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Date April 13, 2021 Report No. 2021-248

To Chair and Members Committee of the Whole - Operations and Administration

From Nicole Wilmot, Director of Planning People, Legislated Services and Planning

1.0 Type of Report Consent Item [X] Item For Consideration [X]

2.0 Topic City of Brantford Comments on the Provincial Consultation: Growing the Size of the Greenbelt (ERO Posting 019-3136) [Financial Impact – none]

3.0 Recommendation

A. THAT Report 2021-248 titled “City of Brantford Comments on the Provincial Consultation: Growing the Size of the Greenbelt (ERO Posting 019-3136)”, BE RECEIVED; and B. THAT the City Clerk BE DIRECTED to forward a copy of Report 2021- 248 to the Ministry of Municipal Affairs and Housing and Will Bouma, MPP, Brantford-Brant as the City of Brantford’s official comments in response to ERO Posting 019-3136. 4.0 Executive Summary

The Province has requested feedback on ways to grow and further enhance the quality of the Greenbelt, including a Study Area focused on the Paris Galt Moraine, and ideas for adding, expanding and further protecting Urban River Valleys. The Study Area does not include the City of Brantford; however it is Report No. 2021-248 Page 2 April 13, 2021 adjacent to the northwest municipal boundary of Brantford. In addition, the consultation does not specifically contemplate adding an Urban River Valley in Brantford. It is to be noted that the discharge of water to the Grand River from Paris Galt Moraine improves the quality and quality of source water for Brantford’s drinking water supply.

This Report provides Planning Staff’s comments in regard to this consultation. The City of Brantford is supportive of the Greenbelt in principle and protections for natural heritage features and agricultural land. However, similar to comments submitted to the Province in 2018 regarding a previous proposal to expand the Greenbelt, the City already has comprehensive policies in place to protect these features within Brantford, established in the new Official Plan recently adopted by Council and the Grand River Source Protection Plan. Therefore, expanding the Study Area for growing the Greenbelt into the City’s municipal boundary, and the addition of an Urban River Valley designation within Brantford, are not necessary and redundant. It may also jeopardize the Province’s timely approval of the new Official Plan recently adopted by Council, including the proposed Settlement Area expansion in the northwest area. If an expanded Study Area or additional Urban River Valleys are contemplated within the municipal boundaries of Brantford in the future, the Province should provide the City with additional opportunities for consultation.

5.0 Purpose and Overview

The purpose of this Report is to provide the City of Brantford’s comments to the Province regarding the Growing the Greenbelt initiative, including the proposed Study Area and considerations for adding new Urban River Valleys. Additional comments may be required in the future when the Province seeks feedback on a more specific Greenbelt expansion proposal within a finalized Study Area.

6.0 Background

6.1 Request for Comments on Growing the Greenbelt (ERO Posting 019-3136)

On February 17, 2021, the Province of released a request for feedback on ways to grow and further enhance the quality of the Greenbelt, with a priority of:

 A Study Area of lands focused on the Paris Galt Moraine, as shown in Appendix A, which is home to critical groundwater resources; and Report No. 2021-248 Page 3 April 13, 2021  Ideas for adding, expanding and further protecting Urban River Valleys, which are publicly owned lands in river valleys within an urban context, as shown in Appendix B. The complete posting on the Environmental Registry of Ontario is available at https://ero.ontario.ca/notice/019-3136. The deadline for submitting comments is April 19, 2021.

The Greenbelt is a broad band of protected land that is established under the Greenbelt Act, 2005. The Greenbelt is covered by the policies of the Greenbelt Plan, the Oak Ridges Moraine Conservation Plan, and the Niagara Escarpment Plan, which identify where urbanization should not occur to provide permanent protection to the agricultural land base and the ecological and hydrological features, areas, and functions occurring on this landscape. The City of Brantford is not currently located within or adjacent to the existing Greenbelt or subject to the Greenbelt Plan, the Oak Ridges Moraine Conservation Plan, or the Niagara Escarpment Plan. Brantford is subject to A Place to Grow: Growth Plan for the Greater Golden Horseshoe (the Growth Plan).

