I am writing to provide…

I am writing to provide feedback in response to the Ministry of Municipal Affairs and Housing’s Proposed Amendments to the Greenbelt Plan, as posted on the Environmental Registry of Ontario for consultation (ERO number: 019-6216).

I do not support removing lands from the Greenbelt Area and I do not support the proposed amendments to the Greenbelt Plan (ERO 019-6216), or to the Greenbelt Area boundary regulation O. Reg. 59/05 (ERO 019-6217), or to the Proposed redesignation of land under the Oak Ridges Moraine Conservation Plan O. Reg. 140/02 (ERO 019-6218).

While I support efforts to address affordable housing in Ontario, your proposal to remove about 7,400 acres in 15 different areas from the Greenbelt – which was created to protect environmentally sensitive regions from development – is not the way to do it.

The government’s proposal contradicts its previously stated public commitments to protect the Greenbelt and undermines the importance of green space and the impact of climate change.

The Greenbelt protected area must remain protected, it must not be cut, and lands must not be moved.

CURRENT PROPOSAL CONTRADICTS PREVIOUS COMMITMENTS

The current proposals directly contradicts previous government statements on protecting the Greenbelt.

In March 2022, your Ministry held a consultation on growing the size of the Greenbelt (ERO 019-4485), which stated the following key principles:

1. No removal or land exchanges proposed.
2. No policy changes proposed that would reduce existing protections in the Greenbelt.

And in February 2021, when confirming plans to expand the protected area by adding a moraine south of Toronto and a series of urban river lands, you are quoted as saying:

"I want to be clear: we will not in any way entertain any proposals that will move lands in the Greenbelt, or open the Greenbelt lands to any kind of development.”

The Ministry’s news release, Ontario Takes Steps to Grow the Greenbelt, on February 21, 2021, further supports the government’s statements not to develop the Greenbelt:

"The Premier has been steadfast in his commitment to protect the Greenbelt and our government will not consider any proposals to remove or develop any part of it."

PROTECTING THE ENVIRONMENT

The Greenbelt was created to protect agricultural and environmentally sensitive lands in the Greater Golden Horseshoe area from development and it should remain that way. It is vital to the well-being of our province, our environment, and our citizens.

The Greenbelt has a role to play in helping to mitigate climate change as it safeguards the resources that clean our air and water, reduces flood risks, provides a home for wildlife, and it also ensures Ontario communities have greenspace.

The Greenbelt is also an important contributor to the economy.

In 2020, the Greenbelt's agri-food sector generated an estimated $4.1 billion in GDP and close to 59,000 jobs (source: Understanding How Greenbelt Agriculture Feeds the Regional Economy and Greenbelt Farmers).

Wetlands in Ontario’s Greenbelt were estimated to provide $380 million in flood mitigation per year (source: Green Infrastructure in Ontario: Economic Impact Assessment).

And a previous report quantified that the annual value of the ecosystem services provided by the Greenbelt are an estimated $2.6 billion, which would be over $40 billion since the establishment of the Greenbelt (source: Ontario’s wealth Canada’s future: Appreciating the Value of the Greenbelt’s Eco-Services).

Proposing to cut the Greenbelt, add lands elsewhere, or exchanging unprotected land for protected land, threatens the stability of the Greenbelt and the important benefits the Greenbelt provides to Ontarians, the environment, and our economy.

The Greenbelt protected area must remain protected, it must not be cut, and lands must not be moved.

ONTARIO’S HOUSING CRISIS

The housing crisis in Ontario is complex with many causes. While supply is an important factor, it is not the only factor.

Ontario’s affordable housing crisis is not new, but has become more severe, especially over the past few years with home prices up by 44% in 2021 since 2018, according to Generation Squeeze Lab’s Report.

Speculation has been a significant issue with homes increasingly being treated as an investment, like stocks and bonds – instead of as a basic human right to shelter – which have inflated home prices.

It is important to focus on creating affordable housing, which would help stabilize rental markets and ease competition, as well as considering other options, which may include:

- Eliminating the land transfer tax for first-time buyers or increasing the existing rebate;
- Managing unregulated rent increases;
- Implementing progressive property taxation, which would disincentivize property flipping and renting out properties to the highest bidder;
- Stronger restrictions on foreign investment;
- Requiring beneficial owners of real estate to identify themselves to land title authorities, and to make that information transparent and publicly available, to address opaque ownership concerns and other conditions that make real estate markets vulnerable; and
- Identifying appropriate and non-protected land to create new supply while holding developers accountable.

It was also recently reported that Ontario has dedicated 14,000 hectares of land for urban development in municipalities in the Greater Toronto and Hamilton Area, showing that land is already available (CBC News, November 12, 2022).

And it is important to note that the Greenbelt was created to restrict urban sprawl, and the government’s current proposal would create more sprawl. Any new housing should be built where there are existing roads, parks, transit, schools, and not on protected land.

There is no single solution to addressing Ontario’s housing crisis and restoring affordability, but trading off environmental protection and conservation is not the answer.

IN CONCLUSION

The Greenbelt protected area must remain protected – it is vital to the well-being of our province, our environment, and our citizens — and it must not be cut and lands should not be moved. I do not support the proposed amendments to the Greenbelt Plan (ERO 019-6216), or to the Greenbelt Area boundary regulation O. Reg. 59/05 (ERO 019-6217), or to the Proposed redesignation of land under the Oak Ridges Moraine Conservation Plan O. Reg. 140/02 (ERO 019-6218).

Thank you for your consideration,
Concerned Hamilton Resident