Re: ERO # 019-3136…

Re: ERO # 019-3136 Consultation on Growing the Greenbelt

Thank you for the much-needed pledge to grow the Greenbelt and thank you for the opportunity to comment on Growing the Greenbelt. The proposed inclusion of the Paris Galt Moraine and public lands within urban river valleys is a welcome start, however much more is needed. To make up for lost time and the many destructive decisions that have been made we must now ambitiously protect precious farmland, wetlands, woodlands, and wildlife habitat. The Greenbelt needs to move north to Simcoe County and encompass central, eastern and western Ontario, in order to build resilience to climate change impacts like flooding and drought.

I have read and endorse the comments submitted to the Environmental Registry of Ontario from Ontario Farmland Trust, Ontario Nature, The Ontario Headwaters Institute, Rescue Lake Simcoe Coalition and Simcoe County Greenbelt Coalition regarding the ERO proposal 019-3136, Consultation on Growing the Greenbelt.

Ontario’s farmland is a finite and non-renewable resource, and it is the foundation of one of the province’s largest economic sectors, the agri-food sector. The agri-food sector annually contributes over $47 billion to the GDP and employs more than 837,000 Ontarians along the supply chain. Despite being an integral part of the provincial economy, farmland continues to be lost at an alarming rate due to non-agricultural development occurring on farmland. This development negatively impacts the long-term viability of the agri-food sector, and jeopardizes the sustainability of the provincial Agricultural System.

Recently, through changes to provincial plans such as the Provincial Policy Statement (PPS), the Province has demonstrated their interest in Ontario’s agricultural sector by expanding the emphasis on the Agricultural System. The Agricultural System helps to promote a contiguous agricultural land base which prevents land fragmentation and protects Ontario’s finite supply of farmland. Expanding the Greenbelt and protecting nature, water and farmland from development supports all provincial priorities given that they are the foundation of social and economic well-being. Without this extension, the long-term regional resilience is expected to decline, including terrestrial and aquatic habitat, water quality, the viability of farming, and the rural economy. In order to restore balance in the region and support well-being and prosperity, we encourage the province to grow the Greenbelt.

The Greenbelt was created to enhance the protections for farmland and natural resources outlined in provincial land use planning policies in an area of the province that was facing extremely high development pressures. Development pressures have continued to grow across the province, and farmland and natural resources outside of the current Greenbelt area are being lost at an alarming rate. Expanding the Greenbelt will provide additional protections for farmland and natural resources in areas where it is most at-risk, and help enhance the long-term viability of Ontario’s agricultural sector.

The expansion of the Greenbelt will complement the newly expanded emphasis on the Agricultural System, and will help protect the long-term viability of the provincial agri-food sector.

The following are some recommendations for the expansion of the Greenbelt that would be beneficial to Ontario’s farmlands and agricultural sector:

1. That the Agricultural System that has been identified and mapped in the GGH be included in the expansion of the Greenbelt in its entirety. The Agricultural System that has been mapped in the GGH contains some of the most at-risk farmland in the province, which would benefit from the additional protections of the Greenbelt. As recognized in the Agricultural Systems planning approach, farmlands must maintain a critical mass and a level of connectivity to maintain their economic capability as agricultural lands. If the Greenbelt is not expanded using this strategy, development will create isolated pockets of farmland on which farming will not be economically viable. The expansion must not create developmental patterns that will lead to farmland loss.

2. That farmers and farmland owners are consulted during the expansion of the Greenbelt. As direct stakeholders, input should be gathered from both farmers and farmland owners in Ontario. Consulting these groups will result in an effective and realistic strategy to expand the Greenbelt that will aid in the continuation of agriculture into the future.

3. Cancel plans to build Highway 413 (GTA West) and the Bradford Bypass (Holland Marsh Highway). These highways are expensive, not necessary and will permanently damage existing farmlands within the Greenbelt while also generating significant pressure by developers and municipalities to allow development along them. There are many other options available to manage the transportation needs of Ontarians that do not require sacrificing vital farmland, natural spaces and water resources.

4. Municipalities should be encouraged to establish policies that go beyond the minimum standard set by the Greenbelt Plan. Policies that provide the highest level of protection for natural and hydrological features and farmland should prevail. There is great concern, for example, that municipalities within the Greenbelt are not able to establish policies that are more restrictive on mineral aggregate extraction than the policies contained within the Greenbelt Plan, even though, outside the Greenbelt, other GGH municipalities are able to establish policies that may be more restrictive on mineral aggregate extraction than the Growth Plan’s policies. This is an odd and troubling situation where municipalities are not allowed to go above and beyond Greenbelt policies to protect precious water resources.

5. Refrain from using Minister’s Zoning Orders (MZOs) to fast-track development on natural areas and farmland. Conservation and agricultural organizations are united in their opposition to this misuse of MZOs which sidestep community consultation and local planning processes. At risk are the many benefits provided by Ontario’s farmland and natural heritage features and areas, including flood control, local food, water purification, carbon sequestration, biodiversity conservation, recreational opportunities and more.

I want to note the government’s stated intent not to consider the removal of any lands from the Greenbelt during this expansion exercise. For years, developers and land speculators have been asking the provincial government to change the Greenbelt boundary to remove their land from Greenbelt protection. In some cases, they suggest that other lands elsewhere be reclassified as Greenbelt lands so that the total Greenbelt area is maintained. This would set an irreversible, dangerous precedent and make farmland less affordable. If it were to happen, the Greenbelt would cease to be a meaningful, permanent protection mechanism. Regional governments are busy calculating land needs to 2051. As evident by the Region of York’s report to Council on land needs and growth forecasts no expansions into the Greenbelt are required to 2051, but settlement boundary expansions will pave over valuable and finite class 1 farmland. As York Region has the highest allocation of employment and population growth in the GTHA, this finding is likely indicative of what other Region’s will experience.

The Greenbelt expansion provides an opportunity for Ontario to become a leader in farmland conservation in Canada. Ontario has some of the best agricultural land in Canada, much of which is not protected by current land-use planning policies. In comparison, other provinces like British Columbia have established themselves as leaders in farmland conservation by protecting over 11 million acres of land suitable for agriculture. This is significantly more farmland than what is protected by the current Greenbelt in Ontario. By significantly expanding the Greenbelt boundaries to include more of Ontario’s agricultural land, the Province can make a bold commitment to Ontario’s farmland and the future of Ontario’s agricultural sector.

Additionally, by protecting Ontario’s agricultural land for agriculture it is being made more accessible for future generations of farmers. Ontario is currently facing a farmland succession crisis wherein young farmers seeking to enter the industry are not able to access land because they are not able to afford the prices competing developers and land speculators are able to pay. Protecting farmland for agriculture will ensure that the land remains accessible for Ontario’s farmers now and in the future.