Re: Proposed Replacement of…

Re: Proposed Replacement of the Provincial Policy Statement (PPS), ERO # 019-6177
The current Provincial Policy Statement provides strong protections for Ontario’s natural heritage and farmland. These protections would be seriously weakened by the proposed new planning policy instrument that would remove or streamline existing policies in order to facilitate development. This proposal is short-sighted and harmful, and would cater only to developers with vested interests, rather than allow long-term protection and stability of natural heritage and farmland, both of which provide healthy benefits for not only humans, but also many other species. It makes little sense for the future if government policies undermine the very resources that sustain us and other species.

The following quotes were taken from Ontario’s “A Place to Grow: Growth Plan for the Greater Golden Horseshoe”, with my emphases in bold text to remind the Ontario Government of environmental protection policies it appears to be ignoring in its proposals to manipulate the Planning Act and Provincial Policy Statement to ease the way for developers to harm the environment in the Greenbelt and Oak Ridges Moraine, among other areas.

Excerpts from Ontario’s “A Place to Grow: Growth Plan for the Greater Golden Horseshoe, 2020”
https://www.ontario.ca/document/place-grow-growth-plan-greater-golden-h…

Under 1.1 Place to Grow: Growth Plan for the Greater Golden Horseshoe:

”The GGH contains many of Ontario’s most significant ecological and hydrologic natural environments and scenic landscapes, including the Oak Ridges Moraine, the Niagara Escarpment and the other natural areas in the Greenbelt Area and beyond. These natural areas support biodiversity, provide drinking water for the region’s inhabitants, sustain its many resource-based industries, support recreational activities that benefit public health and overall quality of life, and help moderate the impacts of a changing climate.”

“The region also has some of Canada’s most important and productive farmland. Its fertile soil, moderate climate, abundant water resources, and proximity to markets support agricultural production that cannot be duplicated elsewhere in the country.”
“The First Nations and Métis communities within the Great Lakes region have a unique relationship with the land and its resources, which continues to shape the history and economy of the area today. Ontario, including the area covered by the A Place to Grow: The Growth Plan for the Greater Golden Horseshoe, is largely covered by a number of Treaties that provide for treaty rights. In addition, Aboriginal communities may have Aboriginal rights within the Plan area. Ontario recognizes the unique role that Indigenous peoples have had and will continue to have in the growth and development of this region.”
B. Under 1.2 Place to Grow: Growth Plan for the Greater Golden Horseshoe
“More than anything, the Greater Golden Horseshoe (GGH) will continue to be a great place to live, work and play. Its communities will be supported by a strong economy and an approach that puts people first. This approach protects the Greenbelt and will ensure a cleaner environment is passed on to future generations. A Place to Grow will support the achievement of complete communities with access to transit networks, protected employment zones and an increase in the amount and variety of housing available.”

Under 1.2 “Vision for the GGH”: “A healthy natural environment with clean air, land, and water will characterize the GGH. The Greenbelt, including significant natural features, such as the Oak Ridges Moraine and the Niagara Escarpment, will continue to be enhanced and protected in perpetuity. The GGH's rivers and streams, forests and natural areas will be accessible for residents to enjoy their beauty. Our cultural heritage resources and open spaces in our cities, towns, and countryside will provide people with a sense of place."

“Natural areas and agricultural lands will provide a significant contribution to the region’s resilience and our ability to adapt to a changing climate. Unique and high quality agricultural lands will be protected for the provision of healthy, local food for future generations. Farming will be productive, diverse, and sustainable.”

“A Place to Grow will continue to ensure protection of our agricultural and natural areas and support climate change mitigation and adaptation as Ontario moves towards the goal of environmentally sustainable communities.”

Under 1.2.1 Guiding principles. Bullet 7: “Protect and enhance natural heritage, hydrologic, and landform systems, features, and functions.”
“Support and enhance the long-term viability and productivity of agriculture by protecting prime agricultural areas and the agri-food network.”

Under 1.2.3 Relationship with the PPS: “As provided for in the Places to Grow Act, 2005, this Plan prevails where there is a conflict between this Plan and the PPS. The only exception is where the conflict is between policies relating to the natural environment or human health. In that case, the direction that provides more protection to the natural environment or human health prevails.
Within the Greenbelt Area, policies of this Plan that address the same, similar, related, or overlapping matters as the Greenbelt Plan, the Oak Ridges Moraine Conservation Plan, or the Niagara Escarpment Plan do not apply within that part of the Greenbelt Area covered by the relevant plan except where the policies of this Plan, the Greenbelt Plan, the Oak Ridges Moraine Conservation Plan, or the Niagara Escarpment Plan provide otherwise."

“As provided in the Places to Grow Act, 2005, where there is a conflict between the Greenbelt, Oak Ridges Moraine Conservation, or Niagara Escarpment Plans and this Plan regarding the natural environment or human health, the direction that provides more protection to the natural environment or human health prevails. Detailed conflict provisions are set out in the Places to Grow Act, 2005.”

Recommendation 1: Retain the policies in the current PPS, and preferably enhance it with more policies that protect Ontario’s natural resources and farmland.

Recommendation 2: Do not change and weaken policies in the PPS in order to facilitate development.

Thank you for the opportunity to comment.