October 4, 2017…

   October 4, 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

  Dear Ms. Boyd:

  Thank you for the opportunity to comment on the criteria, methods, and mapping of the proposed regional Natural Heritage System (NHS) for the Growth Plan for the Greater Golden Horseshoe (GGH).

  The Toronto and Region Conservation Authority (TRCA) is a local watershed management agency with a variety of responsibilities related to natural heritage protection, management and restoration. TRCA protects and manages approximately 18,000 hectares of conservation land and assists its 18 member municipalities in fulfilling their responsibilities associated with natural heritage, water resources and natural hazard management under the Planning Act and Environmental Assessment Act processes. TRCA has an interest in the development of the regional NHS primarily given our roles as a service provider to municipalities supporting their implementation of provincial policy, as a resource management agency and regulator in accordance with the Conservation Authorities Act, and as a major landowner in the Greater Toronto Area.

  In 2015 and 2016, TRCA provided comments and recommendations to the Province as part of the Coordinated Review of the Growth Plan for the Greater Golden Horseshoe (Growth Plan), Greenbelt Plan, Oak Ridges Moraine Conservation Plan, and Niagara Escarpment Plan. We are pleased that many of our comments are reflected in the updated plans and recognize the importance of establishing the regional NHS in a timely manner to facilitate the implementation of the new Growth Plan policies.

  TRCA has reviewed both the summary document and technical report and refer to both in the comments below. The document being referred to in each instance will be specified. Note that these comments should be read in conjunction with TRCA’s comments on the draft Agricultural System (EBR # 013-0968).

  General Comments

  Overall, TRCA supports the intent of identifying a regional NHS and appreciates that MNRF has clearly outlined the principles, criteria, and methods used to develop the proposed regional NHS for the GGH. The decision to use a transparent, repeatable methodology to identify and create core areas and linkages and to fill in gaps and holes is important. We also appreciate the decision to accept NHS information from municipalities and conservation authorities (CAs) as part of this consultation and anticipate that the Province will use it to refine the proposed NHS.

  It is helpful to be able to concurrently review and comment on the draft Natural Heritage System and Agricultural System in recognition of the overlap between the two systems. It appears that MNRF and OMAFRA have taken different approaches, with the former relying predominantly on provincial data and allowing for municipal refinements only for precision, and the latter drawing from existing OP mapping and providing greater flexibility for municipalities to refine the draft agricultural land base. TRCA would like to see the NHS approach more closely resemble the Agricultural System approach in its use of local official plan (OP) mapping and engagement with municipalities and CAs in the determination of the final NHS.

  Policy 4.2.1 in the Growth Plan states that, “Municipalities, partnering with conservation authorities as appropriate, will ensure that watershed planning is undertaken to support a comprehensive, integrated, and long-term approach to the protection, enhancement, or restoration of the quality and quantity of water within a watershed.” In large part, water quality and quantity and overall watershed health depend on a protected, robust NHS. A healthy NHS can filter stormwater and slow flood waters, curb erosion and absorb carbon, as well as provide buffered and connected habitats. The impacts of growth, intensification and the compounding effects of climate change are in many ways more acutely experienced in downstream settlement areas, making a protected NHS even more critical.

  TRCA is concerned about the implications of a regional-scale NHS, subject to Growth Plan policies, that excludes areas that are currently part of local NHSs. This is of particular concern given that, according to the revised Growth Plan, existing NHSs identified in OPs will no longer be protected in accordance with the relevant OP once the regional NHS has been issued (4.2.2.4), even though a municipality “may continue to protect any other natural heritage system or identify new systems in a manner that is consistent with the PPS” (4.2.2.6b). This appears to create two “tiers” of NHSs, in which parts of the local NHS (where the regional NHS does not overlap) risk being devalued in municipal development decisions or at the Ontario Municipal Board. Even if municipalities have the opportunity, as per Growth Plan policy 4.2.2.5, to “refine provincial mapping with greater precision” through a municipal comprehensive review, this two-tier system will exist until municipalities’ OPs are updated and approved (2022 or even beyond).

  Furthermore, without provincial guidelines on the types and extent of “refinements” that municipalities will be able to make, it is unclear whether the municipal refinement process will be sufficient to resolve these disparities. While we appreciate that the proposed NHS is intended to operate at the regional scale, the implications of inclusion versus exclusion are substantial and can create challenges for planning authorities and supporting agencies like CAs going forward. This has significant ecological implications considering that the success of the regional-scale NHS is contingent on local-scale municipal NHSs.

