Dear Ministry of Municipal…

Dear Ministry of Municipal Affairs and Housing:

Thank you for the opportunity to comment. I am not entirely clear on the difference between ERO 019-6216 and ERO 019-6217, so I am also providing a comment here. Apologies for any duplication.

I oppose the proposed removal/redesignation of lands from the Greenbelt (ERO 019-6216, ERO 019-6217) for the following reasons:
- In this era of uncontrolled climate change, and with limited existing greenspace in the GTA, the Greenbelt provides a measure of resilience to Ontarians residing nearby and reduces costs (and taxes) for all Ontarians.
- For example, greenspaces have been shown to improve health. Access to greenspace would be great, but even if the greenspace is private, it is visible and more relaxing than seeing construction or subdivisions.
- Greenspace helps absorb heat and rain, reducing “heat island” effects and flooding (or pressure on stormwater systems). In addition, it reduces the need for air conditioning and repairing damages from flooding which necessitate more resources and further contribute to greenhouse gases and climate change.
- Nearby farmland supports supply chain and resiliency of the area, rather than relying on land that is farther which also results in higher transportation costs.
- In short, the existing Greenbelt land is supporting health and the economy (supply chain resilience) and reducing climate change costs and emergencies that would ultimately be borne by Ontario taxpayers.

Because of these concerns, I find the proposed “trade” (removing 7000 acres and designating 9400 acres of other land as part of the Greenbelt) insufficient, in particular:
- This amendment opens up land for development and removes greenspace but does not replace it with additional greenspace in similar locations (i.e. the land that is being added to the Greenbelt will stay in its existing condition; it is not land that was developed that is being restored back to a more natural state. If you would unpave 9400 acres of unused pavement and make it greenspace, that would be a better trade.) As such, I still have concerns about the diminished greenspace in the GTA that the Greenbelt protects.
- Your proposal earlier this year (ERO 019-3136, ERO 019-4485) already considered adding land from the Paris Galt Moraine and Urban River Valleys (URVs). In particular, Phase 2 of designating URVs (in ERO 019-4485) specified that “Key Principles for Expanding the Greenbelt identified in phase 1 were also applied. In particular, 1. No removal or land exchanges proposed – This proposal is about growing the size and quality of the Greenbelt, and the government will not consider the removal of any lands from the Greenbelt”. The current proposal contradicts ERO 019-4485 and does not explain why land exchanges are proposed for the URVs. In addition, the Summary of Comments for ERO 019-3136 didn’t seem to identify a need to trade the URVs and Paris Galt Moraine for proposed development areas elsewhere, so there is a lack of rationale and transparency as to how this is a relevant or compensatory trade.
- Moreover, if the Paris Galt Moraine and URVs should be protected and added to the Greenbelt based on merit, then they should be added to the Greenbelt for that reason. There is no requirement to remove land in that process.

Finally, I would like to raise alternatives.
- Ontario has a lot of land. There is no fundamental reason development needs to occur in the Greenbelt specifically.
- One could argue that previous or existing development policies and urban planning have not considered and addressed long-term needs. (Apparently we didn’t plan and allocate land around the Greenbelt with a long-term view). However, continuing to make these same choices that got us here will not solve the underlying problem.
- What happens when those 50,000 homes are inhabited and additional people want to move to the area? Do we keep carving up the Greenbelt to build large homes and subdivisions?
- Why is the rest of Ontario not a desirable place to live? How can we build healthy communities throughout Ontario while planning for long-term needs? Why do we need to build on GTA greenspace that is currently protected, that supports health, economic, and environmental resiliency, and whose loss would ultimately result in financial costs for residents of the GTA and Ontario?

Thank you for your time and attention. I hope that you will find alternate solutions to building homes that do not require removing protected Greenbelt land.