As a supplement to my…

As a supplement to my previous comments and as a counterpoint to comments that have or will be coming from the Town of Grimsby, who are requesting that the parcels in the Town, that being parcels at 502 Winston Road and Cline Road in Grimsby, not be re-included as part of Bill 136, I would like to offer the following:

One of the rationale put forward by proponents and the Town of Grimsby not to reinclude the removed/altered parcels is that they are not being used for agriculture and/or nothing is being grown on them. This is a ridiculous and tenuous argument and is akin to saying that an empty lot is unsuitable for a restaurant, since there is no restaurant currently there.

The fact there may be no agricultural there at the moment, does not preclude them from being productive agricultural land in the future.

A second point that needs to be raised, is that at least for the parcel at 502 Winston Road, much of that soil has never been mapped. It along with the Rogers radio tower lands immediately to the west, were not mapped and still are not mapped because these parcels were being used for non-agricultural purposes.

The Town of Grimsby's submission to the last MCR of the Greenbelt, which undoubtedly will be accompanying their comments, notes in the Specialty Crop Report's conclusion that for the northern Greenbelt area, which includes 502 Winston Road (first screenshot):

"the north section of lands proposed to be removed from the specialty crop area designation has 70% of the area not mapped for soils (in 1989 the land use was non-agricultural and therefore not mapped) or developed for non-agricultural uses;"

Furthermore, the proponent at 502 Winston Road, New Horizon Development Group had a AIA study commissioned to support their proposed change of Greenbelt Designation. Much like the Town's report, the report did not map the soils on the subject lands. Instead they used a "secondary study area", delineated by the circle on the second screenshot.

This approach is flawed, the subject lands are 100% unmapped/unrated and the secondary study area is 81% unmapped/unrated (third screenshot). Furthermore the secondary study area includes large amounts of lands that sit a great distance from Lake Ontario. Even if the sample size was sufficient, those soils may be quite different from those that are adjacent to the lake and affected by the lakefront microclimate.

As such, the lands at 502 Winston Road and those at Cline Road should be fully returned to their previous Greenbelt status. These are Specialty Crop lands, the highest order and valuable lands in the Greenbelt.

Should there ever be a will to remove or designate them from full Specialty Crop protection, especially the 502 Winston Road lands or any adjacent parcel, by future regulation, the Province, as an impartial entity, should conduct soil mapping of these unmapped areas to determine the appropriateness of the Specialty Crop designation.

It would be remiss and completely irresponsible to the environment and future food security to allow any development to proceed on these lands based on an absence of important soil data. For the Winston Road lands, development at this location would cause a "mushy edge" to the Greenbelt and encourage further destruction of one of the largest open areas on the southern shore of Lake Ontario.