by Erwin Dreessen
Note: This article appeared in Trail & Landscape 41(3): 160.
This article reviews the background and history of the National Capital Commission’s (NCC) land acquisitions and disposals. It then provides an analysis of newly available information on lands outside the so-called National Interest Land Mass (NILM) and questions the professed vocations for many of these lands with respect to the utility of the NILM concept. Recommendations for the non-NILM land holdings and modifications in Treasury Board rules are made.
Genesis of NCC Land Holdings and Disposals
Ever since Ottawa was designated as the nation’s capital, the federal government and its agents have been active in the acquisition of land in the area. Specifically, the Ottawa Improvement Commission (since 1899), the Federal District Commission (since 1927) and the National Capital Commission (since 1958) have acquired land to create parks and parkways close to downtown, along the Rideau Canal and at the south end of Gatineau Park. The Gréber Plan (1950) resulted in land acquisition for the Greenbelt, a major expansion of Gatineau Park and various other sites, including urban corridors.
Along with federal retrenchment starting in the mid-1980s, the Treasury Board ordered a review of land holdings and, in 1988, approved the concept of National Interest Land Mass (NILM). Not all NILM lands were on the books of the NCC, some were in private hands. Lands not designated NILM were, in principle, to be disposed of. Exceptions included future sites for embassies and future municipal transportation corridors. All disposals were and still are required to be at fair market value. In 1990, the Treasury Board agreed that proceeds of land sales would not go into general revenue but could be retained by the Commission for the purpose of acquiring NILM lands not in federal hands; in 1992, this directive was loosened to also permit the proceeds to support life-cycle management of capital assets such as bridges and official residences.
Since 1995, the NCC can dispose of real property up to $200 000 with little ado. A property worth more than $200 000 can likewise be disposed of provided it is listed in the annual Five-Year Corporate Plan submitted to the Treasury Board (Appendix 1).
NILM and Non-NILM Lands
The NILM concept was described in the 1988 Plan for Canada’s Capital (also known as the Federal Land Use Plan or FLUP). It named as National Interest Lands: “the national institutions and symbols, rivers and canal banks, Confederation Boulevard, the parkway corridors, Gatineau Park and the Greenbelt,” saying these will be retained “in perpetuity.” (The only other lands in which it said the NCC has a legitimate continuing interest were sites for future diplomatic missions and institutional buildings, and potential transportation corridor lands.)
The FLUP distinguished Conservation Areas, Capital Parks, Shorelines, Parkways & Recreational Pathways, and Agricultural and Forestry lands, but provided no lists. There is a map showing these designations, however (Map 4 – Natural Environment). In the Plan’s conclusion, policy direction (j) reads: “selective land acquisition, exchange and disposal program to consolidate the National Interest Lands and support the priorities expressed in this Plan.” There was no list of land holdings to be disposed of.
The 1999 Plan for Canada’s Capital described the NILM as “national shrines; the rivers and canal banks; the ceremonial route encompassing Confederation Boulevard and Brewery Creek lands; Gatineau Park; and the Greenbelt.” It noted that not all NILM lands were in federal ownership (“e.g., the La Baie site in Gatineau”) and that the NILM “will be revised as part of the implementation of this Plan.”
The Plan referred to “Capital Urban Green Spaces,” meaning Capital Parks and green corridors. “Key Capital Parks” were said to “include:” Confederation, Jacques Cartier, Rockcliffe, Major’s Hill, Rideau Falls, Commissioner’s, Hog’s Back/Vincent Massey, Leamy Lake, Brébeuf, and LeBreton Common. The Plan also noted that certain lands considered Capital Parks in the 1988 Plan “are no longer considered to fulfill this role as a result of the 1995-99 review” and that these “include:” the Prince of Wales site, except for the shore lands [this refers to Moffatt Farm], Shirleys Bay and Gatineau Park, south of Gamelin Boulevard, which are now both designated as Natural Heritage Areas (like the rest of Gatineau Park and portions of the Greenbelt).