  Using the recently published digital NHS map, TRCA has been able to identify the areas within our jurisdiction that have been proposed for inclusion in the GGH NHS. Many of these appear to be refinements to the Greenbelt NHS within the whitebelt. Within this area, the proposed additions exclude parts of the NHS identified through TRCA’s Terrestrial Natural Heritage System Strategy, which many of our partner municipalities use to delineate and periodically refine the NHS in their OPs. CAs and municipalities should be consulted on these site-specific areas in order to more accurately capture and map the natural features present. For example, the portion of the proposed regional NHS located southwest of Elgin Mills Road and the 9th line in Markham does not extend to cover the wetland to the north.

  Responses to Consultation Questions

  1. Generally, do you agree with the principles? Are there other key principles?

  The principles are helpful in guiding the technical process for developing the NHS. However, they lack the direction required to ensure the development of the NHS is based on sound ecological principles. The document and process would benefit from having a set of ecological guiding principles in addition to the more process-based ones so that they are embedded in the mapping process and can facilitate the evaluation of NHS outcomes in the future. If ecological principles are established, the NHS development methodology should be reviewed and/or revised to ensure it conforms with these principles. Please see for reference the attached Principles for Terrestrial Natural Heritage Conservation and Restoration developed by the South-Central Ontario Conservation Authorities Natural Heritage Discussion Group in 2002, which relate to scale, amount and distribution of cover, size, shape, matrix, connectivity, and diversity/quality. For example, if distribution is a key principle, core areas smaller than 100ha would be needed in order to capture more areas with high fragmentation and low cover in the NHS so that services are more equitably distributed across the region.

  Edits are proposed to the following guiding principles on p. 4 of the summary document in order to better account for existing local NHS mapping and regional variations in landscape context: •Scale of the regional system is to focus on identifying larger core areas and broader linkages within a regional landscape context: Consider rewording to “Larger core areas and broader linkages are preferred in a regional natural heritage system, but the scale and context of the landscape is to be considered when identifying core area and linkage size criteria.” While large habitat patches are generally better for biodiversity conservation, the appropriate minimum size varies depending on the landscape context, NHS objectives, and even species requirements. By keeping this guiding principle broad it allows the NHS development process to identify appropriate size – for example, 500ha or 100ha or finer, if needed.

 •Connection of the NHS mapping to existing regional mapping in adjacent areas is to be made as much as reasonably possible (i.e., connect to other natural heritage systems in adjacent planning areas): Consider rewording to “Connection of the NHS mapping to existing regional and local jurisdictions’ NHS mapping in adjacent areas is to be made as much as reasonably possible (i.e., connect to other natural heritage systems in adjacent planning areas)”. Having regard for and linking the proposed NHS maps to the existing NHS from other jurisdictions (municipal and CAs included) is important for all of the NHS to be functional across the broader landscape.

 •The criteria and methods are to have potential for application in another similar geography (i.e., could potentially be applied to other areas of southern Ontario): Consider rewording to “The framework, criteria, and methods are to have potential for application in another similar geographical scale and context as well as allow for adaptation if in a different geographical scale and context”. This will allow for the areas where the criteria thresholds are not acceptable to use what is most appropriate in their context without weakening the objectives and outcomes of the NHS.

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

  TRCA supports the application of smaller minimum core area sizes to reflect different fragmentation and natural cover conditions in different parts of the GGH. It is important to apply finer thresholds for areas with low natural cover, as smaller natural features would otherwise be excluded from the NHS. TRCA, which works within a highly urbanized area, is acutely aware of the need to account for regional variability in NHS planning and to recognize the importance of such systems in more developed contexts.

  We are concerned that the alternative 100ha minimum may not be sufficient to address the already low levels of natural cover within certain areas in the GGH outside of settlement areas and the Greenbelt (e.g. in the whitebelt). While it is a good start, this threshold does a disservice to watersheds dominated by still smaller – but important – existing natural areas by excluding them from provincial-level protections. For example, a recent University of Waterloo study  highlighted the disproportionately large role that smaller wetlands play in landscape nutrient processing and the need to value and protect these smaller features. In addition, there are biodiversity groups that benefit from smaller habitat areas, as illustrated on pages 9 and 14 of the technical report, that have been excluded through application of the proposed criteria. While the technical report states that “The objectives of the regional Natural Heritage System are not tailored to a particular species or species group, but are intended more generally to maintain and restore biodiversity and ecological functions over the long term”, by aiming only for larger areas the needs of biodiversity groups with smaller patch areas – often local species in and around settlement areas that are of local conservation concern – could be undermined, especially in areas where they may be the dominant groups. As with core area size, linkage sizes also need to vary depending on the species, scale and context of the study area.

