Comment from the Prince…

Comment from the Prince Edward County Field Naturalists on Proposed Amendments to the Greenbelt Plan re: ERO 019-6216
December 4, 2022

To Whom it May Concern:
The provincial government is proposing to renege on its promise not to develop in the Greenbelt and turn 7,400 acres of land in the Greenbelt over to housing and commercial development. In addition, the government is proposing to redesignate land in the Oak Ridges Moraine Conservation Plan Area for this purpose.

We are concerned that the government has failed to consider the full ramifications of this proposal, or if it has considered them, has yet to demonstrate this to the public.

As an example, a few days ago Steven Guilbeault, the federal minister of the environment, noted that some of the lands where housing or commercial development is being proposed are located in low-lying areas that are subject to flooding.

The Hon. Steve Clark (Municipal Affairs and Housing) responded to Mr. Guilbeault’s observation as follows:

"Undertaking natural hazard mitigation is a standard part of any development and Ontario’s
preventative approach of directing development away from floodplains and other hazardous areas
is highly effective. We continue to help our municipal partners plan for responsible growth and help
build housing where it makes sense, while protecting the environment, so Ontario can continue to
be the best place to live, work, and prosper."

However rather than alleviating concerns about flooding, Mr. Clark has done exactly the opposite. At the same time Mr. Clark is expounding on his government’s “preventative approach”, it is worth bearing in mind that Mr. Clark and his government are preparing to dismantle conservation authorities that for many years have played a major role in directing development away from floodplains and other hazardous areas and in helping municipalities plan for responsible growth.

In reality, conservation authorities (not the government) have traditionally partnered with municipalities to “build housing where it makes sense, while protecting the environment.”
The ”preventative approach” that Mr. Clark refers to has only been effective because of the province’s conservation authorities. It is our conservation authorities that have done the heavy lifting when it comes to directing development away from floodplains and in working with municipalities on responsible land use planning in their respective watersheds.

If the changes proposed in ERO 019-6141 go through, conservation authorities will be prohibited from commenting on any matter related to development and land use planning. Quinte Conservation, the conservation authority in our region, will no longer be permitted to work with our municipality on watershed planning. As others have noted, the proposed new regulations “gag” conservation authorities by not allowing them to share information with municipalities as part of the land use approval process.

In view of the government’s proposal to eliminate the roles and responsibilities of our conservation authorities, Mr. Clark’s response should be taken with a grain of salt. Concerns about flooding in low-lying areas of the Greenbelt are absolutely relevant and will become even more so when conservation authorities will no longer be in the picture.

In its eagerness to open the Greenbelt and the Oak Ridges Moraine and other areas in Ontario to development the government is prepared to get rid of conservation authorities and anything else standing in its way. We strongly disagree with Premier Doug Ford that Mr. Guilbeault needs to "do his research" and that developers are responsible for making sure they protect developments on floodplains. The fact that our Premier is even condoning developing on floodplains indicates that our conservation authorities are needed more than ever.

We strongly object to the government’s proposal to develop the Greenbelt when the government has not undertaken due diligence in conducting its own research into the ramifications of doing so. This includes building housing developments in low-lying areas, as per the concern raised by Minister Guilbeault. Does the government even know how many low-lying areas are located in the lands being partitioned off for development and as such will be subject to flooding?

In summary, our comments in response to the proposed amendments to the Greenbelt Plan re: ERO 019-6216 are:
(1) Leave the province’s Conservation Authorities in place as they are today as it is their authority and oversight of watersheds including the watershed(s) in the Greenbelt that will ensure the sustainability of these environments with established protection criteria;
(2) The irresponsibility of a plan that denies municipalities’ access to centralized information such as watershed mapping that is in the possession of conservation authorities, including municipalities that have lands in the Greenbelt. Relatedly, prohibiting municipalities from seeking advice from conservation authorities on planning matters, including seeking advice on planning matters on low-lying lands in the Greenbelt that are subject to flooding;
(3) Lack of due diligence in ensuring that municipalities directly involved in this proposal to put housing in the Greenbelt have access to vital information about the exact location of low-lying areas in the lands involved in this proposal and access to subject matter experts who can advise on the likelihood of flooding events, taking into account the potential for more frequent and devastating flooding events with climate change and the challenges of mitigating for these events;
(4) Failure to identify the irreparable harm to wetlands, woodlands and wildlife habitat that will be paved over to build new houses and roads;
(5) Failure to give due consideration to the Provincial Policy Statement (the PPS is not mentioned anywhere in the proposal details for ERO 019-6216);
(6) Permitting housing development in the Greenbelt when the government has failed to provide evidence of any kind that there is an urgent need to build houses in the Greenbelt;
(7) The total irresponsibility of a Premier suggesting that developers will be responsible for making sure they protect developments on floodplains when the last thing the government should even be considering is permitting development in a floodplain.

Regards,
The Prince Edward County Field Naturalists