October 4, 2017…

       October 4, 2017

    The Honourable Kathryn McGarry

 Minister of Natural Resources and Forestry

 Ministry of Natural Resources and Forestry Whitney Block 6th Floor, Room 6630

 99 Wellesley St W Toronto, ON M7A 1W3

  MGP File:     17-2594

  Attention: Ala Boyd, Manager – Natural Heritage Section, Ministry of Natural Resources and Forestry

 RE:        Proposed Natural Heritage System Mapping

 EBR Registry Number: 013-1014

 Craighurst Lands, 3555 Penetanguishene Road, Township of Oro-Medonte

 Craighurst Land Corporation

   Malone Given Parsons Ltd.  (“MGP”) are the planning consultants representing Craighurst Land Corporation (“CLC”), owners of approximately 76 hectares (188 acres) of land municipally known as 3555 Penetanguishene Road (the “Subject Property”). The Subject Property is located on the east side of Highway 93 (Penatanguishene Road) at the northeastern corner of the Craighurst Secondary Plan. The western portion of the property is located within the Craighurst Secondary Plan (~55 ha) and the remaining eastern portion of the property is outside the Settlement Area (21 ha). This letter is submitted on behalf of CLC as portions of their landholdings (Figure 1) have been identified in the Province’s draft mapping as additional lands to be included in the Natural Heritage System.

 The Request

 We are writing in response to the Province’s Release of Draft Natural Heritage System Mapping, EBR Registry Number 013-1014.

 The purpose of this letter is to provide comments on the Province’s Draft Natural Heritage System Mapping as it relates to the subject property and specifically request:

  •that the Natural Heritage System (NHS) mapping remain in draft form until local municipalities can effectively review the mapping and make any refinements to the proposed additions to the NHS through the Municipal Comprehensive Review (MCR) process; and,

 •that a correction to the mapping be made that is consistent with the site work that has been completed to date for the subject site.

    In February 2015, the Province began their Co-Ordinated Land Use Planning Review which culminated in updated provincial land use plans for the Greater Golden Horseshoe.  Four updated plans were released in May 2017: the Growth Plan for the Greater Golden Horseshoe, the Greenbelt Plan, the Niagara Escarpment Plan and the Oak Ridges Moraine Conservation Plan.

  With the release of the updated plans, the Ministry of Natural Resources and Forestry (MNRF) has prepared draft mapping of the Natural Heritage System (NHS) across the Greater Golden Horseshoe. The MNRF has indicated that the NHS mapping will be finalized by the end of 2017 with municipalities having to identify and protect in their Official Plans what the Province has defined in their mapping. The new draft mapping shows a portion of the subject property within the proposed NHS designation (as shown in Figure 1).

  Figure 1 – Subject Property on Natural Heritage System Excerpt

 See email correspondence.

  Our consultant team has commenced detailed site work for the Subject Property in advance of a forthcoming formal submission to the Township of Oro-Medonte. We have completed preliminary constraint mapping that identifies the significant natural heritage constraints within the study area.  As a result of this work, we respectfully request a correction to the mapping that is consistent with the identification of the natural heritage constraints as recently identified by our consultants, as shown in Attachment A.

    Conclusion

  It is our understanding that the Province is proposing to incorporate comments to the NHS as appropriate and are aiming to finalize the mapping by the end of 2017 with municipalities having to identify and protect in their Official Plans what the Province has defined in their mapping. We do not support this process but rather recommend that the Province adopt the process taken by the Province/Ministry of Agriculture, Food and Rural Affairs for the Agricultural System mapping, that is to say, that the proposed NHS mapping remain in draft until finalized through the MCR process.

  We also respectfully request that the MNRF remove the portion of the Subject Property identified as Natural Heritage System as per Attachment A as these lands do not have environmental constraints. We would be willing to meet to discuss the site work that we have completed for the Subject Property.

  We appreciate this opportunity to provide comments and refinements to the Province’s Natural Heritage System mapping.  Thank you for your consideration.

     Respectfully submitted,

 MALONE GIVEN PARSONS LTD.

    Matthew Cory, MCIP, RPP, PLE, PMP

 Principal, Planner, Land Economist, Project Manager mcory@mgp.ca

   cc.  Craighurst Land Corporation

 Derek Witlib, Township of Oro-Medonte

     ATTACHMENT A

 Requested Revision to the Draft Provincial Mapping of the Natural Heritage System

 Subject Property, Township of Oro-Medonte

[Original Comment ID: 211114]