Thank you for the…

Thank you for the opportunity to submit comments to the Environmental Registry. These are my own comments but I do want to express my support for many other individuals and groups who are raising concerns with the proposal to remove land from the Greenbelt for development such as Ontario Nature, Conservation Ontario, Victor Doyle, David Crombie, Hike Ontario, ACORN, the Ontario Greenbelt Alliance and many municipalities.

Both Premier Doug Ford and Minister of Municipal Affairs and Housing Steve Clark repeatedly made promises in the legislature, during press conferences, in public statements and during consultations in 2021 when the province committed to expanding the Greenbelt and was considering expanding it onto the Paris Galt Moraine - not to touch, to keep their hands off - the existing Greenbelt. It is unacceptable for them to break their promises after they were re-elected - and instead make plans to start carving land out for development.

I am deeply concerned with the extremely rushed way this proposal to open the Greenbelt for development is being managed, and how Bill 23 and Bill 35 are being/have been pushed through. It is unacceptable that no consultation with First Nations or municipalities has taken place. The recent statements from the Chiefs of Ontario and AMO reveal that they have all been left out. At the same time, home builder associations like BILD and many others have taken out full page ads in newspapers to praise these initiatives, making it more than clear who the provincial government is engaging with in this process. This is not an appropriate or acceptable way to create provincial policy or legislation. The provincial government needs to respect the democratic rights of the people of Ontario and treaty obligations that need to be respected as well.

In order to put effective legislation in place, an essential part of the process is to consult with people who have knowledge and expertise. Instead, these proposals have been introduced without engaging with most of the key knowledge keepers and stakeholders. The comment periods are far too short for such enormous pieces of legislation and proposals, and in the case of Bill 23, rushed through three votes in the legislature and it received royal assent prior to the end of the comment period. All of this is happening immediately following the municipal election in October, when municipal councils are in a period of major transformation and have very limited ability to respond quickly to any proposals or new legislation. Rushing the process to put in place such significant policy changes and legislation increases the risk that mistakes are going to be made. Because planning decisions have impacts that can last for decades - for future generations - the rushed approach is not acceptable. The worst case scenario is permanent damage - such as endangered species going extinct, or people harmed or injured. Why not take the time to make sure changes will not have harmful impacts? The risks here are enormous.

It has become increasingly clear that instead of being careful and engaging stakeholders, decisions and changes are being made primarily considering wealthy land owners, speculators, home builders and developers.

The future generations of Ontario are being completely disregarded.

My observations are based on several investigative pieces in the Narwhal, CBC, the Star and other media. They have found evidence of wealthy developers purchasing protected land inside the Greenbelt over the past few years leading up to this new proposal and legislation changes. The timing of these land deals is extremely suspicious, particularly in light of the video that came out in 2018 before Premier Ford was first elected in which he was seen promising a group of developers his plan was to open up the Greenbelt for development.

It is remarkable to see the increasing amount of opposition to these proposals and especially Bill 23. It is not limited to just some of the opposition parties, or a few environmental groups. It is actually very close to all of them, as well as groups of architects, Conservation Authorities, farmers, housing activists, healthcare workers and more. A large number of protests by grassroots organizations and residents all over Ontario took place over the weekend (December 3 and 4, 2022). Thousands of people showed up to protest. It should be very clear at this point that most of Ontario opposes these proposals and Bill 23. Protests will only increase as more people find out about what is at stake.

Evidence, including the report by the province's own appointed Housing Affordability Task Force shows there is already enough land designated within the GTA and the GGH for construction of homes sufficient to accommodate Ontario’s growth for the next ten years and beyond. The Housing Task Force concluded that the cause of the Ontario housing shortage is not a shortage of land. Thus it is more than a bit concerning that Minister Clark and the Premier are insisting repeatedly that the housing crisis can only be resolved by building homes on the Greenbelt.

To add to my concerns, the submissions from CELA (Canadian Environmental Law Association) and from Kevin Thomason, Kevin Eby and Mark Ruesser from Waterloo provide evidence that the method used by the province to project the number of homes needed to accommodate future growth overestimates the number of homes needed significantly.

I have come to the conclusion that there is no evidence that opening up the Greenbelt for development will fix or even alleviate the housing crisis. And the housing crisis does not appear to be as severe as the province is suggesting. What is needed is not construction of large homes on the Greenbelt. It is affordable and attainable housing that is needed.

