Re: ERO # 019-0279…

Re: ERO # 019-0279 Provincial Policy Statement Review

Thank you for the opportunity to comment on the proposed changes to the Provincial Policy Statement (PPS).

I believe that contrary to the government’s stated intent many of the proposed changes to the PPS will diminish protections for the natural environment and farmland across Ontario. Overall, the proposed changes do not present a balanced approach to land use planning and they unduly favour aggregates extraction and development over other provincial interests, in particular natural heritage and agriculture.

I wish to express strong opposition to changes to the PPS that would undermine protections for significant and at-risk wildlife and habitats and fast-track development at nature’s expense.

Several proposed PPS policies are deeply concerning, as they are likely to move Ontario away from achieving complete, compact and climate resilient communities.

Achieving the provincial goal of enhancing the quality of life for all Ontarians (PPS Preamble, p.1) requires policy direction that will protect and restore the lands and waters that sustain us and that will direct development to suitable areas. With that goal in mind, we outline below our concerns and recommendations.

Although a new policy proposes that municipalities “may choose” to protect non-significant wetlands “in accordance with guidelines developed by the province” (see Policy 2.1.10), many wetlands remain unevaluated at the present time. In the absence of a municipality undertaking to protect them, I am concerned that the significance, values and functions of such wetlands may be degraded or impaired if left unevaluated. Given the alarming losses in wetlands over the past several decades, I conclude that the default position in the PPS should be protection for all unevaluated wetlands in areas of the province where the decline has been most dramatic.

A new policy proposes that “outside of the Greenbelt Area, extraction [of aggregate] may be considered in the natural heritage features listed in section 2.1.5, 2.1.6 and 2.1.7, provided that the long-term rehabilitation can demonstrate no negative impacts on the natural features or their ecological functions” (see Policy 2.5.2.2). Aggregate extraction is a conflicting land use that continues to be given inappropriate priority in the PPS. Extraction activities cause permanent changes to the ecosystem and must be directed away from ecologically sensitive areas, particularly since quarry rehabilitation has often been non-existent or of poor quality throughout the province.

Further, new terms – “market-based” and “market demand” are introduced without supporting definitions or explanations, including in the description of residential types (see Policy 1.1.1), conditions for expansion of settlement area boundary, at time of comprehensive review (see Policy 1.1.3.8), description of housing options (see Policy 1.4.3), and description of long-term prosperity (see Policy 1.7.1). I am concerned that without detailed guidance on how to interpret and apply these terms, past market conditions and trends that result in sprawl will continue to be used when a new approach is needed to create complete, compact and climate resilient communities of the future.

The Provincial Policy Statement is more than a set of individual policies. It is to be read in its entirety and the relevant policies are to be applied to each situation. When more than one policy is relevant, a decision-maker should consider all of the relevant policies to understand how they work together. The language of each policy, including the Implementation and Interpretation policies, will assist decision-makers in understanding how the policies are to be implemented. In situations where there is a conflict with respect to a matter relating to the natural environment or human health, the policy that provides more protection to the natural environment and/or human health prevails.

Aggregates companies should be required to demonstrate need.

In conclusion

All amendments to the PPS must be evaluated in light of the urgent need to respond effectively to climate change and the ongoing and accelerating loss of biodiversity9 here and around the world. As noted in the PPS Vision statement (Part IV), the long-term prosperity and well-being of Ontarians requires planning for sustainability and resilience. Impact studies and policies which protect the natural areas and farmland upon which we all depend are integral to achieving the Vision.