The Preservation of Agricultural Lands Society (PALS) is writing this brief in opposition to the proposed Project Niagara Symphony project for the Department of National Defence (DND) Lands in the Town of Niagara-on-the-Lake. The proposed concert site which will hold up to 9,000 attendees and have parking for over 1,200 cars, along with several washrooms and sales venues , is located on Greenbelt lands, outside of the Niagara-on-the-Lake urban boundaries and not in a Provincially designated "Places to Grow" growth area.
As well, the proposal, by its requirement to end the use of the sewage lagoons on these lands, encourages their re-location 1 kilometre west- outside of federally owned lands . Such a re-location would inevitably lead to the plant and lagoons' construction on unique fruit land protected from urban development by the Greenbelt.
1. Basic Situation at DND Lands Comparable to Mer Blue Conservation Area Before It Became Conservation Area under National Capital Commission
The basic situation regarding the DND lands in Niagara - on- the- Lake is comparable to that regarding the Blue Mer Conservation Area in Ottawa, which is now managed by the National Capital Commission. (NCC) It is a designated as a preserved wetland under the 1971 Ramsar International Convention on Wetlands. This wildlife sanctuary was, previous to its acquisition by the NCC , used by DND as an air force bombing practise. Range. In a similar fashion, much of the ecologically sensitive DND lands in Niagara- on- the- Lake were used for tank practise. While not having the as deleterious impact as bombing, the use of the DND lands for tank practise did have the harmful impact of soil compaction.
It is fortunate that the NCC when it acquired Mer Blue used the entire parcel for wildlife conservation. It had areas that previously had no significant natural characteristics reforested- thus buffering and expanding the core natural area. This is the approach that should be taken to the DND lands, not using peripheral lands as a symphony venue. Doing so will have harmful ecological impacts such as pollution in various forms, ranging from automobile exhaust to contaminated storm water, as well as making it more difficult to protect the rare Carolinian forest. Also the current sewage lagoon which is proposed to be re-located to facilitate the Symphony scheme, contains some of the wetland functions which are appropriate to the use of the DND lands as a nesting site for the Red-Shouldered Hawk, a species of special concern.
2. Lake Ontario Forest is a Rare Ecosystem, Which Needs to Be Expanded.
According to the report, "Significant Natural Areas Along the Niagara Escarpment", prepared in 1976 by the Ministry of Natural Resources, (MNR) some 95% of the former Lake Ontario Plain forest has been occupied and impacted, thus seriously reducing representative natural communities. The forest on the DND lands is one of the largest remaining parts of this precious five per cent of an almost vanished ecosystem. It is also the last Carolinian forest on Lake Ontario shores.
Rather than being partially, but significantly, used for a symphony, the entire DND site, with the exception of the area used for sewage lagoons, should be reforested and linked to the adjacent former Niagara Shores Conservation Area. The former Niagara Shores Conservation Area should be transferred by the Town of Niagara- on- the-Lake, to Parks Canada to become part of a National Park, that could be named Lake Ontario Plains Forest National Park, to highlight the ecosystem it would be mandated to protect, or the Tecumseh National Park, to honour this Shawnee Chief's farsighted reverence of healthy forests.
It was inappropriate for the former Niagara Shores Conservation Area, to have ever been transferred to the Town of Niagara -on- the- Lake. The Town has no conservation biologists on staff in contrast to the Niagara Peninsula Conservation Authority, which formerly managed this area. The wetland habitat here is one of the reasons that the DND lands are a breeding area for the Red Shouldered Hawk, since extensive wetlands are a requirement for this species.
According to MNR's Natural Heritage Information Center the Niagara Shores Conservation Area does contain a number of rare and unusual Carolinian species. If this area is rejoined with the DND lands and the expanded area becomes one forest, these species will be able to expand their range. One uncommon Carolinian species is the Pignut Hickory. Another is the nationally significant species, Pin Oak.
