I am writing to you on…

I am writing to you on behalf of our company Di Blasio (Georgetown) Corporation which owns 100 acres of land located at 10314 5th line in Halton Hills. I have attached Map 77 from the Greenbelt Plan which shows the location of our property in red. We purchased the land on July 31, 2007 for future development purposes understanding that it likely could not be developed beyond the horizon set out in the Growth Plan.

I am writing to you in accordance with the consultation requirements set out on the Environmental Registry of Ontario because we were surprised to learn that the Region of Halton has requested that our land to be included in the Greenbelt. We specifically purchased these lands because they are not located within the Greenbelt. As you will read the Region’s request is unjustified and will significantly prejudice the potential for future development of our land.

Our land is located southwest of the Town of Georgetown and North of the Village of Hornby. It fronts on 5th Line and is currently being farmed. You will see that it is located outside of the Paris Galt Moraine and is separated from it by a hydro corridor to the west, and rail line to the north.

The Region’s request is based on staff report LPS29-21 dated March 24, 2021. The Region provided no notice of its intention to seek an expansion of the Greenbelt to include our land before issuing this report. The Region as provided no notice to us of its request to the Province. There has been no public process. Rather, we learned of the request through a neighbour.

The Region’s reasons for the expansion of the Greenbelt are disingenuous. On February 14, 2018 Regional Council passed a motion requesting that the province be “strongly urged” to extend the study area for Greenbelt expansion to include lands that are “most immediately vulnerable to development”.

With respect to the inclusion of our land within the Greenbelt report LPS29-21 suggests that there is a strong physical and functional connection to adjacent Growth Plan and Greenbelt Natural Heritage Systems without providing any evidence or study. In fact, in the attachment to the report Halton Region staff state that:

- “it is difficult to determine if the study area (Paris Galt Moraine) within Halton Region is fully capturing the Moraine feature and adjacent areas that may contribute to or benefit from the ecological and hydrological functions of the Paris Galt Moraine.” In other words there is no evidence our land is included in the moraine. The report is plain that staff do not know the extent of the Paris Galt Moraine or whether it extends beyond the Study Area. They recommend that the extent of the Moraine be identified.
- With respect to the Region’s Natural Heritage System the report is not definitive. It simply states that it “appears” that the Study Area contains certain features which merit protection.
- The report identifies that the Study Area contains Well Ahead Protection Areas but does not identify that any of them are closed to or affected by our land.
- The Report identifies that “important connections and interactions between natural heritage and hydrogeological features and areas must be considered in defining the boundary of the Paris Galt Moraine to be included in the Greenbelt Plan.” However, no such evidence of such connections set out in the report.

Report LPS29-21 also relies on the fact that the lands are prime agricultural “predominantly comprised of for tile Class1-3 soils” as a reason for an expansion of the Greenbelt. However, we note that the Growth Plan and the Provincial Policy Statement already contains significant policies designed to protect prime agricultural lands where that protection is appropriate. There is no need to use the Growth Plan for this purpose.

Given the foregoing it is clear that the Region is using the Greenbelt consultation as an attempt to control future development through the Greenbelt expansion process. Accordingly, we request that you not entertain the Region’s request to expand the Greenbelt to include our land.