Growing the Greenbelt – ERO …

Growing the Greenbelt – ERO # 019-3136 - My Submission #1 - March.27.2021

(corrected and updated on April.16.2021 to remove any names of persons)

Recently, on Feb. 17, 2021, the Minister of Municipal Affairs and Housing, announced his proposal to expand the Greenbelt. My submission puts forward some very practical ideas, recommendations, requirements and next steps. Together, these would be effective in achieving this goal for the collective benefit of supporting communities, individuals & organizations who have helped create, protect & celebrate the Greenbelt.

To begin with, it is important to acknowledge the intention & vision for the Greenbelt, as currently set out in the Greenbelt Plan approved by the Ontario government:

“The Greenbelt is a broad band of permanently protected land which:
• Protects against the loss and fragmentation of the agricultural land base and supports agriculture as the predominant land use;
• Gives permanent protection to the natural heritage and water resource systems that sustain ecological and human health and that form the environmental framework around which major urbanization in south-central Ontario will be organized;
• Provides for a diverse range of economic and social activities associated with rural communities, agriculture, tourism, recreation and resource uses; and
• Builds resilience to and mitigates climate change”

Successful realization of this vision for the Greenbelt Plan depends on the highly effective collaborations among the Province, other levels of government, First Nations and Métis communities, residents, private and non-profit sectors and all stakeholders.

Permanently protecting lands in the Greenbelt is key to maintaining and improving the resiliency of local food systems and the physical, social and economic health of Ontarions. Healthy ecosystems are the foundation of human prosperity and will become increasingly important for building and sustaining a climate resilient Ontario.

The COVID-19 pandemic has made these facts clearer than ever before. Since the pandemic started, we all rely even more on Greenbelt-protected natural lands for our mental and physical health. We appreciate even more the Greenbelt-protected farmland and farmers that supply us with healthy local food and jobs. And we are profoundly grateful that Greenbelt-protected water resources provide us with a clean and secure water supply.

Collectively, people rely on Greenbelt-protected lands for nearly 180,000 jobs and $9.6 billion in annual economic activity. Meanwhile, the combined activities of plants, animals, insects and microorganisms in its wetlands, forests, farmlands and rivers generate over $3.2 billion in value of annual ecosystem services such as: fresh water, flood control, food supplies, wildlife habitat, forest products, biodiversity, climate amelioration, carbon sequestering, along with health giving outdoor pursuits having recreational and cultural benefits.

Because of all these attributes and benefits, expansion of the Greenbelt is clearly in the public interest. Bringing more lands under its permanent protection is a necessary precondition for a more climate resilient and prosperous future.

Discussions about expanding the Greenbelt have been happening since it was first established in 2005. It’s important to acknowledge that, at present, the Greenbelt Plan only covers 21 per cent of the Greater Golden Horseshoe (GGH).

Key Requirements are Recommended for Growing the Greenbelt Plan.

Requirement 1: Do not remove any lands from protection of the Greenbelt

The land currently in the Greenbelt must remain in the Greenbelt. For years, developers and land speculators have been asking the provincial government to change the Greenbelt boundary to remove their land from Greenbelt protection. In some cases, they suggest that other lands elsewhere be reclassified as Greenbelt lands so that the total Greenbelt area is maintained. This is unacceptable for several reasons and would effectively destroy the Greenbelt’s capacity to protect farmland and key natural areas.

