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February 12, 2001
Ken Whitbread Dear Mr. Whitbread: The Coalition on the Niagara Escarpment (CONE) is pleased to provide comments on the above-noted Niagara Escarpment Plan Amendment ("Amendment 71"). CONE has an interest in all matters pertaining to both environmental protection and development on the Niagara Escarpment. CONE, founded in 1978, is an umbrella group of 24 environmental and community organizations and their many thousands of members and supporters. Ever since its founding, CONE has worked consistently for the protection of the Escarpment and its many values to Ontario society. We undertake public education projects, publish a quarterly newsletter, and monitor development up and down the Escarpment. CONE is in full support of Amendment 71. The current amendment proposal gives effect to an intention on the part of the Province to make these lands part of the Niagara Escarpment Plan Area as early as 1974, and to the expressed will of the Ontario Legislature in 1990 that this addition to the Plan Area be completed. That the 2280 hectares proposed for addition to the Plan Area via Amendment 71 properly belong within the Plan is most graphically demonstrated in Figure 7: Digital Elevation Model: Mount Nemo and Surrounding Area (attached), found in the Niagara Escarpment Commission's Review of Niagara Escarpment Plan Boundary: Milton Outlier East and Surrounding Area (February 1999). Although this report was prepared in relation to proposed Plan Amendments in the Town of Milton rather than the Escarpment Link amendment, Figure 7 clearly shows the eastern portion of the Escarpment Link area. The elevation model shows visually that the Escarpment brow and slopes in the western part of the City of Burlington and the eastern part of the City of Hamilton are currently not within the Niagara Escarpment Plan Area. The elevation model also shows the large number of headwaters found on the Escarpment slopes in this area. The health of downstream ecosystems depends on a high level of protection for headwaters areas. The staff report notes the rich diversity of Life Science Areas of Natural and Scientific Interest (ANSIs) (both provincial and regional), Environmentally Sensitive Areas (ESAs), and Provincial Earth Science ANSIs that will soon be embraced by the Niagara Escarpment Plan when Amendment 71 is approved. CONE accepts, however reluctantly, the 1989 decision by the Province to transfer to the Niagara Escarpment Plan Area via the current Amendment only about 20 percent of the lands originally proposed for the Escarpment Link transfer. While we would greatly prefer that all the lands be included in the Niagara Escarpment Plan so that the legislative requirement be met that "lands in the vicinity" of the Escarpment be included, we realize that that is not going to happen, at least in this round. We are pleased that at least the critically important 20 percent of the lands are to be included now. Inclusion of the Escarpment Link lands of Amendment 71 is very important in terms of UNESCO's Biosphere Reserve designation for the Niagara Escarpment, as it gives further credence to the intention of the designation that the Escarpment landform as a whole be protected from incompatible development. It is very helpful to the objective of Escarpment protection that almost half (47 percent) of the Amendment 71 lands are in public ownership and that most or, indeed, all of those lands will therefore become part of the Niagara Escarpment Parks and Open Space System. It is also helpful that purchase of additional required lands will qualify for funding under the Province's Natural Areas Protection Fund. As the staff report notes at page 20, "some of the most sensitive, unique and attractive Escarpment landscapes and environments are included in this public land base." In addition, it will be exciting to have an additional 32 kilometres of Bruce Trail corridor within the Plan Area, to link many of the parks and open space features. Furthermore, having almost half of the Amendment 71 lands in the public domain makes it easier to fulfill the UNESCO Biosphere Reserve criterion of having sufficient lands available for research, monitoring and educational purposes. While the Cities of Burlington and Hamilton contain large urban areas, the inclusion of the subject lands in the Niagara Escarpment Plan Area should not cause undue hardship in terms of the cities' intended direction of urban growth. As noted in the staff report at page 21, "the municipalities have ... not identified the Escarpment Link lands as a major growth areas for industry or population. Emphasis in all official plans is generally on recreational open space, agriculture and compatible rural uses either associated with agriculture, the rural community or the natural environment." CONE fully supports the land use designations proposed for the Escarpment Link lands, and is pleased to see that a full 94 percent of the lands meet the requirements of the Niagara Escarpment Plan for designation as either Escarpment Natural Area or Escarpment Protection Area. We trust that these comments clearly articulate CONE's support of Amendment 71. Please contact CONE if you have any questions. Sincerely, |