Supplemental Brief By Preservation of Agricultural Lands Society (PALS) re Greenbelt Draft Plan, December 2004 re Natural Heritage Policies- Dr. John Bacher, PALS Researcher November 1st/04

PALS is taking the unusual step of drafting a supplemental brief re the Natural Heritage Policies of the Greenbelt plan because of their unusual complexity. While the our comments apply to the whole of the new "protected countryside", the examples we will employ will be taken from the part of the proposed Greenbelt we are most familiar with- the Niagara Region.

The problem with the approach to natural heritage taken by the draft Greenbelt plan is that the protection is much more ambiguous than that provided by the Niagara Escarpment and Oak Ridges Moraine plans. These plans have protected areas of forests, such as the Escarpment Natural area, contained in clear maps, which are presented in much greater detail than the proposed Natural Heritage System in the draft Greenbelt plan.

The most disturbing aspect of the draft Greenbelt plan is that it will permit development in significant forests outside of the Natural Heritage system- with a proposed coverage of 60% of the existing woodlands. Such isolated forests should receive the highest levels of protection, since they are generally the only remaining natural areas in heavily de-forested parts of rural Ontario.

Isolated forests in southern Ontario are critical to future ecological efforts. These treasure houses are the last repositories of a natural genetic history which evolved over thousands of years, since the last Ice Age. Such species have gradually adopted to our native habitats, becoming well situated to local climates and soils, and giving a great wealth of bio-diversity to our current generation. Nowhere else is this more evident than the last remnants of one of our rarest ecosystems, the Lake Ontario Plain Forest, which survives in very isolated pockets of the Niagara Fruit Belt.

The Greenbelt plan ignores several significant remaining natural areas. The Irish Grove, a small forest of eight hectares in Grimbsy, is one of the finest examples of the Lake Ontario Plain forest remaining in the Niagara Peninsula and is left outside the proposed natural heritage system. Another rare remnant Lake Ontario Plain forest in Lincoln, is the five hectare, Platt's Plot, located one kilometer west of the intersection of the QEW and Regional Road 24. Of similar size and significance in Lincoln, immediately south of the QEW is Myer's Bush. Although the Greenbelt draft plan does recognize the significance of the natural area of Jordan Harbour/Ball's Falls, its extent is greater than the tiny area mapped by the natural heritage plan.

Niagara on the Lake is one of the most heavily deforested municipalities in Ontario. In is therefore necessary to protect all of its remaining forests. The draft Greenbelt plan however, recognizes forests only in a narrow perimeter of Lake Ontario, the Niagara River and the Niagara Escarpment. One forest which is left out through the process is Zuk's Zone, which contains one of the last remaining stands of Paw Paw trees in Ontario. Another significant natural area is the Virgil wetlands on the Four Mile Creek.

The vulnerability of significant isolated woodlots show why the proposed Greenbelt plan and legislation should be strengthened. Forests are at greatest risk in the 205 square mile area left outside the greenbelt immediately adjacent to the current designated urban zoning boundary in the Greater Toronto region and Hamilton. These and forests throughout the Greenbelt, need legislation with greater force that what now exists in most municipal tree by-laws. There must be the ability to send in police to stop illegal cutting- rather than prosecuting after the fact.

All the forests from the edge of the current designated urban area to the limit of the Greenbelt should be protected from development. These forests are greatly shrunken outside the area protected by the Oak Ridges Moraine Protection Act and the Niagara Escarpment Plan. This makes the new proposed "protected countryside", especially in Niagara, heavily denuded of tree cover.

For serious ecological restoration to be possible in the Greenbelt, the core forests should be well protected, so that in future years, they can be gradually expanded and linked. This is a key goal of the Oak Ridges Moraine Plan and it should be similarly spelled out in both the Niagra Escarpment Plan and the entire new "protected countryside."