Dear Minister Clark: I am…

Dear Minister Clark:

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).

The government’s proposal contradicts its previously stated public commitments to protect the Greenbelt; it undermines the importance of green space and the impact of climate change; and it does not solve Ontario’s housing crisis or realistically acknowledge the issues that have led to the crisis.

I acknowledge that the housing crisis in Ontario is complex and needs to be examined from a systems perspective. While available space is an important factor, it is my understanding from the Ontario Housing Affordability Task Force, an expert government panel, that “a shortage of land isn’t the cause of the problem.", especially when 14,000 hectares of non-greenbelt land has already been released for development. Any new housing should be built where there are existing roads, parks, transit, schools, and not on protected Greenbelt land.

I also believe that protecting the integrity of the Greenbelt is an essential strategy for our collective resilience against the impact of climate change. The November 2022 report by the United Nations’ High‑Level Expert Group on the Net Zero Emissions Commitments of Non-State Entities, recommends that "Cities and regions should look to promote compact, dense development that is better able to protect existing nature and build up new and additional natural systems. Examples include: adding transit‑oriented (not car‑oriented) development, avoiding greenfield development, retrofitting old buildings/infrastructure (instead of building new), and establishing protection areas around water resources like wetlands, streams, reservoirs and coastal ecosystems. These actions can serve not only to preserve nature and ecosystems but also to provide climate adaptation and resilience, as well as equity benefits, in urban settings."

We are at a critical moment for humanity. As the climate changes, the safety and prosperity of our cities is put at risk. According to the Climate Atlas, Toronto will experience wetter springs and winters, and modelling suggests that by 2049, Toronto will experience 46 additional days (on top of the current 20) where temperatures exceed 30°C.

The Greenbelt's forests and wetlands have a huge role in helping mitigate climate change from carbon storage, temperature regulation, to the protection from flooding and drought. As outlined in a previous report, Ontario’s wealth Canada’s future: Appreciating the Value of the Greenbelt’s Eco-Services, the annual value of the ecosystem services provided by the Greenbelt is estimated at over $40 billion since the establishment of the Greenbelt. The report goes on to explain:

The Greenbelt’s wetlands and forests hold the greatest value, worth over $2.3 billion. Wetlands are worth an estimated $1.3 billion per year ($14,153/hectare) because of their high value for water regulation, water filtration, flood control, waste treatment, recreation, and wildlife habitat. Forests provide key services worth $989 million each year because of their importance for water filtration services, carbon storage services, habitat for pollinators, wildlife, and recreation. The Greenbelt’s agricultural lands total value is also substantial at an estimated $329 million per year including cropland, idle land, hedgerows, and orchards. Key values include the pollination value of idle land and hedgerows, the storage of carbon in soils, and the cultural value of agricultural lands.

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.