Recent Disposals and Acquisitions
The Treasury Board rationale of NILM designations and a list of lands so designated are not in the public domain (confirmed in an e-mail communication from NCC staff, September 29, 2006). Nor are records of land acquisitions and disposals readily accessible. In September 2002, the Ottawa Citizen published an article on the NCC’s land transactions during the years 1993-2002 based on Access to Information research by Ken Rubin. The list of disposals as documented in The Citizen included:
- 1993-94: sale of Greenbelt land for construction of Hunt Club Road ($2.4 M) and of the Aviation Parkway to Canadian Mortgage and Housing Corporation ($1 M);
- 1994-95: sale of the Britannia storm sewer wetlands ($1 M) and 63 Echo Drive (for condos, $1 M);
- 1995-96: sale of the US Embassy site ($12.4 M), land on the Chemin de la Montagne (for a shopping mall, $3.6 M), a $1 M sale to J.D. Turnbull Development Inc. for an unidentified site in Ottawa, and another $2.6 M in other land sales. The NCC also acquired land from Public Works on Maloney Boulevard for $6 M, turning it over to Gatineau for the Des Draveurs Parkway;
- 1998-99: sale of the Concord-Echo lands (to Claridge Homes, for $3 M), and another $2.9 M in other land sales;
- 1999-00: $3 M in land sales, half of it again to Claridge Homes;
- 2000-01: sale of land on Sussex Drive (to the Agha Khan Foundation, for $5.2 M), an Albion Road property (to a numbered company, for $2.2 M, Greenbelt land at Fallowfield and Woodroffe (to the regional government, for a bus terminal, for $1.3 M), land at Innes and Blair (to another numbered company, for $6.7 M), and another $3.4 M in other land sales; and
- 2001-02 (to February): the Nicholas-Waller triangle (to a Montreal developer, for $1 M); the Heron-Walkley lands (to Claridge Homes, for $1.5 M).
The Commission Chair explained to the Senate Finance Committee in June 2002 that, of the 1273 hectares (ha) sold since 1989, 60% had been conveyed to municipal or provincial governments, 24% remained greenspace and 14% (173 ha) had gone to private developers; of the remaining 2%, 18 ha went to churches or schools, 10 ha to other federal agencies and 1 ha to an embassy. A September 2006 NCC staff paper, “About National Capital Commission Lands,” stated that disposals over the period 1989-2006 amounted to 1450 ha. (A draft version of the paper, provided to the Coalition in June 2006, noted that these figures do not include transactions involving small parcels in the period 2002-2006.) Forty nine percent of this acreage was described as being transfers to municipal and provincial governments and agencies for public infrastructure, while 23% was destined for private or public recreational or open space use, and 28% (405 ha) was destined for development, including 287 ha to the private sector.
Between 1992 and 2006, annual net proceeds from land sales have ranged between $3.3 million and $32.7 million, for an average of $11.1 million per year (e-mail from NCC staff, September 28, 2006.)
Recent acquisitions have included:
- 1994: 617 ha of Meech Creek Valley for lands in Hull, Aylmer and Chelsea, from the Outaouais regional government
- 1995: Rockcliffe Park, from the City of Ottawa
- 2000: 360 ha of Mer Bleue bog
- 2000: 780 ha of the Agricultural Research Farm on Woodroffe Avenue (This acquisition, located in the Greenbelt, did not add to Ottawa’s greenspace as it simply transferred title from the books of Agriculture and Agri-Food Canada to those of the Commission.)
- 2003: the Scott Paper site
The NCC paper notes that total acquisitions over the 1989-2006 period have amounted to 2477 ha, leaving about 700 ha of acquisitions to be identified.
Current Non-NILM Holdings
Of the Commission’s 47 300 ha in land holdings, 3.2% or 1,500 ha is classified as Non-NILM (e-mail from NCC staff, September 29, 2006). Three lists comprising urban, non-urban and Non-NILM lands as well as three associated maps based on GIS data, and the September 2006 NCC paper are now available on the NCC web site (see About NCC Lands). The lists provide a brief description of the property, its acreage (in m2), what the maps call its “potential vocation” and, sometimes, a clarifying comment. The 136 lines add up to 1435 ha (with the remaining 65 ha thought to mainly consist of so-called water lots, primarily along the Ottawa River). The maps also show the NILM lands that are on the NCC’s books. An analysis of this information and a summary table are provided in Appendix 2.
