HARDCOPY OF LETTER,…

   HARDCOPY OF LETTER, SCHEDULES AND APPENDICIES HAVE BEEN COURIERED TO THE ADDRESS BELOW.

  October 3, 2017

  Attn:

 Ala Boyd, Manager of Natural Heritage Section

 Ministry of Natural Resources and Forestry Policy Division

 Natural Resources Conservation Policy Branch

 300 Water Street

 Peterborough, Ontario

 K9J 8M5

   Re:

 Criteria, Methods, and Mapping of the Proposed Regional

 Natural Heritage System for the Growth Plan for the Greater

 Golden Horseshoe.

 Subject Lands: Twenty Road West, City of Hamilton

   Dear Ms. Boyd

  Corbett Land Strategies Inc. (CLS) is the planning consultant to the Twenty Road West (TRW). We have conducted a review of the Policy Proposal Notice - Criteria, Methods and Mapping of the Proposed Regional Natural Heritage System for the Growth Plan for the Greater Golden Horseshoe (GGH) and submit the following as formal comments in accordance with the proposed review of the Proposed Regional Natural Heritage System, concluding on October 4th. The following constitutes both general as well as specific comments in relation to the impact the proposed policy has on the TRW subject lands. Our environmental consultants, Natural Resource Solutions Inc. (NRSI) have concluded that:

  “In reviewing the available digital mapping for the Twenty Road Landowners Group properties, the area of NHS delineated is located in a narrow area between several settlement areas identified in the Urban and Rural Hamilton Official Plans. The NHS polygons appear to be Linkage areas; however, the Linkages do not connect to other features, particularly to the northwest of the lands. It also appears that an attempt has been made to widen the 500m wide Linkages to capture adjacent natural features. These features have been incorrectly identified by the automated system, as there are no features in the areas. As such, the NHS on the subject lands should be removed.”

  On July 6, 2017, the Ministry of Natural Resources and Forestry (MNRF) released a policy notice which included the criteria and methods to delineate a regional level Natural Heritage System (NHS). The intent of this policy was to provide a summary and a mapping system of the draft NHS developed by the MNRF for consultation alongside the Growth Plan for the Greater Golden Horseshoe (GGH), which came into effect on July 1, 2017.

  We note that Section 4.2.2.5 (Natural Heritage System) of the Growth Plan (2017) states that: “in implementing the Natural Heritage System, upper- and single-tier municipalities may, through a municipal comprehensive review, refine provincial mapping with greater precision in a manner that is consistent with this Plan.”

 As the City of Hamilton is currently undertaking an MCR, we ask that Ministry staff confirm that the mapping, as proposed, can be modified to be more specific to local environmental circumstances through a scientific screening process such as a Subwatershed Study.

  The Province has also completed updates to the other four provincial plans including the Greenbelt Plan. Within the updated Greenbelt Plan are new policies aimed at strengthening the natural heritage system. CLS has reviewed the 2017 Greenbelt Plan, and notes that on Schedule 4, no natural heritage system is designated for the Twenty Road West lands. As such, we request that Staff clarify how the proposed natural heritage system mapping relates to the approved NHS designations identified on Schedule 4 of the Greenbelt Plan (2017)?

  Subject Lands

  TRW is bound by Twenty Road West to the north, Upper James Street to the east, Dickenson Road to the south, and Glancaster Road to the west (See Schedule A). Much of the subject lands are characterized by actively farmed agricultural fields with woodlots, wetlands and ponds of varying sizes. An abandoned golf course is located on the westerly portion of the community.

  Lands to the north of Twenty Road North are located within the existing urban boundary and are fully developed for predominantly residential purposes. Lands to the east of Upper James Street are lands designated for rural purposes under the Rural Hamilton Official Plan. Lands to the south, bounded by Dickenson Road, are lands designated for employment purposes, beyond which is the John C. Monroe International Airport. Lands to the west are lands designated for employment purposes in the Urban Hamilton Official Plan.

  Context

  The subject lands have a longstanding planning history, with most of the lands included in the urban area of the City of Hamilton Official Plan. Two fragments, on either side of the Garth Street extension, remain in rural status. This land use dates to the Ontario Municipal Board (OMB) hearing from April 2015 with respect to the approval of the Airport Employment Growth District (AEGD). As part of this OMB decision, the remaining fragments were left out of the urban boundary to be contemplated for integration through a future Municipal Comprehensive Review (MCR).

  As part of our submission to the ongoing City of Hamilton MCR process, a comprehensive package was provided to the City which included the proposed development of a complete community on the subject lands and was accompanied by several technical studies. One of the reports was the Natural Environment Constraints Assessment and Net Developable Area Analysis conducted by NRSI, in September 2017 (See Appendix 2 for a full copy of this report).

