I am a permanent resident of…

I am a permanent resident of Ontario and do not agree with the Proposed Amendments to the Greenbelt Plan (ERO #019-6216) as it relates to removing lands from the Greenbelt, based on the following rationale:

1) Ontario’s Greenbelt is a major economic driver, bringing in $9.6 billion annually in food, tourism and recreation. ‘Hacking’ away at the Greenbelt threatens to diminish the long-term benefits the Greenbelt offers for current and future generations of Ontarians.

2) The Greenbelt was being hailed as an international success story. The proposed amendments to the Greenbelt Plan will reflect poorly on Ontario, and demonstrate that this Ontario government (one again) clearly does not take protection of our natural heritage seriously.

3) Doug Ford said he will "maintain the Greenbelt in its entirety" should he be elected as premier. He further stated "The people have spoken — we won't touch the Greenbelt. Very simple. That's it, the people have spoken. I'm going to listen to them. They don't want me to touch the Greenbelt, we won't touch the Greenbelt.". Allowing the proposed amendments would instill further political distrust in the Premier, the PC Party and the Ontario government as a whole. This is imprudent during unsettling times when political disdain / distrust, heightened by COVID, is in the air and rising.

4) Ford is already under scrutiny for his ties and perceived abuse of power to appease land developers that have donated to his political campaign / PC party and own land adjacent to the proposed Highway 413. Now, additional speculation resounding around the proposed amendments to the Greenbelt are amidst. Suspicion has arisen once again about connections between the Ontario government and the land developers that recently purchased land in the Greenbelt prior to the Ontario governments announcement of the proposed Greenbelt amendment. Where did the government actually get the list of proposed properties that they want to remove? How is it that nine of the developers that stand to benefit most from Ford’s Greenbelt land swap also donated significant sums to the Ontario PC Party? Moving forward with the proposed amendments will add injury to insult and further solidly speculation of Ford’s abuse of power and possible corruption.

5) Ontario government proposes to add 13 urban river valleys (URVs) to the Greenbelt. However, some URVs are expansions of urban river valleys that are already in the Greenbelt, and all URVs were already protected from development through other mechanisms. The proposed Greenbelt amendment and land swap is being sold as ‘fool’s gold’ and the Ontario government appears to be trying to ‘pull the wool over the eyes’ of Ontarians.

6) The proposed Greenbelt ‘land swapping’ sets a dangerous precedent for other developers to push to have their lands removed form the Greenbelt and most likely will unleash a deluge of other requests to open up the Greenbelt for development. This will release a hellish and politically-heated ongoing battle between developers, lobbyists, environmentalists, and the Ontario government.

7) The Ontario government’s basis for the proposed Greenbelt amendment is that, the Greenbelt lands are needed for housing due to a housing shortage, which is completely unfounded and untrue. The amount of land already designated for development within existing municipal settlement boundaries far exceeds what is needed to meet long-range housing targets. That includes nearly 90,000 acres within the Greater Toronto Area and Hamilton Area (GTHA) alone. Earlier this year, the Ontario government’s own Housing Affordability Task Force delivered a report that said the same thing: “A shortage of land isn’t the cause of the problem,” it read. “Land is available, both inside the existing built-up areas and on undeveloped land outside greenbelts.” A bigger problem, the report said, is that Ontario hasn’t used the land it has efficiently. That’s why Premier Ford’s government should make it easier to build housing on the close to 90,000 acres across the GTHA that are already designated and ready for development in communities close to existing transit and services.

8) Natural areas are ecologically connected. Connection with what’s around natural areas also define how successful conservation efforts to protect these areas will be. That’s why land on the edges of the Greenbelt is just as important as what’s at the centre

9) The Ontario government considered properties within the Greenbelt as candidate sites for future and near-term housing development against criteria that included:
- Greater than 1:1 offset must be achieved to ensure overall Greenbelt expansion
- The lands are adjacent to existing settlement areas
- The lands are adjacent to the edge of the Greenbelt area boundary
- The lands have the potential ability to be serviced in the near-term with local infrastructure upgrades to be entirely funded by proponents
- The lands proposed for removal have the characteristics that would enable housing to be built in the near-term.
However, was natural heritage value / attributes (habitat quality, rare species, ecological connectivity, biodiversity, SWH, etc.) considered as a criterion when selecting candidate sites? There is question whether the proposed replacement land has equal or greater natural heritage value than the land being removed from the Greenbelt. Has a comprehensive qualitative and quantitative ecological evaluation been undertaken to assess natural heritage features and functions and compared the natural heritage value / attributes of the lands to be removed with the replacement land to see if there would be a net gain or loss in natural heritage value / attributes?

10) In the case of Minotar Holdings Inc. (Plaintiff) v. Ontario Municipal Affairs and Housing (Defendant), 2018 ONSC 4552 (CanLII), the Defendant in, their deliberation, concluded that the that the subject land (owned by the Plaintiff) was of significant environmental value and that the current boundary is consistent with the policy rationale behind the original Greenbelt Area. The court ruled in favour of the Defendant and the subject lands remained as part of the Greenbelt. The lands proposed to be removed from the Greenbelt contain natural heritage features. It’s highly conflicting for this same Ministry of Affairs and Housing under the current Ford Government to now be proposing to remove lands containing potentially significant natural heritage features from the Greenbelt.

11) The lands proposed to be removed from the Greenbelt contain features designated ‘Natural Heritage System’ based on the Greenbelt Plan (2017). The Natural Heritage System policies of the Plan state that new development or site alteration in the Natural Heritage System shall demonstrate that there will be no negative impacts on key natural heritage features or key hydrologic features or their functions. Complete (or close to complete) removal of any key natural heritage features or key hydrologic features that exist within the lands proposed to be removed from the Greenbelt, would constitute a negative impact to these features, which contravenes the Greenbelt Plan policies. Even if the lands are removed from the Greenbelt and no longer subject to the Greenbelt Plan polices, these features would still be protected under the Natural Heritage policies of the Provincial Policy Statement (PPS, 2020). And, again, complete (or close to complete) removal of the features would constitute a negative impact, contravening the natural heritage policies of the PPS.

12) Despite all else, removal of the lands in the Greenbelt and/or areas designated Natural Heritage System on these lands, would be an absolute disgrace and poor choice in the eyes of Ontarians and the younger generations looking on, particularly in the face of climate change and unprecedented loss of species diversity across the world and right here in Ontario.