Re: ERO # 019-0279…

Re: ERO # 019-0279 Provincial Policy Statement Review

To whom it may concern,

Thank you for the opportunity to review the proposed 2019 Provincial Policy Statement and submit our concerns regarding proposed changes.

The Oak Ridges Moraine Land Trust is committed to protecting the natural environment of the Moraine and Greenbelt including landscape features, prime agricultural lands, forests and wetlands. The Provincial Policy Statement is a necessary document that helps manage urban growth in a way that does not infringe on future growth and the environment. With climate change becoming an increasingly necessary issue to factor into planning, we are fully supportive of the province’s goal of addressing this, as seen in ss. 1.6.1, 1.6.6.1(b), and 1.6.6.7(c).

However, this positive addition to the policy does not offset the numerous changes that will leave significant impacts on Ontario’s natural environments and plans for future development. A Provincial Policy Statement is meant to implore long-term, feasible guidelines that help mitigate development in ways that do not interfere with future growth, sustainable development, and community standards.

The Oak Ridges Moraine Land Trust has identified 3 specific areas of concern where the proposed PPS changes will encourage unrestricted development that could lead to irreversible damage to Ontario’s natural environment.

1. Aggregates extraction being given priority over the protection of forest, wetlands, prime agricultural areas, and ANSIs.

The proposed changes to aggregate extraction into natural heritage lands outside the Greenbelt Area stated in s. 2.5.2.2 and as seen in new ss. 2.1.5, 2.1.6, and 2.1.7, will create irreversible damage to thousands of acres of valuable forests, wetlands, and agricultural lands (supported further by s. 2.3.6.1).

Ontario’s forests and wetlands are key indicators for a healthy environment. They act as sinks for our excess carbon emissions, reduce water source contamination, and act as a food source for citizens and hunters alike. Southern Ontario’s rich agricultural lands serve as necessary crop producers and maintain the ability for forest conversion.

Aggregate operations often last decades and while the new PPS proposes that operator’s carry out with rehabilitation, it fails to address the operation length of a pit/quarry and that there have been issues for decades with operators following through with rehabilitation commitment.

Expansion into these natural heritage areas combined with a lack of proper and successful rehabilitation can lead to irreversible changes to the natural environment that can last hundreds of years. In addition, contamination to water sources often leave permanent damages and can impact the drinking water for hundreds of thousands of Ontario residents.

Recommendation 1: Remove proposed policy 2.5.2.2 as it eliminates the necessary protection of natural heritage lands, ANSIs, and wetlands.

Recommendation 2: Remove current policy 2.4.4.1 which allows aggregates extraction to override protections for prime agricultural land on the faulty premise of future rehabilitation.

2. The option, not obligation, for municipalities to protect wetlands.

While the overall policies have not changed regarding the protection of Ontario’s wetlands, section 2.1.10 on the new policy states that municipalities may choose their own wetland management plan based on provincial guidelines, therefore disregarding ss. 2.1.4 and 2.1.5 completely.

Wetlands are key transitional areas between different ecosystems and serve as a habitat to 47 at risk species in Ontario. Wetlands serve as the most important function when it comes to natural filtration and decontamination of drinking water sources. Wetlands also play a key role in the health of our forests, providing the proper nutrients and grounds for life to thrive. As it stands in Ontario, approximately 70% of wetlands have been lost to development in ecoregions 6E and 7E and 90% lost across the province.

Currently, the majority of discovered wetlands have not been evaluated, meaning their value and significance has not been entirely determined. The ability for a municipality to operate outside the guidelines set out in ss. 2.1.4 and 2.1.5 can mean the irreversible damage and destruction of thousands of hectares of significant wetlands.

Recommendation 1: Eliminate s.2.1.10 from the proposed policy.

Recommendation 2: Change the wording set forth in ss. 2.1.4 and 2.1.5 from “shall not” to “must not” to ensure concrete compliance and reduce impacting factors.

3. The optional wording under urban planning related policies open the window for unmitigated expansion that will lead to incohesive, unsustainable growth.

Previous PPS documents have very clearly stated what is allowable within the means of planning, sprawl, and natural environment preservation. The changing “should” to “shall” in the new document eliminates any requirement for municipalities to follow through with the framework set forth in the PPS. Additionally, the added use of the phrase “market-based” without a definition allows for the opportunity for unmanaged growth.

These choices of wording allow for a lack of mitigation and minimization when curbing urban sprawl within municipalities. This can be identified most clearly in ss. 1.1.3.2 and 1.1.3.3. Additionally, the optional wording set forth in s. 1.1.3.8 and permittable adjustments to settlement boundaries without a comprehensive review outlined in s. 1.1.3.9.

The sections mentioned above directly infringe on the protection of significant areas of natural interest and heritage. Changes to a settlement boundary without a comprehensive review can impact water quality, wetlands, and forests if the proper inquiries are not made. These changes contribute towards urban sprawl and in turn can lead to significant issues for residents including flooding and contamination of drinking water sources.

The inclusion of interpretable language into the proposed PPS permits for a steady infringement on what is deemed acceptable and permittable when it comes to present and future urban development. Such interpretable language also negates the vision and goals of the PPS as optional guidelines mean less protection of natural heritage features, a lack of transparency to the public, an inefficient use of planning resources, and disregards the necessity of having well-planned long-term growth plans.

Recommendation 1: Remove s. 1.1.3.9 and require that any boundary changes to settlement areas must have a Comprehensive Review stage.

Recommendation 2: Replace all instances of “shall” with “should” throughout the proposed policy to ensure province-wide compliance.

Recommendation 3: Provide a definition in the glossary for the term “market-based”.

Concluding Statement

A Provincial Policy Statement is an opportunity for the province to develop a new planning policy that encompasses the values of Ontarians and ensures a manageable and sustainable growth for the future.

We feel that the proposed changes aforementioned in this letter are in direct conflict with these values and creates a lack of transparency between the province and its people.

We hope that you take our concerns and recommendations under consideration during your review process and thank you for allowing us this opportunity to comment.

Should you require clarification on any of our comments, please feel welcome to contact us.

Regards,

Oak Ridges Moraine Land Trust
“Your Moraine…protect water, land and life for tomorrow.”
www.oakridgesmoraine.org