Oct. 2, 2017…

   Oct. 2, 2017

  A natural heritage system is critical in enhancing the quality of life in the heavily urbanized and rapidly growing Greater Golden Horseshoe and helping to prepare the GGH for the impacts of climate change.  The success of a natural heritage system will depend in no small measure on effective and sustainable mapping that ensures strong protection for the region's vulnerable natural resources of wildlife, water and biodiversity.

 As a longtime member and supporter of various reputable conservation and environmental groups in Ontario, I share the concerns of these organizations that they have identified some major gaps in the government's proposed plan.  Sierra Club researchers, for example, would like to see a Growth Plan that fosters a more restrictive regulatory framework than the Provincial Policy Statement. They feel this hope is clearly threatened, for example, by proposed mapping criteria that suggests new economic criteria for determining the designations of varied agricultural designations. If the recommendations are adopted, agricultural designations that traditionally have been based on soil and climate will consider other factors such as distance to market. This, unfortunately, could lead to more intense severance activity that can encourage water pollution through the need to rely on septic tanks.  It's also disturbing that the proposed mapping does not to propose to map any natural areas within urban boundaries.  As the Sierra Club has noted, these invaluable natural areas --- home to biologically diverse Carolinian forest and habitat to many endangered species --- are under the greatest threat from land developers.

 In addition, the existing policies of the PPS are threatened by the quite high bar for a forest, or other natural area, to be considered for mapping protection under the proposed Growth Plan model. In places of severe deforestation, such as the "whitebelt" lands around Greater Toronto, forests of two hectares are seen as provincially significant.  However, it is being proposed that to map core natural heritage areas for the Growth Plan, a size of 100 hectares is required. There is real concern that the proposed mapping, by excluding small forests, shows large swaths of the Growth Plan area --- especially its western fringes --- as being without any protective natural heritage mapping. Ontario Nature, for its part, has strongly urged that the 100 hectare requirement be reduced in areas with low natural cover, as even smaller forests can provide high value biodiversity.  I also support Ontario Nature's recommendation that the province integrate other identified natural heritage systems, as mapped by many municipalities and conservation authorities, into the province's final map.

 The importance of encouraging community input and involvement in establishing the final plan  also stressed by Ontario Nature in its submission and I urge the government to act accordingly.

 Just as the province has shown visionary leadership in establishing the Greenbelt and encouraging a complementary Bluebelt to protect our water resources and watersheds, I urge the government to provide Ontario with a strong, well-connected natural heritage system of which we can all be proud.

 Thank you for the opportunity to comment.

[Original Comment ID: 211038]