The MNR Natural Heritage Study does provide information about both the Niagara Shores Conservation Area and the adjacent DND lands. It notes that, "The rich seepage slopes and rims of the bluffs, along the Two Mile-Four Mile Creek Plain provides habitats for regionally uncommon species as Shephedia canadensis (soapberry), Gentiana crimita (fringed gentian), Solidago chipensis (Ohio godenrod) and Andropogon geradi (turkey foxgrass). ' It also notes that "the open fields may contain rare prairie grasses", a feature which is notes may have arisen because of soil compaction by tanks, which suppressed tree growth.
Problems experienced in the conservation of the endangered Cherry Birch population in St. Catharines adjacent to the mouth of the 15 Mile Creek illustrate the importance of expanding the very limited area of Lake Ontario Plains Forest. Although there has been a serious effort to conserve this population, it has become more vulnerable to Lake Ontario storms because of the openness of the area. This gives in effect the winds that have pushed trees into the lake, greater force. The Executive Summary of the 2006 Committee on the Status of Endangered Wildlife in Canada, (COSEWIC) notes that, clearing has impacted the species survival "by making the remaining habitat more prone to wind damage from storms off Lake Ontario." It finds that "the open location lacking protection from lake storms is a continuing threat."
3. General Ecological Reasons Why Forests on DND Lands Should Be Expanded.
There are a number of reasons why the forests on the DND lands should be reforested from a general rather than immediately site specific perspective. First, it should be understood that although Niagara- on- the- Lake's Carolinian forests are rich in species diversity, they are extremely limited. The two per cent of the rural area of the Town of Niagara-on-the- Lake in forest cover presents one of the worst situations in Ontario, likely only matched by a few townships in Essex County.
There are many good reasons why there should be a greater percentage of Niagara-on- the- Lake's in forest cover. The Canadian Department of the Environment recommends that 40% of rural lands be in forest cover, for such important reasons as bird habitat and the protection of water resources. It is tragic that this information does not seem to have been absorbed by either the Town or Parks Canada.
The basic reasons that Environment Canada is calling for more forest cover in Great Lakes watersheds are based on assumptions of relative climate stability. These reasons are amplified when the impacts of climate change are considered. In this regards expanding forests become an important part of the strategy to both reduce climate change (as a carbon sink), and to mitigate its consequences. (ie. reduce the impact of storm events, modify climate and help improve water tables)
The DNP lands and the associated former Niagara Shores Conservation Area represent the only area in Niagara- on- the- Lake where it is possible to expand forests significantly. This is because the farmlands here are among the most productive in all of Canada. Expanding forests on this site should be a priority, unless the lands area needed for the associated sewage lagoon, or as alluded to earlier contain significant prairie species.
4. DND Lands Contain Threatened White Wood Aster.
One of the most important ecological functions of the DND land is that it provides habitat for the Threatened White Wood Aster. Its Canadian population is confined to the Niagara Region and a few woodlots in southwestern Quebec. There are only 25 reported locations in Canada, 15 in Ontario, and 10 in Quebec.
Fewer than 10,000 plants of the White Wood Aster have been documented. The COSEWIC report notes that, "Of the populations that have been confirmed recently, all but two are threatened to some degree, either by habitat destruction and development, trampling, small population size or environmental factors as competition with invasive species and deer browsing or weevil consumption."
The COSEWIC report points out how both the DND lands and the adjacent former Niagara Shores Conservation Area are part of an MNR Area of Natural and Scientific Interest.
Since this is one of the few descriptions PALS has been able to find of this ANSI feature, which in itself, if properly applied, should not permit the symphony scheme to go ahead, the report here is quoted directly.
"Two Mile-Four Mile Creek Area of Natural and Scientific Interest
Niagara Shores Conservation Area
The Niagara Shores Conservation Area population is located on a forested barrier beach dune between Lake Ontario and Four Mile Creek. Two sub-populations of Eurybia divancata are located on a well-drained wooded sand beach ridge consisting of silt loam to fine sandy loam. (Shape et al, 1995) A total of 25 plants were found by the author in 2000. In 2002, this population had increased to 185 plants.
