October 4, 2017…

October 4, 2017

Honourable Minister Jeff Leal

Ministry of Agriculture, Food and Rural Affairs

1 Stone Road West

Guelph, Ontario

N1G 4Y2

Via webform for EBR Registry number 013-0968MGP File No.: 17-2616

Via email to: Minister.OMAFRA@ontario.ca

Dear Minister Leal and Ministry of Agriculture, Food and Rural Affairs Staff,

RE:Release of Draft Agricultural System Mapping and Implementation Procedures for Consultation

EBR Registry Number: 013-0968

Glen Eagle Golf Course, 15731 Highway 50, Town of Caledon

This letter is submitted on behalf of Royal Glen Eagle Investments Limited, the owner of Glen Eagle Golf Club (15731 Highway 50), located within the Town of Caledon (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 118 hectares (293 acres) in size and is located north of Castlederg Sideroad and west of Mount Hope Road in the Town of Caledon. The site is currently occupied by the Glen Eagle Golf Club. Existing estate residential communities border the west and north side of the property.

My Request

We are writing in response to the Province’s Release of Draft Agricultural System Mapping and Implementation Procedures for Consultation, EBR Registry Number 013-0968.

The purpose of this letter is to provide comments on the Province’s Draft Agricultural System Mapping and Implementation Procedures and specifically request:

•That the Province revise its Draft Agricultural Land Base Map to remove the designations of “Prime Agricultural Area” and “Candidate Agricultural Areas” as shown in Attachment A.

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 and Candidate Agricultural Areas designations (as shown in Figure 1).

Figure 1: Agricultural System Mapping Excerpt

See email correspondence.

The Subject Lands are 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.

Lands outside of the Natural Core Area is entirely designated Palgrave Estates Residential Community in the Oak Ridges Moraine Conservation Plan (ORMCP) as shown in Figure 2. The designation is a component of the Countryside Area and as per Section 14 of the ORMCP, residential development is permitted.

Figure 2: Oak Ridges Moraine Conservation Plan Mapping Excerpt

See email correspondence.

The majority of the subject site is located within the Palgrave Estates Residential Community in the Caledon Official Plan (“COP”). The southeastern portion of the subject site has been excluded from the Palgrave Estate Residential Community on Schedule G (see Figure 3). Town staff have confirmed the discrepancy between the COP and ORMCP as per our correspondence in early September 2017. As part of the Palgrave Estate Residential Area Policy Review, the study consultant (WSP) will be reviewing the schedules and make any appropriate revisions as part of the final phase of the study. The Review is in its initial stages and Council adoption of an OPA is not expected until December 2017 at the earliest.

Figure 3: Caledon Official Plan – Schedule G Mapping

See email correspondence.

It is my opinion that this portion of the subject site should be included within the Palgrave Estate Residential Community as it is a mapping error. It is my understanding that this will be corrected through the Review that is currently being undertaken. As a result, these lands should not have been analyzed as part of the Draft Agricultural System Mapping.

Furthermore, in the 1960s, the subject site was developed into a golf course, the Glen Eagle Gold Club, and the surrounding estate subdivision in its current form. The combination of recreational golfing uses and housing over the past 50+ years have rendered the lands not suitable for agricultural uses and therefore unsuitable to the Prime Agricultural Area designation.

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

Refinement of the Draft Agricultural Land Base Mapping

We understand that the draft Implementation Procedures for the Agricultural System in Ontario’s Greater Golden Horseshoe provide opportunity to refine the agricultural land base map during a Municipal Comprehensive Review (MCR) based on additional information and local context. MCRs may only be initiated by an upper- or single-tier municipality, in this case it means the Regional Municipality of Peel.

Further, we understand the Province expects refinements to mapped prime agricultural areas to be minor in nature and based on consistent mapping methods and specific refinement criteria. We believe our requested changes are minor and meet the refinement criteria described in Section 3.1.1.1 of the draft Implementation Procedures; specifically, the following criteria apply to the Subject Lands:

•Systematic review of local data including municipal LEARs and unique local circumstances not found in other areas

•Recognition of large areas of existing, permitted non-agricultural land uses that could not be rehabilitated to agriculture (e.g. developed rural industrial park, aggregate extraction below the water table)

As discussed, the lands that are designated prime agricultural lands in the draft mapping and has been operating as a golf course for 50+, which has rendered the site as unusable for agricultural purposes. Therefore, although permitted for agricultural uses in the COP, these lands would not be effectively utilized and therefore could not be rehabilitated to agriculture.

Therefore, we request the Province revise the draft Agricultural Mapping to remove the portions of the subject site designated Prime Agricultural Areas and Candidate Agricultural Areas from the mapping as shown on “Attachment A”.

Concerns with the methodology utilized in the review of the Provinces Agricultural System

The background studies and the methodology utilized in the review of the Provincial Agricultural System has been analyzed by AgPlan Ltd. whom specialize in agricultural impact assessments. AgPlan has indicated that they have significant concerns with background sources and assumptions utilized by the Province, and would like to further discuss theses concerns in a meeting with the Province. 

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 portions of the subject property from the Prime Agricultural Areas and Candidate Agricultural Areas designations. It is my opinion that these designations are 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 input into the Province’s Draft Agricultural System Mapping and Implementation Procedures and thank you for your consideration. We would further request to meet with you and your staff to discuss this matter and address any concerns you may have.

Respectfully submitted,

MALONE GIVEN PARSONS LTD.

Don Given, BA, MCIP, RPP, PLE

Principal

cc. Richard Pivnik, Royal Glen Eagle Investments Limited

Helma Geerts, OMAFRA

att/A Requested Revision to the Excerpt from the Draft Provincial Mapping of the Agricultural Land Base

 

ATTACHMENT A

Requested Revision to the Draft Provincial Mapping of the Agricultural Land Base

Remove “Prime Agricultural Area” and “Candidate Agricultural Area” Designations Glen Eagle Golf Club, Town of Caledon

[Original Comment ID: 211090]