Dear Ms. Geerts:…

Dear Ms. Geerts:

Thank you for the opportunity to comment on the draft Agricultural System mapping and implementation procedures for the Greater Golden Horseshoe (GGH).

The Toronto and Region Conservation Authority (TRCA) protects and manages approximately 18,000 hectares of conservation land and assists its 18 member municipalities in fulfilling their responsibilities associated with natural heritage, water resources and natural hazard management under the Planning Act and Environmental Assessment Act processes. TRCA has an interest in the development of the GGH Agricultural System primarily given its roles as a service provider to municipalities supporting their implementation of provincial policy, as a resource management agency and regulator in accordance with the Conservation Authorities Act, and as a major landowner in the Greater Toronto Area. TRCA leases some of its land to farmers and manages approximately 400 hectares in its agricultural land inventory. TRCA’s Sustainable Near-Urban Agriculture Policy (2008) permits and encourages agricultural uses on TRCA owned and managed lands, where appropriate, as a component of sustainable communities. The Policy recognizes that agricultural land is a vital resource that must be conserved and that progressive environmental stewardship in the agricultural sector and the production of local food for the Toronto region are requirements for TRCA and its partners to collectively realize The Living City vision.

In 2015 and 2016, TRCA provided comments and recommendations to the Province as part of the Coordinated Review of the Growth Plan for the Greater Golden Horseshoe, Greenbelt Plan, Oak Ridges Moraine Conservation Plan, and Niagara Escarpment Plan. We are pleased that many of our comments are reflected in the updated plans and recognize the importance of establishing the GGH Agricultural System in a timely manner to facilitate the implementation of the new policies.

Based on our review of the draft Implementation Procedures, Agricultural Land Base map, and Agricultural System portal released for consultation, TRCA would like to provide the following comments. Note that these comments should be read in conjunction with TRCA’s comments on the proposed regional Natural Heritage System (EBR # 013-1014).

Remove the Oak Ridges Corridor Conservation Reserve from Prime Agricultural Area

The Oak Ridges Corridor Conservation Reserve in Richmond Hill has been included as a prime agricultural area in the draft agricultural land base. Restoration has been completed for a number of years now on the former agricultural lands owned by the Province and the majority of this area is no longer suited for agriculture. This restoration, including tree and shrub planting as well as wetland creation, has been successful due to the quality of the soils. The opportunity for agriculture now exists only on a small portion of the lands. The remainder of the lands has significant natural and cultural heritage value and provides nature-based recreation and outdoor education opportunities. Furthermore, they are part of the Greenbelt Natural Heritage System and the Oak Ridges Moraine Conservation Plan Natural Core and Linkage areas, and are not designated as agriculture in either the Richmond Hill or York Region official plan. TRCA supports York Region’s recommendation that this area should not be included in the prime agricultural area in the agricultural land base.

Integrate urban agriculture components into the agri-food network

It is important for the Agricultural System to recognize the role of urban agriculture in helping achieve many economic, social, and environmental objectives. Even though the agricultural land base does not extend into urban areas, urban agriculture features are an important part of, and should be included in, the agri-food network. Specifically, urban lands where agricultural activity is occurring (e.g. open space and parks used for community gardens) or that have been made available for agriculture to occur should be mapped in the Agricultural System portal and recognized in the Implementation Procedures. Mapping these urban agricultural opportunities would facilitate planning for urban agricultural activities and demonstrate their functional and economic connections with the broader regional Agricultural System. It could also help broaden the uses of the portal, for example to provide opportunities for potential new farmers without rural connections or farming backgrounds to engage in farming within or near cities.

Ensure information on the Agricultural System portal is updated and practical

The Agricultural System portal is a useful tool for informing agricultural impact assessments and economic development and land use planning. It can also enhance agricultural viability by providing pertinent information for farmers. To that end, OMAFRA could consider including additional information on some agri-food network components that would be helpful to potential users. For example, information regarding the size of processing facilities would enable smaller-scale farmers to easily identify facilities they can use. In addition, clarification on how and when updates to the mapping layers in the portal will be made – for example, to reflect crop layers that may change yearly – would be helpful.

