I wish to comment on ERO posting No. 019-6217 - Proposed amendments to the Greenbelt Area boundary regulation.
This is a notice of a proposed regulation under the Greenbelt Act, 2005, posted by the
Ministry of Municipal Affairs and Housing
The premise that Greenbelt lands are required for housing has been refuted by the province's signature consultation body -- the Ontario Housing Affordability Task Force --- in its February 2022 report; in fact, the Task Force warned of the danger of developing environmentally sensitive areas:
“But a shortage of land isn’t the cause of the problem. Land is available, both inside the existing built-up areas and on undeveloped land outside greenbelts ...”
“Greenbelts and other environmentally sensitive areas must be protected, and farms provide food and food security. Relying too heavily on undeveloped land would whittle away too much of the already small share of land devoted to agriculture.” (p. 10)
Opening up the Greenbelt will lead to the loss of habitat and ground water protection, irreplaceable loss of farm land, reward land speculators and establish the principle that Greenbelt lands are no longer off limits for development.
The proposed countervailing measure of adding equal (or even greater) amounts of lands to the Greenbelt to replace carve outs is, like the idea of carbon offsets, not tenable.
- What guarantee is there that the replacement lands will not themselves be opened for development?
- The replacement lands are in some cases already protected, thereby resulting an a decrease in protected lands.
- Protecting part of a feature, such as the Galt Moraine, is only a partial measure and does not result in comprehensive protection of the feature.
Finally, given the multiple investigations of property purchases in the areas of the Greenbelt that are proposed to be released for development, it would be entirely inappropriate to proceed with this regulation prior to the completion of all investigations.
I strongly urge the Ministry of Municipal Affairs and Housing you not to proceed with this regulation.
Submitted December 2, 2022 5:32 PM