Dear Honorable Minister…

   Dear Honorable Minister McGarry and Ministry of Natural Resources and Forestry Staff,

  RE:      Proposed Natural Heritage System Mapping

 EBR Registry Number: 013-1014

 School West Investments Inc., School Valley Development Ltd., School Valley South Ltd., and Brook-Can Holdings Inc., Caledon Development #2 LP, and Caledon Development #2 General land holdings (Mayfield West Study Area), Town of Caledon

  Malone Given Parsons Ltd. (“MGP”) are the planning consultants representing School West Investments Inc., School Valley Development Ltd., School Valley South Ltd., and Brook-Can Holdings Inc., Caledon Development #2 LP, and Caledon Development #2 General (“landowners”), the owners of approximately 175 hectares (430 acres) of land generally located west of Hurontario Street, north of Etobicoke Creek, south of Old School Road, and east of Chinguacousy Road in the Town of Caledon (herein referred to as the Subject Lands). This letter is submitted on their behalf as a portion of their landholdings at the southwest corner of Old School Rd. and Chinguacousy Rd. (Figure 1) have been identified in the Province’s draft mapping as additional lands to be included in the Natural Heritage System.

  The Request

 We are writing in response to the Province’s Criteria, methods, and mapping of the proposed regional Natural Heritage System for the Growth Plan for the Greater Golden Horseshoe, EBR Registry Number 013-1014.

  The purpose of this letter is to provide comments on the Province’s Natural Heritage System Mapping and Implementation Procedures and specifically request the Province:

  •To remove the proposed NHS limits for the affected portion of the Subject Lands as shown in “Attachment A”;

 •To allow the Natural Heritage System (NHS) mapping to remain in draft form until local municipalities can ground truth and make the necessary refinements to the NHS limits through the Municipal Comprehensive Review (MCR) process; and,

 •To allow local municipalities to use the local municipal NHS mapping where it meets the intent of the Provincial NHS policies in the Growth Plan, unless additional rationale is provided from the Province.

  Ministry of Natural Resources and Forestry aiming to finalize NHS mapping by end of 2017.

 In February 2015, the Province began their Co-Ordinated Land Use Planning Review which culminated in updated provincial land use plans for the Greater Golden Horseshoe.  Four updated plans were released in May 2017: the Growth Plan for the Greater Golden Horseshoe, the Greenbelt Plan, the Niagara Escarpment Plan and the Oak Ridges Moraine Conservation Plan.

  With the release of the plans, the Ministry of Natural Resources and Forestry (MNRF) has prepared draft mapping of the Natural Heritage System (NHS) across the Greater Golden Horseshoe.  The MNRF has indicated that the NHS mapping will be finalized by the end of 2017 with municipalities having to identify and protect what the Province has defined in their Official Plans.

  As indicated in Figure 1, the Province has proposed an addition to the NHS system on the portion of the Subject Lands in southwest quadrant of Chinguacousy Road and Old School Road.

  Figure 1 – Subject Lands on Natural Heritage System Excerpt (see original email correspondence dated October 4, 2017)

  Detailed mapping of the feature limits has been conducted at the regional and local municipal levels

 In September 2014, Peel Regional Official Plan Amendment 29 (“ROPA 29”) was adopted to expand the Settlement Area boundary to include Mayfield West Phase 2 (area west of Highway 10, south of the Greenbelt). As part of the MCR process for the settlement boundary expansion, significant environmental work was completed to identify and determine the limits of environmental features within the Mayfield West Study Area. The findings of these reports informed the delineation of the NHS features in the Mayfield West Land Use Plan in the Caledon Official Plan. Further environmental studies have recently been conducted in the Mayfield West Study Area including additional environmental work for the Mayfield West Phase 2 – Stage 1 development and the Mayfield West Phase 2 – Stage 2 development. These studies confirm and refine the delineated NHS features as shown in the Caledon Official Plan.

  It is our opinion that the environmental work completed by municipalities to identify natural heritage areas to be protected, enhanced or restored, should be utilized instead of the Provincial NHS limits. Local municipal NHS criteria has been ground truthed and developed to reflect local geography and conditions compared to Provincial NHS criteria, which is suited to a regional scale. With respect to the Subject Lands, the limits as established in the detailed environmental work at the local municipal level should be utilized.

  The Subject Lands are identified as a priority growth area for the Town of Caledon beyond 2021

 In 1997, the Town of Caledon adopted a “tri-nodal” approach to growth, which aimed to balance growth among its three Rural Service Centres, namely Mayfield West, Caledon East and Bolton, while limiting growth within the rural area. The Subject Lands are located within the Mayfield West Study Area as identified in the Region of Peel and Caledon Official Plan. The Mayfield West Study Area, which is generally bound by Old School Road to the north, Dixie Road to the east, Mayfield Road to the south and Chinguacousy Road to the west, was identified as the area in which the next round of growth in Mayfield West was intended to occur beyond the year 2021.

  It is our opinion that the approval of the Provincial NHS limits prior the review and refinement of these limits at the local municipal level has the potential to undermine the anticipated growth of the Mayfield West Service Centre by limiting the Rural Service Centres ability to accommodate future population and employment. The use of the NHS limits as refined by environmental work completed at the local municipal level would serve to provide protection of the environmental features while allowing the Mayfield West Service Centre to reach its growth potential and meet the intent of the Growth Plan.

  Conclusion

 It is our understanding that the Province is proposing to incorporate comments to the NHS as appropriate and are aiming to finalize the mapping by the end of 2017 with municipalities having to identify and protect what the Province has defined in their Official Plans.  We do not support this process but rather recommend the following:

  •To remove the proposed NHS limits for the affected portion of the Subject Lands as shown in “Attachment A”;

 •To allow the Natural Heritage System (NHS) mapping to remain in draft form until local municipalities can ground truth and make the necessary refinements to the NHS limits through the Municipal Comprehensive Review (MCR) process; and,

 •To allow local municipalities to use the local municipal NHS mapping where it meets the intent of the Provincial NHS policies in the Growth Plan, unless additional rationale is provided from the Province.

  We appreciate this opportunity to provide comments and revisions to the Province’s Natural Heritage System mapping.  We would be pleased to meet with you and your staff to discuss the refinement of the limits of the NHS and their implementation. Thank you for your consideration.

  Respectfully submitted,

 MALONE GIVEN PARSONS LTD.

   Matthew Cory, MCIP, RPP, PLE, PMP

 Principal, Planner, Land Economist, Project Manager

 mcory@mgp.ca

  ATTACHMENT A

 Requested Revision to the Draft Provincial Natural Heritage System Mapping

 Subject Lands, Town of Caledon

 (see original email correspondence dated October 4, 2017)

[Original Comment ID: 211112]