Dear Ms. Boyd:…

   Dear Ms. Boyd:

  Re:Criteria, methods and mapping of the proposed Natural Heritage System for the Growth Plan Environmental Registry Number 013-1014

  City of Waterloo staff are providing this submission in response to the draft Natural Heritage System materials released in support of the Grown Plan. Staff have read the document entitled “Development of the Proposed Regional Natural Heritage System for the Growth Plan for the Greater Golden Horseshoe – Summary of Criteria and Methods”, dated June 28, 2017, and offer the following comments. These comments are provided in the context of the City of Waterloo, where only a small portion of the City is included in the proposed Natural Heritage System and that small area abuts the urban settlement area.

  1.The methodology for mapping the Growth Plan’s Natural Heritage System is based on creating an automated and repeatable process. Staff understand the rationale behind this but think there is merit in giving consideration to existing Official Plan mapping and policy frameworks. Specifically, the Region of Waterloo’s Official Plan identifies a Greenlands Network that is supported by both detailed mapping and a robust policy framework. The City’s Official Plan further builds upon this by capturing features at the local level. Together, our two Official Plans provide a high level of protection for natural heritage across the City, including the area captured by the proposed Natural Heritage System. Should the Province move forward with the proposed Natural Heritage System, substantial effort will be required to amend the City’s Official Plan to incorporate the mapping and modify the policies. In spite of that effort, however, there would essentially be no further protection provided to the City’s natural heritage.

  2.Should the Province move forward with the proposed Natural Heritage System, clarification on how it is to be implemented at the interface with settlement areas needs to be provided. For example, in the City of Waterloo, the dripline of a Significant Woodland, which is included in the proposed Natural Heritage System as a core area, abuts the settlement area boundary. Through Growth Plan policy 4.2.4.1c), a minimum 30 metre vegetation protection zone would be required. Since the dripline corresponds to the settlement area boundary, this vegetation protection zone would fall within the settlement area. At the same time, under Section 6.1 of the “Development of the Proposed Regional Natural Heritage System for the Growth Plan for the Greater Golden Horseshoe – Summary of Criteria and Methods” document, it is stated that core area boundaries were extended to include a 30 metre zone around the edge of the feature. However, under Growth Plan policy 4.2.2.1, it is stated that the Natural Heritage System mapping will exclude lands within settlement areas.

  These comments will also be provided in a hard copy letter.

  Thank you for the opportunity to comment.

[Original Comment ID: 211052]