I suggest you update the…

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019-0279

Comment ID

35617

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Comment

I suggest you update the language in policy 2.1.10 to suggest that municipalities "should" manage wetlands not subject to policy 2.1.4 and 2.1.5. It seems strange and inconsistent that the PPS, a provincial guidance document, would not recommend that provincial guidelines be followed by a municipality. Instead, the provincial guidelines are undermined by providing language that says "may choose to", which of course implies that municipalities may choose NOT to as well.
The current Natural Heritage Reference Manual is from 2010 and two PPSs ago. It should be updated. It is also the direction for management of non-significant wetlands. Further, the majority of wetlands in southern Ontario (6E and 7E) have NOT been evaluated as significant, or have not been re-evaluated in a reasonable timeframe to be certain of whether they have the features and functions that would warrant management as a significant wetland. What is the provincial direction for evaluating these wetlands for significance? What is the time scale or criteria for which wetlands should be re-evaluated, where they are found to be significant or not?

Policy 1.2.4 d) - "major transit corridors" requires definition

Policy 1.4.3 "market-based needs" requires definition

Policy 2.4.2.2 and 2.5.2.1 require additional interpretation for the "long-term public interest". This will be tested in appeals. What is the time scale for "long-term"? This policy seems to directly contradict 2.5.2.1, as the greater long-term public interest should include a demonstrated need for mineral aggregate resources. Please provide more definitions or specific policy language to clarify how this can be interpreted and applied, particularly as this could be very inconsistent among municipalities without greater clarification and guidance, and the loss of a mineral aggregate resource through incompatible land use development is not easily reversed.