The Study Area released by the Province as part of the current consultation to grow the Greenbelt is focused on the Paris Galt Moraine, which runs generally from Caledon in the northeast to Brantford in the southwest. The Study Area does not include the City of Brantford or Settlement Areas within other municipalities also subject to the Growth Plan; however it is adjacent to the northwest municipal boundary of Brantford. The Paris Galt Moraine is an area of rolling, hilly terrain comprised of sand and gravel deposits that is the headwaters for many rivers and streams. Moraines allow rain and snowmelt to soak into the ground more rapidly and in much greater amounts than the surrounding, less permeable areas. The Paris Galt Moraine helps to protect and recharge groundwater aquifers and provides baseflow to rivers and streams, including the Grand River which is the source of Brantford’s drinking water supply.

The Urban River Valley designation in the Greenbelt Plan applies to publicly owned lands in 21 river valleys within an urban context, connecting the Greenbelt to Lake Ontario in the Greater Golden Horseshoe. Urban River Valleys are often lands designated in municipal official plans for parks, open space, recreation, conservation and/or environmental protection. The Province notes that there may be opportunities for additional Urban River Valleys to be added to the Report No. 2021-248 Page 4 April 13, 2021 Greenbelt or existing ones to be expanded to include additional publicly owned land. In particular, the Province is seeking feedback on adding new Urban River Valleys to provide connections to the Paris Galt Moraine through the Speed and Eramosa Rivers in the urban areas of Guelph and Cambridge. The Province has not specifically identified any potential Urban River Valleys in Brantford, such as the Grand River, for inclusion in the Greenbelt Plan.

6.2 Previous Comments to the Province

The Province previously initiated public consultation regarding growing the Greenbelt in December 2017. At that time, the Study Area for a potential expansion of the Greenbelt included much of the northern Boundary Expansion Lands that were transferred from the County of Brant to the City of Brantford through the Municipal Boundary Adjustment approved by the Province in 2017. Planning Staff outlined a number of concerns with a potential expansion of the Greenbelt into Brantford’s northern Boundary Expansion Lands in Report CD2018-033, attached as Appendix C. Since growing the Greenbelt into Brantford’s northern Boundary Expansion Lands would have prohibited a future Settlement Area expansion, these concerns were largely centred around the conflict the Greenbelt would have with the provincially approved municipal boundary adjustment, including the following:

 The inability of the City to meet population and employment forecasts and intensification and density targets set by the Province in the Growth Plan;  The inability of the City to gain the anticipated growth in assessment value in order to fulfill the City’s contractual requirement to compensate Brant County for the Boundary Expansion Lands; and  The disruption to the City’s ongoing Official Plan Review and Municipal Comprehensive Review, which was planned to include extensive technical analysis on water resources and natural heritage features. On February 27, 2018, Council passed the following resolution to serve as the City’s official comments on that consultation:

A. THAT Report CD2018-033, City of Brantford Comments on the Provincial Initiative: Protecting Water for Future Generations – Growing the Greenbelt in the Outer Ring, BE RECEIVED; Report No. 2021-248 Page 5 April 13, 2021 B. THAT the Ontario Ministry of Municipal Affairs BE ADVISED that the official comments from the City of Brantford in regard to the Provincial Initiative: Protecting Water for Future Generations – Growing the Greenbelt in the Outer Ring are as follows:

i. The City of Brantford DOES NOT SUPPORT the inclusion of any City of Brantford lands within the Study Area for the Expansion of the Greenbelt in the Outer Ring for the reasons outlined in Report CD2018-033; and

ii. The City of Brantford DOES NOT SUPPORT any future extension of the Greenbelt into the City of Brantford’s municipal boundary for the reasons outlined in Report CD2018-033;

C. THAT a copy of Report CD2018-033 BE APPENDED to the City’s official comments submitted to the Ontario Ministry of Municipal Affairs; and

D. THAT a copy of the City’s letter to the Ontario Ministry of Municipal Affairs, including a copy of Report CD2018-033, BE FORWARDED to Phil McColeman, MP, Brantford-Brant and Dave Levac, MPP, Brant.

