I strongly oppose several of…

I strongly oppose several of the proposed changes to the Provincial Policy Statement (PPS), particularly those which allow resource extraction at the expense of natural heritage sites. I would like to comment on the following sections of the proposal (ERO# 019-0279):

Section 2.5.2.1 – I presume that this section is an attempt to eliminate ‘red tape’, but it seems obvious that there should be some proof, even minimal proof, that there is actually a market for the extracted resource. I do not know why anyone would attempt to develop an area for extraction if there was no need for the resource, but if they are going to destroy a natural area, even ‘temporarily’, then that certainly warrants at least some demonstration that the resources are going to be used (otherwise it is simply wasteful destruction of nature for no reasonable purpose). It need not be a huge analysis, but some reasonable proof of demand should be required.

Section 2.5.2.2 – I would request the complete removal of this section and to retain any existing protections to natural heritage features. According to the definition of natural heritage features, as given in this very proposal, these are areas which include habitat for endangered/threatened species, contain significant amounts of wildlife, and are important for the fact that they are the LEGACY of natural landscapes. The fact that they are considered a legacy of what were once large natural areas, as well as the fact that they contain the remnants of species on the brink of extinction, suggests that they should be protected at all costs, regardless of the mineral aggregates they contain.

I also take issue with the fact that the word ‘rehabilitation’ is defined nowhere in the document, which leaves open the possibility of misinterpretation. Additionally, there is a false understanding of rehabilitation which appears to run through the entire document, i.e. that one can merely rehabilitate a natural landscape to eliminate the ‘negative impacts’ introduced by human disruption. According to your definition, negative impacts include the degradation of ecological functions, i.e. of the natural processes of species, ecosystems and landscapes. In fact, one of the first things one learns about rehabilitating nature is that it is virtually impossible to return a natural environment to the state it was in prior to human disruption. (Everything I say here can be easily backed up. I recommend the introductory textbook Foundations of Restoration Ecology by Palmer, Zedler and Falk.) More likely, rehabilitation will yield what restoration ecologists call an alternative stable state, wherein some portion of the original system is restored, but most of the ecological functions have not been restored.

Section 2.5.2.2 therefore proposes to allow developers to develop on protected wetlands, woodlands, and wildlife habitat as long as they show in advance a rehabilitation plan to eliminate all negative impacts on ecological functions, even though it is nearly impossible to rehabilitate an ecosystem to that point (something which they wouldn’t find out until long after they had already disrupted the natural heritage feature). Therefore, I would ask that you remove this entire section, as it simply presents a loophole for developers to destroy protected lands and then later excuse themselves from fixing it, since restoring it entirely is impossible.

Section 2.5.3.1 – In addition to the rehabilitation comments I made for the previous section, this proposal for when rehabilitation should occur seems to contradict what was stated in 2.5.2.2. Section 2.5.2.2 said that rehabilitation should ensure that NO negative impacts would occur in the long term, while here it is suggested that the goal of rehabilitation should be to simply mitigate negative impacts.

I would also like this section to emphasize natural rehabilitation, rather than rehabilitation to suit human land uses. Additionally, it should make note of climate change. Rehabilitating an ecosystem to its former state will not be useful if the climate has changed since the landscape was disrupted, and human intervention would likely have disrupted the ability of the ecosystem to adapt to climate change. Therefore, returning the system to its original state without ensuring resiliency in the face of climate change is not acceptable.

An emphasis on long-term, ADAPTIVE rehabilitation plans should also be made, so that the plan can be adapted to changing circumstances and unexpected results.

I would request that these changes please be made to the proposal, which is not acceptable in its current state. While I understand the need to assist Ontario businesses and the fact that society requires mineral aggregate resources for many purposes, these are not sufficient reasons to allow the unrestricted destruction of protected lands. We can survive without these resources if necessary, but endangered species cannot survive without the legacy remnants of their habitats.

Thank you for your time,
Jason