Letters & Submissions

December 16, 2022

Attention: Public Input Coordinator
Resources Planning and Development Policy Branch
Ontario Ministry of Natural Resources and Forestry
300 Water St. 2nd Floor, South Tower
Peterborough, ON
K9J 3C7

Re: ERO 019-6161 Conserving Ontario’s Natural Heritage

Dear Ministry,

The Christian Farmers Federation of Ontario (CFFO) is an Accredited Farm Organization representing the interests of over 4,000 farm families in Ontario who are called to the vocation of farming. CFFO policy promotes economically, socially, and environmentally sustainable farming, advocating that farmers receive fair return for their production and stewardship efforts.

The CFFO is concerned about the proposed offsetting policy for natural heritage features including wetlands, woodlots and other natural wildlife habitat.

Natural features such as wetlands and woodlots cannot be replaced. Every effort should be made to preserve existing natural features. The loss in one area will not be compensated by a feature in another area. It takes years to establish a high level of ecosystem benefits such as water quality improvements, flood mitigation and habitat from newly established wetlands and woodlots. The loss of the established feature will be immediate and the benefits from anything created to compensate will be long delayed and not provide the same benefits of the original feature.

Furthermore, this proposal would exacerbate pressure on productive farmland. In a context of policy to drive increased and expedited housing development, farmland, both prime agricultural and rural lands, will be under pressure from settlement area expansions and increased lot creation in rural areas, particularly in areas under the strongest development pressure. The proposed policy of offsetting loss of wetlands, woodlots and other wildlife habitat from development will come at the direct cost of even more agricultural lands.

Successful incentives and support programs already exist for interested landowners to re-establish wetlands and woodlots in appropriate areas that have low agricultural productivity. An offset policy like this will negatively impact productive farmland that should instead continue to provide food, economic and environmental value in its current use as farmland.

The CFFO recommends that an offsetting policy should not be implemented. At the very least, the CFFO asks that the ministry consider impacts to agriculture.

In particular the CFFO recommends that:

• An offsetting policy should require proponents to demonstrate efforts to avoid, mitigate, and minimize impacts on existing natural features and to consider alternatives that might better avoid, mitigate or minimize impacts before offsetting is even considered. Offsetting should be a last resort and permission to develop via the use offsetting should not be guaranteed without meeting required standards.
• No prime agriculture areas (based on OMAFRA’s definition1) be permitted to be used for offsetting purposes.
• If requirements are met and offsetting goes ahead, the policy should further require proponents to do an Agricultural Impact Assessment in selection process for potential sites for the creation of the new feature.

Conclusion
Ecosystem benefits cannot simply be replaced when destroying an established feature in one place and creating a new feature in a new location. It is important to recognize the value of existing natural features and to protect them.

In a context of increased pressure for housing development, productive farmland stands to be the loser from settlement boundary expansions and increased lot creation. Offsetting policies that create new natural features to offset losses elsewhere will come at the cost of even more productive farmland, especially in regions under the strongest development pressure.

The CFFO does not support the proposed offsetting policy. If an offsetting policy moves ahead, the CFFO recommends that the policy emphasize offsetting as a last resort following consideration of avoidance, minimizing and mitigating and alternative options to impacting existing natural features. The policy should not permit offsetting on prime agricultural land, and if offsetting goes forward, should consider the impact on potential site selection via an Agricultural Impact Assessment.

We appreciate this opportunity to provide input and thank you for your consideration of our concerns and comments.

Sincerely,

Ed Scharringa, President
Christian Farmers Federation of Ontario