Sault Ste. Marie City Planner, Don McConnell, was recalled before the Pointes OMB yesterday afternoon, to respond to evidence provided by the professional planner, Anthony Usher, who spoke on behalf of Pointes Protection Association this week.
Usher laid out several areas disagreement in particular regard to how each respective planner understood provincial and planning policies.
In regards to ‘limited development’ Usher summarized of McConnell’s evidence, presented earlier in the hearing, as a generous interpretation.
Under the 2014 PPS 126.96.36.199 (c) ‘limited’ residential development is permitted on rural lands.
Through much of his evidence McConnell presented that policies are flexible and that varying opinions between professionals is a natural course of interpretation. Regarding, the classification as the Pointe Estates 91 sub-lot, McConnell waffled as to whether it was a limited or not a limited residential development.
In his July 15th, 2013 report to City Council, McConnell clearly said that the Pointes Estate Development was not a limited residential development. However, before the OMB over the course of this hearing he has presented that it is limited development.
When given an opportunity to address this in his cross examination with Pointes Protection Association lawyer, Helen Scott, he stated that he might have provided a better explanation in his report.
McConnell indicated that when one considered the larger geographical area of Sault Ste. Marie as opposed to the much smaller area of the Pointe Louise wetland site that the development could be considered as limited.
He further explained that the development could be interpreted as limited because it was concentrated in an area where there were already 200 homes built. McConnell explained in his evidence yesterday that a scattered development throughout the entire Sault Ste. Marie area would be a far more detrimental to the rural landscape.
“To me the preferred situation is to have as much of that development concentrated in an area where we already have significant residential development. And that’s consistent with the PPS.”
In Usher’s evidence this week he remarked of McConnell’s understanding of the term ‘limited.
“What ‘limited’ means is open to some interpretation, but only an extremely elastic interpretation would admit a 91-lot subdivision in the context of Sault Ste. Marie. After all, 91 lots is about the same as three years’ total demand for rural residential lots in the City, according to Mr. McConnell’s figures in evidence. In any case, since there is an element of discretion in ‘limited’, the Official Plan should be determinative as long as it is more prescriptive while remaining consistent with the PPS.”
Usher also recommended in summary before the OMB that the Pointe Estates Development did not meet the criteria in the City Official Plan. During his July 15, 2013 presentation to Council recommended to Council that the City amend the Official Plan to suit the Pointe Estates development. Yesterday McConnell elaborated on Usher’s comment and his recommendation to Council.
“I think Mr. Usher’s point was that because that amendment to the Official Plan was necessary –this is a bad proposal. I shouldn’t, you know I don’t mean to speak on behalf of Mr. Usher, but that’s the way I heard it. He was saying this project should be turned down because it doesn’t conform to the City’s Official Plan. He’s right. This project does not conform to the City’s Official Plan either with regard to our rural area policies or with our wetland policies. And that’s why we have Official Plan amendments. Since the Official Plan was adopted in 1996 the City has approved over 200 amendments to the Official Plan.”
McConnell and Usher also differ in their understanding of the Provincial Policy Statement.
It is worth noting at this point that during the 2005 PPS regime wetlands that met the threshold to be classified as ‘significant’ were not be developed on. Ultimately, the Pointe Louise wetland was not classified as a ‘significant’ wetland meaning that as per provincial policy development of the wetland could be permitted- meeting certain criteria.
However, the 2014 PPS is now in effect and a provision is made that coastal wetlands are prohibited from development in ecoregion 5E, unless it can be demonstrated that there will be no negative impact on natural features or ecological functions. The Pointe Louise wetland is: 1) a coastal wetland, and 2) within catchment of ecoregion 5E.
In his cross examination with Klaas Oswald- who was representing on behalf of the Bi-National Advisory Council, McConnell did not entirely agree that the Pointe Louise wetland falls under special protection as a coastal wetland. McConnell also stated that these policies are mostly important to wetlands in Southern Ontario- not Northern Ontario.
Referring to the 2014 PPS’s new provision protecting coastal wetlands in Southern Ontario and coastal regions in 5E (the Pointe Louise wetland is located in 5E), 6E and 7E McConnell said, “They are now protecting all coastal wetlands in Southern Ontario. And if you go to – and they have strong focus- they’ve said in Southern Ontario ‘we need to protect these wetlands’ –that’s a really big issue with us- Northern Ontario– not so much. I’m not saying that’s a good policy or a bad policy. I’m just saying that’s what this is. Then it says in 5E, 6E and 7E-development and site alteration are not permitted in significant or any coastal wetland- I would suggest that that is not consistent with what the document actually says- which is ‘unless it has been demonstrated that there will be no negative impact on the natural features or ecological functions’.”
