RE:234-2021-813, Growing the…

RE:234-2021-813, Growing the Greenbelt
ERO 019-3233 – Proposed changes to MZO and the Planning Act

Dear Minister Clark;

Thank you for providing your letter to Mulmur Council dated February 17, 2021 and providing sufficient time (61 day period) for the Township Council to meet during regular monthly meetings and discuss the Provincial consultation on growing the size of the Greenbelt. We have since become aware of proposed changes to the Planning Act, however, that have much tighter commenting deadlines (30 day commenting period).

Mulmur is concerned with the optics and the lack of consistency in messaging around the protection of natural heritage features and functions. This concern arises with the recent
ERO#019-3233 posting whereby Minister’s Zoning Orders (MZO) would not need to be consistent with the Provincial Policy Statement. It is our understanding that the proposed amendments to the Planning Act, could conceivably allow decisions inconsistent with protecting Provincially significant resources. This appears to be contrary to the messaging and openness of the proposed growing of the greenbelt campaign. There appears to be a disconnect and a struggle between supporting sustainable growth and protecting the environment.

Mulmur supports the principle of protecting critical groundwater resources and natural heritage features and functions. It also supports the protection of unique landforms, and world biosphere – Niagara Escarpment – through the greenbelt designations, for which it hosts. It does caution the Ministry though, in adopting a computer-based identification system without ground-truthing. It is essential that the land be appropriately assessed prior to being included in the Greenbelt.

Mulmur has been very concerned with expansions within the Township due to the financial impacts. Financial support to lower tiers to offset tax incentive programs related to greenbelt and protected natural features is necessary. Mulmur Township provided significant data on the financial implications to the Province at its 2017 ROMA conference delegation with the Minister. The Township has not received any updates on the status of review of the financial implications of the tax programs and continues to be interested in continued dialogue.

While the proposed map does not include lands within its Township, Mulmur is still concerned with the lack of attention to the financial implications of the Greenbelt (and associated Niagara Escarpment) designations.

We thank you for the opportunity to comment on the proposed legislation and growing the Greenbelt, and ask that you reconsider the balancing of development versus environment, consistency of messaging, commenting periods and financial implications to rural Ontario municipalities.