I'd like to thank the…

I'd like to thank the government for this opportunity to comment. I am concerned that among other things, the government has not included that sufficient natural spaces and movement corridors exist in order to support self-sustaining biodiversity. That means there needs to be enough of a species in order for it to remain viable, and collectively as well as individually those species need sufficient natural spaces to sustain themselves.

The problem with this plan is that where policies have been made in general, it always then defers the power or final note to the statement or policy that is specific. While the introduction has some very convincing language around commitments to sustainable development that does not hinder the environment, agriculture, climate impacts, and also directs development away from areas of natural catastrophe (such as flooding), the more specific language and polices are found in the economic development portion, which means, according to your opening statement, that will always trump environmental and ecological integrity.

Why is this dangerous? Because, our natural systems, green infrastructure, biodiversity, natural areas, large connected corridors, large greenbelts, large wetlands, large forest tracts, and network of smaller natural areas that are interconnected - together these are worth billions, if not trillions of dollars every year. When development is made a priority, one or two small parties reap the financial benefit of an immediate and small gain, to the detriment of a large benefit for more people.

When we pave over the greenbelt, this increases the heat island effect of adjacent towns and cities - this can not only increase air conditioning use, health complications, hospital stays, and even deaths, but reduces workdays (for employees that are unable to work in the heat), productivity days (for example if materials are too hot to use properly), as well as reduces overall quality of life in general.

When we pave over our natural areas, we also reduce our flood absorption capacity, making us more vulnerable to flooding on the whole - this can also lead to an increase in sinkholes (which again reduces work productivity), increases commuting times, increases insurance costs and therefore premiums, and also increases human exposure to moulds and other toxic substances that can result in hospital stays, or even death.

It's not just beneficial to our biodiversity to ensure that we maintain, preserve, and enhance our natural areas and their connectivity as best we can, but when we lose biodiversity, we lose out on important functions and other resources. For example, pollinators provide free labour that farmers would otherwise have to pay for. When we reduce habitat for our pollinators, and reduce their survival, we increase our own financial burden. Same thing goes with reducing habitat for pest control animals. Each bats and songbird is known to eat hundreds if not thousands of mosquitoes a day - when we eliminate their chance of survival, we increase our dependency on insecticides, and increase our chance of exposure to those insecticides and exposure to vector-borne illnesses that mosquitoes carry, such as West Nile Virus.

We may not be aware, or even grateful for all of the functions that our natural spaces, our biodiversity, and our linkages perform, but it doesn't mean they don't contribute tremendous, invaluable benefits that would be, in many cases, too costly for us to manage without help from "green services".

Wetlands, for example, may perform water filtration services that would otherwise cost a municipality billions of dollars to address by implementing a treatment plant, that would cost millions of dollars to operate annually, and require on-going upgrades and repairs.

These are just some of the examples of how our natural spaces and biodiversity help us and save us money, which results in "real income" to use an economic term. Every dollar I don't need to spend on water filtration, or an asthma inhaler, or an air conditioning bill is money I get to keep - which is then an increase in my "real income".

Thus for this particular statement: "1.1.3.8 A planning authority may identify a settlement area or allow the expansion of a settlement area boundary only at the time of a comprehensive review..." If a developer can make a case that s/he cannot find adequate space to develop large golf estates, then they could make the case that policy 1.1.3.8 needs to be disregarded here as their needs can't be met elsewhere. However, it should be considered that perhaps we need to then change our development patterns, as they have caused the loss of 50% of our natural spaces, which is why we are experience a number of significant problems currently - such as climate change, a 6th great extinction, and other dire consequences.

Section 1.6 encompasses several policy areas where development in greenbelts and rural areas could be problematic. It will come at great expense to municipalities not just in paying for transportation and sewage/ water connectivity, but also the loss of natural elements that help pay for these services - e.g. natural areas filter water and in some cases sewage, and natural areas provide carbon offsets for car and automobile trips. When you convert those natural areas you are not just removing free services and offsets, you are increasing those costs as you are increasing trip length or infrastructure length - which can increase spills, leakages, and emissions.

Lastly, 1.8 is so weak, vague and not very helpful. There are numerous building, transportation, agricultural, energy production, land conversion, and development policies, that should be added to this policy section. 1.8 should and could easily become a 3-4 page policy which sets out general terms around development. Such as, wetlands, due to their significant amount of stored greenhouse gasses should not be converted to any other land use.

Another policy should include that all new development should have some sort of self-sufficient renewable energy component included - such as solar, wind, or geothermal. Also, all new development should be a minimum of LEED designated design. All new developments much contain X percentage of recycled building material. All roads must contain X percentage of recycled material. Given we have been called on to plant 1.2 trillion trees, there should be a clause that all municipalities must plant X number of trees per year and that all developments must be tree neutral - meaning any trees removed or cut for development must be replaced with a tree that will grow to as large if not larger than the one removed.
Recycled cement would significantly reduce greenhouse gas emissions.

Deforestation and habitat loss, cities, cement production, transportation such as airplanes, vehicles, and tankers, energy production for residential, commercial and industrial use, and lastly, animal agriculture comprise of the largest greenhouse gas emissions - the new Provincial Policy Statement should at least mention this, mention ways to restrict these uses, and mention the recommendation to offset these emissions and obtain net zero emissions.

Lastly, I am deeply concerned with the fact that animal movement has not been prioritized in development and that coordination is generally left to small non-profits with limited funds and power. The reason why wildlife movement is so important is that it strengthens wildlife genetic diversity. It also allows for increased survival when some areas are impacted by fires or ice, allowing wildlife to move to safer areas with a food source. Also, plant species have better migration opportunities when natural spaces are connected. Currently areas with one or more highways are in need of implementing animal corridors and crossings (such as tunnels or overpasses).