The negative consequences of land removal would include:
• Harming both farmers and nature. A spider web of subdivisions, roads and factories in the Greenbelt would reduce the ability of forests, fields and wetlands to clean our air and water and absorb the rain, of wildlife to move as needed for foraging, breeding and raising their young, and of plants to be pollinated and disperse seeds. As urban development encroaches on agricultural land and buffers between agricultural and non-agricultural uses are reduced, people with no attachment to farming come into close contact with farm operations. As the Ontario farm organizations have said, this can give rise to conflict between farmers and new arrivals in the countryside, impeding normal farm practices and undermining the long-term viability of farming in affected areas. In addition, creating an escape mechanism in land planning to remove productive farmland from the Greenbelt would erode the incentive and the intentions for long term business investments in farm infrastructure.
• Creating a “Swiss-cheese” Greenbelt. In 2017, the provincial government reviewed the current Greenbelt boundaries as part of the legislatively required 10-year Greenbelt Plan review. At that time, they received over 700 requests from developer landowners to remove land from the Greenbelt. In the end, only minor adjustments were made to refine the mapping from when the Greenbelt was established in 2005. The rest of the requests were denied because approval of these requests would have resulted in many islands of development within the Greenbelt. These new housing subdivisions, factories and big box stores would also have required roads, sewers and water supply. Hence, these islands of development would become linked to towns and cities outside of the Greenbelt and a spider-web of development would have begun to impair the protected lands.
• Setting an irreversible, dangerous land use precedent. Once a developer or a municipality is allowed to remove land from Greenbelt protection what would stop the next proposal from being approved? Once this happens the land use planning for the Greenbelt ceases to be a meaningful, permanent protection mechanism.
• Making Farmland less affordable. If Greenbelt protection is not permanent and farmland is seen as open for development, there will be a significant impact on its value. Permanent protection keeps farmland more affordable for the purpose of farming.
• Harming those who followed the rules. Landowners or developers who have played by the rules and worked within the municipal land planning system to have their land approved for development would be competing with someone who had sidestepped this public process. Land removal to secure a development approval will cause serious harm.
• Breaking the intent of planning law. It is a fundamental purpose of the Greenbelt Act and Plan to protect these lands and waters forever. While the Greenbelt Plan may be amended, it is fully contrary to the Greenbelt Act and Plan which say, no amendment shall reduce the total land area contained within the Greenbelt Plan.
In summary, allowing land inside the Greenbelt to be approved for development would make the Greenbelt no more protected than the lands outside of it. Hence, any credible and viable plan to expand the boundaries of the Greenbelt cannot allow land removals.

Requirement 2: Enrich what’s been done already (don’t reinvent the wheel)

Discussions about growing the Greenbelt have occurred since 2005. In 2017 lands in 21 urban river valleys around the GGH and seven coastal wetlands were added to the Greenbelt. As well, the Province launched an extensive consultation process to get feedback on adding more land in seven areas across the GGH to the Greenbelt.
As part of the consultation processes, member groups of the Ontario Greenbelt networks system submitted a detailed report with map containing additional lands to be added to the Greenbelt, known as the “Bluebelt Expansion Area”. The proposed “Bluebelt” areas of expansion involved extending the Greenbelt to protect areas of strong ecological and hydrological value such as forests, moraines, lakes, wetlands, swamps, headwaters and coldwater streams.
The collective voices-group submission of March 07, 2018 to the Ontario government, summarized in Appendix 2, should be the focus of new plans to expand the Greenbelt.

Requirement 3: Work towards simultaneously improving public health, food & water security, climate resilience, biodiversity conservation and economic prosperity

The COVID-19 crisis has made it abundantly clear that governments have a duty to protect the public interest. This is equally true for issues that require long term action, like the protection of key natural infrastructure, including the Greenbelt. The huge economic, social and ecological benefits provided by the Greenbelt demonstrate the value of its protection today and the promise of even greater value for generations in the future.
The Province can act to simultaneously improve public health, help farmers create a more secure local food supply, better protect our water resources, and build climate resilience in ways that create economic prosperity for Ontarions by expanding the Greenbelt.

Requirement 4: Acknowledge that there is more than enough land to grow the Greenbelt and build complete communities to handle projected population growth

Discussions about expanding the Greenbelt will once again ignite debate around how much new land is needed to house and employ Ontario’s projected population growth. The evidence is clear in Appendix 1. There is more than enough land already set aside for development within existing town and city boundaries to meet the demand for all types of housing and businesses until far past 2031. This is because each municipality is required by law to identify and zone enough land for these uses up to at least 2031. In fact, for all municipal regions except Toronto and Peel growth has been less than projected and there are large surpluses of land available for development. In 2017, Neptis Foundation found the total supply of un-built land for housing and employment to 2031 and beyond across the GGH was 125,560 hectares.
Given decades of low-density development patterns, suburban municipalities will find they do have a capacity to provide housing and employment within their Built Up Area (BUA) if they undertake an analysis. According to a recent report by professional MGP consultants, approximately 70 per cent of land within both the Built Up Area and Designated Greenfield Area in the GTA is within a low-density designation. And the population and employment densities across the region are generally at or below 50 residents and jobs per hectare, which is on the low end of recommended targets for communities specified in the Growth Plan.
Municipalities should require increased density in these low-built or un-built areas before expanding their boundaries. Appendix 1 at the end of this report provides a summary of the multiple reasons why the housing needs of communities in the GGH can be met within lands already designated for development. So instead of developing in the sensitive farmland and natural areas of the Greenbelt, it is clear that we can, and should, build complete communities (gentle density, people friendly, walkable, jobs close by, climate resilient) inside the boundaries of our existing towns and cities. As for commercial and industrial development, brownfields close to existing infrastructure should be the priority for siting.