The Province did not make any changes to the size of the Greenbelt as a result of the 2017/2018 consultation. As noted previously, the Study Area being considered through the current consultation excludes all lands located within the City of Brantford, including the northern Boundary Expansion Lands.

7.0 Corporate Policy Context

This Report is related to two of the desired outcomes outlined in City Council’s priorities for 2021-2022.

 Desired Outcome 5: Growth is successfully accommodated in expansion lands.  Desired Outcome 7: The City is mitigating its environmental footprint and adapting to climate change. o Priority a: Demonstrate the City’s commitment to environmental leadership through visible projects. The new City of Brantford Official Plan – Envisioning Our City: 2051 guides how and where the City of Brantford will grow and intensify to the year 2051. It Report No. 2021-248 Page 6 April 13, 2021 includes an expanded Settlement Area to accommodate future urban growth in the Boundary Expansion Lands, while demonstrating the City’s commitment to environmental leadership by protecting an extensive Natural Heritage System as well as agricultural lands. The new Official Plan will support Provincial goals to protect groundwater resources and river valleys without the need to expand the Greenbelt into Brantford, which could impact the Settlement Area expansion and future growth in the Boundary Expansion Lands.

8.0 Input From Other Sources

Planning Staff consulted with Environmental Services Staff in the preparation of this Report. The City’s CAO and Planning Staff also attended a round table discussion with other stakeholders organized by the office of Will Bouma, MPP, Brantford-Brant.

9.0 Analysis

As noted in Section 6.1 of this Report, the Province’s consultation on growing the size of the Greenbelt is focused on seeking feedback on the current Study Area of the Paris Galt Moraine, including input on the considerations in moving from a Study Area to a defined boundary of the Paris Galt Moraine. The Province is also seeking input on adding, expanding, and further protecting Urban River Valleys and suggestions for other potential areas to grow the Greenbelt.

On March 23, 2021, Brantford City Council adopted the new City of Brantford Official Plan – Envisioning Our City: 2051, which includes a Settlement Area expansion into the Boundary Expansion Lands as well as policies to protect an extensive Natural Heritage System and agricultural lands. The City is now awaiting final approval of the new Official Plan from the Province. Staff have concerns that the inclusion of any City of Brantford lands within the Study Area and potential expansion of the Greenbelt into Brantford may prohibit the proposed Settlement Area expansion in the northwest area and jeopardize the timely approval of the new Official Plan. In addition, applying the Greenbelt Plan policies in Brantford would provide a redundant layer of protection for environmental features and agricultural lands given the full scope of policies included in the new Official Plan.

The City relied on the technical analysis completed through the Official Plan Review and related Master Servicing Plan update to design a new Official Plan that will facilitate managed growth while protecting the natural environment and agricultural land. This analysis included a Comprehensive Environmental Impact Report No. 2021-248 Page 7 April 13, 2021 Study and Headwater Drainage Feature Assessment for the Boundary Expansion Lands in north Brantford and Tutela Heights. These studies are part of the North Brantford and Tutela Heights Subwatershed Study completed to support the Stormwater component of the Master Servicing Plan. The new Official Plan also refers to the Grand River Source Protection Plan and includes an extensive Natural Heritage System and a Rural/Agricultural Area as key components of Brantford’s urban structure. The Source Protection Plan identifies vulnerable areas related to the quantity and quality of drinking water sources and outlines policies and programs to prevent and manage or remove significant threats.