Include the regional Natural Heritage System in the Agricultural System portal

The Ministry of Natural Resources and Forestry’s technical report for the development of the regional Natural Heritage System (NHS) for the GGH indicates that the proposed NHS falls on 28% of the region’s prime agricultural areas. However, as the mapping for these two systems has been provided on different map viewers, it is currently impossible to systematically identify these areas and plan for agricultural and ecological functions in these areas. Once the maps for the NHS and agricultural land base are established following this consultation, the Province should not only provide public access to associated GIS data, but make these mapping layers available to view on the same online portal so that municipalities, planning authorities, and landowners are better able to plan within these areas. Additionally, these layers should be integrated and included with other existing provincial data sets, viewers and portals from other Ministries, where appropriate.

Consistency and Clarity in Language and Definitions

The language used in the Implementation Procedures document that references or defines the various natural heritage systems (NHS) needs to be very clear and precise to avoid confusion in implementation. Multiple NHS are now included and subject to different policy frameworks. Local-scale NHS in settlement areas are subject to the policies of the Provincial Policy Statement (PPS) and implemented as a land use designation. The Greenbelt NHS (Greenbelt Plan) and the Regional-scale NHS (Growth Plan) are each subject to their own respective policy frameworks and implemented as an overlay (to the underlying designations). In that light, the following sections of the document should be clarified and/or amended as follows:

Section 1.6 – Clarify that Figure 2 (page 14), showing the NHS as an overlay, is NOT applicable to all NHS (as described above). Also, additional text is needed to indicate that Key Natural Heritage Features (KNHF), Key Hydrologic Features (KHF) and their Minimum Vegetation Protection Zone (MVPZ) plus hazard lands, should NOT contain an agricultural designation. Fig. 2 also needs to account for the future Water Resources System, which requires its own designation, as per Growth Plan policy 4.2.1.2.

Section 2.1.2.4 - Significant refinements to the draft mapping and implementation guidance are required to ensure that finalized agricultural land base mapping clearly illustrates the intent of planning authorities to maintain a balance of broad contiguous areas for both agricultural uses and a protected, linked and restored natural heritage system that avoids competing and conflicting land uses on a working landscape. The current mapping and implementation guidance does not achieve this objective.

Section 3.1.1.1 - The way this section on Prime Agricultural Areas is written means that significant refinements are required to the provincial agricultural land base map. Local and single‐tier land use mapping of local‐scale natural heritage systems, features and areas, water resource systems and natural hazards, for example, must be either recognized in the provincial agricultural land base map or the implementation provisions must be broadened to allow planning authorities to refine the mapping for both of these systems. Significant public and private landholdings for environmental protection, such as conservation areas, KNHF, KHF and their MVPZ, and hazard lands must be removed from the agricultural land base map following local consultation.

Section 3.1.1.3 needs to be clarified to confirm the difference between regional‐scale and local‐scale systems, which has been lost in this section of the guidance document. Direction to promote new agricultural uses within local‐scale NH systems is often not appropriate, especially within features. Outside of settlement areas, permitted land uses in features and associated vegetation protection zones in the NHS are governed by Growth Plan policy 4.2.3.1. NEW agricultural uses are NOT permitted. Additionally, a recognition of natural hazards should be included in this guidance document.

Thank you once again for the opportunity to provide comments on this important initiative. Should you have any questions, require clarification, or would like to meet to discuss any of the comments, please contact the undersigned.

Sincerely,

Carolyn Woodland, OALA, FCSLA, MCIP, RPP

Senior Director, Planning, Greenspace and Communications

Toronto and Region Conservation Authority

[Original Comment ID: 211108]