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OFA does not believe that new natural heritage features (such as wetlands, woodlands, and other natural wildlife areas) can be created and restored in replacement of these existing natural heritage features.  We believe that duplicating the environmental benefits provided by these natural heritage features, including their ecological function (e.g., hydrologic functions, carbon storage, and biodiversity) is very difficult. Achieving a “net gain” of function will likely require large tracts of land to replace the function of a wetland or woodland that has been around for decades or even centuries.

We are concerned that if these offsets are permitted, it will result in further loss of farmland. OFA is categorically opposed to any form of non-agricultural use of our prime agricultural land.

Agricultural operations can be negatively impacted by the presence of these natural heritage features on their own lands, or even on neighbouring properties. Natural wildlife habitat, wetlands and woodlands can all bring added restrictions to agricultural operations due to the possible presence of species at risk and invasive species, and loss of productive land to setbacks and buffers, along with wildlife damage to crops and livestock. Agricultural practices are impeded when farmers face severe restrictions on possible improvements and maintenance of agricultural drainage ditches that are deemed to be fish habitat. Creating new wetlands, woodlands and other natural wildlife areas through offsetting can lead to significant difficulties for farmers.

Given the limited details provided in the consultation document and the lack of available non-agricultural lands, we can only assume that the potential cost to farmers, their operations, and the continued production of high-quality food, fuel and fibre for Ontarians would be held responsible for this bill – and that cost is too high.