  NRSI conducted field, biological and headwater drainage feature surveys of the subject lands in 2013 and 2017 which identified the presence of several natural features including Provincial Significant Wetlands (PSWs), Significant Woodlands, Aquatic Habitat and headwater drainage features. The features were evaluated against applicable policies, legislation and planning studies from the Province, Municipality and Conservation Authority. A Vegetation Protection Zone (VPZ) was applied to protect these features, and a conservative approach was used in mapping all natural features.

  As part of the works completed by NRSI, a Natural Feature Constraints Assessment and Net Developable Area Analysis Map was prepared (See Schedule B). The mapping was produced to maintain habitat connectivity wherever possible, and to preserve the widths of natural corridors and watercourses.  It is important to note that the mapping prepared by the MNRF as part of the Proposed Policy Notice (See Schedule A) appears to conflict with the proposed mapping completed by NRSI. As such, we request a meeting with the MNR to discuss and clarify this delineation.

  Impact of the Proposed NHS Mapping:

  The subject lands have undergone rigorous planning exercises to attract future employment to the lands surrounding the John C. Monroe International Airport. The works completed brought into fruition the AEGD Secondary Plan which is envisioned as the priority location for future employment lands in the City of Hamilton.

  The ultimate development of the TRW lands will deliver the road network necessary to facilitate the employment lands reaching their full potential. As such, the proposed mapping would fracture or inhibit the City’s ability to ensure the future development of the employment lands, by constraining the adjacent properties and infrastructure corridors.

  Further, it appears that the NHS mapping has been done on an isolated basis without matching or aligning to other Growth Plan objectives. These include the updated density targets, growth requirements for people and jobs, employment protections and requirements for infrastructure.

  General Comments

  In response to the Section 8.0 Inviting Public Comment, the following table provides responses to the points listed in the report.

  •Generally, do you agree with the Principles?

  The principles are not harmonized with other Growth Plan principles, namely those relating to infrastructure, employment and compact residential development.

  •Do you agree with the criteria for the composition and size of core areas and linkages?

  NRSI acknowledges and agrees that a 2-tier approach for the minimum size requirement of Core areas is appropriate and in line with good environmental planning practice. It should be noted that a minimum size of 100ha for highly fragmented and developed lands is quite large and this will result in fewer core areas designated across much of the landscape.

  In addition, it is our opinion that 500m wide linkages are too wide. Both the length and width criteria suggest that wildlife will live in the Linkages, rather than use them to migrate between Core areas where higher quality and more sustainable habitat is present. We recommend that a 2-tier approach to Linkages be applied (as with the Core areas), with narrower Linkages used for fragmented and highly developed lands. A width of 100m is supportable for developed areas.

  •Do you agree that there should be consideration of smaller core areas to acknowledge highly fragmented areas with limited natural cover?

  Smaller Core areas for highly fragmented areas with limited natural cover is supportable, and is in keeping with good science and planning practice.

  These areas could be more precisely delineated at the time of completion of a Subwateshed Study completion.

  •Do you agree with the automated approach to consistently apply the criteria across the landscape?

 The approach does not recognize or accommodate other Growth Plan principles. Additionally, it does not address environment constraints from a site-specific or level on a scientific or subwatershed based analysis.

  The guidelines also do not have any indication of implementation processes. Overall, it is not known how it will be implemented at the local level.

  It is recommended that the mapping be tested against natural heritage data where available. We recommend for the subject lands to be reviewed against the analysis conducted by NRSI, which included detailed field work conducted in the summer of 2017.

  In addition to this course of action, the final delineation must be determined through formal planning processes including Municipal Comprehensive Reviews and Secondary Plan preparation.

  •Do you have other suggestions for the Ministry of Natural Resources and Forestry to consider?

 Further public consultation is essential prior to adoption. Greater technical review with involvement by municipal, conservation authority and the planning industry is necessary.

  Conclusion

  CLS remains committed to participating in the consultation and preparation of the policies and mapping relating to the proposed Regional Natural Heritage System for the Growth Plan for the Greater Golden Horseshoe. In addition, we ask that a meeting be scheduled to discuss our comments further with staff from the Ministry of Natural Resources and Forestry.

  Thank you for your consideration of the foregoing comments. Should you require any additional information, please do not hesitate to contact CLS.

    Schedule A – Proposed Natural Heritage System for the Subject Lands, Ministry of Natural Resources and Forestry.

 Schedule B – Natural Feature Constraints Assessment and Net Developable Area Analysis Mapping prepared by NRSI.

  Appendix 1 – Letter from NRSI, Review and Comment on the Proposed Regional Natural Heritage System for the Growth Plan for the Greater Golden Horseshoe.

 Appendix 2 – Twenty Road West, Hamilton – Natural Environment Constraints Assessment and Net Developable Area Analysis, prepared by NRSI, dated September 2017.

[Original Comment ID: 211055]