The study area in focus must…

The study area in focus must be expanded beyond the Paris Galt Moraine to include all hydrological and ecological features (natural heritage, water resource or agricultural systems) that are adjacent or vitally connected to systems within the Greater Golden Horseshoe (GGH) and established Greenbelt.

In particular, it needs to include Paris-Galt moraine lands which are found within the Clair-Maltby secondary plan area.

As expanding the Greenbelt west will support Groundwater communities, the policies for this area need to reflect that regional priority. The quality of protection must also be addressed through policy review; the greatest protection must apply in implementation guidance. As a result of dependence on groundwater, some municipalities have adopted stronger protection policies. Policies that provide the highest level of protection for natural and hydrological features and farmland should prevail.

DISCUSSION QUESTIONS

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 an ideal area to expand Greenbelt protections. To protect this water system, including headwaters and all hydrological features means securing a water source for at least 800,000 people. The Province must be more ambitious in its approach to expanding the Greenbelt if it intends to protect precious farmland and natural areas from development and safeguard the countless benefits that they provide. I urge the province to expand the area of study West and include all adjacent areas and important parts of larger ecological systems (i.e. agricultural systems, wildlife corridors, headwaters, etc.). Protecting the entirety of the system, means looking beyond political boundaries. A scientific approach demands all natural systems adjacent or vitally connected to the Greenbelt need to be protected, including but not limited to;

• Orangeville Moraine
• Grand River Watershed, including land contiguous with Greenbelt in Brant
• Waterloo Moraine
• Escarpment Area Moraines such as the Gibraltar and Singhampton Moraines
• The Horseshoe Moraines that flank the Niagara Escarpment to the north near Clearview
• Former glacial lake Algonquin and Iroquois shorelines and plain
• Lake Simcoe Basin
• Headwaters of south flowing stream systems within the inner ring of the GGH (the ‘Whitebelt’) where there are high development pressures (i.e. Humber, Don, and Rouge Rivers and Duffins and Carruthers Creeks)

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

An important consideration is engagement with Indigenous communities to fulfill constitutional and treaty obligations. The duty to consult is a constitutional obligation that arises from s.35 of the Constitution Act, 1982, which recognizes and affirms Indigenous and Treaty rights. Indigenous traditional practices, responsibilities and knowledge systems must be honoured by ensuring Indigenous voices are key to any discussions involving expanding the Greenbelt.

A scientific and evidence-based approach must be used to identify and protect all key significant hydrological and ecological features. Continuity and contiguity in water system mapping that recognizes groundwater dependencies by nearby municipalities (e.g. City of Guelph and Region of Waterloo) on Paris-Galt Moraine water recharge capacities should drive boundary-setting approach by the Ministry. The recent staff report by the Grand River Conservation Authority (GRCA) on the Greenbelt proposal included evidence of the water recharge dependencies by local Urban River Valleys (URV) on the Paris-Galt Moraine. Further, the Paris-Galt Moraine study area currently does not extend West of the Grand River. This is contrary to the 2009 Blackport Report commissioned by the Ministry of Environment, Climate and Parks that demonstrates significant moraine formations or smaller lobes extending into Norfolk County. A scientific and ecosystems approach recognizes the importance of connecting the Paris Galt Moraine to Norfolk county including URVs to connect to Lake Erie’s coastal system.

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

Urban River Valleys (URVs) are an established means of connecting residents in the Greater Toronto Area to Greenbelt. Expanding the designation of URVs could be a way of connecting communities dependent on groundwater to the headwaters that recharge their drinking source. I suggest that URVs be further protected by ensuring that the Greenbelt includes headwater areas and establishing direct connections with downstream urban communities. It is recommended that the expansion of URVs incorporate connections to the Paris Galt Moraine through the Speed and Eramosa Rivers in urban areas. Further, I recommended that the Province add the following as Urban River Valleys;

• Lake Simcoe recharge areas including the Severn Sound and Carden Alvar, Waverly Upland, Clearview Township, Holland River
• Lake Iroquois shoreline areas
• The Nottawasaga watershed.

I urge the government to expand this protection area as this will support green infrastructure like wetlands, floodplains, and riparian edge - key ecological features to preventing downstream areas from flooding and erosion. These features protect habitat and promote biodiversity and they provide healthy outdoor recreation and support the regional trail system.

Generally, the focus on Urban River Valleys is too limiting. Expanded protections should include the Grand River and its tributaries. The Grand River Valley is the largest river watershed in southern Ontario and has been designated as a Heritage River. Riverway lands are important to put into public ownership or be included in Greenbelt designation as a way of protecting access to the rivers and tributaries. Also protecting these waterway lands help preserve wildlife corridors.

