July 11, 2018 Michelle…

July 11, 2018

Michelle Doncaster
Policy Advisor
Ministry of Agriculture, Food and Rural Affairs
1 Stone Road, Floor 3
Guelph, ON N1G 4Y2

RE: ERO #013-2454: Agricultural Impact Assessment Guidance Document

Dear Ms. Doncaster:

City of Markham staff appreciates the opportunity to review the Ontario Ministry of Agriculture, Food and Rural Affairs’ draft Agricultural Impact Assessment Guidance Document, dated March 2018. Overall, the document is very informative and provides useful examples of mitigation measures to avoid, minimize, and mitigate impacts to the Agricultural System. The following are staff comments on the draft document.

City of Markham Agricultural Context
The City of Markham recognizes the importance of planning and protecting its agricultural resources. Markham’s agricultural land base is identified as ‘Countryside Agriculture Area’ in Map 9 of the City’s 2014 Official Plan (as partially approved on November 24, 2017 and further updated on April 9, 2018). The majority of the lands outside of Markham’s urban settlement area are identified as Prime Agricultural Area which includes the Greenbelt Plan Protected Countryside lands and the Oak Ridges Moraine Countryside and Natural Linkage lands (See Figure 1). The City’s Countryside Agriculture Area lands have been entirely included within the Province’s draft Agricultural System for the Greater Golden Horseshoe as Prime Agricultural Areas.

Agricultural Impact Assessments for Greenbelt Plan Corridors
Markham contains several Greenbelt Plan corridors or “fingers” that extend along the Berczy, Bruce, Robinson, and Little Rouge Creek valleys (See Figure 2). In order to meet the City’s projected population and employment targets, a settlement area expansion was approved which includes lands on both sides of the Berczy and Bruce Creek Greenbelt Plan corridors. This settlement expansion was supported by both the Region of York’s 2009 LEAR Study and the City of Markham’s 2008 Agricultural Assessment.

In accordance with the Provincial Growth Plan section 2.2.8 and Greenbelt Plan section 3.4.2, the Greenbelt Plan “fingers” remain outside of the City’s settlement boundary and are technically maintained as Prime Agricultural Area in the City’s 2014 Official Plan even though they will be surrounded by urban land uses and contain the Natural Heritage System overlay. As development proceeds adjacent to the Greenbelt Plan “fingers”, these lands will no longer be able to support viable agricultural activities and will be restored as natural heritage features consistent with the vision and goals of the Greenbelt Plan and the City’s Official Plan.

City staff have concerns that the requirement for a standalone AIA appears onerous and may not be warranted for the planned road crossings and other infrastructure within these Greenbelt Plan “fingers” (See Figure 3). Provincial staff should review the interpretation of Greenbelt Plan policy 3.1.3.3 and 4.2.1.2.f) and Section 4.4 of the AIA guidance document requiring an Agricultural Impact Assessment for all infrastructure crossing prime agricultural areas and consider an exemption for the Greenbelt Plan “fingers” intended for transition and restoration as part of the Natural Heritage System. Alternatively, the guidelines could clarify whether existing background studies such as LEAR Studies or equivalent may be used to fulfill the AIA study requirements.

Section 4.2.3.3 of the Greenbelt Plan also recognizes that naturalized stormwater management facilities may be permitted “within those portions of the Protected Countryside that define the major river valleys that connect the Niagara Escarpment and Oak Ridges Moraine to Lake Ontario.” Provincial staff may wish to consider an exemption from an AIA for naturalized stormwater management facilities within these Greenbelt Plan “fingers” as part of planned growth.

Should you have any questions, please contact Patrick Wong, Natural Heritage Planner at patrickwong@markham.ca or 905-477-7000 x6922.

Sincerely,

For Biju Karumanchery
Director, Planning and Urban Design
City of Markham

Note: Please see attachments (3) in e-mail.