1. Lot creation and multi…

1. Lot creation and multi-lot residential development in rural areas re section 2.6

Prince Edward County Field Naturalists (PECFN) Recommendations re#1:
• We urge you to reconsider implementing this policy. Policies should be forward-looking. This policy puts this province back to a time when residential development could be located virtually anywhere in rural areas. If that didn’t work then, it certainly isn’t going to work now. Developers were not proposing high rises and subdivisions in rural areas fifty years ago.

• In the event that the government chooses to implement this policy, a way needs to be found to differentiate between low and high density residential development. High density residential development should without exception only be permitted in settlement areas designated in official plans.

• Put at least some limits on lot severances. As is, this policy has the potential to undo in an instant years of concerted efforts in many municipalities to protect the natural environment. If the government cannot achieve its agenda of building 1.5 million new homes in the next 8 years without harming the natural environment, the solution is not to bring in new policies and regulations that will allow the environment to be harmed.

• We understand that multi-lot development will (only) be permitted where site conditions are suitable. However “where site conditions are suitable” is so open-ended that basically all site conditions seem to be suitable. For example, section 3.6.3 states that: "Where municipal sewage services and municipal water services are not available, planned or feasible, private communal sewage services and private communal water services are the preferred form of servicing for multi-unit/lot development to support protection of the environment and minimize potential risks to human health and safety.” There would appear to be few (if any) rural areas where multi-lot residential development will not be permitted. Unbelievably, this policy would even appear to permit large scale residential developments to have private communal sewage and water services.

• Recognize that there is no one-size-fits-all policy. Certain types of residential development may be appropriate in one rural area where the exact same type of development will have serious adverse impacts on people and on the natural environment in another. For example, municipalities that have highly vulnerable aquifers should be given the option of opting out of this policy. A 2004 Groundwater Study undertaken by Quinte Conservation found that 59% of the Prince Edward County population relied on groundwater, with the majority relying on private wells. The addition of large numbers of well-users in rural areas will further strain the groundwater supply, conceivably to the tipping point where wells frequently run dry during the summer months and potentially beyond the summer months.

2. Biodiversity

PECFN Recommendations re #2:
• The current PPS begins by noting that: “Ontario's long-term prosperity, environmental health, and social well-being depend on conserving biodiversity, protecting the health of the Great Lakes, and protecting natural heritage, water, agricultural, mineral and cultural heritage and archaeological resources for their economic, environmental and social benefits.”

This section has not been carried over into the proposed Planning Statement. This is an important section and there is no possible reason we can think of for leaving it out. We urge you to reconsider its inclusion.

• The Planning Statement clearly needs to take biodiversity more seriously. A good start would be a policy that supports the conservation of biodiversity in rural areas as opposed to promoting policies that do exactly the opposite.

3. Utilizing Minister’s Zoning Orders (MZOs) as a new planning tool

PECFN Recommendation re #3:
• MZOs should not be part of this provincial planning statement and putting them in this Statement sets a dangerous precedent. The provincial government should not be using provincial policy statements in this way, i.e., as a means to support and legitimize the provincial government’s authority and prerogative to override local planning authorities and official plans.

4. Official Plans

PECFN Recommendation re #4:
• Restore section 4.6 in its entirety in the Planning Statement including the first two paragraphs as follows:
The official plan is the most important vehicle for implementation of this Provincial Policy Statement. Comprehensive, integrated and long-term planning is best achieved through official plans.

Official plans shall identify provincial interests and set out appropriate land use designations and policies. To determine the significance of some natural heritage features and other resources, evaluation may be required.

5. Climate Change and lack of leadership from the province

PECFN Recommendation re #5:
• The provincial government should take responsibility for its own policies that will only exacerbate the climate emergency instead of shifting it onto municipalities to deal with.

6. Definitions in the current PPS that are not carried forward into the Planning Statement

PECFN Recommendations re #6:
• That when the natural heritage section is completed and posted on the Environmental Registry definitions for “Adjacent Lands”; “Coastal Wetland”; “Ecological function”; “Endangered Species”; “Fish”; “Fish Habitat”; “Habitat of Endangered Species and Threatened Species”; “Natural Heritage Features and Areas”; “Natural Heritage System”; “Negative Impacts”; “Significant”; “Threatened Species”; “Valleylands”; “Wetlands”; “Wildlife Habitat”; “Woodlands” and any other definitions with respect to the Province's natural heritage will be included.
• That all definitions found in the current Provincial Policy Statement are included in Part 7 of the Planning Statement.

7. What, exactly, is the "provincial interest" and why isn't this clearly stated in the Planning Statement?

PECFN Recommendations re #7:

• There are a number of references in the Planning Statement to the “provincial interest” and to “provincial interests”, but the Statement is vague on details about what the provincial interest is, exactly. This is problematic, particularly when the Planning Statement requires that Official Plans identify provincial interests and that they “provide clear, reasonable and attainable policies to protect provincial interests” s. 6.1(5) and when planning authorities are being instructed to keep their official plans up-to-date in order to protect provincial interests. Planning authorities and the public should not be left in the dark like this.

• The inclusion of Part IV in the current PPS in the proposed Planning Statement. This section states up front in clear terms that the province’s key provincial interest is the wise use and management of natural heritage resources, water resources, agricultural resources, etc. It also clarifies the Provinces’ responsibility to ensure that resources are managed in a sustainable way to among other things, conserve biodiversity, protect essential ecological processes and minimize environmental and social impacts.

8. Protection of natural heritage, etc.

PECFN Recommendations re #8:

• The only reference to protection in the Planning Statement (other than in the Definitions section) is in the context of protecting the provincial interest. The Planning Statement should recognize the importance of leveraging rural assets and amenities while at the same time protecting the environment. At the very least, we therefore recommend retaining the following section in the current Provincial Policy Statement:

Section 2.0: “Ontario’s long-term prosperity, environmental health, and social well-being depend on conserving biodiversity, protecting the health of the Great Lakes, and protecting natural heritage, water, agricultural, mineral and cultural heritage and archaeological resources for their economic, environmental and social benefits.”