And to this Oswald asks McConnell about the discrepancy of wetland loss. Throughout the entire hearing numbers ranging from 40% to 80% wetland loss have been batted around.
“You obviously struggled with the place at which no negative impact becomes effective in terms of the percentage of wetland loss,” stated Oswald. “What is your feeling on where no negative impact- where that line is drawn in terms of percentage?”
McConnell replied, “I don’t have an exact number you know. You look at overall –is the wetland still there, is this part of the larger complex-is that still there. Is there damage to the whole thing, is it going to disappear? Nothing that I read indicated that that was going to happen. Are there other benefits that go along with this- yes there are. I can’t just give you a number and say that it’s like 50% or 60% wetland.”
Earlier in yesterday’s cross examination of McConnell, Pointes Protection lawyer, Helen Scott, asked of him, “With respect to the definition of negative impacts –it indicates that it is the degradation that threatens the health and integrity of the natural feature or ecological function. Can you explain to me how you got that it has to be ‘fatal’ to the entire feature [feature meaning wetland]in order to be a degradation that threatens its ecological health and integrity?”
To which McConnell replied, “Well that’s integrity to me. And I’m reading this as a planner. Maybe a wildlife biologist would look at this differently. But there has to be some significant degradation. I don’t actually remember seeing that except that there is some wetland being lost. And it’s a significant amount of wetland being lost as it relates to this project which I put in my report for Council. But I didn’t read anything where there is a long term fatal- I don’t know if fatal is the right word- that sounds harsh- you know, significant impact. We are losing part of the wetland- yes we are. We’re also gaining a fish habitat- yes we are. We’re also fixing problems associated with the existing Alagash channel –yes we are. There are benefits there. And there are more positive benefits than negative. Are we losing part of a wetland- yup. Are we gaining a fish habitat- yup. In my reading I didn’t read anything where they said ‘Whoa. This is a big stop here’.”
The OMB hearing resumes today at 9:45 a.m. in Council Chambers at the SSM Civic Centre. Lawyers and all parties will be presenting their final arguments before the OMB.
Below is a partial transcript of SSM City Planner’s evidence presented on December 4, 2014.
ORLANDO ROSA (lawyer for the appellant)/ DON MCCONELL
Rosa: Mr. Usher said yesterday was that he was somewhat confused as to why you initially in the 2005 PPS you indicated that the 91 lot subdivision could not be considered as a limited development and take a different position under the 2014 PPS. Can you explain or comment on that.
McConnell: If I may Mr. Rosa. I don’t believe I did take a different position. I think the discussion with the Board was actually in two parts. I did speak one afternoon and we talked about the 2009 PPS. During my comments I made reference also to the 2014, but to a guidance document with the 2014 PPS. Which I hadn’t brought up before because it was draft. The Board suggested that might be useful and then we had a second discussion on that. That may be what Mr. Usher is referring to.
R: Well you made the comment that it could not be considered a limited residential development under the 2005 PPS but now you’re saying under the 2014 PPS it is- it could be considered a limited residential development.
M: Let me explain what I didn’t do in 2005. Actually that was in 2013…(inaudible)…PPS document we were dealing with. And I also wrote this for Council and I now see what the confusion is. I may not have been as clear as I could have been. I think a stated to the Board early a 91 sub-lot division in Sault Ste. Marie whether its urban or rural- that’s a big development. That’s not a limited development. That’s a big development. I stand by that statement. The City’s Official Plan is consistent with Provincial Policy on this matter in the sense that when we prepared our official back in 1996 we did not allow any permanent residential development. Over the years that has changed. We now allow one severance by right. We changed the more recently…we now allow…(inaudible)….We still allow big developments to be spread throughout the community, throughout the rural area. What I like to do is to sit back and say ‘what’s the impact’. Because you have to demonstrate at the end of the day that it is consistent with Provincial Policy. Because if it’s not I would not have recommended this to Council. So I always look at the impact. If you just kind of read through this report here- it says that policy is intended to ensure that lands required for agriculture or other resource based activities and …(inaudible)…require larger areas in separation from other uses are not compromised by residential development. In this case its not. I mean that property is not going to be used for agriculture. It’s not going to be used for natural resources. The property has already been developed with more than 200 residential dwellings. (Edited) I believe, and this was the statement made to the Board, this development is preferable to say ‘ok if we don’t approve this, well what happens? Well were going to be..’- scattered development throughout the area. That is a worse situation. To me the preferred situation is to have as much of that development concentrated in an area where we already have significant residential development. And that’s consistent with the PPS.
