Thank you for this…

Thank you for this opportunity to comment on the proposed Agricultural System policies for the Greater Golden Horseshoe (GGH).

The four updated provincial land use plans contain new Agricultural System references and policies that support the protection of farmland while promoting economic development of the agri-food sector within the Greater Golden Horseshoe (GGH). Approximately 420 kilometers of the Bruce Trail Optimum passes through the GGH and may be negatively impacted by the new lot division polices proposed for the Agricultural System.

The Bruce Trail is recognized as a Trail of Distinction by the province and is secured and managed by the Bruce Trail Conservancy (BTC) along with other Niagara Escarpment Parks and Open Space System (NEPOSS) partners. The BTC is recognized as a public body under Part 3 of the NEP and secures the Bruce Trail Optimum Route primarily through severing land pursuant to the Planning Act and as permitted by the New Lot policies under section 2 of the NEP. After examining maps provided through the Agricultural System Portal of the Environmental Registry, we noticed that large sections of unsecured Bruce Trail Optimum Route pass through prime agricultural areas. It is therefore, of great concern to the BTC that the new Agricultural System polices discourages severances of these lands.

Prime agricultural areas are found within the Escarpment Rural Area, Escarpment Natural Area and Escarpment Protection Area designations through which the Optimum Route (OR) of the Bruce Trail passes. Invariably, the OR will either skirt the edges of agricultural fields or pass through areas too marginalized to cultivate. Either way, it is the BTC’s mandate to secure its OR through or on these lands and in doing so, fulfill the goals of the NEP.

Our goal is not to fragment and/or convert prime agricultural areas to non-agricultural uses. On the contrary. Our goal would be to exclude prime agricultural land from our corridor wherever possible but in cases where that is not possible we would keep these lands in production. The BTC has policy that permits keeping productive farm land in cultivation through lease back agreements. Currently, we have 16 lease agreements with farmers who cultivate land almost 600 acres of farmland.

The BTC requests an exemption from the proposed lot division policies for the Agricultural System in the Greater Golden Horseshoe and relevant policies under Part 2.4 (20) of the NEP. We also request that wording be inserted to provide more clarification that the Bruce Trail is considered infrastructure under Part 2.4 (20) (c) of the NEP and other relevant policies.

Thank you,

[Original Comment ID: 211002]