September 19, 2017…

September 19, 2017

Honourable Minister Jeff Leal

Ministry of Agriculture, Food and Rural Affairs

1 Stone Road West

Guelph, ON N1G 4Y2

Attention: Helma Geerts, Policy Advisor, Ministry of Agriculture, Food and Rural Affairs

RE: Proposed Agricultural System Mapping

23 Brownlee Drive and 2820 Line 5, Town of Bradford West Gwillimbury

ICG Golf Inc., Bayview-Wellington (Highlands) Inc. & 2523951 Ontario Inc. (the “Bradford Highlands Joint Venture”)

This letter is submitted on behalf of the Bradford Highlands Joint Venture (BHJV), the owner of Bradford Highlands Golf Club and surrounding land (23 Brownlee Drive and 2820 Line 5), located within the Town of Bradford West Gwillimbury (herein referred to as the subject property). This letter represents my response to the draft Agricultural System mapping proposed by the Ontario Ministry of Agriculture, Food and Rural Affairs (OMAFRA).

Subject Site

The property measures approximately 59.5 hectares (147 acres) in size and is located west of Simcoe Road, south of Holland St (municipal address: 23 Brownlee Drive and 2820 Line 5) in the Town of Bradford West Gwillimbury. The majority of the site is currently occupied by the Bradford Highlands Golf Course and Golf Club. Existing estate residential communities border the west and southeast side of the property along Brownlee Drive and Golfview Boulevard.

My Request

The purpose of this letter is to respectfully request that OMAFRA remove the portion of the subject property designated Prime Agricultural Areas from the proposed Agricultural System mapping. It is my opinion that the proposed designation is not reflective or suitable for the subject property as the subject property is no longer suited for agricultural uses.

 

In February 2015, the province began the 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 plans, the Ministry of Agriculture, Food and Rural Affairs (OMAFRA) have proposed changes to the Agricultural System Mapping across the Greater Golden Horseshoe. The new detailed draft mapping shows the subject property within the proposed Prime Agricultural Areas designation (as shown in Figure 1).

Figure 1: Agricultural System Mapping Excerpt

See email correspondence.

Subject Site is Not Suitable for Agricultural Uses

It is my understanding the OMAFRA developed the draft mapping utilizing land already designated by municipalities in their existing Official Plans as well as additional lands identified through its Land Evaluation Area Review (LEAR) process. The subject site is not designated agricultural and should not be considered agriculturally important land.

The subject site is designated Rural in the existing Bradford Official Plan as shown in the figure below. As per Policy 7.3.1, lands designated Rural do not form part of a prime agricultural area and they are located in an area that is characterized by intensive non-agricultural development that precludes the long-term maintenance of viable agricultural operations.

Figure 2: Bradford Official Plan – Schedule A Rural Land Use Plan

In the early 1980s, the subject site was re-designated to “Rural” to permit a golf course, the Bradford Highlands Gold Club, and the surrounding estate subdivision in its current form. The combination of recreational golfing uses and housing over the past 25+ years have rendered the lands not suitable for agricultural uses and therefore unsuitable to the Prime Agricultural Area designation. As stated by Mr. Dale Toombs, an agricultural land use specialist providing evidence on the Subject Lands in the OMB Decision 0708 dated May 30, 2002:

“In the case of the ICG property (subject lands), the block of land in which it is located has been converted to a combination of housing and recreational golfing uses, which together have supplanted agricultural uses and make any return to agriculture on any portion of the block, including the golf course, extremely unlikely”

Due to the history and uses of the subject site, we believe that these lands are now non-agricultural in nature and unsuitable to the Prime Agricultural Area designation.

Conclusion

It is my understanding that the Province is proposing to incorporate comments as appropriate but will keep the map in draft form and allow municipalities, through the Municipal Comprehensive Review (MCR) process to refine the agricultural land base mapping with OMAFRA prior to final implementation in their respective Official Plan. I am supportive of this process and I respectfully request that OMAFRA remove the subject property from the Prime Agricultural Areas designation. It is my opinion that the designation is not appropriate for the subject property as the lands are no longer suited for agricultural uses due to its long history as a golf course.

We appreciate this opportunity to provide comments and revisions on the Province’s Agricultural Systems mapping and thank you for your consideration.

Respectfully submitted,

MALONE GIVEN PARSONS LTD.

Don Given, BA, MCIP, RPP, PLE

Principal

cc. Celeste Iacobelli, BHJV.

David Parks, County of Simcoe

Ryan Windle, Town of Bradford West Gwillimbury

[Original Comment ID: 211086]