RE: ERO posting #019-6216,…

RE: ERO posting #019-6216, Proposed amendments to the Greenbelt Plan

The Algonquin to Adirondacks (A2A) Collaborative is a Canadian, U.S. and First Nations organization of over 50 partners. We work with scientists, policy-makers and a variety of conservation groups to protect and enhance the unique ecological features and functions of the region stretching from and encompassing Algonquin Park in Ontario and Adirondack Park in New York State. In order to ensure the long-term health of Ontario’s natural environment and the province’s agricultural sustainability, it is critical that ecologically sensitive natural areas and farmland be permanently protected.
Therefore, we are greatly alarmed at the proposal in ERO posting #019-6216 to remove portions of the Greenbelt for purposes of housing development.

IMPORTANCE OF THE GREENBELT

The Greenbelt contains some of the most ecologically and hydrologically significant lands in Canada, as well as some of the country’s most productive farmland. The Greenbelt Plan (2017) identifies “where urbanization should not occur in order to provide permanent protection to the agricultural land base and the ecological and hydrological features, areas and functions occurring on this landscape” (our underlining). Five years does not amount to “permanent” protection.
The lands that are under threat of being lost or degraded by the Greenbelt ERO proposal encompass numerous sensitive ecological features, including important wildlife corridors, important wetlands, headwaters and river valleys, the habitat of endangered species, as well as important farmlands. The protection of such sensitive ecological features is especially critical given the growing climate crisis and widespread loss of biodiversity, which has been highlighted most recently in the just-released report of the Canadian Endangered Species Conservation Council (Wild Species 2020: The General Status of Species in Canada. National General Status Working Group, 2022). The protection of farmland in the Greenbelt is also of great importance given the growing population of Southern Ontario and the continuing loss of farmland there.
Furthermore, placing developments in the Greenbelt will contribute to urban sprawl and the unnecessary expansion of related infrastructure such as roads and highways.

ONTARIO GOVERNMENT’S BROKEN PROMISE TO PROTECT THE GREENBELT

Both the Premier and the Minister of Municipal Affairs and Housing, have stated publicly that there would be no development in the Greenbelt. In 2018, the Premier said: “The people have spoken. I’m going to listen to them, they don’t want me to touch the Greenbelt, we won’t touch the Greenbelt”. In 2020, he repeated his promise not to allow development in the Greenbelt. In 2021, you said: “I want to be clear: we will not in any way entertain any proposals that will move lands in the Greenbelt, or open the Greenbelt lands to any kind of development." Given the proposals in ERO posting #019-6216 to open Greenbelt lands to development, it is clear that the government’s previous promises misled the people of Ontario.

In fact, it seems that the government is willing to sacrifice even the province’s most sensitive natural areas and farmlands to satisfy the developers’ seemingly insatiable demands. This despite the fact that the government’s own Housing Task Force reported earlier this year that “a shortage of land isn’t the cause of the [housing] problem”, that “Most of the solution must come from densification. Greenbelts and other environmentally sensitive areas must be protected”, and that currently land “is not being used efficiently across Ontario” (Housing Affordability Task Force Report, 2022).

In other words, there is no need to develop Greenbelt lands or other sensitive natural areas or farmlands, because there is already enough land designated for current and future housing needs, provided it is used efficiently.

DANGEROUS PRECEDENT

Removal of protected lands from the Greenbelt would set a dangerous precedent for the removal of additional lands from then Greenbelt or from any other protected lands in the province. This threat is very real, as evident from Bill 23, the More Homes Built Faster Act, which has just been rammed through the legislature without adequate consultation with the public, First Nations, Conservation Authorities or municipalities. This Bill aims, in part, to gut the role of the Conservation Authorities in protecting ecologically sensitive natural areas and flood plains from inappropriate development.

SUMMARY

In summary, we strongly oppose the removal of any lands from the Greenbelt, as this will:
• Result in the destruction of wildlife corridors, wetlands, headwaters, and important agricultural lands
• Increase pressure on already endangered and threatened species
• Result in even more urban sprawl and the unnecessary expansion of related infrastructure such as roads and highways which in turn, fragment the landscape
• Set a dangerous precedent for the development of other Ontario protected lands
• Break the promise made by Premier Ford and his government to not remove lands from the Greenbelt

Therefore, we ask that the proposed removal of lands from the Greenbelt be withdrawn, and that the government keep the promise made to the people of Ontario not to allow developments in the Greenbelt.