M: We had two conversations- the second conversation was the guideline that came out earlier this year. And if we look at the guideline- it talks about what we had talked about earlier which was that it’s not defined anywhere. Which is a challenge for people sometimes. So what they are suggesting is that they go to …(inaudible)…the definition and see what that means. And that is consistent with what I think what I did- when I was reviewing the 2005 policy. Sit down and look at the effects of this development and what the impact is –positive vs. negative, how does it sit with provincial policy…well you have to read the Provincial Policy as a whole. How is consistent with the whole of a provincial policy statement….When we go through the PPS there’s nothing that leaps up and goes ‘whoa’. You know where did in the water here. We’re totally opposite of what is intended here. (Edited) I don’t believe that it’s creating very much more development in a rural area and it’s actually helping concentrate it. So that from a planning perspective is a benefit.
R: You and Mr. Usher differ in terms of the interpretation of the PPS 2014. I believe that he says that you say that you apply flexibility given the words and the preamble given the geographic…
M: I think Mr. Rosa if I can be of assistance. I think what you’re looking for is the preamble to the PPS…
R: Yes the preamble to the PPS- and he said that two of you differ in regard to the interpretation based on this particular part of the PPS. Could you explain?
M: I don’t recall Mr. Usher’s testimony on that I can explain what my take is on this.
R: Well. Ok.
M: When you look at the geographic scale of policies what they’re saying is that some policies you need to consider community wide. Or perhaps area wide and other policies are very very specific area. (Inaudible) I tend to look at things on a community wide basis. However, if the project, if that development is a bad development and there’s a strong negative impact associated with that- then it fails.
R: Now Mr. Usher also indicated in regards to the Official Plan – basically said that the plan didn’t provide that this particular rural type of development isn’t permitted by the Official Plan.
M: And on that matter he’s correct. I think Mr. Usher’s point was that because that amendment to the Official Plan was necessary –this is a bad proposal. I shouldn’t, you know I don’t mean to speak on behalf of Mr. Usher, but that’s the way I heard it. He was saying, you know even if it does it…sorry my words- even if it does conform with the PPS, his words- this project should be turned down because it doesn’t conform to the City’s official plan. He’s right. This project does not conform to the City’s Official Plan either with regard to our rural area policies or with our wetland policies. And that’s why we have Official Plan amendments. Since the Official Plan was adopted in 1996 the City has approved over 200 amendments to the Official Plan because what that gives Council the ability to do is to review the proposed developments in detail against the ….(inaudible)…which is the Official Plan, and see if it makes sense to change the Official Plan. The Official Plan is not a static document.
R: Mr. Usher also indicated that under 2.1.5 in his view, that development in coastal wetlands ought not to be permitted because it was not proven that there would be no negative impacts here. What is your view as a planner in regard to that position?
M: Well I think this was reviewed- there is a definition in the PPS as to what a negative impact is…There definition of negative impacts. I’ll summarize this- negative impacts mean that in regards to natural heritage and…(inaudible)…I think that’s what we’re discussing here- degradation that threatens the health and the integrity of ecological functions, whether it be on this development or on other additional developments that may happen in the future. The way I read that is that some feature is going to be irreparably damaged. It doesn’t mean that it’s not going to be changed in some fashion and nothing I read, in any of the reports submitted by the consultants indicated that there was going to be some threat to the health and the integrity of the feature. In some cases it would be better- there would be fish habitat. There was a loss of that feature which was the wetland. But there was nothing that I read that said – you know- that this is going to be fatal to this natural resource.
HELEN SCOTT (lawyer for Pointes Protection Association)/DON MCCONELL
Scott: Mr. McConnell with regards to you answers to Mr. Rosa’s first questions, I’m still not very clear what your answer was. So I’m going to take you back please. [Regarding McConnell’s report to Council July 15th 2013] You stated that …inaudible… ‘…rural subdivision cannot be considered as limited residential development.’ So in 2013 you were saying that this couldn’t be considered as rural limited residential development.
McConnell: It’s a major development ‘yes’.
S: Ok. Have you changed your position on that? Are you now saying it is limited residential development?
