Thank you for the…

ERO number

019-1680

Comment ID

47395

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

Thank you for the opportunity to comment on the proposed amendment to the Growth Plan for the Greater Golden Horseshoe (GGH).
The proposed removal of the Growth Plan policy that prohibits wayside pits and quarries in the habitat of endangered and threatened species is of concern to me as a longtime active member/supporter of various conservation and environmental organizations. I share the opposition to the proposed removal that has been expressed throughout the consultation period and I urge the province to maintain the prohibition.
While the aggregate industry ha maintained that providing aggregate resources "closer to market" is vital to the success of the Growth Plan, I agree with organizations who believe this position is unfounded. Aggregate operations already occur throughout much of the GGH, including the Natural Heritage System established to protect biodiversity. As such, prohibiting aggregate operations within the habitat of our most vulnerable plants and animals is the bare minimum that should be required.
The industry has also contended that removal of the prohibition will not impact the Greenbelt. I don't accept this. The Natural Heritage System was designed with multiple connections to the Greenbelt and must be protected.
If anything, the Greenbelt and a complementary Bluebelt need to be expanded to help sustain the health of our lands, waters and wildlife in rapidly growing and heavily urbanized southern Ontario. The province should accept the advice of the Environmental Commissioner of Ontario in 2017, urging further measures to lighten the footprint of aggregates in Ontario.
Given the fact that a "closer to market" approach can be detrimental to other valuable land uses, the province should also urge the industry to expand gravel shipment by rail. That's a more cost-effective and environmentally friendly method of shipment.
I also have serious concerns about the ministry's proposal to extend the plan horizon year in the Growth Plan from 2041 to 2051. A number of organizations and planners believe a 10-year extension will only facilitate unsustainable urban boundary expansions, especially in municipalities that are trying to control urban sprawl and protect greenfield areas. There is evidence that we have enough land, particularly if the province promotes smarter, more sustainable growth rather than growth that is more car-dependent and make is it more difficult to expand public transit.
In addition, I do not support proposed land needs assessment methodology that could take the Growth Plan away from "target-based" to "market demand based" assessments. Firm targets to control sprawl, protect prime agricultural land and natural areas are preferable to the uncertainties of a market-based approach. The goal should be to create urban communities that are sustainable, inclusive and climate resilient and I have real concern that a market-based approach would take the province in the wrong direction.
Ontario is best served by an approach that emphasizes an environmentally sustainable quality of life for present and future generations. That should be the guiding principle for the Growth Plan for the Greater Golden Horseshoe.
'Thank you.