Requirement 5: Consult with and recognize interests of Indigenous communities

The Province must meaningfully consult with Indigenous communities about expanding the Greenbelt within their traditional territories. The duty to consult is a constitutional obligation that arises from s.35 of the Constitution Act, 1982, which recognizes and affirms Indigenous and Treaty rights. Indigenous traditional practices, responsibilities and knowledge systems must be honoured by ensuring Indigenous voices are in dialogue on the Greenbelt.

Next Steps for Actions and Decisions in Growing the Greenbelt

Immediate Actions for Greenbelt Expansion:
1. Commit to the continued permanent land use protection of all the lands within the existing Greenbelt area and within the expansion of the Greenbelt.
2. Cancel the planned GTA West (Highway 413) and Bradford Bypass. These highways are expensive, not necessary and will permanently damage existing lands within the Greenbelt while also generating significant pressure by developers and municipalities to allow more development along them. There are many other options, such as public transit and smart growth available to manage the transportation needs of Ontarians that do not require sacrificing vital farmland, natural spaces and water resources.
3. Bring forward Bill 71 (the Paris Galt Moraine Conservation Act, 2019) to provide protection for this important area and in the expansion of the Greenbelt.
4. Release the results (including maps) from the previous 2017 consultations on Greenbelt expansion. This information, including the “Growing the Green & Protecting the Blue” proposal, on March 07, 2018, as summarized in Appendix 2, is a treasure trove of information that can guide future decisions about where to expand the Greenbelt based on science and the views of Ontarians. We must ensure that all identified, significant areas under threat of urban sprawl in the “Bluebelt” maps including the Paris-Galt Moraine, Urban River Valleys, Nottawasaga Watershed, Grand River Watershed, Simcoe County farmlands, moraines wetlands & forests, Lake Simcoe Watershed and Northumberland Iroquois Shoreline are given top consideration in Greenbelt expansion.

Develop Longer Term Expansion Principles:
1. Consult with the public, community groups and farm organizations to get feedback on the criteria to be used and the lands to be considered in Greenbelt expansion.
2. Respect Canada’s constitutional and Treaty obligations to Indigenous peoples and support addressing structural injustices and inequities facing marginalized groups.
3. Use the rich material from previous consultations, such as the Bluebelt proposal to ensure the most significant lands, forests, habitats and waters are in the Greenbelt.
4. Ensure expansion criteria follow science-based agricultural, ecological, hydrological, and conservation-oriented best practices in guiding decision-making processes.
5. Ensure that the economic viability of farming and farmlands as a predominant and productive land use is a fundamental consideration in Greenbelt expansion.
6. Analyze the impact of other government policies on existing and proposed Greenbelt protected lands and develop recommendations to mitigate negative impacts.

Appendix 1
Summary of Facts about Ground Related Housing Supplies in GGH
“Extract from Greater Golden Horseshoe Ground-related Housing Supplies (2018) written by a land use planning consultant and published in the OPPI Journal 33(6)”

• As of Dec 2016, Upwards of 125,000 ha of land in the GGH (308,000 acres) have been approved for urban use to accommodate projected growth to 2031.
• As of Dec 2016, of this only 20 per cent has been used – despite being 40 per cent (10 years) through the Growth Plan’s 25-year planning horizon – reflecting drastically lower land consumption trends than in prior decades (e.g. from 1991-2001 the urban footprint expanded by about 26 per cent to accommodate 1.1 million people whereas between 2001-2011 it only expanded about 9 per cent to accommodate 1 million people).
• About 800,000 ground related units (single detached, semi-detached and row houses – all of which typically have 3 bedrooms and a yard) and hundreds of thousands of apartments were planned on this land supply – with about 500,000 of these in the GTHA. Of these, about 540,000 are single-detached houses.
• As of the end of 2016, only about 288,000 of these ground related housing units had been constructed across the GGH.
• This means there were over 500,000 (half million) ground related units still unbuilt in the planned supply in the GGH.
• These 800,000 units can accommodate about 2.45 million people (using a conservative assumption of 3 persons/unit) or about 83 per cent of all planned population growth to 2031 (excluding the City of Toronto).
• In addition, as of 2006, there were 700,000 single, semi-detached and row houses owned by people 55 or older. Of these, 370,000 were owned by those 65+ - the youngest of which will be 90 years old in 2031 meaning virtually all these units will come to market by that time. Of the remaining 330,000 owned by those 55+, the youngest of those will be 90 in 2041 such that all those houses will come to market as well. Collectively, these units could accommodate at least another 2.1 million people.
• Combined, the planned supply and existing supply of ground related homes that will come to market by 2041 can accommodate about 4.6 million people whereas the total growth projected to 2041 is only 4 million (excluding Toronto).
• The overall mix of ground related vs apartment units will barely experience any shift between 2006 and 2031.

