The changes to the Growth…

The changes to the Growth Plan for the GGH include new areas that I work in. City of Kawartha Lakes, Peterborough and Northumberland. It is good to see some changes in the density targets for these largely rural areas, that have limited urban settlement areas but still want to see shoreline plans of subdivision, cottages and rural severances. As an area increasing inhabited by retirees, these types of development are important to rural townships and the Kawartha Lakes cottage country economy.

As a biological consultant, the policy changes proposed will allow development to still proceed in an environmental way. The key issue being the proposed change in the requirement for the NHS system for the Growth Plan (s. 4.2.2) not overlapping or applying to these municipalities. At the same time forcing those municipalities to complete the required NHS mapping exercise and policy implementation in their official plans. This has been completed by many municipalities in the last 5 years, but not in our area.

Comments on specific policies:

1) section 4.2.3.1: outside of settlement areas development and site alteration not permitted in NHS or key hydrologic features except for aggregate operations....

This seems to be inconsistent with section 4.2.8.2 a) where no new mineral aggregate operations will be permitted in significant wetlands, habitat of endangered species and significant woodlands. Although other wetlands ( non-significant), ANSI's, rare veg communities and fish habitat are also included the definition of KNHF. Other legislation states that development may be permitted in significant woodlands if an NHE is prepared that shows no negative impacts. Most quarry properties have extensive woodlands, making this constraint a major obstacle.

The PPS and current aggregate policy standards allow for new aggregate to go through an ESA permit process with MNRF as part of the rehab plan requirements. This requires a lengthy process, compensation and long term monitoring. In our experience the large size of aggregate pits makes it very difficult to not have an endangered or threatened species on a site. The wording " to the satisfaction of MNRF/MECP or " except as per provincial or federal species at risk legislation and policies" would allow some flexibility. As aggregate extraction is a temporary land use, the rehabilitation plan requirements allow for the habitat to be restored as the progressive rehab occurs.

Section 4.2.8.4 b) states that removal of an KNHF or KHF can occur, as long as the area is rehabilitated post-extraction. This is inconsistent with section 4.2.8.2 a).

2) Key hydrologic features (s. 4.2.3); This feature duplicates the 'key natural heritage features' using the term 'wetlands'. The definition does not specify that the wetland is provincially significant or unevaluated. If the wording was clearer to define wetland as " as those evaluated under the OWES system by the MNRF", this would separate unevaluated, unmapped wetlands from the evaluated ones. KNHF could be for PSW's only with key hydrologic features applying to other unevaluated wetlands.

Changes to section 4.2.2 that remove NHS requirements as per the Growth Plan until municipalities include their own NHS mapping, should also exclude 'key hydrologic features' in the areas outside of settlement areas. Those features are covered under conservation authority regulations (wetlands, watercourses) and Fisheries Act policies in fish habitat already and in most official plans.