Question 4: Do you have suggestions for other potential areas to grow the Greenbelt?
An expanded Greenbelt needs to include the Clair-Maltby region with Guelph’s built boundary. I have long held a deep-seated concern and alarm that we have even been contemplating sprawling onto such a sensitive area. And even as someone who has been following and engaging on this issue for years, I don’t think I fully appreciated how far Guelph’s development is set to penetrate into the Paris-Galt. It’s truly startling.
Professional planners are required by their Code of Practice To respect and integrate the needs of future generations. Members recognize that their work has cumulative and long-term implications.
When addressing short term needs, members acknowledge the future needs of people, other species and their environments, and are to avoid committing resources that are irretrievable or irreplaceable.
In the context of global heating and a looming mass extinction, fresh water will become one of those resources that is irretrievable or irreplaceable. Only 3% of the water on the planet is fresh water, and 5/6th of that is inaccessible because it’s underground, frozen or polluted. If I had earth’s water delivered to in 5 water cooler jugs, there would just be 2 cups that you could actually drink.
Studies of Clair-Maltby have told us The topography, soils and surficial geology currently determine how the area drains.
All that will permanently change once it’s graded for development. Then add paving, oil, chemicals and pet feces into the mix. All the disturbances we humans usually bring. City of Guelph reports acknowledge the negative impact on groundwater from development of Clair-Maltby, but claim that it’s not relevant because the Mill Creek watershed is not currently tapped for water for Guelph.
Project 11 in Guelph’s Water Supply Master Plan anticipates a future well within the Mill Creek watershed. We need to be taking a 1,000-year plan to protect water, not just a 25-40-year plan.

https://guelph.ca/wp-content/uploads/2014-Water-Supply-Master-Plan-Upda…
Developing Clair-Maltby is a want, not a need. Guelph has significant land assets within our built boundary which have yet to be developed: the Innovation District, IMICO, Downtown and possibly Dolime. We’re also looking at accessory dwellings in backyards and re-development of plazas.
Guelph Staff wrote in the Parkview hotel report: The proposed development represents a compact form of development…within the city’s settlement area that will allow the efficient use of land, infrastructure and public service facilities where infrastructure is already available and transit is available,
In contrast, Clair-Maltby is going to cost taxpayers a fortune because there is no infrastructure readily available.
To use the homeowner analogy, why are we building an extension on our house while we have 3 empty bedrooms?
Back in 2014 a consortium of Clair-Maltby landowners took the City of Guelph to the OMB to oppose the prioritization of the Innovation District. .
Darrin Drake, head of the Guelph and District Homebuilders Association at the time was quoted in the Guelph Mercury: It is his understanding that the city does not intend to expand development south of Clair for at least another 15 years. That will have a direct financial impact on landowners.
"It increases the costs of carrying the land," Drake said. "It stalls their projected builds. A lot of the companies have projected their business growth based on this official plan and what is going to be moving forward on certain dates. Then for it to get sidelined and put off for 15 or 16 years is going to throw all of their projected finances into the wind.
I urge the Province to undertake studies and consultations adding areas in the Greater Golden Horseshoe Natural Heritage System, areas in the Bluebelt map, and any other headwater areas not captured in that mapping to the Greenbelt.
It is important to include Natural Heritage System features throughout the GGH, both adjacent and systemically connected to the Greenbelt. This will be integral to sustaining the water resource system including groundwater water quality and quantity, and;

• Providing clean air, water storage and filtration
• Building resilience to climate change
• Nourishing rural communities
• Preventing invasive species, flooding, and soil erosion
• Conservation and biodiversity recovery
• Downstream communities and economic activities
• Supporting and securing agricultural and agri-food sector
• Enhancing community well-being through access to recreation, local-base tourism

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

Expanding the Greenbelt will support many provincial priorities such as Ontario’s Biodiversity Strategy, Ontario’s Wetland Conservation Strategy and Ontario’s Great Lakes Strategy. Nature, water, and farmland are the foundation of social and economic well-being. Protecting these natural assets is the only way of achieving all other provincial priorities. Expansion will enable our region to achieve Sustainable Development Goals and secure our communities vital natural systems. The protection of natural and water resource systems and farmland must take priority. They are finite, irreplaceable, and invaluable in terms of community and ecosystem health and resilience to climate change. Growing the Greenbelt is the next step in ensuring that the balance between development and natural heritage is achieved.