  TRCA recommends that the Province re-evaluate size criteria for core areas and linkages, based on a finer analysis of the region and data provided by CAs and municipalities, which more fully reflect the context of the area to which the criteria are applied. Core area and linkage thresholds should be determined according to the needs of the majority of species, scale, and landscape context of the targeted region at a finer scale.

  With regard to the composition of core areas and linkages, while valleylands of major stream systems were included in the proposed NHS, TRCA would like to see all valley and stream corridors included in the NHS. Valley and stream corridors, which support the interactions between terrestrial and aquatic systems, form the “backbone” of the NHS of a watershed, and within TRCA’s jurisdiction are considered both core areas and linkages. Local NHSs are critical to the health of watersheds, which in turn is key to the health of the regional NHS.

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

  Yes – see response to Question 2.

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

  We understand the approach described in the technical report to be a consistent, repeatable approach but not necessarily an automated one, as it employs a number of manual steps and expert judgment. We think this is appropriate. The consistent application of criteria is supported, as long as the criteria are context- and scale-specific given the wide variability in the amount and distribution of natural cover across the GGH as well as the needs of the inhabiting species.

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

  Provide Additional Context

 Both the technical report and summary document would benefit from additional context and content for the development of the regional NHS and its associated policies as it relates to local NHSs. To this end, the Introduction, Purpose or Scope section(s) of the documents could include:

 •A clearly stated goal and objectives for the regional NHS, including what it contains and how it is designed. This could be drawn from the definition of NHS in the Growth Plan. Objectives could include, but are not limited to, the enhancement of ecosystem services, biodiversity protection and recovery, and climate change mitigation and adaptation.

 •Recognition of the local NHS identification and protection that municipalities and CAs have been undertaking since the early 2000s and continue to do. The regional NHS may not identify all natural features or potential restoration areas important at the local scale, but the overall long term functionality of the regional NHS and equitable distribution of ecosystem functions and services are dependent on the identification and protection of local NHSs. The impacts of urbanization and the compounding effects of climate change are in many ways more acutely experienced in urban settlement areas, making a protected NHS that much more important in these areas.

 •Recognition that, although the GGH NHS does not extend into settlement areas, the identification and protection of natural features in settlement areas is still important.

 •Clarification on how the proposed NHS relates to other provincial NHS development initiatives such as Marxan, which was developed over a number of years and has been used (and funded) by a number of municipalities within the GGH.

 •Recognition that ecosystem restoration, and identification of areas for restoration, is an important part of the regional NHS and that municipalities and CAs are to identify restoration opportunities.

 •Recognition of green infrastructure’s concurrent role in achieving some of the same objectives as the regional NHS, including supporting ecosystem functions. This would complement the references to green infrastructure in the updated Growth Plan.

 •Recognition of current and future impacts of climate change and the relationship between the NHS, ecosystem services, climate change mitigation and adaptation, and community resilience needs. •Key ecological guiding principles for the development of the NHS (see response to Question 1 above).

  Account for local NHSs

 As stated above, TRCA would like to see local (municipal and CA) NHSs be better acknowledged in the development of the GGH NHS. Substantial public resources have been expended to develop and defend these local NHSs. TRCA has learned that the Province is accepting mapping data for consideration for inclusion in the regional NHS, and is pleased to include our GIS data with this submission for your consideration. Incorporating municipal and watershed NHSs would mitigate the “two-tier” problem mentioned earlier and be more consistent with the process OMAFRA has used to map the agricultural land base of the GGH Agricultural System, which relied heavily on existing designations in approved OPs. We would encourage the Province to consider the information and data provided by all CAs.

  Provide guidance for municipal refinement and implementation

 Provincial guidance and oversight are needed for municipal refinement and consistent incorporation of the regional NHS into OPs. This would address Recommendation 43 in the Advisory Panel Report for the Coordinated Review, which calls for the provision of guidelines on mapping NHSs and connections between regional- and local-scale systems. Any criteria for municipal refinement should be made publicly available. MNRF may wish to consider establishing a process for municipal conformity/refinement for the NHS similar to that of OMAFRA’s for the Agricultural System.