M: No. Because I looked at the impacts and what I should have done given the intent of this and what I see overall in the community- this is consistent with the section of the PPS – which is don’t scatter development all over the community and give up having major lots of land for other uses. That was an interpretation that I made. That was my approach. The guideline that’s being followed for 2014 supports that. That you can look at things on a geographic basis and not just on that particular property. What’s the impact of this development on the rural area of Sault Ste. Marie? Is it good? Is it bad?
M: When you look at what we’re trying to achieve with the Provincial Policy Statement – is it good?
S: Ok. Are we in agreement that the subject lands are rural lands within the definition of the Provincial Policy?
M: Yes they are.
S: (188.8.131.52- PPS 2014- Scott reads this. See right column of this article) So are we in agreement sir, that as a prescriptive, of policy statement there, that these policies must be applied.
M: Yes and this is consistent with the preamble where they talk about you have to read the document as a whole.
S: Right. Ok. So policy 184.108.40.206 (Scott reads. See right column of this article.) So if this is not a limited residential development sir, which of those categories qualifies this development.
M: It is.
S: It is what?
M: It is limited residential development. And this is where I – you know, I wrote this (referring to his 2013 report) for Council. This is a big project. When you look at the intent of the PPS- what are we trying to achieve on this- a community wide basis here. And we’ve had … (inaudible)… from the 2014 PPS…(inaudible)…that you don’t have to. Depending on what the issue is you look at things on a community wide basis- this is consistent with a provincial wide Policy Statement. So were talking limited residential development. Here’s what we’re talking about – rather than build thirty houses in the rural area- scattered randomly about, what we’re going to do is feature about nine of those houses, according to market experts, seems reasonable to me- we’re going to build nine of them in this area where we already have two hundred homes. That accomplishes what we’re trying to do- what we’re trying to achieve here.
S: I’ll get to that in a minute. But you’ve now said that this is limited residential development. And your report said that it was not and a minute ago you said that it was not. So is it limited residential development or not?
M: It is not. Sorry- hold on. It’s a limited residential development. It’s a significant project in itself- 91 lots is a big project for Sault Ste. Marie. I mean you know that you don’t get a lot of 91-lot subdivisions in Sault Ste. Marie.
M: But when you look at it in the overall context of the City- you’re only building 91 lots a year, you’re not scattering it through the rural area – that’s limited residential development. We’re trying to limit development in the rural area by putting it one space- that’s a good idea. And I’m not trying to play with words here. I’m not trying to play with words. And I talk about this in my original comments- one of the problems we have is when someone goes and builds a house on fifth or sixth line and they actually sterilize the property around them for other uses. So were actually losing a chunk of land- we’re losing an opportunity that property could be used for agriculture uses or aggregate or whatever in the future- because you’ve got a house there now. If we can get those houses into an area where we already got 200 houses that helps to limit, on a community wide basis- the residential development in a rural area.
S: So this limits residential development but it is not a limited residential development?
M: It’s not limited in the sense that it is big. It does limit the amount of rural area development that we’re going to get scattered throughout the community because that is a much greater negative effect. What is the negative affect of this development…
S: Aside from the wetland?
M: Aside from the wetland. Ok. If you look at it from municipal servicing, from protecting other lands that are suitable for other development purposes –it meets all those definitions. It meets those criteria.
S: I understand what you are saying about consolidation. I understand that limited residential development is not strictly defined anywhere. What I’m having an issue with is the fact that your report says that it is not limited residential development and you appear to be saying now that it is.
M: And I should have explained that better in your report. Your correct. I see how it is possible that someone else could read it that way.
S: So it cannot be considered as a limited residential development of us?
M: It is a big development. And on that property it’s a big development…
S: And all 91 lots are going to be developed at the same time?
M: They’re going to be developed- I think the nature of the development is that you have to build the subdivision plan in one piece here. But you’re not going to have 91 houses under construction at one time. It’s going to take some time to build out this development. I believe the market expert said somewhere around 10 years.
S: Ok but the actual subdivision- the actual groundwork short of building the houses is going to be done immediately is my understanding?
M: I would imagine so. If they could delay the construction of the second road- but- and that’s a question for Mr. Avery – In all probability it’s going to be built in one block at one time.
S: I’d like to go to a comment you made about Mr. Usher’s testimony with respect to the official plan. And I wrote it down as you were saying it so hopefully I’ve understood you correctly but essentially you’ve …(inaudible)…. that because this development requires an amendment to the official plan that alone is- sufficient to say that it is sufficient to be turned down. Is that your take on Mr. Usher’s testimony?
