I am writing to express our…

I am writing to express our concern regarding ERO 019-6177 of Bill 23 or the More Homes Built Faster
Act, 2022. I believe the proposed changes will harm native Ontario wildlife species and their habitats
and will undermine the province’s commitments and accomplishments for biodiversity conservation and climate change mitigation and adaptation. I urge the Government of Ontario to provide cities, towns, and rural communities with a mix of ownership and rental housing types that meet the needs of all Ontarians without implementing the changes discussed in ERO 019-6177. I oppose the changes
discussed under ERO 019-6177 for the reasons summarized below.

Natural heritage offsetting
ERO 019-6177 introduces natural heritage offsetting as a tool for reducing development pressure on
wetlands, woodlands, and other natural areas. I think this is a serious mistake because these valuable
natural areas are typically complex and diverse, established over long periods of time, and cannot be
replaced by simple substitution with anthropogenic wildlife habitat creation projects. A majority of
woodlands, wetlands, and other natural areas in southern Ontario have been lost, fragmented, and
harmed over the decades through development, urban sprawl, and other pressures. Rather than
enabling further loss, we urge the Government of Ontario to preserve and protect remaining natural
features in southern Ontario, notably wetlands and woodlands. Offsetting should not be enabled as a
tool to facilitate development because this creates an inevitable loss for biodiversity, natural areas,
natural heritage systems, and for ecosystem services. Created or restored wetlands rarely replace the
full wetland structure and function they were meant to offset (Moreno-Mateos et al., 2012. Structural
and functional loss in restored wetland ecosystems. PLoS Biology 10, e1001247). Restored wetlands also rarely replace the entire wetland bird community they were meant to offset (e.g., Anderson et al., 2019. Differences exist in bird communities using restored and natural wetlands in the Parkland region,
Alberta, Canada. Restoration Ecology 27, 1495–1507). The same is true for woodlands and other natural
areas. I urge the Government of Ontario to protect existing natural areas and features, such as those
identified in natural heritage systems by Conservation Authorities, Upper Tier Municipalities, and
community and conservation groups. Further, the government should focus on restoring and enhancing natural heritage features above and beyond the current extent of these features in southern Ontario. The Government of Ontario should not offset our valuable natural heritage features to make way for development as is the case in ERO 019-6177.

Conclusion
I am concerned that ERO 019-6177 moves Ontario backwards and not forwards with respect to housing, biodiversity conservation, climate change mitigation and adaptation, and the land-use planning process in general. I urge the Ontario Government to abstain from natural heritage offsetting, as discussed under ERO 019-6177, and instead, increase, not reduce or offset, the current extent and function of existing natural features.
 
Thank you for the opportunity to provide feedback on ERO 019-6177.