April 18 2021 The Honourable…

April 18 2021

The Honourable Steve Clark
Minister of Municipal Affairs and Housing 17th Floor, 777 Bay St.
Toronto, ON
M5G 2E5

Re: ERO # 019-3136 - Growing the Greenbelt

Dear Minister Clark:

Thank you for this opportunity to provide input on this consultation.

Thank you also for your government’s statement that you would not consider removals of land from the Greenbelt. I assume this also means that no “swapping” of land currently in the Greenbelt for parcels elsewhere will be considered.

I would respectfully ask that the government consider dropping plans to build a 400 series highway through the Greenbelt which will destroy it as surely as removing land would. The cost of this highway to taxpayers, to the environment, to our agricultural economy and to our ability to meet GHG reductions targets make it simply too destructive to consider. Plans to build the Bradford Bypass, through the Holland Marsh, should also be cancelled for the same reasons.

Question 1: What are your thoughts on the initial focus area of the Study Area of the Paris Galt Moraine?
The Paris Galt Moraine is certainly an area worthy of Greenbelt protection. Further consideration should also be given to including other moraines in the GGH and beyond. Moraines, as stated in the ERO posting, serve many critical functions, including supplying drinking water for many communities. This vital resource deserves protection.

Question 2: What are the considerations in moving from a Study Area to a more defined boundary of the Paris Galt Moraine?

Any boundary decisions must be based on the science that identifies the moraines headwaters and aquifers, and the ecosystems that they support. It must take the effects of climate change into account and it must focus on protecting adequate drinking water supplies.

It is also important to consult with Indigenous communities in a meaningful way and learn from their traditional knowledge of the landscape and environment.

Question 3: What are your thoughts on the initial focus area of adding, expanding and further protecting Urban River Valleys?

Adding more Urban River Valleys to the Greenbelt is a good idea but it should also include areas that are under private ownership. As well, the remaining coldwater creeks in the GGH should be considered for inclusion such as 12 Mile Creek in Niagara Region and 14 Mile Creek in Oakville.

Many of the river valleys connecting the Greenbelt to the lakes are in poor shape and their health is diminishing daily as the areas surrounding them are urbanized. We cannot protect the health of the Great Lakes, which supplies water to millions of Ontario’s citizens, if we don’t protect the streams, creeks and rivers that feed the lakes.

Question 4: Do you have suggestions for other potential areas to grow the Greenbelt?

Aside from adding all moraines and rivers, creeks and streams in the GGH and beyond, southern Ontario’s remaining wetlands need protection. You may believe that wetlands are already adequately protected, however, they are not. I know of PSWs in Niagara Region that have been paved over by municipalities; I have seen that legislation does not specifically protect the water sources for wetlands and therefore does not protect the wetlands when development applications come forward and I have also seen that sufficient buffers are not being applied to protect wetlands from adjacent development.

To protect the rivers, creeks and streams, the headwaters of those areas also deserve protection.

With relatives in Barrie, I have become very familiar with how quickly that area is being developed. We know Lake Simcoe is in trouble and the protection plan that is currently in place has not worked to improve the lake’s water quality. Therefore, I suggest special land use and protection policies need to be considered for the Lake Simcoe basin and Northern Simcoe County.

Remaining fragments of Carolinian forest in Southern Ontario should also be considered for protection. The Carolinian life zone is the most biodiversity-rich area in the entire country but it also under the most severe threat.

I also believe the Province should look at the north shore of Lake Erie. The Bert Miller Nature Club, in conjunction with many other groups and organizations, and with the help of the Province, conducted an inventory of the flora and fauna of the 7E-5 Eco-district in 2010, and documented dozens of rare and threatened species. We know that the kind of areas where two ecosystems meet, such as great lake and shore, are some of the most ecologically rich areas. Almost every inch of the north shore of Niagara Region has been developed and habitat and species richness lost. There is an opportunity to save the remaining habitat, and all the plants and animals it supports, on the south shore, that should not be overlooked.

Finally, I’m aware of the work that was done during consultation on the “Bluebelt” in 2018 and support including the former Glacial Lake Algonquin and Iroquois Shorelines Plain that are not already included in the Greenbelt.

Question 5: How should we balance or prioritize any potential Greenbelt expansion with the other provincial priorities mentioned above?

Southern Ontario’s communities need to grow and develop, however, that growth should mostly be contained within existing urban boundaries. Every community has acres of low-rise commercial sprawl along major transportation routes that could be redeveloped into vibrant mixed-use communities. Almost every community has brownfields waiting for remediation and redevelopment. Most communities have downtowns that are in need of revitalization and sensitive redevelopment that preserves heritage features while accommodating new growth. Many existing low-density residential areas could tolerate gentle densification. Also, we don’t know what the long-term impacts of the pandemic may be. We may have many commercial areas and high-rise office buildings that will no longer be needed as more people continue to work from home. These buildings may be able to be converted to residential uses or redeveloped.

As well, we are facing a climate crisis and the Province has GHG reduction goals to meet. One of the best tools the Province has to meet those goals is sound urban planning. Expanding urban development across natural areas and agricultural lands will make it impossible to meet those goals. Covering greenfields with acres of roads, pavement and impermeable surfaces will only worsen the effects of global warming.

Also, allowing continuing residential sprawl will impoverish municipalities over time as taxes from residential development, without commensurate, higher-taxed industrial and commercial development, cannot pay for the services and infrastructure residents require on an ongoing basis.
Southern Ontario’s communities need to grow and develop, but they cannot continue to do so by threatening Ontario’s agricultural economy which contributes $13.7 billion to Ontario’s annual GDP. By not focusing growth within existing urban boundaries, the agricultural industry is damaged in many ways. First, speculation on greenfields by developers is driving the price of agricultural land beyond what farmers can afford. Second, when enough as farmland is lost is lost in an area, the ancillary businesses that support farmers, such as seed stores and farming equipment sales and service, disappear. As well, there are increasing conflicts between residents and normal agricultural practices whether it is moving equipment between fields, use of pesticides or manure spraying. Niagara is almost entirely Class 1 and Class 2 agricultural land and much of it is specialty crop area — in other words, the very best farmland in the country and we are paving it over at an incredible rate. This cannot continue.

We have seen how global supply lines can be disrupted during this pandemic. We know world food supplies will only become more imperiled by the impacts of Global Warming. We need to protect Ontario’s food supply.

This government should do what it can to protect our prime agricultural lands by inclusion in the Greenbelt or by creating an Agricultural Land Protection Plan and by committing to hard urban boundaries around our Urban Areas.

Finally, the Province should refrain from using MZOs which circumvent sound planning policies.
In conclusion, the Province should prioritize Greenbelt expansion and agricultural land protection and support growth within existing urban boundaries.

Question 6: Are there other priorities that should be considered?

As mentioned above: developing an agricultural land policy.

Developing a real plan to mitigate the impacts of Climate change through protecting the green infrastructure that already exists, that enhances those areas and that encourages the creation of green infrastructure.

To consider the health and wellbeing of citizens when enacting planning policies. People need nature. People need greenspaces — if COVID has taught us anything, it has taught us that.

All Provincial policy should regard the natural environment, not a barrier to overcome, but as a precious commodity to be retained to protect our economy, our health, our drinking water and our biodiversity now and for future generations.