Dear Minister, The Ontario…

Dear Minister,

The Ontario Association of Landscape Architects (OALA) is joining the growing number of professional organizations and other groups concerned about changes to the Greenbelt Plan.

The OALA is the regulatory body whose mission is to promote, improve and advance the profession of landscape architecture and maintain standards of professional practice that serve and protect the public interest. The OALA represents 2,000 professional landscape architects practicing in both public and private sectors across Ontario. We plan and design the public and private realm, including parks, streetscapes, green infrastructure, recreational amenities and manage natural landscapes that support our growing communities.

This letter outlines the following areas of concern for the current proposal to remove protected lands from the Greenbelt Plan:

• scientific criteria & rationale for the land removal identified
• impacts on natural functions and sustainability
• impacts on finite land resources & sprawl

The OALA appreciates and supports advancing legislation and programs that address the current housing crisis in Ontario. However, the Association believes, in the absence of knowing the science behind the Province's proposed changes to the Greenbelt Plan, that removal of areas from the policy area could have significant long term environmental consequences. Without this information and while other housing and development options exist, including urban infill options, we cannot support the proposed changes and loss of land in the protected Greenbelt area.

With the Province’s announcement to selectively remove 15 discrete tracts of land from the Greenbelt Plan is of concern to the OALA. Our organization is voicing its objection to removal of these lands from the Greenbelt Plan in view of the larger public interest and with particular regard for the potential impacts this proposal would have on Ontario’s natural landscapes, systems, and environment, in the absence of a scientific rationale for this initiative.

CONCERN ABOUT SCIENTIFIC CRITERIA & RATIONALE FOR LAND REMOVAL

The Greenbelt Plan has been developed over half a century through a science evidence based consultative process, with the purpose of supporting sustainable development and providing environmental protection to Ontario. We believe the proposed removal of lands from the policy area by the Province should prior to any decision of removal of tracts follow the same science-based consultative and evidence based process.

Recently, the Province has put forward a suite of amendments to legislation that are considered risks to the Greenbelt lands. The cumulative effects of the proposed changes to associated legislation as outlined in Attachment No. 1 to this letter, have the very real potential to reduce the ability of the Greenbelt lands and its systems to perform their intended functions. To our knowledge, this has been done without undertaking the same science evidence-based consultative process.

CONCERN FOR IMPACTS ON NATURAL FUNCTIONS AND SUSTAINABILITY

Ontario’s Natural Heritage is composed of wetlands, forests, valleys, rivers, lakes and farmlands. Its health is reflected in the native biodiversity, features and inter-connected systems that have survived from precolonial eras. History unique to the Ontario landscape including our geologic, cultural and biologic record have created environments found nowhere else in the world. These critical natural systems protect our water systems for the larger Greater Toronto Area (GTA) and Ontario long into the future. The Province has shown its leadership in protecting these valuable natural heritage and water resource assets by instituting the Greenbelt and in establishing regulatory authorities that can act at regional and watershed scales.

Today, Ontarians are confronted with the impacts of climate change and biodiversity loss. It is well known that our natural heritage systems play a key role in nature-based solutions providing benefits such as mitigating and attenuating flood risks by infiltrating and slowing the runoff from more frequent and intense storms. Natural areas improve our mental and physical health. They provide food security by providing habitat for pollinators. Natural areas are filters contributing to our air and water quality. They provide habitat, recreation for people and simple amenities.

The Greenbelt Plan protects land to maintain vital environmental and ecological functions essential to the overall well-being of the Greater Toronto Area (GTA) and southern Ontario. The proposed amendment’s implementation will have long term impacts, consuming agricultural lands, and significant ecological and groundwater resources that cannot be replaced.

The OALA strongly recommends the Province reconsider its current proposal to take land from the established Greenbelt Plan to accommodate greenfield residential development.

CONCERN FOR IMPACTS ON FINITE LAND RESOURCE & SPRAWL

According to Ontario’s Housing Affordability Task Force, “a shortage of land isn’t the cause of the problem … land is available.” The Task Force further advised that “Greenbelts and other environmentally sensitive areas must be protected, and farms provide food and food security. Relying too heavily on undeveloped land would whittle away too much of the already small share of land devoted to agriculture.” Residential development within outlying rural areas exacerbates urban sprawl, with more roads and other necessary infrastructure and facilities.

The Greenbelt Plan's formulation over the last few decades has been based on scientific strategies and criteria for environmental benefits and protection. The integration of the natural environment in our urban areas has been a quintessential cornerstone to good development practices in Ontario. Our growing and redeveloping communities need substantial natural systems to remain healthy and resilient as the frequency and intensity of flood, heat and other extreme weather events increase.

The OALA is concerned about how current policy and planning decisions influence the permanent disposition of our finite land resources. We anticipate that eliminating lands from the Greenbelt Plan will impact the integrity of the essential natural systems that it was planned to protect. It will also reduce the already limited agricultural lands available in closest proximity to Ontario and Canada’s most densely populated areas. Solving the current housing crisis should not be done at the expense of the food security and environmental sustainability of future generations.

Instead, we encourage the government to work with municipalities to develop strategies and strengthen planning frameworks emphasizing creative redevelopment within existing built-up areas. With policies and initiatives leveraging infill development opportunities wherever possible, housing can effectively, quickly and efficiently be provided within communities rather than encouraging development that contributes to types of sprawling development with its associated economic, social, and environmental challenges and costs.

THE PUBLIC INTEREST

As city-builders, we as landscape architects appreciate the importance of managing growth and development. As stewards of the natural environment and our cultural landscapes, we also appreciate the importance of protecting the land, resources, community, and its diverse peoples. It is our hope that amendments to the legislative framework meant to bolster our housing needs will be balanced with the fulsome regard for all the needs of our complex society. While we agree that there is a need for more housing in Ontario, without a science-based justification for removal of lands from the Greenbelt Plan area, we hold the view that the current proposal to remove lands from the Greenbelt Plan is not necessary to address the current housing crisis as other options, potentially less harmful to the land and environment, exist.

We look forward to receiving information from the Province outlining the scientific basis for selecting sites for removal from the Greenbelt Plan. We are proposing to participate in a healthy productive dialogue with your government about how the OALA can assist in moving forward a long-term strategy and agenda for the Greenbelt Plan that maintains and enhances the essential services it provides to the Province.

We look forward to continuing to work with your government and the citizens of Ontario.

Yours truly,
ONTARIO ASSOCIATION OF LANDSCAPE ARCHITECTS

Steve Barnhart OALA, CSLA
OALA President