Submission to Provincial Policy Statement Review: Food and Water first

Honourable Bob ChiarelliMinister of Municipal Affairs and Housing
 
Provincial Policy Statement Review
Ministry of Municipal Affairs and Housing
Provincial Planning Policy Branch
777 Bay Street, 14th Floor
Toronto, ON M5G 2E5
 
E-mail: PPSreview@ontario.ca
 
Dear Hon. Minister Chiarelli,
 
The Provincial Policy Statement (PPS) is an important document as we look to build a better Ontario, one with a rich quality of life today and in the future. I appreciate the consultation efforts of the Ministry of Municipal Affairs and Housing as we undergo the mandatory review process.  
 
Building strong, sustainable and resilient communities in Ontario is key to our future strength as a province. One of the most positive steps the updated PPS has delivered is the addition of language in the PPS around achieving these goals.
 
I am deeply concerned, however, about proposed changes to the PPS that give greater preference for aggregate extraction. These changes contradict the draft PPS agriculture section that calls for protecting prime agricultural areas for long-term use.
 
It’s distressing that the draft PPS weakens protections for farmland, water and natural heritage. This must not be allowed to happen. Ontarians are clearly demanding stronger protections for water and farmland. 
 
On the right track
The new proposed PPS contains positive steps forward by referencing:
 

• “strong, sustainable and resilient communities” 
• the “importance of consulting with Aboriginal communities”
• “transportation choices that increase the use of active transportation and transit before other modes of travel”
• the need to create communities that are “resilient to climate change”
• the need to manage resources “to maintain biodiversity, protect essential ecological process”
• the need to maintain/increase the “extent and function of vegetative and pervious surfaces”
• that planning authorities “shall support energy conservation and efficiency, improve air quality, and climate change mitigation and adaptation”
• opportunities for development of energy supply, including the use of renewable energy systems;
• “green infrastructure”

These changes should be maintained and strengthened in the new PPS. 
 
Strong, sustainable and resilient communities
In particular, the PPS could be improved by consistently referring to “strong, sustainable and resilient communities” throughout. 
 
To build strong and resilient communities, good planning is required that includes coordination across geography and levels of government. Section 1.2.1, which promotes coordination, could be improved with the following provisions:
i) energy conservation and community energy planning;
j) water, stormwater and wastewater use, water conservation, and source water and Great Lakes water protection;
k) prioritization of active transportation, and public transportation corridors;
l) waste reduction and materials management; and
m) greenhouse gas reduction activities.
 
Green Infrastructure
As noted, the inclusion of “green infrastructure” is a positive step forward. Section 1.6.1 could be strengthened with the inclusion of the following: “planning for local food systems, water systems, energy systems, waste systems and transportation systems, so that these are available to meet current and projected needs.”
 
Working with Aboriginal communities
The language in 2.6.5 should be strengthened from “should” to “shall”:
Planning authorities should consider the interests of Aboriginal communities in conserving cultural heritage and archaeological resources.
 
Conflicts with natural environment or human health
Throughout the PPS, in situations where there is a conflict with respect to a matter relating to the natural environment or human health, the PPS should be revised so that the policy that provides more protection to the natural environment and/or human health prevails. 
 
The wrong direction: Aggregates
Unfortunately, draft section 2.5 of the PPS includes changes that run contrary to the goals of preserving and protecting prime farmland, vital freshwater supplies and natural heritage, by offering more preferential treatment to aggregate and mining operations. 
 
During hearings for the review of the Aggregate Resources Act, a consistent criticism of the existing PPS was that it gave clear preference to mining operations (such as quarries) over prime farmland, water resources, wetlands and natural heritage. 
 
The people of Ontario have clearly indicated that preserving prime farmland and protecting clean water supplies must be given preference over aggregates in the new PPS. The citizens movement that stopped the proposed mega quarry in Melancthon Township made this demand very clear.
 
Therefore, I am calling on you to include these revisions in the updated PPS:
 

• Require a demonstration of need for the designation or licensing for extraction of mineral aggregate resources. The close-to-market provisions of this section should be revised to better reflect conflicting land uses in southern Ontario and the need to provide stronger protections for farmland and water. (2.5.2.1)
• Require a quarry operation to submit a new application for expansion. Also revise this section to give preference to public health, public safety or environmental impact over aggregate extraction. (2.5.2.4)
• Prohibit quarries from excavating significantly below the water table. 
• Prohibit aggregate extraction at the headwaters of rivers, sensitive recharge areas and/or near source water protection areas.
• End the Interim Use designation for quarries when they can operate for decades once a license is granted. Evidence shows that land is being degraded at a faster rate than pit and quarry sites are being rehabilitated.
• Remove (2.5.3.2) so that our natural features are provided the same protection from quarries as from any other development.
• Require consideration of cumulative impact of quarries in rehabilitation efforts. (2.5.3.3)
• Provide permanent protection for class 1 to 4 farmland. At the very minimum, no quarries should be permitted on prime farmland or in Specialty Crop Areas.  (2.5.4.1)
• Agriculture protections should have preference over aggregate extraction. (2.3.1) 
• Stronger language to require aggregate recycling, and to mandate minimum standards for increased use of recycled materials in public and private development. (2.5.2.3)

In general, it’s essential that improvements in the PPS are not undermined by giving stronger preference for aggregate extraction over protecting water, farmland and natural heritage in the revised PPS. 
 
Conclusion
I appreciate your consideration of these comments and recommendations. Revising the PPS is an important and essential endeavor as we work toward building strong, sustainable and resilient communities. I would be happy to offer more detailed comments or any answer any questions you may have.
 
Sincerely,
 
Mike Schreiner
Leader
Green Party of Ontario