In brief, the analysis shows that:
- 276 ha, almost all in Quebec, have a Transportation vocation. They are generally along major highways and in many cases under contract with the Province or the City of Gatineau
- 252 ha are labelled “Development (Municipally Designated).” One-half is in non-urban Quebec, including 106 ha in La Pêche and 22 ha at the edge of Gatineau Park. Most of the rest is in urban or non-urban Ontario and is presumably also destined for development
- the largest category (575 ha) is one with a vocation “To Be Determined.” Almost half of that acreage is in non-urban Quebec, including 85 ha at the edges of Gatineau Park. In urban Quebec, properties include the Champlain Corridor and part of Moore Farm. In urban Ontario, the 166 ha labelled “To Be Determined” include portions of the Southern Corridor and 18 ha at the edge of the Greenbelt
- “Open Space” (and/or “Urban Natural Feature”) are vocations almost exclusively found in Ontario. In the urban area, apart from 58 ha in the Southern Corridor (including McCarthy Woods) and the 11-ha Hampton Park, these properties are mostly very small parcels. Lands in non-urban Ontario with this vocation are the Innes Road by-pass and parcels near Carlsbad Springs, all at the edge of the Greenbelt and totalling 77 ha
- three sites in Ontario, all leased to the city, are labelled “Recreation” as is the 58-ha Champlain Golf Club in Quebec
- seven small properties in Ontario are marked as “NILM Designation to be confirmed”
In total, 107 ha are located at the edge of Gatineau Park, 95 ha border the Greenbelt and one 2-ha parcel is along the Rideau River.
The NCC’s planning documents do not provide accountability for the NCC’s actions with regard to land holdings. The NILM concept and designations were arrived at in 1988 without input from the public – only municipal staff was consulted (e-mail from then NCC Senior Planner Richard Scott, June 21, 2004). Lands changed NILM status between 1988 and 1999, again without public input. More lands than those named in the 1999 Plan lost their NILM status. For example, the so-called Eastern Corridor (from Pleasant Park Woods to Walkley Road) was shown on the 1988 map as a Recreational Pathway but was (with preservation of at best a 20- or 30-metre pathway) conveyed to the city, the region and private developers in 1995.
In the recently provided lists, the lands described as having their NILM status “To be Confirmed,” are in this holding category because there is an issue whether they should be declassified (possibly then allowing development). (E-mail from NCC staff, September 29, 2006. The response notes that any change in designation would be examined through a planning study that would include public consultations.)
The “potential vocations” ascribed to the Non-NILM listings have an uncertain relationship to the legally valid designations found in municipal official plans and zoning by-laws. We know of no NCC planning documents that provide a definition of these vocations or a rationale for their application to these lands.
A number of designations make intuitive sense but, in general, the public cannot escape the impression that whether a particular piece of land is part of the NILM or not, or what the status is of non-NILM land holdings, has essentially been determined by the Chair’s office. Attesting to the large measure of uncertainty is that, in the recent lists, the largest “potential vocation” category, comprising 575 ha, is “To Be Determined.”
The NILM lands display a certain degree of coherence (Gatineau Park, the Greenbelt, along the Ottawa, Gatineau and Rideau Rivers and Canal), but there are also curious gaps, e.g., along the Rideau River. (One should note that NILM status does not guarantee protection. Only strong popular opposition and a decision by the Quebec Minister of Finance prevented conversion of part of Leamy Lake Park to a golf course for the Hôtel du Casino in June 2002.) Transactions or decisions about otherwise similar lands appear to be inconsistent. E.g., the Pinecrest Corridor (connecting Britannia Bay to the Central Experimental Farm and the Rideau Canal) is in the NILM but the Eastern Corridor was abandoned. The vocation of the Southern Corridor (except for McCarthy Woods) remains “To Be Determined” and is still before the Ontario Municipal Board in an NCC appeal of the 2003 Official Plan designation of part of this land as Major Open Space. (This is consistent with earlier behaviour, e.g. the NCC’s appeals of the former City of Ottawa’s 1991 Official Plan and 1998 comprehensive new zoning by-law. For a detailed analysis, please see Amy Kempster, “National Capital Commission: Protector of Greenspace or Protector of Developer Rights?” 7 April 2003.) The corridor of the Aviation Parkway remains part of the NILM, but the lands around the Airport Parkway were conveyed to the Region in the late 1990s.
The Non-NILM lands include a number of major blocks (including the Southern Corridor, lands at Hurdman, Hampton Park, the Champlain Golf Course and Champlain Corridor, and Moore Farm), and over 200 ha bordering either the Greenbelt or Gatineau Park, but show otherwise little coherence.