M: I may have just misunderstood what you say said. Let me try this back. I believe that part of Mr. Usher’s testimony is that because an amendment was required- it’s a bad development. I think that’s what he says.
S: Ok. I will put to you that Mr. Usher discussed the fact that this is a significant shift in the perspective of the City’s Official Plan with respect particularly to the wetland policies and the rural policies. Did you hear him discuss any of that.
M: Yes I did and to be honest I can’t remember the exact wording but he did have a concern that – ‘here’s what the Official Plan says and here’s what’s not consistent on rural area or wetland policies according to what the Official Plan requires’. I think that was his point. And he’s correct. That’s fair statement.
S: Ok. The next thing I’d like to talk to you about is the conversation that you just had with Mr. Rosa with respect to policy 2.1.5 in the 2014 PPS, specifically the question of negative impact or improvement has or has not been proven. And you indicated that the standards that you were using- if I’ve got the quote correctly, was that ‘if the feature was irreparably damaged’. And you discussed the fact that none of the reports you had seen indicated that this development would be quote unquote ‘fatal’ to the natural feature.
OMB: Is there a question coming?
S: Yes. With respect to the definition of negative impacts –it indicates that it is the degradation that threatens the health and integrity of the natural feature or ecological function. Can you explain to me how where you got that it has to be ‘fatal’ to the entire feature [feature meaning wetland]in order to be a degradation that threatens its ecological health and integrity?
M: Well that’s integrity to me. And I’m reading this as a planner. Maybe a wildlife biologist would look at this differently. But there has to be some significant degradation. I don’t actually remember seeing that except that there is some wetland being lost. And it’s a significant amount of wetland being lost as it relates to this project which I put in my report for Council. But I didn’t read anything where there is a long term fatal- I don’t know if fatal is the right word- that sounds harsh- you know, significant impact. We are losing part of the wetland- yes we are. We’re also gaining a fish habitat- yes we are. We’re also fixing problems associated with the existing Allagash channel –yes we are. There are benefits there. And there are more positive benefits than negative. Are we losing part of a wetland- yup. Are we gaining a fish habitat- yup. In my reading I didn’t read anything where they said ‘Whoa. This is a big stop here.’
S: Your understanding of this is that there will be a significant loss to the wetland in terms of wetland habitat…
OMB: Don’t use that…Don’t use ‘significant’…
S: Ok. Sorry sir.
OMB: Especially at the end of the day.
S: Ok- the wetland will be a lot smaller.
M: Yes. I think I indicated in my report that at the end of the day the wetland will be 40% smaller.
S: Ok. And within the definition of negative impact do you consider that to be a negative impact to the wetland?
M: It’s certainly a negative impact to the wetland on this property. But when you look at the entire Pointe Louise wetland, when you look at the number of wetlands in Sault Ste. Marie this is not a provincially significant- you know, does this threaten the health and the integrity of the feature. No. We’re still going to have a wetland there- probably an improved one.
S: Can you explain to me what study you saw that indicated that this would be an improved wetland?
M: Sorry I’ve misspoken. What I was thinking of was an improved fish habitat, not an improved wetland.
S: So will have benefits to fish habitat but negative impact to the wetland?
M: That’s my understanding.
KLASS OSAWALD (Representative for the Bi-National Public Advisory Council)/MCCONNEL
Oswald: Mr. McConnell you’ve used the 40% figure in you earlier testimony and again today. What’s the source of that percentage?
McConnell: You know what? I’d actually have to go back to the original materials. It’s been over a year since I read it. It was – I’m just looking at my report where I made reference to various studies by Great Lakes Environmental. …you know and I’m assuming it’s out of there but I can’t tell you yes that’s exactly where I got that number from.
O: Over the past few days we heard estimates of the percentage of wetland loss on the subject lands –all the way up to the 70-80% range. Is it possible that it could be that high?
M: Let me clarify. Mine was taken from –here’s what we have now. Here’s where were going to be at the end-and it’s going to be 40% less. So it would have taken into account any other wetland areas that were, would be created. So it’s not – you are you saying is it more than 40% of the wetland that is there that is being lost? I would agree with the statement-yes.
O: So you obviously struggled with the place at which no negative impact becomes effective in terms of the percentage of wetland loss. What is your feeling on where no negative impact- where that line is drawn in terms of percentage?
