Effects of proposed…

Effects of proposed development of the Duffins Rouge Agricultural Preserve on federal interests—Rouge National Urban Park and a potential Pickering Airport

I am writing to express my objections to the proposed excision of the Duffins Rouge Agricultural Preserve from the Greenbelt and its development, and its effects most particularly on Rouge National Urban Park. The name of the preserve itself suggests the two areas work hand in hand. This government’s actions will now sever one of these hands.

The removal of the agricultural preserve will generate significant challenges for the park and Parks Canada's management of it, and potentially pose implications for any future potential Pickering Airport. Ironically, Ontario’s proposed actions now pose a threat to the viability of the significant amount of land Ontario contributed to the park just a few years ago.

Overall Comments
Every analysis to-date, beginning with that of the Ontario Housing Affordability Task Force, has concluded that, as the task force wrote, “a shortage of land isn’t the cause of the [housing] problem.” What analysis has Ontario undertaken to refute this conclusion? What analysis supports the need to remove lands in the Greenbelt, in these specific locations?

Where is Ontario’s evidence that a chronically under-capacity trades industry can deliver the 150,000 housing units the province has targeted annually?

The Duffins Rouge Agricultural Preserve—How its loss could affect key federal interests
As important as the protection of intrinsically-valuable ecological and agricultural Greenbelt resources is the strategic buffer role of the Greenbelt. Location matters as well.

This critically-important role has been undermined by Ontario’s proposals, particularly in the proposed addition of the lands in the Galt Moraine—which are under no development pressure—and the removal of the Duffins Rouge Agricultural Preserve, which in addition to its intrinsic value, plays several strategic roles critical to the health and function of Greenbelt lands both adjacent to it and further afield. For instance, the Preserve contributes to the separation of urban Markham and Seaton, providing long-standing plans to create self-contained, complete communities. But most significant is the role the Preserve plays in supporting the ecological integrity and agricultural viability of its immediate neighbour—Rouge National Urban Park.

Implications of developing the Duffins Rouge Agricultural Preserve for Rouge National Urban Park
Ontario has transferred thousands of hectares of provincially- and TRCA-administered agricultural and ecological lands to Parks Canada over the past few years to help assemble Rouge National Urban Park. Ontario presumably maintains an interest in the continuing functioning of the lands it has transferred for the very purpose of farming and nature protection.
Development of the Duffins Rouge Agricultural Preserve could pose significant issues for Rouge National Urban Park, including:
• The agricultural preserve forms a key part of the only intact ecological connection in the entire GGH between the Oak Ridges Moraine and Lake Ontario, one of the fundamental roles identified in Parks Canada’s vision for Rouge National Urban Park. Its loss would undermine Parks Canada’s efforts to manage the park in support of this critical ecological connection.
• The loss of any buffer whatsoever between the park and adjacent urban areas in Markham and Pickering.
• The need for additional or widened roads and other infrastructure to cross the park to serve development of the preserve, and the additional road traffic in the park that will affect its ecological integrity, agricultural viability, and visitor experience.
• What is the potential for the loss of the “critical mass” of agricultural services needed to support the farming community in this part of the Greenbelt, such as seed sales and milling and farm machinery sales and repair? Has the province assessed the impact of removing the agricultural preserve on the ability of farming to continue in Rouge National Urban Park?
• When in 2013 Ontario agreed to transfer provincial and TRCA lands to Parks Canada it committed via a Memorandum of Understanding to consult with Parks Canada when considering changes to the Greenbelt. Has it done so? Does it intend to?

Effects on servicing a potential Pickering Airport
With respect to the long-standing question of an airport in Pickering, the federal government still holds 8,000 acres of land expropriated in the early 1970s for this purpose. Can Ontario confirm the servicing capacity used by development of the agricultural preserve will not constrain or impair any future federal plans to proceed with the Pickering Airport?

Federal Approval Requirements
One important factor that Ontario and municipalities MUST ACCOUNT FOR is the requirement of a federal environmental assessment for any new infrastructure that must cross Rouge National Urban Park to serve development in the Duffins Rouge Agricultural Preserve. Does Ontario even know what infrastructure might be required and where it must go? Has Ontario consulted with Parks Canada regarding the federal approvals required for infrastructure crossing the park and the amount of time the process takes?

Concerns over Ontario’s Approach to Public Consultation
• There is no evidence of consultation with Indigenous Peoples and First Nations in the material Ontario has posted.
• The timing of consultation for these many changes during a period of transfer of authority from old to new municipal councils leaves little room and time for any meaningful input from the municipal level. It is difficult to believe the timing was not deliberate. It leaves one with cynicism about the belief of this government in fundamental democratic processes.