Only more detailed information could reveal the ecological and social significance of these holdings, large or small. What is clear, however, is that, whether NILM or not, these lands are part and parcel of the landscape of the national capital area. Various authorities, the public and other processes bring specific interests to bear on any given parcel, but all are about the one land. Labelling certain lands as of “national” and others as of “local” importance runs counter to the holistic approach that would permit seeing the land on its own terms, in its real context.
In the mid-1990s, work was begun on an Urban Lands Master Plan but the project was abandoned without explanation. More recently, it was again announced that such a master plan would be developed, but once again the work seems to have stalled. The NCC paper refers to this planning process without providing any specifics except to promise that there will be a public consultation component.
The Summaries of the annual Five-Year Corporate Plans include no lists of properties over $200 000 that are intended for disposal.
Two Treasury Board rules run counter to land use planning in the public interest. One, having part of the NCC’s budget depend on proceeds from land sales (at the average rate of $6 million per year according to the current Corporate Plan) provides a perverse incentive to sell off land to meet revenue requirements. Two, the requirement that land must be disposed of at fair market value overlooks the fact that these lands were acquired with a public interest in mind and that, while a determination fairly could be made that the NCC should not hold on to certain land, that does not necessarily extinguish the public interest.
“Vocations” such as Open Space/Urban Natural Feature, Recreation and Transportation leave the definite impression that these lands are not up for disposal. One may wonder what being labelled “Non-NILM” really means.
Various transactions and contractual arrangements over the past 18 years demonstrate that the NCC confers with other governments in seeking a destination for lands on its books that it considers outside the NILM. It is also evident, however, that if another government is not interested or unable to pay, then with rare exceptions the Commission turns to private developers, in pursuit of maximum value. (Staff was unable to state whether Non-NILM lands that are labelled Municipally Designated for Development acquired that status before or after the NCC obtained the property. In certain instances (e.g., the Southern Corridor in the late 1990s), the Commission went to bat in an attempt to up-zone land so it would fetch a higher value. In recent years, it has let the prospective buyer/developer face the community and City Hall (e.g., Moffatt Farm in 2004). It is not known whether in such instances the ultimate selling price was made a function of the degree of the developer’s success. On the other hand, as the text above noted, the Commission has fiercely resisted any diminishment of its development rights and continues to do so in cases pending before the Ontario Municipal Board.) Options that would preserve the value a local or wider community may attach to the land do not appear to be considered. National or local land trust organizations have, to our knowledge, never been approached, let alone that new community trusts that could take on stewardship of the land would be encouraged.
- Consideration needs to be given to the role of all Non-NILM lands in the life of the community. All Non-NILM land holdings should be subjected to a detailed review, involving a public consultation process and full disclosure of information. This review should then lead to the development of an Urban Lands Master Plan.
- Treasury Board rules for disposal of real property should be modified to allow for environmental, community and heritage values in addition to fair market value.
- All land use planning, including all disposal considerations, should include a meaningful consultation process that involves the general public.
- If it is concluded that a holding is to be disposed of, then all options for conveyance should be considered, including transfer to a community land trust.
- The NCC should receive sufficient annual funding so that it is not compelled to sell off lands to fund its program requirements and proceeds from its land sales should be credited to the government’s general revenue fund.
- Adam, Mohammed, “The NCC’s decade-long, $60M property sell off,” The Ottawa Citizen, September 25, 2002, p. D1.
- Kempster, Amy, “National Capital Commission: Protector of Greenspace or Protector of Developer Rights?” 7 April 2003, available at: http://greenspace.bluephyre.com/node/229.
- National Capital Commission, Plan for Canada’s Capital, a.k.a. Federal Land Use Plan, 1988.
- National Capital Commission, Plan for Canada’s Capital, 1999.
- National Capital Commission, 2004-2005 Annual Report and previous issues.
- National Capital Commission, 2004-2005 to 2008-2009 Summary of the Corporate Plan and previous issues.
- National Capital Commission, “About National Capital Commission Lands,” 8 pp., available on the NCC web site under Plan, Preserve & Develop / Planning Canada’s Capital / About NCC Lands.
- National Capital Commission, lists of Non-NILM lands; and maps of NCC NILM and Non-NILM lands, available on the NCC web site.
