Ala Boyd, Manager…

   Ala Boyd, Manager

 Heritage Section, Natural Resources Conservation Policy Branch

 Policy Division

 Ontario Ministry of Natural Resources and Forestry

 300 Water Street

 Peterborough, Ontario      K9J 8M5

  October 2, 2017

  Subject:  EBR Registry Number: 013-1014 - Criteria, methods, and mapping of the proposed regional Natural Heritage System for the Growth Plan for the Greater Golden Horseshoe

  The Simcoe County Greenbelt Coalition represents 30 community groups from across Simcoe and the province that have agreed in principle that the Greenbelt needs to expand into Simcoe County to ensure water, natural heritage, and farmland is protected.With representation from farmers, naturalists, environmentalists, ratepayer organizations, and citizen groups, the Simcoe County Greenbelt Coalition is a balanced voice that believes that the Greenbelt would ensure Simcoe County is better prepared to respond to the challenges of the future.

  We very much appreciate the opportunity to comment on the proposed regional Natural Heritage System for the Growth Plan. We forward our comments in two parts as follows:

  Part One

  Our comments in this section reflect our work with and support of comments prepared by the Oak Ridges Moraine Partnership (Eco Spark, Ontario Nature, STORM Coalition and Earthroots).  To this end we recommend the following:

  1) Improve mapping criteria and further integrate important regional variations:

  a) MNRF should integrate the natural heritage systems mapping that is already identified in municipal official plans and incorporate conservation authority data layers into the final provincial map.

  b) Smaller core natural areas are needed in areas with high habitat fragmentation and where few Core Areas of a minimum of 100 hectares are identified.  In areas of low natural cover, these features are disproportionately high in ecological value.

  c) All valley corridors should be identified in the system.  Valley lands should be wide enough to protect water and riverbank habitats, and provide for the free movement of plants and animals with appropriate buffers based on defined valleys and adjacent natural features.

  2) Improve opportunities for public involvement to help develop a consensus around a required vision, objectives and targets for the implementation stage of this important natural heritage protection mandate.  The currently drafted "Key Principles" need to be modified to take advantage of local and regional knowledge. The argument put forth in the document that the current proposed approach avoids "the bias that some individuals may have" ignores the significant and critical improvements that can be made to the map with local input—bias indicates a value that, when viewed objectively, can provide worthwhile data.  MNRF needs to deal professionally with differences of opinion.

  3) Biodiversity recovery as well as climate change mitigation and adaptation must be included as primary objectives of the GGH`s Natural Heritage System. These objectives should be complimented by a target of at least 50% of the landscape identified within the Natural Heritage System on a watershed basis. The lack of attention to protection of natural heritage systems has recently been highlighted in the outcomes of hurricane damage in Houston, Texas.  We need to better prepare here in Ontario.

  4) Linkages must be wide enough to better reflect the existing and potential connectivity between Core Areas in a fragmented natural landscape. Most linkages will overlap primarily with agricultural lands, where all farming activities are permitted, and some isolated natural lands. These areas must receive elevated protection in policy to ensure they are not converted out of agriculture or natural cover.   These areas need to be protected now or many may be lost in the near future.

  5) Strong and active oversight is needed from the Province to ensure the objectives and targets set out in the GGH`s Natural Heritage System are properly adhered to as municipalities incorporate the Natural Heritage System into their official plans.

  6) Along with  the improved policy in the Growth Plan and finalized mapping, an enhancement strategy that highlights areas of concern or areas that need improvement to satisfy the objectives, with dedicated funding, is necessary to achieve the objectives of the GGH`s Natural Heritage System.

  Part  Two

  The following comments address some of the critical site specific concerns that the Simcoe County Greenbelt Coalition has in our area:

  a) Criteria and methods used to develop and map the NHS must be selected and applied in a manner that protects the Wasaga Beach Wetlands.  This is a wetland complex of great regional significance and provides, in addition to other ecological benefits, critical flooding and erosion protection.

  b) The regional NHS needs to insure strong connectivity in the Severn Sound sub-watershed.  This is made up of five main watercourses - Wye River, Hogg Creek, Sturgeon River, Coldwater River and North River - rivers that discharge directly to Severn Sound between Midland and Coldwater.   This area is greatly influenced by farmers, municipalities, developers, golf courses and others and needs to be readily recognized to permit local actions for protection and improvement (e.g. nutrient management, reducing impacts of shoreline/streambank erosion).

  c) The Oro Moraine is the headwaters for watersheds draining west to Nottawasaga Bay, north to Severn Sound and south to Lake Simcoe (NVCA/LSRCA, 2010).   Headwater wetlands provide natural flood control along the flanks of the Moraine and marsh and swamp wetlands along the base provide important ecological functions.   The regional NHS needs to reflect and highlight the importance of the natural heritage features within this critical feature.

  d) In 2017 a 100-year flooding event was confirmed by the NVCA on the Nottawasaga River.  In 2014, a mere three years earlier, there were flooding challenges in the area. On this river system heavy rain or snowmelt from the upper reaches drains to the Minesing Wetlands and then eventually through Wasaga Beach.  The wetlands work as a giant holding area that holds back water and releases it at a slower rate than would otherwise occur.  The value of the wetlands in the upper reaches of the river system and of the Minesing Wetland is more important than ever for protecting homeowners and infrastructure from flooding damage.  The new regional NHS mapping must highlight all the significant natural areas that are required to protect against flooding.

  e) In the Lake Simcoe Protection Plan (effective June 2, 2009), the Ministry of Natural Resources (and Forestry) (MNRF), was required to collaborate with the Lake Simcoe Region Conservation Authority, the Ministry of the Environment (and Climate Change)(MOEE) and other ministries to further define key NHS features in the watershed (Policy 6.30-SA). These areas must be included in the regional NHS.  Also, under policy 6.31-SA of that plan, MNRF and MOEE, in collaboration with other ministries, the First Nations and Metis communities, and the LSRCA were required to map natural areas abutting Lake Simcoe.  This work should also be reflected in the new regional NHS.

  f) In improving on the current regional NHS proposal, we have noted above a need to improve objectives and targets. Since a great many residents in Simcoe County depend on groundwater, it is important that the protection of private water sources be considered as part of the mapping. Wetlands are closely connected to the groundwater system and may be the receptors for groundwater discharge. Including at least 50% of the landscape within the NHS on a watershed basis would help with the challenge of protecting our groundwater.

  g) Simcoe County is a large upper-tier municipality in Central Ontario, and is ecologically significant and diverse. Given that relatively little of Simcoe's natural heritage features receive a high level of protection, and that mapped connections are required between provincially and locally significant wetlands,  a more comprehensive and detailed NHS mapping system would provide a crucial foundation for improved natural heritage protection while simultaneously providing a flexible, multipronged tool for addressing the challenges of climate change.

  h) Under the current criteria an insufficient percentage of cool and cold water streams are protected.   We know that these habitats are in decline. The algorithm/criteria need to be changed so that ALL cool and cold water streams are included.  That would include Willow and Matheson Creek as well as other streams in Simcoe County.

  Again, we thank you for the opportunity to comment and contribute to this important exercise and look forward to working with you to produce a final and effective Regional Natural Heritage map for the Greater Golden Horseshow.

  Simcoe County Greenbelt Coalition

  36 Hillview Crescent,

 Midhurst, L9X 1N4

 http://www.simcoecountygreenbelt.ca/

 info@simcoecountygreenbelt.ca

[Original Comment ID: 211069]