This comment is being…

This comment is being submitted on behalf of the Willow Beach Field Naturalists (WBFN), a community-based organization that was founded in 1953 and brings together nature lovers to explore, enjoy, and learn more about Northumberland County’s diverse natural environment and to encourage its preservation. WBFN works with many other nature groups in Ontario and Canada, including its parent body Ontario Nature. It is open to public membership, and organizes lectures, nature outings and a bi-monthly newsletter to keep its members informed of local ecology. We are a citizen’s group that is very concerned about declining biodiversity, climate change and the loss of natural spaces that support biodiversity and help mitigate climate change. Within our community we have worked with local governments (County and Municipal) regarding official plan updates and the development of the County Natural Heritage System. In that respect we have, in the past, found it necessary to review the Provincial Policy Statement (PPS) and A Place to Grow: Growth Plan for the Greater Golden Horseshoe (A Place to Grow).

Municipal Affairs and Housing is planning to create a new policy statement that would merge and replace the PPS and A Place to Grow. Its intent is to streamline the planning process and make overlapping policies more transparent. In general we support these over-arching goals.

However, we are keenly aware of the importance that these two documents have in the protection of natural spaces and agricultural lands. In particular, they are the basis for protection of key natural heritage features that are identified in local planning documents such as our Northumberland County Natural Heritage System (NHS), and other NHS documents that have been developed over the past several years across the Province.

We are concerned that if the new policy statement is developed with the primary goal of removing restrictions for housing, and accelerating development, it risks severely damaging the foundation to natural heritage protection. We are located in Ecoregion 6E. At present section 2.1 the PPS provides explicit protection within Ecoregion 6E for natural heritage features that are identified as:
• significant wetlands,
• coastal wetlands,
• significant woodlands,
• significant valley lands (including ravines),
• significant wildlife habitat, and
• significant areas of natural and scientific interest.

The PPS currently states that development and site alteration shall not be permitted in areas identified as such unless it has been demonstrated that there will be no negative impacts on the natural features or their ecological functions.

Other aspects of the PPS are particularly valuable, including protections for:
• fish habitat, and habitat of endangered species and threatened species,
• adjacent lands to natural heritage features and areas unless the ecological function of the adjacent lands has been evaluated and it has been demonstrated that there will be no negative impacts on the natural features or on their ecological function.

Furthermore, Section 2.2 the PPS discusses the importance of the watershed planning approach for its ability to cross jurisdictions and provide a more comprehensive understanding of the functioning of linked natural heritage features within a watershed area. This is critically important in our area, with its longer border along the north shore of Lake Ontario, and important biological linkages through watersheds to the Oak Ridges Moraine.

Parts of our Ecoregion are already severely under-represented in terms of natural cover and protected areas, being well below the Province of Ontario Biodiversity Strategy’s target of protecting 17% of terrestrial and aquatic systems through well-connected networks of protected areas and other effective area-based conservation measures. We are working with other partners in this County to increase the amount of land that meets the criteria for long-term protection. For example, we are working to protect valuable natural heritage systems in Ecodistrict 6E13, which runs along the critically important Lake Ontario Shoreline and includes the valuable ecological area known as the Glacial Lake Iroquois Plain. However, these areas along the lakeshore are also under significant pressure for development, and have been heavily disturbed. The current PPS is very important to our efforts.

We ask that the new Policy Statement does not weaken environmental protections for natural heritage features, and does not increase the standard for recognition as significant natural heritage features (which would lead to a loss of land that would qualify for protection). We note that the PPS was thoughtfully and well written, for the long-term benefit of the people of Ontario. Its natural heritage sections should be maintained or strengthened, particularly for Ecoregions and Ecodistricts that are under-represented in terms of long-term protection.

We note that the new combined policy statement proposes to use offsetting/compensation mechanisms to reduce development impacts. There has been significant discussion in a separate ERO on the use of offsets (019-6161) which will not be repeated here, but we note that in general offsets can easily lead to ecological degradation that cannot be compensated for financially.

Furthermore, we ask that the new Policy Statement is thoroughly reviewed by Ministries whose mandates are affected by it, by other levels of government, and that sufficient time is provided for public consultation on any changes.

We recognize there is significant scientific competency in the MNRF and in MECP that must be consulted on any changes to the PPS, particularly as they impact natural heritage. Experts in these two departments should be explicitly required to estimate the potential long-term impacts on Ontario’s ability to meet its biodiversity and climate change targets as a result of any changes to the PPS.