I am an Ontario citizen and…

I am an Ontario citizen and a voter. I strongly oppose the changes being proposed to the Greenbelt Act 2005, described in ERO proposal #019-6216, as part of the Bill 23 suite of legislation changes.
I strongly oppose all removals of land from the Greenbelt Plan area, regardless of whether other lands are added to the Greenbelt Plan area elsewhere. This proposal is wrong for a variety of reasons.
The Ontario government’s stated rationale for this proposal is based on the mis-guided premise that building more homes will somehow address Ontario’s housing affordability crisis. It will not. There is nothing in this proposal or in Bill 23 that addresses housing affordability – to the contrary, under Bill 23 housing will become even more expensive to build and to own for new home buyers. Under Bill 23 housing will also become more expensive for current homeowners through the massive municipal tax increases that will be needed to pay for Bill 23 actions. Housing volume does not equal affordability. Building more sprawl homes will not solve the affordability crisis.
And even if the government is convinced that it needs to build more homes, there is currently plenty of greenfield land that is not in the Greenbelt that is already approved for residential development, standing ready for development immediately. There is enough of this greenfield land for at least the next 20 years of building. This land is cheaper to develop because it is close to existing municipal infrastructure and the transit network. Thus, there would be lower infrastructure costs to developers which could be passed along to home buyers (with the resulting possibility of slightly reducing affordability). The bottom line is that the Greenbelt land is not needed to build the homes being proposed under Bill 23. There is no reason to dip into the Greenbelt and no real justification for these proposed Greenbelt Act changes (unless one counts the Premier’s need to provide profits for his developer friends who bankrolled the Conservative election campaign, as justification).
This proposal to “swap lands” goes against the core purpose of the Greenbelt. The stated purpose of the Greenbelt is to protect a continuous, unfragmented belt of natural and agricultural lands around the urbanized Greater Golden Horseshoe. This Greenbelt sustains agricultural production of food for residents of the GGH on high quality agricultural lands and it also protects water quality (including drinking water) and quantity by protecting headwaters and groundwater aquifers that GGH residents rely on. The Greenbelt lands work wholistically as a functional unit. But this proposal intends to start fragmenting the Greenbelt, pulling patches out and adding other patches haphazardly based on convenience (read “convenience” as the holdings of developers who have speculated that this legislation will open up the Greenbelt for development) and not on sound ecology. Fragmented systems suffer irreparable damage to their functions. All pieces of land are not equal. It’s not OK to swap out one piece for another when you are relying on lands to provide significant ecosystem services. There is a logical inconsistency here – one the one hand, this proposal suggests that one piece of Greenbelt land can be swapped out for another piece elsewhere; likewise, it should be OK to build the homes this government feels are needed on the existing approved lands that are not in the Greenbelt, instead of building on Greenbelt lands.
Mr. Ford lied about the Greenbelt. At least twice. All of Ontario was witness to the lie. He adamantly claimed he “would not touch the Greenbelt”. Ontarians were relieved when Mr. Ford told them that he wouldn’t touch the Greenbelt. They were relieved because they care about protection of the Greenbelt and of their environment. Lying is shameful – shame on Mr. Ford. It
is a travesty for a government to have to lie like this to its citizens so they can get into power and carry out their hidden agenda of personal profiteering. If the actions proposed in these changes to the Greenbelt Plan were really in the best interests of and agreeable to all Ontarians, then the government would not need to lie about them. Given this government’s lie about touching the Greenbelt, none of the claims and “impact analysis” in this proposal can be believed. There is no basis for trust about anything in this proposal. When the government says it will add other lands to the Greenbelt (the “land swap”) to compensate, that cannot be trusted. The government attempts to rationalize their change in position on Greenbelt lands by claiming that a “housing crisis” has suddenly come up but the housing crisis existed during the last provincial election when Mr. Ford made his promise not to touch the Greenbelt, so that excuse holds little water. Moreover, the existence of plenty of building-ready lands that are not in the Greenbelt also refutes the government’s claim.

While I oppose the Greenbelt Act changes proposed here on the four higher principles mentioned above, I also find several details (or lack thereof) problematic, if the proposed changes to the legislation go forward. These details are as follows:
If lands are removed from the Greenbelt, the proposed changes only state that development must be started by 2025. Given all the other draconian measures to speed up the permitting process under Bill 23 it is astonishing that it would still take two years before building could be started! With “barriers” all removed, why would building still lag so much? Instead of providing a “start” timeframe for building, it would be more effective to give a completion date. Developers are quite capable of back-calculating when they need to start from their completion target.
Similarly, “start development” needs to be defined. There is nothing in this proposal to prevent developers from doing the most minimal “start” and then delaying further development for years, waiting for sprawl to creep out from settlements (because these “removal” parcels are not adjacent to urban areas with existing infrastructure) that would build infrastructure. Since under the proposal, the developer is responsible for paying upfront for all infrastructure required to serve their new subdivisions, waiting for other developments to gradually build out infrastructure would provide large cost savings to developers of Greenbelt parcels. Thus, to keep development on Greenbelt-removal parcels speeding along, it would be best to define what a “start” is and more importantly, to provide a timely completion date in keeping with the pace of development this government wants to see.
A timeframe for the addition of lands on the Paris Galt moraine to the Greenbelt Plan needs to be established. These lands were already promised as additions to the Greenbelt a year ago yet that promise is still outstanding. The Greenbelt Act states that the Greenbelt must not be allowed to diminish in size, addition of lands should occur at exactly the same time as (or earlier than) removals.
The government claim, that it is going above and beyond by adding more land to the Greenbelt than it is removing, is window-dressing. The “extra” Urban River Valley lands it is proposing to add to the Greenbelt is insignificant because the river valleys are already
protected from development as hazard land. Inclusion in the Greenbelt confers no additional protection. Instead, the government proposal is simply replacing what it is removing, on an approximately 1:1 ratio. By normal off-setting standards, a 1:1 ratio is inadequate. Replacement lands should be significantly higher that 1:1.
This proposal to remove lands from the Greenbelt Plan area, especially when there is plenty of existing developable land making the removals unnecessary, is an attack on the values of Ontarians. The Greenbelt exists to protect agricultural and natural lands so they can provide a healthy environment and place for us to live. Ontarians value our healthy environment and have strong environmental ethics. It is an affront to Ontarians that Mr. Ford and his government have lied to us about their plans for the Greenbelt.
The proposed removal of lands from the Greenbelt should be scrapped – use other existing buildable lands instead. And make good on the Government’s earlier promise to add the Paris Galt moraine lands to the Greenbelt with no strings attached (i.e. without being a compensation for removed lands).

Regards.
3 Dec. 2022