March 28, 2017
Infrastructure & Development Services Division
789 Broadway Street, Box 3000
Wyoming, ON N0N 1T0
Mr. Cole;
Mr. Posliff;
The Lambton Federation of Agriculture (LFA), after consultation with the OFA, Mr. Peter Jeffrey and our members remain concerned with the Heritage Corridors in the Lambton County Official Plan.
Mr. Jeffrey has communicated his research with the LFA, which we would like to share.
Natural Heritage; section 8:
The County’s website has amended wording, dated January 23, 2017 for a portion of the Natural Heritage section of the OP. It deletes “secondary corridors”, which is positive. that being said, I think this section would benefit by including the following from section 3.4.5 of the MNRF Natural Heritage Reference Manual, “Farmland in a rural area may function to some extent as a linkage between natural heritage features, or at least it may not impede the movement of any species. This farmland area should be included in its present form(my emphasis) within a natural heritage system and remain that way for as long as the agricultural use remains.” In section 2.3.2 of the Manual, it describes these corridors as an “overlay”, only to be considered when a Planning Act application to re-designate the lands out of agriculture, was being considered. I think the NH section, as it pertains to corridors and linkages, would benefit from including the language from sections 3.4.5 and 2.3.2 of the MNRF Natural Heritage Reference Manual.
In addition, I think that “linkage features” should also be deleted. It’s vague and not defined in the OP or the PPS.
The term “secondary corridors” is found in section 8.1.1 (page 8-4). If it’s being deleted from other parts of the OP, it should be deleted here too.
On page 8-2 (section 8.1.12, the statement from the 2014 PPS reads, “Nothing in policy 2.1 (PPS Natural Heritage policy section) is intended to limit the ability of agricultural uses to continue”. We successfully argued to remove “existing” from this subsection in the PPS. It should not appear here either.
It might also be helpful to clarify that “adjacent areas” are not “buffers” or “no go” zones. Firstly, they are areas where “development”, in the PPS sense (subdivisions, land use changes from agriculture to some urban use) shouldn’t occur. From an agricultural perspective, day-to-day farming activities, including changing from pasture to row crops, are unaffected. Farm buildings may be permitted, depending on their location with respect to a specific feature.
On page E-4 in Appendix E, the definition of “rural or rural lands” seems to combine the PPS definitions of “rural areas” and “rural lands”. The PPS defined these terms as;
Rural areas: means a system of lands within municipalities that may include rural settlement areas, rural lands, prime agricultural areas, natural heritage features and areas, and resource areas.
Rural lands: means lands which are located outside settlement areas and which are outside prime agricultural areas.
I think the draft OP should use these 2 definitions in place of what they are currently proposing.
Peter Jeffery
Sr. Farm Policy Analyst
Ontario Federation of Agriculture
We appreciate the continued open dialogue that the county maintains and encourages with the LFA.
On behalf of the Lambton Federation of Agriculture,
~Al Langford~
President, Lambton Federation of Agriculture
cc: committee members