are permitted in the NHS, the Growth Plan does prohibit new development and site alteration and new buildings and structures in natural features, with some exemptions for expansions to existing agricultural, agricultural-related and on-farm diversified buildings and structures.  The inclusion of large areas of farmed tableland in the NHS could potentially impose new regulatory burdens on farm and farm-related buildings as the Growth Plan NHS policies for natural features are more restrictive than the Provincial Policy Statement’s no negative effects policy. The Province should consider how it establishes regional scale criteria for the NHS and ensure that it does not extend to large areas of agricultural land in order to avoid unnecessary regulatory burdens on farming.

      Recommendations

  The following are recommendations from the GHFFA in response to its review of the proposed Provincial Regional Natural Heritage System (NHS) for the Growth Plan and its implications to the Agricultural System and the agricultural sector. These recommendations are for consideration as the GHFFA’s formal submission to the Province.  It is recommended that:

  •Province release the GIS shape files for the draft Growth Plan NHS to enable municipalities to undertake an accurate comparative analysis and to verify the proposed NHS boundary and natural features.

 •The Province should consider how it establishes regional scale criteria for the Growth Plan NHS and ensure that it does not extend to large areas of agricultural land in order to avoid unnecessary regulatory burdens on farming.

 •Boundaries of the Growth Plan NHS be reviewed by the Province to verify that the methodology and criteria is accurately applied, identified and mapped.

  •Implementation of the Growth Plan NHS boundaries should permit appropriate refinement by municipalities in consultation with the Province.

  •Agricultural lands are adaptive by nature.  Depending on market conditions, cropping cycles, labour and weather conditions, it is appropriate for some agricultural lands to be left in a fallow condition for periods of time.  Fallowing of land is a normal farm practice.  It is not appropriate for agricultural land left fallow for 4 years to be returned to natural heritage designation.  This is not an acceptable practice.  Historically farmed land should remain in farming.

  Thank you for the opportunity to comment on the Natural Heritage System.  Should you have any additional questions, or require clarification, please do not hesitate to contact our Executive Director, Janet Horner at janet@whitfieldfarms.com.

 Sincerely

  Bill Hodgson

 Chair,

 Golden Horseshoe Food and Farming Alliance

[Original Comment ID: 211109]