M: I don’t have an exact number you know. You look at overall –is the wetland still there, is this part of the larger complex-is that still there. Is there damage to the whole thing, is it going to disappear? Nothing that I read indicated that that was going to happen. Are there other benefits that go along with this- yes there are. I can’t just give you a number and say that it’s like 50% or 60% wetland …
O: In terms of the planning regimes in Ontario, if across the province that method of calculating negative impact is used- isn’t there sort of a slippery slope where at some point no matter how large the wetland is or the wetland area that is lost, a percentage- that you could always compare it to a larger geographic area and then say ‘well it’s only a small percentage of this larger area’?
M: I have two comments on that. One- I think that’s why the province differentiates between a significant wetland areas because those areas cannot be touched. Because if this was a significant wetland my report to City Council would have been very short [Note: McConnell’s July 15, 2013 report was written during the 2005 PPS regime] – and would be a completely opposite recommendation. I think there is also a recognition beginning with the Ministry of Municipal Affairs and the people who wrote the Policy Statement that the situation in Southern Ontario is different than Northern Ontario. They state in their guideline that Northern Ontario comprises 90% of the province of Ontario. And there is definitely a big concern about wetlands in Southern Ontario. I agree. In Northern Ontario –it’s a concern but it’s not a significant wetland and you if you just look at the land mass involved and the percentage of that is a wetland- the overall impact is not huge. Having said that you look at the big scale- I don’t go beyond the City limits. And you look at the impact on this property- is there anything that has come up in any of the reports, that I reviewed- that would indicate to me that here is a fatal stop to on this property. I didn’t see anything.
O: In your answer you just eluded to Southern Ontario and the fact that the new 2014 PPS gives some flexibility for Northern Ontario. [Oswald refers McConnell to PPS introduction]. In the ‘what’s new section’ in bullet point number one the new policy- or the amended policy, protects all the Great Lake’s coastal wetlands in Southern Ontario that are not already protected as significant coastal wetlands through policy 2.1.5 (f). And it also says development and site alteration are not permitted in significant wetlands or any coastal wetlands. So my question is –isn’t this a pretty clear demonstration of where the province wants to go with this and it fills out- if you will- what the province wants local planning authorities to take into consideration with their planning decisions.
M: You’ve raised two points and I’d like to talk to them in the order that you’ve raised them. You brought our attention to the fact that the PPS now protects all Great Lakes in Southern Ontario that are not already protected.
OMB: Significant coastal wetlands.
M: That were not already protected as significant –yes. But they are now protecting all coastal wetlands in Southern Ontario. And if you go to – and they have strong focus- they’ve said in Southern Ontario ‘we need to protect these wetlands’ –that’s a really big issue with us- Northern Ontario– not so much. I’m not saying that’s a good policy or a bad policy. I’m just saying that’s what this is. Then it says in 5E, 6E and 7E-development and site alteration are not permitted in significant or any coastal wetland- I would suggest that that is not consistent with what the document actually says- which is ‘unless it has been demonstrated that there will be no negative impact on the natural features or ecological functions’. I suggest we have to deal with the PPS as written. I mean- this is intended to be a guideline and it left out that other part.
O: Isn’t the guideline pretty clear that the province wants coastal wetlands to be protected?
M: I think they want all coastal wetlands in Southern Ontario to be protected.
K: And if policy 2.1.5 (f) is the policy which includes 5E, 6E and 7E –isn’t that a demonstration that intends that those three ecoregions be treated as Southern Ontario.
M: You’re going to have a hard time convincing me that Sault Ste. Marie, North Bay and Sudbury are Southern Ontario. I mean the ecoregion is something that has been developed by the province, likely- I mean I assume this, to talk about areas that have similar geographic characteristics but we are not in Southern Ontario.
*Note: It is true. Sault Ste. Marie and the Pointe Louise wetland are not in Southern Ontario, however.
The Algoma District- the Pointe Louise wetland, as per PPS 2014, falls within the catchment of ecoregion 5E. It is clarified that there shall be no development or site alteration of a coastal wetland (Pointe Louise is a coastal wetland) permitted in ecoregion 5E unless it has been demonstrated that there will be no negative impact on the natural features or on their ecological functions.
Further, Ecoregion 5E, also known as the Georgian Bay Ecoregion, “is situated on the southern portion of the Precambrian Shield, in south-central Ontario, extending from southeastern Lake Superior in the west to the central portion of the Ottawa River valley and the Quebec border in the east. It encompasses 7,447,869 ha (7.5% of the province).”