Appendix 2

Summary about Growing the Green --- Protecting the Blue in 2018

Extract from “Growing the Green and Protecting the Blue” report prepared and submitted by the Ontario Greenbelt networks (over 100 groups) to the Ontario government on Greenbelt expansion as part of public consultation for EBR# 013-1661 on March 07, 2018

Permanently protecting farmland, water supplies and air-purifying forests from sprawl, the positive impacts of the Greenbelt will only become more important over time. As our regions continue to grow rapidly, the Greenbelt maintains a healthy, world-class quality of life and prosperous economy. The looming realities of climate change only magnify the Greenbelt’s
importance and underline the urgency to act and expand its reach.

Ontario must protect its significant land and water supplies for our future health.

Many community groups and leaders support growing the Greenbelt to protect critical water supplies—creating “Bluebelt” additions around the existing Greenbelt. This can permanently protect the sources of clean drinking water for over 1.25 million residents as well as supporting agriculture and rural economies and preserving natural heritage.

Areas identified for protection serve highly important functions by acting as ‘rain barrels’ to filter and store precipitation, recharging aquifers and groundwater supplies, providing base flow to rivers and lakes, and protecting communities from flooding and erosion.

The Ontario Government wants to expand the Greenbelt and nine out of ten citizens agree that Growing the Greenbelt will significantly enrich and improve its economic, social and environmental benefits for citizens and communities as follows:

Provides Permanent Protections:

• stops urban encroachment and inappropriate development
• sustains the source of drinking water for millions of residents
• increases community and environmental resilience to negative climate change impacts
such as frequent droughts, hazardous floods and extreme weather events
• sustains pollution-fighting forests and prime agricultural growing soil
• reduces fragmentation and disruption of natural and agricultural systems
• uniformly protects wetlands, streams, seepage areas and springs

Strengthens Local Economies:

• provides increased assurance and certainty for future land-uses, spurring investment in food producing agriculture and the rural landscape economy
• directs investment towards natural capital and green infrastructure as well as significantly reduce the related taxpayer costs of flooding and erosion
• supplies productive farmlands to feed the people living in cities
• protects natural areas that are enjoyed by locals and tourists

Supports Municipal Decisions:

• provides stronger direction to protect and improve water quality/quantity
• supports and reinforces re-directing growth to compact, livable communities
• deters improper land speculation and excessive land use decision appeals
• allows municipalities to have strong policies in support of natural heritage and agricultural
protection, acting as a provincial safety net against opposition

To ensure our prosperous future, many like-minded groups recommended that the Province of Ontario strengthen the Greenbelt and Growth Plans by making the following changes:
• Grow the Greenbelt to protect our vital watershed resources
• Extend protection of the Greenbelt’s agricultural and natural systems to the entire region
• Direct all urban growth over the next 25 years to existing built-up areas
• Create livable communities that support transit, walking, a range of housing types and prices, and of mixed-use neighourhoods within which to live and work
• Consider the impacts of climate change in making decisions.

Growing the Green and Protecting the Blue mapping submitted by these like-minded groups as part of consultation submission for EBR# 013-1661 on March 07, 2018 included the map for reference on the following pages. Blue areas on the map for addition to the Greenbelt Plan are shown in “blue”, and to identify these more specifically, the areas listed below have been identified in Protecting the Blue as key additions to the Greenbelt Plan:

• The remainder of the Lake Simcoe watershed basin
• Significant recharge areas in Severn Sound & Carden Alvar
• Significant recharge areas known as the Waverley Uplands
• Wetlands and Moraine areas of Clearview Township
• The watersheds of the Humber, Don and Rouge Rivers
• The watersheds of Duffins and Carruthers Creeks
• Urban River Valleys and related connecting links
• Iroquois Shoreline area in Northumberland County
• Wetlands of Luther Marsh and Minesing Swamp
• All the watershed of the Nottawasaga River & tributaries
• All of the Waterloo, Galt-Paris and Orangeville Moraines
• Grand River valley lands from its source to outlet

Footnote: Bluebelt-Greenbelt Map 2017 is posted/uploaded in the ERO supporting documents.