  Publish NHS and agricultural land base mapping together

 Table 8 in the technical report states that 28% of prime agricultural areas in the GGH have been captured within the proposed NHS. This suggests significant potential for competing uses but also for determining areas for restoration. However, as the mapping for these two systems has been provided on different map viewers, it is currently impossible to systematically identify the areas of overlap and plan for agricultural and ecological functions in these areas. Once the maps for the NHS and agricultural land base are established following this consultation, the Province should not only provide public access to associated GIS data, but make these mapping layers available to view on the same online portal so that municipalities, planning authorities, and landowners are better able to plan within these areas. Additionally, these layers should be integrated and included with other existing provincial data sets, viewers and portals from other Ministries, where appropriate.

  Develop a restoration and enhancement strategy

 The establishment of the regional NHS requires an accompanying enhancement strategy to both restore NHS areas to natural cover and expand the overall size of the NHS in the long term. In the technical report, public lands and linkages are identified as areas for restoration, but a more comprehensive strategy is needed that includes the opportunity to identify both areas for restoration and the local jurisdictions that should focus on restoration. The Natural Heritage Reference Manual could be updated to better reflect these needs and provide guidance on how NHSs should be developed to account for restoration. An NHS enhancement strategy would help achieve Recommendation 44 in the Advisory Panel Report for the Coordinated Review.

  Thank you once again for the opportunity to provide comments on this important initiative. Should you have any questions, require clarification, or would like to meet to discuss any of the comments, please contact the undersigned.

  Sincerely,

  Carolyn Woodland, OALA, FCSLA, MCIP, RPP

 Senior Director, Planning, Greenspace and Communications

 Toronto and Region Conservation Authority

   Attachment:

  BASIC PRINCIPLES FOR TERRESTRIAL NATURAL HERITAGE CONSERVATION AND RESTORATION

 SOUTH-CENTRAL ONTARIO CONSERVATION AUTHORITIES NATURAL HERITAGE DISCUSSION GROUP

 November 2002

  With so many organizations and governments of all levels defining and evaluating natural

 heritage systems using a diversity of approaches there is a real need to identify basic principles related to conservation biology and landscape ecology that are common to all programs to act

 as a basis for comparison and to demonstrate compatibility. The following is an attempt to

 describe these principles under basic issue-related categories. The first two are strategic considerations, while the others are more specific to system design and habitat patch qualities. These are not necessarily presented in order of importance, rather it should be recognized that there is some overlap between principles, and the interrelation between them is important. Following each principle is an explanation of why it is relevant.

  1. Approach

 A comprehensive approach to natural heritage addresses ecosystem form and function based

 on a landscape perspective. There is a difference between maintaining the health of a defined terrestrial natural heritage system occupying a portion of the landscape, and maintaining the health of the landscape itself. If terrestrial natural heritage conservation is to be integrated with

 aquatic ecosystems and geophysical elements such as hydrology and soils, then the condition

 of the entire landscape, including human land use, must be considered. Land-water interactions

 are especially important in the protection of headwaters.

  Ecological and evolutionary processes function at a landscape scale and therefore must be

 addressed within a landscape context. Ecosystems are not limited by the boundaries of

 individual habitat patches; they interact with each other and the surrounding landscape. The movements of wildlife such as migratory birds elevate this function to a global scale. There is a danger in assessing patches only at the site scale, which can lead to cumulative loss. A

 systems approach must be used in determining their relative importance within a landscape and

 the interrelationship of all the principles in this document need to be considered. Furthermore, natural disturbance patterns such as erosion or fire are necessary for the continuance of some ecosystem types.

  Because ecological systems and processes are so complex and damage cannot always be

 repaired, the Precautionary Principle should apply when defining, managing, and defending the natural heritage system. Demographic trends and their potential impacts should be considered

 in the design of the system, and adaptive management should be applied to ensure long-term ecological health. Actions that have the potential to negatively impact the natural heritage

 system should be avoided unless it can be proven beyond a reasonable doubt that there will be

 no serious ecological harm. Protection of existing features and expansion of the natural

 heritage system are generally better than mitigative action.

  2. Scale

 A natural heritage system that is defined and evaluated at a small local scale should be

 compatible with a system defined at the larger regional or provincial scale. To the greatest

 degree possible it should also be compatible with neighbouring natural heritage systems across local jurisdictional borders. Consideration of temporal scale is also important. For example, although some decisions may be made based on short-term targets, these may be increments

 towards a larger vision that can only be fulfilled over the longer term. We should also recognize the evolving nature of ecosystems, and make provision for the continuation of successional processes.