The Natural Heritage System in the Official Plan is intended to protect the health and water quality of the Grand River Watershed, protect surface and underground water resources, conserve biodiversity, and protect all significant natural heritage features and their associated ecological and hydrological functions. The Natural Heritage System includes the Core Natural Areas Designation, surrounded by an Adjacent Lands Overlay. The Core Natural Areas Designation protects significant natural heritage features and is delineated with a 30 metre buffer to those features, which include significant wetlands, woodlands, valley lands, wildlife habitat including species at risk and rare plants, enhancement and restoration areas. The majority of lands adjacent to the Grand River are within the Core Natural Area Designation. The Adjacent Lands Overlay identifies lands within 90 metres of the buffered features in the Core Natural Areas Designation. Limited uses are permitted within the Natural Heritage System and any lands being considered for development, redevelopment or site alteration within the Core Natural Area or Adjacent Lands Overlay must be supported by an Environmental Impact Study (EIS) to ensure there is no negative impact to the features.

The Rural/Agricultural Area is within the Agricultural Designation and includes lands outside of the Settlement Area that will be used for agricultural and other rural land uses. Policies applicable to this area are focused on protecting lands that are suitable for agricultural production from fragmentation and the intrusions of non-agricultural land uses, and supporting the existing agricultural industry.

It is the opinion of Planning Staff that the City’s Official Plan policies, combined with the Grand River Source Protection Plan and the existing applicable Provincial policies of the Provincial Policy Statement (PPS) and the Growth Plan, appropriately protect agricultural lands and significant natural heritage features within the City’s municipal boundaries in a way that is consistent with the intent of the Greenbelt Plan. The mutual goals of the City and the Province Report No. 2021-248 Page 8 April 13, 2021 for protecting groundwater resources, natural heritage features, and suitable agricultural lands can be achieved without the need to expand the Greenbelt into Brantford and duplicate protections that are provided in the City’s Official Plan and the Grand River Source Protection Plan. If an expanded Study Area or additional Urban River Valleys are contemplated within the municipal boundaries of Brantford in the future, the Province should provide the City with additional opportunities for consultation. Any future expansion of the Greenbelt into Brantford should be based on relevant data to support more restrictive protections than those already contained in the City’s existing and robust policy framework.

10.0 Financial Implications

There are no financial implications to the City of Brantford associated with this Report.

11.0 Conclusion

The City of Brantford is supportive of the Greenbelt in principle and protections for natural heritage features and agricultural land. The City already has comprehensive policies in place to protect these features within Brantford, established in the new Official Plan recently adopted by Council and the Grand River Source Protection Plan. Therefore, expanding the Study Area for growing the Greenbelt into the City’s municipal boundary, and the addition of an Urban River Valley designation within Brantford, are not necessary.

Staff recommends that this Report be forwarded to the Ministry of Municipal Affairs and Housing as the City of Brantford’s official comments in regard to the consultation on growing the size of the Greenbelt. However, as noted in Section 6.1 of this Report, the commenting period for ERO Posting 019-3136 will close on April 19, 2021 which is more than a week before Council’s regularly scheduled meeting on April 27, 2021. As such, Staff will advise the Ministry that while the Report will have been considered by Committee of the Whole – Operations and Administration at the April 13, 2021 meeting, the future Council resolution regarding this matter will be provided to the Ministry following the regularly scheduled Council meeting on April 27, 2021.

Nicole Wilmot, MCIP, RPP Director of Planning Report No. 2021-248 Page 9 April 13, 2021 People, Legislated Services and Planning

Prepared By:

Victoria Coates, MCIP, RPP Intermediate Planner, Long Range Planning People, Legislated Services and Planning

Alan Waterfield, MCIP, RPP Manager of Long Range Planning People, Legislated Services and Planning

Attachments:

Appendix A – Study Area Map

Appendix B – Urban River Valleys Map

Appendix C – Report CD2018-033

In adopting this report, is a by-law or agreement required? If so, it should be referenced in the recommendation section.

By-law required [ ] yes [X] no

Agreement(s) or other documents to be signed by Mayor and/or City Clerk [ ] yes [X] no

Is the necessary by-law or agreement being sent concurrently to Council? [ ] yes [X] no