Department of National Defence
A population was also located on the Department of National Defence property. This consisted of 3 sub-populations totalling 165 plants, all within a 1 km area. A second colony of plants reported from this area has not been located since 1991. "
In the Summary of the Status Report for White Wood Aster it is noted that, "The populations at Four Mile Creek-Niagara Shores are just barely 1km apart. They should be considered part of the same population, although it should be noted that the sub-populations within the Niagara Shores Conservation Area are at high risk of extirpation due to their location along the main trail system. The population located within the Department of National Defence property contain more plants and are probably more protected, as gaining access to that property is difficult."
From reading the status report on White Wood Aster, it is clear that attracting thousands of people for concerts to the DND lands is not a good thing. This rare species has done well here since "gaining access to that property is difficult." If the existing forest on DND lands were expanded to the east and connected to the Niagara shores Conservation Area this would also be a good place where the threatened population could expand its range.
4. Red-Shouldered Hawk Breeding Site Shows Importance to Expand Forest
Since 1983, the Red-Shouldered Hawk has been recognized as a Species of Special Concern. One of the reasons for this is that the species has essentially abandoned south-western Ontario due to the lack of the large areas of mature forest that it requires for survival. The status report for Red-Shouldered Hawk notes that, "Large contiguous forest tracts are necessary to sustain breeding populations of Red-Shouldered Hawks". This is in part because of competition in more open areas from the more aggressive Red Winged Hawk and Great Horned Owl. Many Red-Shouldered Hawks will avoid areas of human use. The DND lands according the status report, are the only confirmed breeding area in the entire Niagara Peninsula. There are very few breeding locations in Ontario south west of Toronto. To encourage breeding success for the Red-Shouldered Hawk, the existing DND forest area needs to be expanded. The symphony scheme collides with the continued success of this noble indicator of a healthy ecosystem.
5. Sewage Lagoon Should Continue to Function on Site with Constructed Wetland Polishing Function.
As indicated earlier, the existing sewage lagoon on the DND lands should stay in place, with the additional polishing stage provided by the constructed wetland. The feasibility of this approach was documented on site by the late Dr. Edgar Lemon, who was recently posthumously awarded, the Niagara Region's Lifetime Environmental Achievement Award. Such a polishing constructed wetland would moreover, provide such of the wetland and aquatic habitat needed for the continued breeding in Niagara, of the Red-Shouldered Hawk.
Both a constructed wetland and buffering the lagoon with a forest, should eliminate the odour problems which have been used to justify the symphony project. In this regard, odour problems have not been a problem in Arcata , California, where a constructed wetlands area was added as a final polishing element to the lagoon treatment- which is not present in Niagara.
Although as indicated earlier, there is a problem with encouraging more access to the DND lands, one of the potential benefits of a constructed wetland is a a tourist attraction. Since it attracts so many birds, the constructed wetland in Arcata California, is a major tourist attraction, drawing 150,000 visitors annually. The Ford Foundation recently founded a nature interpretation center here in recognition of the environmental and economic benefits of Arcata's constructed wetland treatment system. Such a center on the DND lands could effectively police visitors, to keep them out of environmentally sensitive areas.
In this regard, as mentioned previously, PALS objects strongly to having a sewage plant and lagoons on the unique fruit land surrounding Niagara- on- the- Lake. This excellent farmland will be increasingly needed as a result of the instability of climate change.
6. PALS Urges Creation of Lake Ontario Plains (or Tecumseh) Forest National Park
In conclusion, PALS urges the creation of a Lake Ontario Plains Forest (or Tecumseh) National Park, which would expand the rare Carolinian forest and make use of it and a constructed wetland as an eco- teaching site Overall, protection of this area, both the forest and grasslands, as well as the protection of adjacent fruitlands, should be seen as more important than the relatively trivial pursuits suggested by the Niagara Project (which could be located elsewhere in Niagara) and should be viewed as an important adaptive strategy to the negative impacts of climate change.