  3. Cover/Distribution

 More natural cover is better. The more natural cover on the landscape, the greater the

 ecological health. Natural cover improves soils, retains and filters water, improves air quality and regulates climate. It also promotes biodiversity by allowing for greater representation of genes, community types and species, as well as natural disturbance cycles. Even distribution of this natural cover ensures that these functions occur across the landscape.

  4. Size

 In general, large habitat patches are better for biodiversity conservation. This is because they provide more resources to support more species and more individuals of those species,

 promoting population viability and internalizing connectivity and the values which corridors are designed to provide. They also support more vegetation community types and more age

 classes of vegetation. They provide a better buffer against negative external impacts, and

 greater opportunities for natural disturbance cycles to occur. In short, size is perhaps the most important patch measure and overriding principle because the larger the size, the less important the other landscape issues become (i.e. a single patch covering the entire landscape would

 make consideration of distribution, shape, connectivity, and surrounding land use irrelevant). Another issue is minimum size of a patch to be considered for evaluation, for part of a defined natural heritage system, or to be considered functionally significant. Decisions about minimum

 size are often based on the habitat type in question, and the total cover and distribution of natural habitat within the study area.

  5. Shape

 For forest habitat in a fragmented landscape compact patch shapes are generally better than convoluted shapes. This is particularly the case in uplands as opposed to riparian habitats that may naturally be thin and convoluted. Many forest species of concern - in particular birds - are known as ”forest interior“ species because they require the dark, cool habitat that can only be found in deep forest. Forest interior is also considered to be that area of the patch that is beyond most negative edge effects, that is from negative external influences. According to literature, these edge effects penetrate at least 100 metres into a forest, and up to over 400 metres. Typically, forest interior is mapped as the area that is more than 100 metres from the edge. Interior is a function of both size and shape of the patch. The shape with the least

 amount of edge is a perfect circle. Long, slender, convoluted or perforated patches have the highest amount of edge. Shape of patches may become less important with increasing size.

 There may be value in defining interior, or ”core“ area for non-forest habitats, or combinations of habitats, although the literature to support this seems to be limited, with the exception of defining core areas in large reserves that are off limits to human use.

  6. Matrix

 Size and shape many determine the degree to which a patch is exposed to negative external influences, but what ultimately affects the quality of the habitat is the specific types of influences

 resulting from the character of the surrounding landscape, known as the matrix. Human land

 uses such as agriculture and urbanization have different degrees of impact, while other nearby habitat patches may have a positive effect by providing additional resources for species that can move between the patches and by providing support services such as pollination.

  7. Connectivity

 Landscape connectivity refers to the functional relationship among habitat patches based on

 their spatial proximity and the movement responses of organisms. Plants need adjacent

 habitats to support pollination and seed dispersal. Animals must move or disperse to find

 suitable resources and to mate. Small populations that have become isolated in a fragmented landscape are at risk of extinction due to resource depletion or inbreeding and the associated

 loss of genetic vigour. Two main types of connectivity have been defined: structural connectivity refers to the physical adjacency of habitat patches, and functional connectivity refers to the ability of species to traverse the landscape between the patches. Theoretically functional connectivity must be defined differently for each species because each has a different

 movement capacity. However, structural connectivity, whatever its form, will not meet the needs

 of all species. Provision of wildlife corridors, although popular, is only one way in which connectivity can be provided. These issues illustrate the difficulty in finding one measure that suits all circumstances. Based on potential positive or negative impacts of linkages, to connect

 or not to connect is an important consideration.

  8. Diversity/Quality

 Native species and vegetation communities should be a focus of conservation and restoration efforts. Species evolve together over time to create ecosystems. Non-native, or exotic species

 are those that have been introduced deliberately or accidentally from distant areas. Although

 the impacts of some species may be relatively benign, those that become invasive can have catastrophic impacts. It is therefore appropriate to focus conservation on native species and ecosystems, and this may in fact involve the control of exotic species or to maintain the conditions that favour native species.

  The quality or condition of natural areas is also important. For example, areas that are close to pristine are likely to be more valuable than areas that are heavily degraded. Special features

 such as excellent representation of biodiversity, rare species or community types, old growth,

 etc. are also important considerations.

[Original Comment ID: 211107]