ERO Number 019-5865 Do Not…

ERO Number 019-5865
Do Not Approve York Region Official Plan
I am writing to you today to recommend you do not approve the York Region Official Plan, submitted in early July 2022. The Draft Official Plan is illegal, precedent-setting and will lead to more environmentally damaging urban sprawl. York Region has a “massive glut” of greenfield land, more than enough to meet housing needs up to 2051, Please Premier Ford’s clear and often-repeated promise to protect the Greenbelt. Please reject York Region Council’s attack on Ontario’s Greenbelt.
Recently, York Region voted to seek provincial government approval for their draft Regional Official Plan. Shockingly, this draft plan proposes to allow development on the Oak Ridges Moraine portion of the Greenbelt. The draft plan violates the Provincial Planning Act which mandates that municipalities must complete and submit plans that comply with provincial law, policies and plans. The approval of the York Region plan depends on the provincial government overriding the development prohibitions of the Greenbelt and Oak Ridges plans.
The Greenbelt is made up of over two million acres of quality farmland, forests, rivers and wetlands that have been designated by provincial law as permanently off-limits for suburban residential, commercial and industrial development. It cannot be made smaller. This makes it unique in Canada. It has been around since 2005 and Ontarians love it. Over 90 percent want it left alone, and many want it to be made bigger. As the Greenbelt Act stipulates that the Greenbelt must remain permanent and can not be reduced in size,
So what are the consequences of the provincial government allowing York Region to develop the Greenbelt?
It will harm farmers and nature: A growing spider web of subdivisions, roads and factories in the Greenbelt would adversely impact the ability of forest fields and wetlands to absorb rain and clean our air and water. It would also impact local wildlife’s ability to naturally move, forage and breed, and reduce plants' ability to pollinate and disperse seeds. Furthermore, as development increases the buffer zone between agricultural land and residential/ commercial zones will be reduced. As the Ontario Federation of Agriculture has said, this can give rise to conflict between farmers and new arrivals in the countryside, impeding normal farm practices and undermining the long-term viability of farming in affected areas. Additionally, creating a mechanism to remove farmland from the Greenbelt would erode the incentive for high capital investments in farm infrastructure.
Creating a “Swiss-cheese” Greenbelt: In 2017, the provincial government reviewed the current Greenbelt boundaries as part of the legislatively required 10-year Greenbelt Plan review. At that time they received over 700 requests from developer landowners to remove land from the Greenbelt. In the end, only minor adjustments were made to refine the mapping from when the Greenbelt was established in 2005. The rest of the requests were denied because approval of these requests would have resulted in islands of development within the Greenbelt. Of course, these new housing subdivisions, factories and big box stores would also have required roads, sewers and water supply. Therefore they would have needed to be linked to towns and cities outside of the Greenbelt and a spider web of development would have begun to weave its way through protected lands.
Approving York Region’s Official Plan will spark a potentially devastating landslide of requests for development that would see the destruction of protected natural areas and critical farmland. Once a developer or a municipality is allowed to remove land from Greenbelt protection what would stop the next proposal from being approved? Once this happens the Greenbelt ceases to be a meaningful protection mechanism and opens a Pandora’s Box, where sprawl could take over critical green spaces.
Harming those who followed the rules: Landowners or developers who have played by the rules and worked with the municipal planning system to get their land approved for development would be competing with someone who had sidestepped this public process and secured a development approval in the Greenbelt.
There is no need for municipalities to expand into areas outside their boundaries, or to expand into the areas north, south and west of the Greenbelt. Thousands of acres of undeveloped land within existing GTHA city and town boundaries are already approved for development, yet remain vacant or underutilized. If municipalities develop these areas efficiently and eliminate rules obstructing the construction of more townhouses, semis and small multi-units in existing neighbourhoods, we can easily meet housing demand — while substantially expanding the Greenbelt’s area to include most of the current farmland surrounding our cities. The solution is to immediately increase the supply of affordable housing and housing options, within the existing urban boundary, with the missing middle. Municipalities and the provincial government need to immediately eliminate exclusionary zoning. We need the missing middle in existing neighbourhoods, not McMansions to address housing affordability. It will also allow our senior population to downsize in their community.
Allowing land inside the Greenbelt to be approved for development would make the Greenbelt no more protected than the lands outside of it and signal the demise of Ontario’s most important farm, forest and climate protection tool.
In conclusion, the submitted OP has significant financial, legal, planning and environmental risks that were well articulated by York Region’s staff and ignored by politicians. This approach does not put people first; it’s up to you to uphold good planning and financial management principles for the people of York Region and Ontario. Please, do not approve York Region’s Official Plan.