Dear Madam/Sir Please accept…

Dear Madam/Sir

Please accept this submission as Environment Hamilton’s comments regarding the Ford Government’s proposed amendments to Ontario’s Greenbelt Plan. We are deeply concerned about the proposal to remove 11 parcels of currently protected rural natural areas and prime farmland from the Greenbelt for urban development. More specifically, we are concerned about the large parcels proposed for removal from the Greenbelt area within the City of Hamilton’s boundaries. First and foremost, there is no logic nor is there any justification for the removal of these lands to address the housing crisis over the short term, despite the provincial government’s assertion that this is why these removals are being pursued. Our municipality’s own planning staff and our Hamilton City Council do not support the proposed removals for a host of reasons – including the fact that there is no need for these lands to accommodate urban growth in the municipality over the next thirty years.

The two larger parcels of land proposed for removal in Hamilton are not serviced lands and they are not contiguous with existing urbanized areas. This is particularly true in the case of the lands located along the south side of Whitechurch Road. We also understand sizeable portions of the parcel located along Garner Road is in the airport exclusion area and federal regulations restrict development within this area. Other portions of these lands include natural heritage features that would be at risk with urban development combined with other problematic policy changes being ushered in by the provincial government.

We also know that this proposal will do nothing to help the housing affordability crisis. There is no indication of how new residential units built on these lands will be made more affordable to those in desperate need of housing. However, it is very apparent that this approach will cost municipalities and municipal taxpayers more money. We will be absorbing the financial burden should costly urban expansion proceed into these areas. These costs are on top of the costs to society from the loss of prime farmland and natural areas at a time when we can least afford to lose these areas.

Community advocacy in combination with policy shifts at the municipal level have resulted in a municipal decision to accommodate urban growth within Hamilton’s existing urban area. The municipality has demonstrated that it can conform with provincial planning requirements while accommodating population and job growth projections. The provincial government must respect this reality, and allow the municipality to proceed. Given the fact that we are facing a climate crisis, it is prudent to commit to building complete communities that will be better able to mitigate and adapt to climate impacts. Doing this, in turn, enables the protection of prime farmland and rural natural areas that are also integral to building up climate resilience.
We are also concerned that the protected Greenbelt was never envisioned as an area that would be pushed outwards over time through ‘land swaps’. The intended outcome of the reintroduction of regional planning via a Greenbelt Plan and a Growth Plan was to create the dynamic necessary to encourage more efficient use of urban land to accommodate population growth while continuing to protect our valuable farmland and rural natural areas. The intent was never to simply pull out chunks of Greenbelt and extend the boundary on the other side of the Greater Golden Horseshoe. This defeats the purpose of the approach altogether. It is worth noting, too, that the lands being added on the other side are not equivalent to the lands being pulled out and this only makes the land swap approach that much more flawed.

This proposal is not in the interest of the Province of Ontario and its residents. It works against the efforts of several municipalities to build a climate resilient future, pulling them in the very opposite direction. The proposal locks communities into a growth model that will cost us dearly now and into the future. We are deeply opposed to this proposal!

Yours truly,

Lynda M. Lukasik, PhD
Executive Director
Environment Hamilton

*Please note that there is no information in this submission that prevents it from being shared publicly in the decision posting for this proposal.