This paper, in slightly different form, formed Annex D of a paper submitted by a Coalition for NCC Renewal to last year’s NCC Mandate Review Panel. The Club was a member of this Coalition. More on the Coalition and the Panel’s recommendations
The author is a former Chair of the Greenspace Alliance of Canada’s Capital and recently became a member of the Club.
Appendix 1: Legal Framework for the Disposal of Surplus Land
(Information provided by NCC staff, June 2006)
The NCC’s authority to dispose of surplus land is derived from the National Capital Act (NCA) and the Financial Administration Act (FAA) & Regulations. Subsection 15(2) of the NCA allows the NCC to dispose of real property for up to $10 000 and requires Governor-in-Council approval for disposals above $10 000, in accordance with subsection 99(2) of the FAA.
Under subsection 99(2), an agent Crown corporation may dispose of property and use the proceeds but only in accordance with regulations or the authority of the Governor in Council.
The Crown Corporation General Regulations were issued in 1995. Sections 5 and 6 of these regulations apply to the disposal of property pursuant to 99(2) of the FAA. They allow corporations like the NCC to sell real property at fair market value as follows:
- properties with a fair market value of $200 000 or less; and
- properties valued over $200 000 where the transaction is consistent with the most recently approved corporate plan.
The NCC includes a list of potential property disposals valued over $200 000 in its annual corporate plan that is submitted for Governor-in-Council approval.
Section 6 of the regulations allows the NCC to use the proceeds from sale in a manner that is consistent with its approved corporate plan.
Appendix 2: NCC Non-NILM Land Holdings: An Analysis
NCC staff has created a listing of Non-NILM land holdings as of October 2006, comprising a total of 136 line items over three lists. They are posted on the NCC web site and are not reproduced here. The line numbering is not continuous across the lists. The Urban Lands list refers to Ontario in lines 1-61, 101-106 and A-F; and to Quebec in lines 62-100. The second list is for Non-Urban Ontario and has lines 1-6 and A. The third list covers Non-Urban Quebec in 20 lines. As well, three corresponding maps are provided, which also show the NILM lands that are on the NCC’s books. The table at the end of this appendix summarizes these data. (The author was provided with an earlier version of the lists in July. In the new version, 9 line items for small properties, totalling less than 4 ha, are added; 3 properties, comprising a total of 10 ha, are shown as having been sold in September 2006; and the size of many holdings has vastly increased. Between the July and October versions, total land holdings identified increased, net, from 966 ha to 1435 ha.)
What the lists provide under “Description” is on the maps called “Potential Vocation.” There is no explanation of the definition of the various “vocations” nor of the source or authority for these categorizations.
The largest category (575 ha) is “To Be Determined.” Almost half of that acreage is in non-urban Quebec (281 ha). Of these, 85 ha are at the edges of Gatineau Park (lines 12-18) and another 131 ha are near Pink, Terry Fox and Cook Roads (line 19). (In the list for Non-Urban Quebec, line 19 is labelled “Transportation” but the Map colours it as “To Be Determined.” NCC staff has confirmed that the description “Transportation” is in error (e-mail from Sandra Pecek, October 4, 2006). Another error regards line item 84 in Urban Quebec: It is Open Space but is erroneously coloured as Recreation on the map (idem).)
In urban Ontario, the 166 ha labelled “To Be Determined” comprise 18 line items. Three of the properties are in the Southern Corridor and are in whole or in part the subject of an NCC appeal of the 2003 Ottawa Official Plan to the Ontario Municipal Board (lines 1, 6 and 8, totalling 130 ha). Two properties, both at Bank Street and Lester Road, totalling 18 ha, are at the edge of the Greenbelt (lines 13 and 14). Six ha are part of LeBreton Flats (line 58). Two small properties in non-urban Ontario (lines 1 and 2) are at the edge of the Greenbelt.
In urban Quebec, major components of the 127 ha “To Be Determined” are the Champlain Corridor (99 ha), part of Moore Farm (20 ha), and Chars de combat Park (5 ha) (lines 66, 68 and 77 respectively).
The vast portion of what is labelled “Transportation” is found in urban and non-urban Quebec, almost all under contract with the province and generally along the major highways; the Philemon-Wright Corridor is leased to the City. There is a total of 276 ha in the Transportation category (plus some at Hurdman – see below).
