NIAGARA SOUTH…

     NIAGARA SOUTH FEDERATION OF AGRICULTURE

    October 1, 2017.

  Ala Boyd, Manager- Natural Heritage Section

 Ministry of Natural Resources and Forestry Policy Division

 Natural Resources Conservation Policy Branch

 300 Water Street, Peterborough Ontario K9J 8M5

 Phone:705755-5088 Fax: 705-755-2168

  Re: Proposed Natural Heritage System  for the Growth Plan EBR Number 013-1014

  Dear Ms Boyd,

 The Niagara South Federation of Agriculture is a local general farm organization that advocates for the social and economic well being of our Members. We have our roots in the Welland County Board of Agriculture which began more than a hundred years ago. We are affiliated with the Ontario Federation of Agriculture, the largest and most effective general farm organization in Ontario

 Agriculture is a leading economic engine in Niagara and throughout the Golden Horseshoe. Agricultural land is a scarce and precious non renewable resource that must be protected from perils such as development, Natural Heritage Systems mapping, and restoration.

 We would offer the following comments and questions, in no particular order, for your consideration:

 Only holding three Public Open Houses across the entire Golden Horseshoe was grossly inadequate. The distance to travel to those locations and the busy summer season limited opportunities for participation. There is absolutely no reason why more Open Houses spread out across the entire Golden Horseshoe could not have been held. Assuming the Government was interested in the input that participants could bring this process would have benefited immeasurably.

 One background document would have been better than two which seemed to conflict.

 Our understanding is that mapping was done using a vegetation based approach using satellite and aerial photography. It is well documented that this method results in errors in identification. Could for example Christmas Tree plantations, orchards tree nurseries, or tree plantations be identified as forest? Could pasture and hay fields be identified as grasslands or perhaps even fallow lands? Could land awaiting planting be identified as fallow land? Could harvested land be identified as fallow land? Ground truthing is absolutely essential for the accurate identification of NHS. It is the responsibility of the MNRF to get it right the first time. Failing that corrections should be made promptly and at MNRF expense. Landowners and Municipalities should bear no responsibility for MNRF mapping nor should they be subject to any resulting costs.

 NHS policies must recognize and permit the full range of agricultural uses.

 The MNRF must map the Natural Heritage System that exists and not one created by uncompensated expropriation through Regulation. It is our understanding that the usual Core Area size is 1000 hectares and that it was reduced to 500 hectares for the Greenbelt ti address “fragmentation” although really it was so that more linkages could be mapped. We strongly object to the further reduction of the Core Area to only 100 hectares in the Growth Plan. We would prefer that both Greenbelt and Growth Plans be mapped at the 1000 hectare level. At a minimum the 500 hectare level used in the Greenbelt should also apply in the Growth Plan area. Consistency across all four Provincial Plans is absolutely essential.

 We strongly object to the proposed minimum linkage width of 500 meters. This is the largest width in MNRF’s Natural Heritage Manual. To use the largest width available in unscientific and indefensible. We recommend that any linkage widths reflect the local landscape and the species likely to use the linkage and that linkages or corridor widths should be no wider than the widths of the features and areas they are connecting.

 The ecological benefits of both annual and perennial crops should be recognized.

 Agriculture is the highest and best use of arable land. Farmlands should not be considered candidates for restoration.

 We recommend that MNRF Be directed by the Province to directly notify all landowners affected by the mapping of a Natural Heritage System for the Growth Plan.

 We have always regarded the Growth Plan as simply “Greenbelt Lite”. If the proposed NHS is imposed the Growth Plan will be much less so.

 Thank you. It is hoped that you found our ideas interesting and helpful as that was our intention.

 Yours truly,

 Joe Schonberger, President, Niagara South Federation of Agriculture

 Cc: Keith Currie, President, Ontario Federation of Agriculture

 Robert Bator, Niagara North Federation of Agriculture

 Henry Swierenga, OFA Member Services

 Peter Jeffery, OFA Senior Researcher

 Carmen D’Angelo, Niagara Region CAO

 Erik Acs, Niagara Region Senior Planner

 Austin Kirkby

[Original Comment ID: 211071]