OSM Township is a lower tier…

OSM Township is a lower tier municipality within the County of Peterborough in the outer ring of the Greater Golden Horseshoe. OSM takes great pride in its local land use policies and mapping that protect and support our agricultural sector. The Township does have concerns with the implementation procedures for the Agricultural System in Ontario's Greater Golden Horseshoe and in particular the mapping of the agricultural land base here in OSM for the following reasons:

- the OSM Official Plan is separate from the Peterborough County Official Plan. The OSM OP (2015) was developed in consultation with OMAFRA staff, approved by the Ontario Municipal Board and the County of Peterborough. The OSM OP has more comprehensive and up-to-date mapping for the prime agriculture lands within OSM Township than the County OP used by the Ministry in their mapping.

- the OSM Official Plan already identifies and designates prime agricultural lands in a separate category from rural lands in our Official Plan. The mapping of Ag versus Rural in OSM has not been taken into account when preparing the Agricultural Land Base mapping. Nor does the current mapping tool allow for any analysis of the impact of the proposed new mapping in OSM, particularly within the very limited time period for comments.

- Both the Agricultural and Rural designations in OSM provide for agriculture and only limited, site specific development is permitted on the Rural lands outside of prime agriculture. All designations in OSM (outside of the Settlement Areas and Shoreline) currently require new development to comply with MDS . There is no benefit to agriculture by placing the more marginal lands currently designated Rural into the prime agricultural category.

- the OSM Official Plan identifies and designates a Commercial Corridor along Highway 7 east of the City of Peterborough as well as lands at the intersection of Highways 7 and 28. These highways are identified as Transportation Corridors in the Growth Plan. OSM has designated the adjacent lands as Commercial/Employment Areas in accordance with the goals and objectives of the Growth Plan to provide areas for employment growth. These land use designations have not been accurately recognized and excluded from the mapping of the prime agricultural lands.

- OSM Township is located within the heart of the Peterborough Drumlin field. Our landscape is variable and the use of aerial photography to interpret agricultural capability without understanding the contours does not take into account the limited nature of agricultural production on steep slopes. The LEAR analysis appears to make assumptions about what might appear to be an agricultural field in production when what you might be looking at is a vegetated area on the side of a hill or low-lying lands which regularly flood.

- Within the Peterborough Drumlin Field, and particularly within OSM Township with its many egg-shaped hills of variable sizes, stormwater runs radially down all sides creating wetlands and watercourses between the drumlins. The OSM Official Plan recognizes these unique environmental features through the use of Environmental Protection designations. While agriculture is permitted setback from the edges of the wetlands and watercourses, the EP designation is intended to protect the species at risk and important hydrogeological functions of these environmental areas. In addition, the wetlands and watercourses in OSM serve as important water storage areas, particularly during the spring melt as well as the "100 year" storms which seem to be now happening every year. All persons, including farmers, need to recognize, protect and keep activities - including agriculture, outside of these flood storage and floodplain areas.

OSM is part of the very large Trent watershed. The floodplains along our waterways, including the Otonabee River, Indian River, Rice Lake and their many tributaries, need to be protected to prevent damage to property and the life/safety of residents - both upstream and downstream. It has long been known that agricultural production up to the water's edge is not recommended due to the potential for erosion/soil loss and environmental degradation. All significant environmental features should continue to be recognized and mapped as Environmental Protection. These lands as set out in the OSM Official Plan should be excluded from the mapping of the Agricultural Land Base. OSM staff have concerns that the proposed use of an "underlay" rather than an EP designation for environment features will place these important natural areas, including species that inhabit them, at potential risk.

- The Growth Plan and Provincial Policy Statements provide for recreational opportunities within the Rural areas of Ontario. OSM has identified limited Shoreline designations where recreational developments are permitted occur along Rice Lake and the non-floodplain areas of the Otonabee River. This shoreline is an important part of the economy as tourism is one of the main sectors here in Peterborough & the Kawarthas. While some lands within the shoreline designation may continue in Agricultural production, the OSM OP land use designation has long identified these areas for tourism-related uses. It is the Township's position that the Shoreline designations as set out in the OSM Official Plan should be excluded from the Agricultural Land Base mapping.

- The Township questions the proposal to place other Rural land uses normally designated in a separate land use classification into the Agricultural Land Base. Examples are the lands currently designated as Aggregate to protect the resource and provide for licensed pits. It is agreed that these lands may be used for agriculture and that many pit rehabilitation plans provide for lands to return to agriculture, but the Aggregate designation provides for highly detailed policies that govern the development of these lands. In addition, the Aggregate policies ensure that these areas are protected from incompatible land uses which would otherwise occur within an Agricultural designation. It is unclear how the Agricultural Land Base mapping will take these unique and limited resource areas into account.

- Another designation that should be recognized as a separate entity is the Waste Disposal designation. The regional City/County Bensfort Landfill is located within OSM. Likewise there are several closed landfill sites across the Township which have been mapped as prime agriculture. Due to the potential for offsite contamination, the Ministry of the Environment and Climate Change has requested that these landfill sites be clearly identified in the OP mapping and a 500 metre buffer applied to require environmental review for any new sensitive land use. Once again agriculture may not be restricted but farmers as well as others using these lands (and staff answering their questions) need to be aware of the restrictions. Special designations ensure that these sites are not overlooked or forgotten and the landfill sites should be excluded from the Agricultural Land Base mapping.

In conclusion, the Greater Golden Horseshoe is not made up solely of Settlement Areas with a surrounding Agricultural Land Base. Rural municipalities include a number of important components that support of the Ontario economy, protect the environment and provide for both population and employment growth outside of urban centres. These important features have been recognized in our Official Plans since the 1970s. The policies and mapping of each Official Plan have been refined in consultation with the Province and the County based on experience here in OSM over the past 40+ years. A LEAR analysis at the Provincial level should not, seemingly overnight, replace this wealth of local knowledge.

OSM Township believes that the protection of prime agricultural land is important for the Province, the County and our municipality. However, when policies are applied or areas mapped in OSM, there needs to be a more local context in order to take into account the variable landscape. The topography and drainage patterns here in Peterborough County result in a much more variable and diverse landscape than the LEAR analysis used by the Province suggests for our region. If OMAFRA wants to truly collaborate and augment the LEAR analysis with local information, the County and its affected local municipalities would need the time, resources and funding to carry out a detailed analysis that can be "ground truthed" in consultation with our local agricultural community.

Let's take the time needed to work together to implement an Agricultural System and Agricultural Land Base mapping that recognizes the reality of rural Ontario and OSM.

Thank you for the opportunity to comment and the time spent by OMAFRA staff to hold webinars, information sessions and the conference call with OSM about the new agricultural policies and mapping. Otonabee-South Monaghan has offered to share our Official Plan mapping with the Ministry via the County of Peterborough GIS system. Please do not hesitate if you require any other information or clarification in order to review our EBR submission. ........................................

[Original Comment ID: 211081]