Provincial Policy Statement…

Provincial Policy Statement Review
Ministry of Municipal Affairs and Housing
Provincial Planning Policy Branch
777 Bay Street, 13th Floor
Toronto, ON M5G 2E5

Re: Proposed policy changes to PPS 2014, ERO # 019-0279, July 2019

I am writing to express my strong opposition to proposed changes to the Provincial Policy Statement, 2014 (PPS) that would undermine environmental protections and health for not only humans but also significant and at-risk wildlife and habitats, all to justify the facilitation of development at the expense of prime agricultural areas, wetlands, biodiversity, and natural heritage. Specifically, I provide comments about the following proposed policies:

1.1 Managing and Directing Land Use to Achieve Efficient and Resilient Development and Land Use Patterns:

1.1.1a) How does the Ontario Government reconcile “promoting efficient development and land use patterns which sustain the financial well-being of the Province” when successive Ontario provincial governments have been increasing the deficits and the overall debt for Ontario in recent years? This proposed policy is more likely to promote increased financial hardship and environmental degradation for Ontario, under the Provincial Government’s push for “More Homes, More Choices”. Recommendation: Do not increase facilitation of development at the cost of losing prime agricultural areas, wetlands, biodiversity, and natural heritage, which are all vital for healthy populations.

1.1.3.2c) The wording of this policy is confusing. Does it mean to say “minimize negative impacts on air quality and resources under a changing climate . . . ? Or, does it mean to say “”Minimize negative impacts on air quality and from a changing climate”? Recommendation: Change the wording of this policy to make its meaning clear.

1.1.3.8c) Why is development of a settlement for human accommodation allowed in any prime agricultural area in Ontario, especially in southern Ontario?? Prime agricultural areas in Ontario appear to be at a premium while serving the current burgeoning population. There should be no future development allowed in these areas if Ontario’s future population is to be served well by provincial agriculture. Note that Policy 2.3.1 states that “Prime agricultural areas shall be protected for long-term use for agriculture”. Recommendation: Do not permit extraction of minerals, petroleum resources and mineral aggregates in prime agricultural areas.

1.1.3.9c) See comment above under policy 1.1.3.8c).

1.1.4.1h) This is a sound and good policy, especially important for Ontario in trying to achieve Canada’s biodiversity Target I of 17 % terrestrial lands and 10% inland waters protected under the international Aichi agreement. The policy also recognizes the important ecological benefits provided by nature. There are also health and economic benefits provided by nature. Recommendation: Add health and economic benefits to the ecological benefits provided by optimal biodiversity.

2.1 Natural Heritage

2.1.5a) to f) It is highly unlikely that, in the event of development or site alteration being permitted in the areas listed in policies a) through f), there will be no negative impacts on the natural features or their ecological functions! Any site alteration will cause some form of negative impact. Therefore, I would like to see the wording “unless it has been demonstrated that there will be no negative impacts on the natural features or their ecological functions” removed from the PPS. Recommendation: For policies 2.1.5a) to f), remove the wording “unless it has been demonstrated that there will be no negative impacts on the natural features or their ecological functions”, at the end of the list.

2.3 Agriculture

2.3.5.1 See comment under policy 1.1.3.8 above.

2.3.6.1a) Preservation of prime agricultural areas should take precedence over extraction of minerals, petroleum resources and mineral aggregate extraction, unless the extraction can be done by tunnelling at sufficient depth under the prime agricultural area so as not to interfere with its agricultural use.

2.3.6.1b) See comment under 1.1.3.8. Prime agricultural areas should be preserved.
Recommendation: Do not permit extraction of minerals, petroleum resources and mineral aggregates in prime agricultural areas.

2.5 Mineral Aggregate Resources

2.5.2.2. I am opposed to this policy as it relates to mineral aggregate extraction outside the Greenbelt Area. It’s highly unlikely that the long-term rehabilitation following mineral extractions in natural heritage features listed in 2.1.5, 2.1.6 and 2.1.7 will be able to demonstrate “no negative impacts on the the natural features or their ecological functions”. The very process of alteration of the site for mineral aggregate extraction is sure to have long-term negative impacts. See comment on 2.1.5a) to f) above. These areas are far too valuable and sensitive to be disturbed, and mineral aggregate extraction in them would seriously undermine biodiversity, which is needed as a buffer for dealing with the challenges posed by a changing climate. Recommendation: Do not permit mineral aggregate extraction in the significant natural features listed in 2.1.5, 2.1.6 and 2.1.7.

Whereas the Provincial Government plans to maintain protections for provincially significant wetlands in southern Ontario, many wetlands in this region have not yet been evaluated for significance. Without a requirement for their evaluation, unevaluated wetlands which may be significant could be open to mineral aggregate extraction. It is distressing to realize that both significant and unevaluated wetlands in central and northern Ontario would be open for aggregate extraction. Recommendation: Require evaluation of all unevaluated wetlands in southern Ontario prior to any proposed development. Do not permit mineral aggregate extraction in the most biodiverse and ecologically balanced wetlands in central and northern Ontario.

2.5.4.1a) to d) I oppose the use of prime agricultural areas, on prime agricultural land, for mineral aggregate extraction. What is more more important—preserving prime agricultural areas for feeding humans and other animals, or extracting aggregates for infrastructure? Food is a basic need; infrastructure is not. Aggregate extraction should be undertaken only in areas where it will not have an impact on feeding a province. It is highly unlikely that the site could be fully rehabilitated back to an agricultural condition. Recommendation: Do not permit mineral aggregate extraction in prime agricultural areas, on prime agricultural land.

Whereas the proposed policy changes are designed to support increased housing supply and jobs, they weaken protections for the environment and natural heritage, and threaten biodiversity. Therefore I oppose any policies that will reduce necessary red tape/oversight in the development planning. The policy changes seem focussed on promoting urban settlement, without much regard for agricultural and environmental degradation concerns of the rural population. Therefore, I do not think they strike the right balance.

Thank you for the opportunity to comment on the proposed changes to PPS policies. I hope my comments will receive thoughtful consideration.