Public consultation is essential to democracy. I am pleased that Bill 23 was amended and third party OLT appeals were returned, but too many restrictions are being put in place on public input. The province needs to protect our natural environment, the people who live on the land, including Indigenous people and our democracy. This proposal and the legislative changes accomplish none of these things.
Ontario needs precious water sources, farmland, wetlands and natural heritage protected. The Greenbelt protects these for the GTHA. The Greenbelt also gives stability to farmers and protects land from becoming the target of speculators. Agriculture is necessary as both a stable secure source of food and as a major economic driver. Once a precedent is established with some land having the protection removed it is difficult to stop more land from being carved out. Farmland functions much better if it is located away from residential development. Building housing on farmland creates conflict between homeowners and farmers. Farmers need to know their land is stable, it creates instability if they feel pressure - their land is might be expropriated or developers and land speculators come knocking on their door offering to buy their land for high prices.
It is both logical and economical to build housing on land that is away from farming operations, closer to urban centres, closer to employment, schools, shopping and transit. It is important that our natural environment and our well being are protected. Thank you for the opportunity to submit comments to the Environmental Registry. These are my own comments but I do want to express my support for many other individuals and groups who are raising concerns with the proposal to remove land from the Greenbelt for development such as Ontario Nature, Conservation Ontario, Victor Doyle, David Crombie, Hike Ontario, ACORN, and many municipalities.
Both Premier Doug Ford and Minister of Municipal Affairs and Housing Steve Clark made promises in the legislature, in meetings with the press, in public statements and during consultations in 2021 to protect (not touch, keep their hands off) the existing Greenbelt. It is unacceptable for them to break their promise after they were re-elected and make plans to start carving land out.

I am deeply concerned with the extreme rush that this proposal to open the Greenbelt for development, along with how Bill 23 and Bill 35 have been pushed through. It is unacceptable that no consultation with First Nations or municipalities has taken place. The recent statements from the Chiefs of Ontario and AMO reveal that they have all been ignored. At the same time, home builder associations like BILD and many others have taken out full page ads in newspapers to praise these initiatives. That makes it more than clear who the provincial government is engaging with. This is not an appropriate or acceptable way to create policy or legislation.

In order to put effective legislation in place, an essential part of the process is consultation with people who have knowledge and expertise. Instead, these proposals have not only been introduced without engaging with most of the key stakeholders they are subject to very short comment periods and in the case of Bill 23 rushed through and passed and received royal assent prior to the end of the comment period. All of this is happening at a time just after the municipal election, when municipal councils are in a major transformation and have very limited ability to respond quickly to any proposals or new legislation. Rushing the planning process to put in place such significant policy changes and legislation increases the risk that mistakes are going to be made. Because planning decisions have impacts that can last for decades - for future generations - the rushed approach is particularly troubling. The worst case scenario is permanent damage - such as endangered species going extinct, or people harmed or injured. Why not take the time to make sure changes will not have harmful impacts?

It has become increasingly clear that instead of being careful and engaging stakeholders, decisions and changes are being made primarily considering developer profits. Future generations of Ontario are also being completely disregarded. My observations are based on several investigative pieces in the Star, the Narwhal, the Globe & Mail, CBC and others who have found evidence of numerous developers purchasing protected land in Greenbelt over the past few years leading up to this new proposal and legislation changes.

It is remarkable to see the increasing amount of opposition to these proposals. It is not limited to just some of the opposition parties, or a few environmental groups. It is actually very close to all of them, as well as groups of architects, Conservation Authorities, farmers, housing activists, healthcare workers and more.
Evidence, including the report by the province's own appointed Housing Affordability Task Force shows there is already enough land designated within the GTA and the GGH for construction of homes sufficient for Ontario’s growth for the next ten years and beyond. The Housing Task Force concluded that the cause of the Ontario housing shortage is not a shortage of land. Thus it is more than a bit concerning that Minister Clark and the Premier are suggesting repeatedly that the housing crisis can only be resolved by building homes on the Greenbelt.

The submissions from CELA (Canadian Environmental Law Association) and from Kevin Thomason, Kevin Eby and Mark Ruesser from Waterloo provide evidence that the method used to project the number of homes needed to accommodate future growth overestimates the number significantly.

There is no evidence that opening up the Greenbelt for development will fix or even alleviate the housing crisis.

Public consultation is essential to democracy. I am pleased that Bill 23 was amended and third party OLT appeals were returned, but too many restrictions are being put in place on public input. The province needs to protect our natural environment, the people who live on the land, including Indigenous people and our democracy. This proposal and the legislative changes accomplish none of these things.
Ontario needs precious water sources, farmland, wetlands and natural heritage protected. The Greenbelt protects these for the GTHA. The Greenbelt also gives stability to farmers and protects land from becoming the target of speculators. Agriculture is necessary as both a stable secure source of food and as a major economic driver. Once a precedent is established with some land having the protection removed it is difficult to stop more land from being carved out. Farmland functions much better if it is located away from residential development. Building housing on farmland creates conflict between homeowners and farmers. Farmers need to know their land is stable, it creates instability if they feel pressure - their land is might be expropriated or developers and land speculators come knocking on their door offering to buy their land for high prices.
It is both logical and economical to build housing on land that is closer to urban centres, close to employment, schools, shopping and transit. It is important that our natural environment, our well being are protected. Takeouts from the Greenbelt are not necessary. Once farmland is developed it can never be used for farming again. We have already lost so much farmland - over 1.5 million acres were lost between 1996 and 2016, the loss has continued.

My request is for the proposals to take land out of the Greenbelt in order to develop and build housing be withdrawn, and for Bill 23to be rescinded. Approval is necessary for the Official Plans that municipalities submitted as they are based on evidence from studies and went through public consultation as well as consultation with Indigenous people and First Nations. Forcing municipalities to expand unnecessarily onto farmland is not acceptable.