Thank you for providing the…

Thank you for providing the opportunity for the County of Bruce to comment on ERO Posting
019-6813 on the proposed 2023 Provincial Planning Statement through the Environmental
Registry.

Bruce County and our eight local municipalities are committed to supporting the province’s
goals to increase housing supply, bring more affordable housing to market and streamline
the development process to get more homes built faster. Bruce County delivers planning
services to our eight partner municipalities and delivers a range of housing services,
including the construction of County owned/operated housing.

Throughout the recent changes to the Planning System, Bruce County and its partner
municipalities have been advancing initiatives to increase the supply of affordable housing
by updating planning documents and preparing a new County Official Plan. An Official Plan
Amendment implementing Growth Management policies and new population projections into
the Bruce County Official Plan was adopted in October 2022 and is before the Minister of
Municipal Affairs for approval.

Bruce County delivers planning services to our eight partner municipalities and delivers a
range of housing services, including the construction of County owned/operated housing.
This letter is in relation to the updated information posted to the registry on June 16, 2023.

Natural Heritage:
Bruce County appreciates the general consistency between the natural heritage policies of
the currently in-effect Provincial Policy Statement (2020) and the proposed Provincial
Planning Statement (2023). The County, consultants, and stakeholders have been working
diligently to identify a natural heritage system for implementation through the new Bruce
County Official Plan. Maintaining alignment will support the work to date and the completion of the project to support the management of natural resources for future generations.

Two changes to the proposed Provincial Planning Statement are highlighted below:

1. The definition of “Natural Features and Areas” no longer includes “habitat of
endangered species and threatened species.”

“Natural Features and Areas” are directed to be protected for the long term however other
provincial legislation applies to protect the habitats of these species, and includes
permitting processes where impact to habitat may be permitted subject to conditions. As
such, requiring that habitat of endangered species and threatened species be protected for
the long term under the Provincial Planning Statement creates a potential conflict with the
other legislation.

“Natural Heritage Features and Areas” are also listed as a component of natural heritage
systems, which Bruce County and local Municipalities are required to identify. The Plan the
Bruce: Natural Legacy project which is setting out to a identify natural heritage system for
the County has identified endangered and threatened species mapping as a category that
could not be effectively mapped, given species may be included/removed from the list,
permits may be obtained to permit habitat removal, and habitat may include things like old
bank barns.

Habitats that occur in natural areas may derive policy protections as significant wetlands,
significant coastal wetlands, other coastal wetlands, fish habitat, significant woodlands and
significant valleylands, significant wildlife habitat, and significant areas of natural and
scientific interest, which are important for their environmental and social values as a legacy
of the natural landscapes of an area.

Overall the revised definition of natural heritage features and areas enables the natural
heritage system to be more fully mapped in accordance with provincial direction, and
habitat of endangered and threatened species will continue to be addressed through
provincial legislation, with referral of proponents to the province when such habitats are
identified through the planning process.

2. The definition of ‘significant’ is revised, in relation to wetlands, coastal wetlands,
and areas of natural and scientific interest, to remove reference to the role of
the Ontario Ministry of Natural Resources and Forestry (MNRF) in determining
significance.

The revised definition includes these as an area identified as provincially significant using
evaluation criteria and procedures established by the Province, as amended from time to
time. This change reflects a decision by the province in December 2022 to change the
Ontario Wetland Evaluation System Manual to remove a ministry role in the identification
and approval of wetland boundaries (see ERO Posting 019-6160) and sets up the possibility
for revisions to the process and responsibility for identifying and delineating areas of natural
and scientific interest.

Bruce County submitted comments with respect to the ERO posting 019-6160 that identified
concerns with the removal of the provincial Ministry’s role in the determination of
provincially significant resources.

Those changes remove MNRF from the administrative function, without indicating a clear
replacement to support municipalities. It appears that the intent is for municipalities to
assume this role. Bruce County and its local Municipalities do not have the resources or
capacity to assume this role. Further, distributing this role across 400+ municipalities will be
neither efficient nor yield consistent stewardship of provincially-significant wetlands, let
alone areas of natural and scientific interest.

Bruce County recommends that the province consider the impacts to features and the
capacity for administration of any further changes to natural heritage policies.

Agriculture:
The original ERO posting indicated a policy to require municipalities to permit 3 lots to be
severed from any farm lot existing as of January 1, 2023, provided MDS was maintained. At
the time the posting was extended, the province indicated that the intent of this policy was
to facilitate housing for next-generation farmers and for farm workers, and that the
government would not be moving forward with this policy and was extending the comment
period to hear other ideas.

The updated Planning Statement posted on June 16th continues to include the originally
proposed agricultural consent policies.

Bruce County recommends that the province consider the feedback and engage on revised
policies before putting them into effect in a new Provincial Planning Statement.

Summary

Bruce County Council and staff appreciate the opportunity to provide input on the
government’s efforts to address the need for housing in Ontario through the proposed 2023
Provincial Planning Statement. We appreciate the overall alignment on natural heritage
policy between the current Provincial Policy Statement in the updated Provincial Planning
Statement posted June 16, 2023.

We encourage the province to work with groups such as AMO and the Warden’s Caucuses, as
well as rural and small urban communities to engage in meaningful dialogue on the proposed
changes and their implications for municipalities across Ontario.