1. The natural heritage…

1. The natural heritage policies adopted by the Region should NOT be approved by the Ministry. All OPA's across Ontario should only contain the provincial minimum standards prescribed by the province. These standards have been professionally developed over time. They have been developed by multiple Ministries using qualified science. These would include MNR, MOE, MMA&H and several others. They were developed over time and are well-informed by real life development experience. They also contain expertise submitted by professional consultants over many years.

Conversely, in the leadup to the current municipal election the Region of Niagara politicians were bullied by an environmental lobby to adopt a natural heritage plan that goes well beyond provincial standards. They did so against their own staff and professional consultant original advice. It is not at all based on science but rather on 'concepts' advanced toward stopping all greenfield development. Concepts aggressively advanced by a small but effective lobby group.

This plan advances greater than needed setbacks around environmental safeguarded areas; accepts a concept of 'linkages' which will sterilize otherwise developable land; by doing so it will actually force municipalities to inefficiently extend urban boundaries even further afield than they might otherwise have to, in order to bring in enough development land to meet provincial growth target requirements. Public infrastructure will have to be extended further afield which is costly and inefficient.

This plan goes well beyond what other Ontario municipalities require. The plan will reduce the immediate, medium term and long term supply of housing thereby exacerbating the current housing supply and affordability crisis throughout Niagara. It runs counter to the provincial governments goals meant to ease the housing shortage and the affordability crisis.

2. All Employment Areas are supposed to have very close proximity to a 400 series highway. Since 2007, the Places to Grow Act, has identified the lands adjacent to the QEW between Fort Erie and Niagara Falls as the most important employment lands in Niagara. The province further recognized these lands with its own identification of the eastern portion of the future mid-peninsula corridor running along Netherby Road, intersecting with the QEW at the midpoint of this Gateway Economic Corridor. The Region, I believe in Appendix C, properly identified this QEW corridor for future employment areas.

These lands, along with other properly identified lands adjacent to the QEW throughout the Region, should be the Employment Areas for the Region. Together, they would more than meet the Region wide employment lands required by the provincial growth targets. In recognizing these lands now, the province would free up other lands that the OP currently tries to define as employment lands and areas. These lands could and should be converted into commercial and residential uses now.

A prime example of this is in St. Catharines. The Council there is attempting to change lands on Lakeshore and Seaway Haulage Road, the Port Weller lands, from employment lands to employment Area. These lands have been employment lands since the 1970's and have never been developed. The Regional economic development staff won't even recommend these parcels to outsiders looking for industrial land, because "their trucks would have to traverse 10kms of heavily populated intercity roads just to get to Port Weller".

The city council wrongly assumed that they had to change these lands to employment Area to accommodate converting the heavily polluted Ontario Street GM lands to residential, to help that landowner afford to clean up those lands. Those lands are heavily polluted with PCBs, asbestos and other materials. Original owners General Motors even attached a provision to these lands, that the buyer could never use them as residential lands unless they agreed to take over GMs long term environmental liability on the properties. These lands as residential would require years of cleanup and an estimated $50 million of developer or likely local taxpayer money (from CIPs attached to the lands) to get them cleaned to a state where one could even consider putting housing on them and selling them to unsuspecting citizens desperate for housing.

They city and Region should leave the Port Weller lands as employment lands. These are clean lands that can be developed more cost efficiently and developed now. They should see mixed use development with some commercial, some residential and some warehousing. Such a use would assist businesses at the nearby drydock lands, would provide a growing number of nearby residents with access to commercial and retail supplies and services of which they currently have NONE. It would allow 700 units of affordable housing to be added within a year or two. Changing the land designation here to employment Area will provide less future flexibility for these lands to be developed and will require another Region or city wide Land Needs Analysis and MCR. The lands should be left as employment lands general.

At the same time, other properties throughout the region adjacent to the QEW, already identified by the Region in the OP, should be designated Employment Area thereby providing an ample supply of these lands in the proper location for the entire region.