October 6, 2017…

   October 6, 2017

  Ala Boyd, Manager – Natural Heritage Section

 Ontario Ministry of Natural Resources and Forestry

 Policy Division

 Natural Resources Conservation Policy Branch

 300 Water Street

 Peterborough ON

 K9J 8M5

  RE:EBR Registry No. 013-1014: Criteria, Methods and Mapping of the Proposed Regional Natural Heritage System for the Growth Plan for the Greater Golden Horseshoe

  The Township of East Garafraxa submits the following comments related to the aforementioned EBR Registry Notice No. 013-1014.

  The Township of East Garafraxa contains many significant environmental areas and features. The valley systems, significant forest areas, Provincially and locally significant wetlands, Areas of Natural and Scientific Interest, and other natural areas in the Township provide habitat for a wide range of species. While the Township of East Garafraxa’s land base is dominated by productive farmlands and viable agricultural operations, the Township of East Garafraxa has developed an Official Plan that balances the needs of the residents of the municipality and protects the agricultural and natural resource base that is so important to the municipality.  The Township continues that process through its current Official Plan review.

  The Township of East Garafraxa has identified and designated significant Natural Heritage Features in their Official Plan. The identification of significant Natural Heritage Features was based on input from the Grand River Conservation Authority and Credit Valley Conservation. The study was the subject of mandatory and rigorous examination by the public and agencies including the Ministry of Municipal Affairs. It is the Township’s opinion that the accuracy of mapping of significant natural heritage features, as set out in the municipal Official Plan must be acknowledged and supported by the Province.  Additionally components of this mapping was agreed to in settlement by the Province of the appeal of OPA 4, with that settlement endorsed by the Ontario Municipal Board.  Further, the Township continues to review Natural Heritage Features through its current Official Plan review process which ensures the appropriate technical and public engagement in the consideration of these features.

  The Township of East Garafraxa is of the view that the general mapping prepared by Province as part of the proposed regional Natural Heritage System for the Greater Golden Horseshoe does not provide an accurate reflection of the Natural Heritage System in the Township.  The local mapping of significant natural heritage features and associated corridors/linkages does not appear to have been appropriately considered by the Province in developing their mapping. In the Township’s view this local mapping is more accurate and reflective of local conditions and provides for appropriate stewardship and protection of the Township’s Natural Heritage System. In particular, it appears that the proposed linkages/corridors are too wide and include extensive tracts of non-natural ecosystems, including active mineral aggregate operations and prime agricultural lands.

  Further the Township of East Garafraxa is of the view that it is incumbent upon the Province and MNRF to defer the implementation of this proposed mapping until there has been significant and transparent municipal and public engagement by the Province and MNRF to ensure that concerns have been appropriately addressed. The Township of East Garafraxa is concerned that the draft Natural Heritage System Mapping appears to ignore non-environmental designations, including prime agricultural lands and long-standing industrial designated lands.

  We thank you for consideration of these comments.

  Yours very truly,

  Susan Stone

 Chief Administrative Officer/Clerk Treasurer

[Original Comment ID: 211150]