The next largest category is labelled “Development (Municipally Designated)” and comprises 252 ha. This is based on an official plan or zoning designation of the respective municipalities that offers development rights “and with which the NCC agrees” (e-mail from Sandra Pecek, September 29, 2006). It is not clear what these rights are and whether they were obtained before or after the properties were acquired by the NCC.
Over one-half of this acreage is again in non-urban Quebec (140 ha). Of these, 106 ha are at La Pêche (line 11). Another 22 ha are at the edge of Gatineau Park (line 9).
Almost all other acreage in this category is in urban or non-urban Ontario, 73 and 37 ha respectively. Four large properties, on Walkley at Hawthorne Road, a future Hunt Club Road extension at Russell Road, and at LeBreton Flats, comprise the vast portion of urban land in this group (61 ha, lines 15-17 and 56). Of non-urban land, 33 ha are at Limebank Road, south of Leitrim (line 4); the remaining parcel is at nearby Honey Gables (line 3).
“Open Space” (and/or “Urban Natural Feature”) are designations almost exclusively found in Ontario, over a total of 176 ha. Note that these terms are defined in the 2003 Ottawa Official Plan (if one accepts that “Open Space” stands for the OP’s “Major Open Space.”). In the urban area, these are mostly very small parcels; the exceptions are: portions of the Southern Corridor (lines 5 and 7, totalling 58 ha), 7 ha at Moffatt Farm that are under contract with the City (lines 20 and 21), and Hampton Park (11 ha, line 60). The 77 ha in non-urban Ontario (lines 5 and 6) are at the edge of the Greenbelt.
In urban Ontario, “Recreation” refers to three sites, all leased to the City: Mooney’s Bay, a ball diamond along Mann Avenue, and a tiny parcel next to the RCMP headquarters (lines 18, 40 and 43). Note that “Recreation” is not an Official Plan designation; in the 2003 OP, Mooney’s Bay is Major Open Space. In urban Quebec, almost all of the acreage refers to the Champlain Golf Club (58 ha, line 65); there is no annotation next to this item that the site is leased or under contract.
Line 32 of the Urban list 1 refers to 42 ha at Hurdman and ascribes four designations to various portions. Lines 33 and 35 to 36 refer to land close by, a further 16 ha with a mixture of designations. (Line item 34, also near Hurdman, was sold in September 2006.)
Finally, seven lines describe lands in Ontario for which the NILM Designation is to be confirmed. Six of these are in the urban area, of which five are subject to a planning study; one of the latter, at Maplelawn (line A in the urban list) is a subject of the NCC’s appeal of the Ottawa OP. The one rural property in this group (line A in the Non-Urban list) is at the edge of the Greenbelt and is also subject to a planning study. These lands, currently part of the NILM, are in this holding category because there is an issue whether they should be declassified, presumably then allowing development (e-mail from Sandra Pecek, September 29, 2006).
Altogether, the lands on these three lists comprise 1435 ha. Staff estimates that Non-NILM land amounts to about 1,500 ha. The remaining 65 ha are thought to comprise primarily so-called water lots, mainly along the Ottawa River, which are not included in the GIS-based data reflected in the lists(e-mail from Sandra Pecek, September 29, 2006).
- These non-NILM land holdings comprise but a small portion (3.2%) of the NCC’s total land holdings of about 47 300 ha in the National Capital Region. Still, over 1400 ha is much land.
- There are some major blocks (including the Southern Corridor, Mooney’s Bay, lands at Hurdman, Hampton Park, the Champlain Golf Course and Champlain Corridor, and Moore Farm) and many, many small holdings.
- Outside these major blocks and apart from the lands at the edges of Gatineau Park and the Greenbelt there is little coherence evident in the set of holdings. One wonders under what rationale this amalgam came into the NCC’s hands.
- Much uncertainty remains about the meaning of the various “potential vocations” and their implications. How they relate to municipal plan designations is not evident.
- While this summary analysis has highlighted the major parcels, many of the smaller holdings may be of high value to the surrounding communities, or may have special ecological value. More detailed assessments are required.
Table: NCC List of Non-NILM Land Holding
(As of October 2, 2006)
|“Potential Vocation”||Hectares||Acres||# of items|
|Development (Municipally Designated)
|To Be Determined
|Hurdman (various designations)||57.6||142||4|
(some Urban Natural Feature)
|NILM Designation to be Confirmed
|Total Non-NILM Lands
Estimated Total Non-NILM
Unaccounted for (waterlots?)