Infrastructure to support housing needs of communities in the GGH can be met within lands already designated for development. Aside from Toronto and Peel, growth in all other municipalities has been less than projected and there are existing large surpluses of land available for development. The Neptis Foundation estimated in 2017 that the total supply of unbuilt land to accommodate housing and employment to 2031 and beyond across the GGH is 125,560 hectares. Instead of developing in the sensitive farmland and natural areas, I urge the province to build complete communities (gentle density, people friendly, walkable, jobs close by, climate resilient) inside the boundaries of our existing towns and cities. Brownfields close to existing infrastructure should be the priority for siting for commercial and industrial development.

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

I urge the Province to consider meaningful consultation with affected Indigenous peoples, treaty rights and duty to consult as a central priority. This requirement is clearly outlined in the 1701 Nanfan Treaty, 1784 Haldimand Treaty and the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP) for which Free Prior Informed Consent (FPIC) are required by the Crown for all activities past, present and future that have, are or may be impacting lands within these treaty land entitlement/claim areas. While the federal Crown has attempted to delegate consultation to provincial and municipal levels of settler governments, full, deep, and meaningful consultation must be fulfilled, as so confirmed by numerous Supreme Court Decisions and International Conventions. Any matter pertaining to activities, policies or land planning negotiations within the 1784 Haldimand Deed Lands fall under the purview of the Six Nations of the Grand River Elected Council's (SNGREC) Lands Research and Consultation Dept. There is also the Haudenosaunee Confederacy of Chiefs that assert jurisdiction for matters pertaining to outstanding land claims. Further there is the Grand River Notification Agreement, for which Six Nations was an active participant. Through the Provincial Places to Grow policy, expansion of housing projects on lands identified in land claims, triggered land protests in Caledonia. The Paris-Galt Moraine sits with an active land claim of the Six Nations. See details of BLOCK ONE, North and South Dumfries Township as well as Parts of Brant Township in the Global Solutions publication. It would be most prudent for the Crown not to engage in active planning, zoning and/or changes in land/use designation without full, deep and meaningful consultation with Six Nations, especially involving lands covered by active land claim negotiations. Additionally, there is a resolution from the Ontario Chiefs-in-Assembly rejecting the ERO as a means to communicate and/or solicit any comments or fulfill any perceived consultation processes.

The February 2, 2021 Grand River Source Protection Area Approved Assessment Report highlights water quality issues for the Six Nations Ohsweken water supply The report states that primary water quality concerns are related to colour, total dissolved solids, and aluminum in the surface water from the Ohsweken Intake point.

The government must proceed in a manner that honours and is informed by the responsibilities, rights, interests, and Traditional Knowledge of Indigenous communities. Exploring options to expand the Greenbelt presents a potential opportunity to advance reconciliation among the peoples who share this land.

The quality of protection must be prioritized. To do this, Ontario will need to recognize the better quality of protections in some jurisdictions including the Region of Waterloo. Municipalities within the Greenbelt are not able to establish policies that are more restrictive on mineral aggregate extraction than those in the Greenbelt Plan while outside the Greenbelt other GGH municipalities are able to do so. This policy is counterproductive for municipalities where more restrictive policies are necessary to protect water quality and quantity: inclusion in the Greenbelt expansion would prohibit them from doing so.

Waterloo Region has strong water resource protection policies that are more restrictive with respect to aggregate extraction than Greenbelt Plan policies. The region relies almost exclusively on groundwater for its drinking water supply, a critical consideration from a public health and safety perspective. It is unreasonable to expect Waterloo Region to sacrifice these higher local standards. Mineral aggregate extraction policies should default to the policy offering the highest level of protection for water resources, including municipal policies. Until this policy is revised, more restrictive municipal mineral aggregate extraction policies than those in the Greenbelt Plan should be prioritized for municipalities that are part of the Greenbelt expansion, recognizing that the policies in the Provincial Policy Statement, the Growth Plan and the Greenbelt Plan generally represent minimum standards which decision-makers are encouraged to exceed to address matters of local importance. I advocate for restriction on extraction below the water table in concert with other groundwater dependent municipalities such as Puslinch and North Dumfries.

Protecting natural and hydrologic systems from development is a recognized “nature-based solution” to climate change impacts. Protecting natural and hydrologic systems from development is a recognized “nature-based solution” to climate change impacts. Ontario’s Special Advisor on Flooding noted in 2019 both the increasing frequency and intensity of extreme rainfall events and the importance of natural features such as wetlands in reducing associated flood damages and financial losses.