Please find attached…

Please find attached comments from the City of Toronto re: ERO 019-7739.

Toronto's Planning and Housing Committee adopted this Report on November 30, 2023. This will be presented to City Council on December 13, 2023 for their consideration. City Clerk will forward Council's decision following that meeting.

SUMMARY
As the region continues to experience high population growth and a growing housing affordability crisis, effective regional planning must prioritize infill development and intensification within settlement boundaries. Protection of the Greenbelt, coupled with land use planning that prioritizes compact form, complete communities, and better use of existing and planned infrastructure is a key strategy to address the dual crisis of biodiversity loss and climate change.

The Province is consulting on a proposal, posted on the Environmental Registry and presented to the Legislature in Bill 136 that includes two key elements:

• to restore 15 parcels of land, which were removed from the Greenbelt in December 2022 (City Council had previously adopted a Staff Report in October 2023 that supported the return of these 15 parcels of land to the Greenbelt in addition to the Province's proposal at that time to return of one parcel in Ajax); and
• to define the Greenbelt Plan Area boundaries directly into the Greenbelt Act.

A permanent Greenbelt supports the foundation for the long-term ecological integrity of the region's natural systems. A robust regional natural system supports Toronto's biodiversity and increases our resilience to the impacts of climate change. Consistent Greenbelt policies and land use certainty enables the agri-food sector to make long term agricultural investments and reduce speculation across a land base that includes the most productive agricultural land in the country. The City of Toronto has long supported the permanent protection of the Greenbelt, and regional planning policies that reduce the impacts of urban sprawl.

This report discusses the Province’s reversal on their previous decision to amend the Greenbelt Plan Area boundary to remove or redesignate 15 parcels of land totaling 2,995 hectares (7,400 acres) and outlines staff comments and recommendations related to the Province’s current consultation on their “Proposal to return lands to the Greenbelt – Greenbelt Statute Law Amendment Act, 2023” posted on the Environmental Registry of Ontario.

The comment period for this consultation is open from October 16 to November 30, 2023.

COMMENTS
The following comments are in response to the Province’s proposal to restore 15 parcels of land to the Greenbelt, previously removed in December 2022. This proposal has been presented to the Legislature through Bill 136 and has been posted on the Environmental Registry of Ontario (ERO) for comments from October 16 to November 30, 2023 (ERO 019-7739).

City Planning staff support the Province’s proposal to return lands to the Greenbelt and to update: the Greenbelt Act, 2005; Oak Ridges Moraine Conservation Act, 2001; and the Duffins Rouge Agricultural Preservation Act, 2023 as outlined in Bill 136 and the ERO posting.

City Council had twice noted their opposition to the removal of the land from the Greenbelt through Amendment 3, made in December 2022. City Council’s position was made clear in a motion made on November 24, 2022 (quoted below), and re-stated in Comments submitted to the now closed ERO posting proposing the return of one parcel of land in Ajax to the Greenbelt (Item PH6.5):

"City Council request the Province of Ontario to rescind the proposed changes to the Greenbelt to protect environmental features that support biodiversity, natural spaces, recreation trails, agricultural land, and watersheds that sustain all residents of the Greater Toronto and Hamilton Area." (Item CC1.2)

Scope of Proposed Changes in the Province's Current Proposal
The current Provincial proposal will: 1) reinstate 15 total parcels of land to the Greenbelt Plan Area; and 2) define the boundaries of the Greenbelt’s boundary directly in the Greenbelt Act.

The re-introduction of 15 parcels to the Greenbelt and Oak Ridges Moraine will restore the 2,995 hectares (7,400 acres) of land removed/redesignated in December 2022 through Amendment 3 to the Greenbelt Act, while maintaining the lands that were added at that time to the Greenbelt.

Defining the Greenbelt’s boundaries directly within the Greenbelt Act, ensures any future removals or additions of Greenbelt Plan Area would require the approval of the Ontario Legislature. This is a change from the existing policy where the Greenbelt area boundaries are defined in regulation (O. Reg. 59/05). The existing regulation can be amended by a Cabinet decision, as was the case with Amendment 3 of the Greenbelt Act. This change to formalize the boundaries directly in the Act creates the opportunity for a more transparent process if any future Greenbelt area changes are considered.

The Province’s proposal will include all boundary changes made to the Greenbelt, prior to the December 2022 removals. This includes the addition of Toronto’s Urban River Valleys that were brought into the Greenbelt Plan Area in May 2017. There are no changes considered in the Province's proposal that would negatively impact the land use of the Urban River Valleys in Toronto or broader Greenbelt.
Toronto's Ongoing Support for a Permanent Greenbelt
For more than two decades, the City of Toronto has supported a regional planning approach that minimizes the environmental and social impacts related to urban sprawl. This support included advocacy related to the creation and maintenance of permanent protection for the Oak Ridges Moraine and Greenbelt. A permanent Greenbelt supports the foundation for the long-term ecological integrity of the region's natural systems. A robust regional natural system supports Toronto's biodiversity and increases our resilience to the impacts of climate change.

As outlined in the Official Plan, the City of Toronto is committed to work with neighbouring municipalities, conservation authorities and the Province to address mutual challenges and implement the Provincial framework for dealing with growth across the GTA which “protects, enhances and restores the region's system of green spaces, water resources, natural heritage features and functions, and the natural corridors that connect them" (OP 2.1.1 k).

Consistent Greenbelt policies and land use certainty enable the agri-food sector to make long term agricultural investments and reduce speculation across a land base that includes the most productive agricultural land in the country.

Potential Future Greenbelt Review
In his September 6, 2023 letter to the City Clerk, the Minister of Municipal Affairs and Housing noted his Ministry is working to prepare a review of the Greenbelt, this was also alluded to in public comments following the release of Bill 136.

City Planning does not believe any future review of the Greenbelt should consider the Greenbelt Plan Area’s ability to accommodate growth. This premise runs counter to the vision and goals of the Greenbelt, including to: “protect against the loss and fragmentation of the agricultural land base”; and give “permanent protection to the natural heritage and water resource systems that sustain ecological and human health”.

Staff are of the opinion that the Greenbelt Plan Area should remain protected and does not need to be examined at this time for its potential to accommodate anticipated growth. The Province’s 2022 Housing Task Force reinforced the position that a “shortage of land isn’t the cause of the [housing affordability] problem”, and that there is enough land within municipal boundaries to achieve the Province’s goal of building 1.5 million homes in ten years (Housing Affordability Task Force Report, 2022). The Task Force supported the ongoing protection of the Greenbelt, environmentally sensitive areas and farmland, noting they “must be protected” (Housing Affordability Task Force Report, 2022).

As the region continues to experience high population growth and a growing housing affordability crisis, effective regional planning must prioritize infill development and intensification within settlement boundaries. A focus on efficient use of land and resources, achieved through infill and intensification, reduce the financial strain on municipalities related to outward expansion of infrastructure to support growth. Land use planning, infrastructure investment and community services need to be closely aligned to ensure the needs of the region's growing population will be met, while reducing the financial and environmental costs related to urban sprawl.

Conclusion
The consultation period for this policy proposal, as posted on the Environmental Registry closes on November 30, 2023. For the City’s comments to be included within that consolidation period an interim response will need to be submitted immediately following the November 30, 2023 meeting of Planning and Housing Committee. A supplementary report will be sent to the Province following the December City Council meeting, including any further comments following Council's consideration.