The rare Charitable Research…

The rare Charitable Research Reserve is a land trust and registered charity operating in the Region of Waterloo and Wellington County. Currently we own and steward over 1200 acres of land for conservation, scientific research, and educational purposes. As an organization, rare is supportive of efforts to increase protections of land in southern Ontario. We urge governments at all levels to recognize that processes and services provided by intact ecosystems, together with a full complement of biodiversity, support our human population and our economy. Acknowledgement of these indisputable facts, both in principle and in the planning process, is central to building and sustaining prosperity in Ontario. We believe it is important to initiate conversations around expanding the existing Greenbelt and protection of urban river valleys. However, we caution that progress in this area must
not come at the expense of poor land use decisions elsewhere in the Province.

Overall, rare would encourage full protection of existing Greenbelt land, and expansion of the Greenbelt wherever possible. The conservation of intact ecosystems (forests, prairies, wetlands) must take precedence over other land uses, as the restoration of these systems following their loss is not possible in the short term. While it may seem costly to devote land to conservation, the alternative costs in the form of imperfect technical solutions, grey infrastructure, health care resulting from pollution, and so forth, are much higher. The conservation of urban river valleys is an excellent step in improving connectivity, and therefore resilience of ecological systems, across Ontario’s landscape. Expansion of protected river valleys to rural areas, and improved stewardship of these areas, will be critical to the success of this effort.

A key concern is the possibility of confusion in areas where two (or more) different designations of protection apply to the same area of land. Any additional designations must be explicit in stating that the most stringent protection category applies when reviewing activities on a particular piece of property. Any ambiguity in this regard could lead to legal challenges to the designation, resulting in proceedings costly in both time and money to all parties. It must also be explicitly defined what exactly is meant by the most stringent protection category, in order that municipal staff and consultants have technical guidance on questions of ecology and environmental science.

Please find our answers to the specified discussion questions below:

Question 1:
• What are your thoughts on the initial focus area of the Study Area of the Paris Galt Moraine?
A moraine is an incredibly important landscape feature from a variety of perspectives. On the surface it creates a topography that generates a variety of habitats, based on its diversity of slope, elevation, and aspect. This variety of habitats across the landscape is responsible for a significant amount of southern Ontario’s biodiversity, one of the richest areas in Canada. Mineral deposits have value in extraction, but arguably have a greater value in the ability to store and purify water. The Paris-Galt Moraine, in its current position contiguous with the existing Greenbelt, and as a source of drinking and irrigation water for a significant number of human inhabitants, should indeed be a primary area for protection. Land values are very high in this area for uses such as urban and suburban development, aggregate, and agriculture. A government plan that accounts for (and compensates landowners for) additional values in conservation, source water protection, nutrient and water management, and a host of other ecological services. We hope that the study will result in the inclusion of the Paris-Galt Moraine in the protected area of the Greenbelt and serves as an example for further inclusion of important landscape features in future expansions.

Question 2:
• What are the considerations in moving from a Study Area to a more defined boundary of the Paris Galt Moraine?
We would encourage the use of evidence-based approaches to determining the boundary of the protected area, including areas overlying aquifers, surrounding headwater streams (including intermittent streams), and all areas of intact woodland and wetland remaining in the area. We also encourage a meaningful buffer around surface features.

Question 3:
• What are your thoughts on the initial focus area of adding, expanding and further protecting Urban River Valleys?
This is an excellent idea, in terms of providing connectivity between larger areas of habitat. In highly developed areas of southern Ontario, the river valleys themselves represent some of the highest quality habitat due to their unsuitability for development. These rivers and their valleys (basins) also represent water retention and storage on the landscape, mitigating flooding, storing runoff, and supporting the chemical processes needed to reduce pollution of air and water.

Question 4:
• Do you have suggestions for other potential areas to grow the Greenbelt?
We would like to see all additional areas of high-quality contiguous habitat ultimately included in the Greenbelt, to conserve and protect the ecosystems that support Ontario. A landscape-level analysis using existing provincial resources (natural heritage and agriculture resource mapping, wetland and woodland mapping) plus those provided by Conservation Authorities (hazard lands, flood plains, source water) should be conducted. The additional connectivity provided by river valley conservation, as proposed in this consultation, should provide guidance. Specific example areas could include the high-quality habitat in the Eramosa River Valley in the vicinity of Rockwood and Everton (Wellington County), and the Environmentally Sensitive Landscapes identified by the Region of Waterloo. The inclusion of both agricultural and natural heritage areas is central to the philosophy of the Greenbelt, protecting all resources Ontario will require now and in the future.

Other Provincial Priorities
In deciding on where and how to possibly grow the Greenbelt, we must also consider other key provincial priorities that could be impacted. These key provincial priorities include:

Growth Management - it is critical to recognize that Ontario’s land base is finite, and that there are limits to the growth that can be supported. When articulating a vision of the future for the province, physical space for people and jobs must be recognized, but also the physical space for food production, source water systems, and all other natural heritage functions that are required. The plan will not be effective if future revisions simply increase population projects and expand development incrementally. Once ecological function is lost, it is extremely difficult to restore, and highly expensive to replace.

Natural Heritage and Water Resource Systems - a particularly clear example of exactly what is required in terms of source water to support Ontario. Intact and properly functioning ecosystems perform services of water purification and storage without financial cost, outside of space occupied by the natural heritage lands. If these landscapes are lost, they will need to be replaced with much more expensive infrastructure, such as water purification plans, pipelines, and so forth. Salt contamination (from road de-icing) is a particular problem in developed areas, and salt cannot be removed except through reverse osmosis processes, at a very high cost for infrastructure and energy.

Agriculture – The use and stewardship of Ontario’s agricultural land is a question not just for the Province, but for the entire country, as a significant proportion of agricultural land in Canada is found here. Sustainable practices should be encouraged, and the opportunity to diversify agriculture seized in the Greenbelt, as an area of high-quality farmland near our greatest concentration of population. Over-reliance on commodity crops and livestock has led to land degradation and economic dangers. An opportunity to build a superior and more self-sufficient agriculture in Ontario is possible.

Infrastructure – Both the Greenbelt Plan and A Place to Grow recognize that new infrastructure and upgrades to existing infrastructure will be needed to serve the substantial growth projected for the Greater Golden Horseshoe. However, infrastructure should be avoided whenever possible, and limited to shortest-path crossing of the Greenbelt if that is not possible. Additional roads for motor vehicle traffic must be banned outright, and building non-linear infrastructure (industrial plants) also must not occur within the Greenbelt.

Question 6:
• Are there other priorities that should be considered?
Protecting the entirety of the ecologically valuable systems of southern Ontario means looking beyond political boundaries. A scientific approach demands all ecological and hydrological systems be evaluated independently of such considerations, and decisions made based on that information.