Comment
I completely oppose this amendment to the Greenbelt Plan. There is no need for it, and it would cause significant harm. This amendment would not solve the affordable housing crisis – instead, it would undermine the whole point of the Greenbelt as permanent protection for irreplaceable lands. It would also speed up urban sprawl, endanger an important water source, proceed without any legitimacy, enrich a few developers and worsen government opaqueness, leading to rising public distrust and suspicion. We must build affordable housing in existing settlements and near transit hubs. There is, in fact, enough land in those places already designated for housing to meet Ontario's foreseeable needs. We must also protect the Paris Galt Moraine without sacrificing other valuable Greenbelt land, e.g. in the Oak Ridges Moraine.
There is no need for this amendment to the Greenbelt Plan. Studies show that there is enough land in existing designated settlement areas in Ontario to accommodate current and future populations. See the Canadian Environmental Law Association (CELA) brief, "Bill 23 and The Question of Need", in the Supporting Links section, below.
The real housing crisis in Ontario is not the shortage of expensive single-family units in the far suburbs or rural areas, which this proposed amendment would encourage. The real crisis is the lack of affordable housing near city centres and transit hubs. Yet this proposal does not require that the resulting housing be affordable. It would just cause expensive and unaffordable urban sprawl.
This proposal would also undermine the entire Greenbelt Plan by making it a temporary holding place for speculator's land, to be unprotected at government whim (possibly after specilator lobbying and/or undue influence). The Greenbelt is supposed to provide permanent protection, to actually stop urban sprawl and encourage compact development, while protecting important farmland and natural features forever. But this proposal would shrink the Greenbelt on the GTA side, while expanding it on the outside of the belt. The net result would be a rolling movement of the Greenbelt outward. No land would be really protected, as the next crisis (housing, jobs, etc.) would push the Greenbelt outward again. Instead, the protection should be permanent. As with National and Provincial Parks, any additions to the Greenbelt must not be at the expense of removals.
We need to ensure that the currently designated lands are developed, rather than sacrificing protected Greenbelt lands to line the pockets of speculators.
Moreover, one piece of natural land cannot be exchanged for another as if they were widgets. The Oak Ridges Moraine protects a vital water source for the GTA and provides irreplaceable habitat for wildlife. Protecting the Galt Moraine is valuable in itself, but it is wrong to lose protection for any other land in the process.
Finally, the proposal lacks any legitimacy. There was also no consultations with indigenous communities, contrary to Ontario's constitutional obligations. There is no democratic mandate for this scheme - there was no mention of such trade-offs in the government’s election platform. There was no public consultation on the whole idea of taking lands out of many Greenbelt areas, supposedly for housing. There is zero transparency on how any Greenbelt lands were chosen for redesignation – or who, exactly, chose them.
The government has shown no proof that these lands are “ready for housing development” (some of them are not even near roads); no information on who owns this land; how, exactly, they got their lands into this proposal; or how much land speculators and developers they would profit from this process. Many media stories have emerged, linking some of the people who would profit to the party in power in Ontario. Despite government denials, there were some land transactions with suspicious timing, not long before this proposal's surprise announcement. All this creates an atmosphere of distrust and suspicion.
In summary, I strongly urge the government to withdraw this ineffectual, illegitimate and wrong-headed proposal, and ensure affordable housing development where it’s actually needed most: in existing settlement areas and near transit hubs. I also urge the government to expand the Greenbelt to protect the Paris Galt Moraine without removing land from any other part of the Greenbelt or any other protected area. The Greenbelt must provide permanent protection!
Supporting links
Submitted December 3, 2022 11:25 AM
Comment on
Proposed Amendments to the Greenbelt Plan
ERO number
019-6216
Comment ID
76963
Commenting on behalf of
Comment status