1. I will start by…

1. I will start by commenting on a statement provided in the context section of the proposal: Section 5.6 of the Greenbelt Plan provides that amendments to the Greenbelt Plan could be considered outside of the 10-year review in the event of major new Provincial policy, legislation, or regulation that creates the need for an amendment. It may be argued that More Homes Built Faster legislation is what triggers the need for amendments outside the 10-year review process. This is not a legitimate or valid argument.
• The need has been self inflicted; and the alleged need for more land to build the needed homes identified in More Homes Built Faster is not supported by the facts. The Province’s own commissioned task force has denied that it is land scarcity which has created the housing crisis.
• The writers of the proposed Amendments to GB have never provided the data to support their claim of land scarcity. In contrast the municipalities can detail the land zoned for greenfield development which is still untouched and the brownfield lands which are still in original state. And the municipalities can identify the draft subdivision plans which have not been executed. In my municipality there have been two subdivisions, each being >700 residential units which have had their lapsing provisions extended beyond the usual 3 years.
• It is said that the GB lands will enable the building of 5,000 homes; this is <1% of the identified need of 1.5 million. Surely those 5,000 can be incorporated across all the new developments over the next 10 years.
Finally the clear indication that it is a façade to claim the appropriateness of making amendments outside the 10-year review is the recently revealed coincidence of 8 of 15 parcels proposed to be taken out of the GB to have been purchased since the Conservative party victory in 2018.
2. To quote the context again: The plans [GB] provide permanent protection to the agricultural land base and the ecological and hydrological features, areas and functions within the Greater Golden Horseshoe and beyond. Given the purpose of the GB, where are the studies that the impact of removing lands from this protection has insignificant impact as surely this would be the only reason for allowing removal of the protection. Where is the study which shows that the watercourses providing drinking water to 250,000 persons further south will not be harmed by taking lands out of the ORM in in York Region. One of the reasons for a 10-year review is to thoroughly review all of the data; collecting that data is labour and time intensive; its impossible to do in a 30 day window.
3. There is the statement that anticipated regulatory impacts are positive. Again where is the data?
• How many acres of productive farmland will be developed?
• How many acres of farmland adjacent to the “cut out” acreage and will become lands valued only as being candidates for the next round of “cut outs” and accordingly the stewardship of those lands will be downgraded?
• How much natural heritage will be lost as there will be no conservation authority, given Bill 23, to review development applications and features which make our communities more healthy will be destroyed.
4. Ontario needs more homes which people can afford to either acquire them and maintain them or to rent them. Enabling the building of more residential units outside current urban boundaries does not accomplish this. Even though the developers of these “cut outs” are supposed to fund installation of services it is the municipalities who maintain them. Providing effective public transit to the outer boundaries of urban area is a challenge today; people living tomorrow, in what is currently the GB, will be even further from the core of the urban area. Without public transit households require one or multiple cars which adds to daily living cost.
5. The argument that the net result is a bigger GB is very weak and disingenuous. First to include the 13 urban river valleys is an insult as that land, by virtue of what they are, cannot be developed. Second, the idea of the Paris Galt Moraine was presented and extensively analysed as a candidate for truly expanding the GB a couple years ago and was not acted upon.
The GB is not like collecting baseball cards whereby you make your collection by trading up to get a special card but in doing so you lose a couple lower value cards.
6. Finally, removing these parcels of land from the Greenbelt makes Premier Ford and Minister Clark liars. Given that there are no recognized professional groups or associations with relevant expertise & credentials who agree that the housing crisis is due to land scarcity their lies deserve condemnation.