I am a Registered…

I am a Registered Professional Planner in Ontario (Ret. Status) who has been practicing land use planning for over 45 years now. I’m opposed to the whittling away of parts of the Greenbelt as proposed. I attempted to ascertain the rationale for the removal of the various blocks of land in the proposal but I was at a loss to find justification analysis. This is a basic tenant of good government policy and therefore on this basis the proposed legislation is flawed.

The issues on land use are guided by the ON government’s Provincial Policy Statement (PPS). I have reviewed the proposition via the Ford Gov’ts 2020 PPS policies found at https://files.ontario.ca/mmah-provincial-policy-statement-2020-accessib…

I will reference this document to give substance to my remarks here. My remarks are structured on the basis by which the proposal should reflect good planning policy considering all of the matters that are relevant to the Province, i.e., not just the availability of housing in the future. The PPS is clear in Part III: How to Read the PPS (pg 2) that the entire document is to be considered and that one type of land use does not take priority over others.

a) How has the government shown that it has effectively engaged the general public in reviewing, commenting and refining the proposal before us? In reviewing the background info on the ERO site just a simple political statement that we need more land to build 50k houses is necessary. This is not a sufficient reason for proposing the removal of the land. Already ‘protected lands’ within urban floodplain areas and within the prime agricultural and core greenlands of Erin are not in danger of being developed on and are not a reasonable replacement equivalent. As a result of the poor planning engagement exercise by the Province, there is little buy in for the proposal, except for the benefiting house building industry.

b) How has the government demonstrated its ‘duty to consult’ with indigenous nations concerning the proposal’s details? This is a violation of PPS Policy 1.2.2 namely “Planning authorities shall engage with indigenous communities and co-ordinate on land use planning matters”. From on-line correspondence by the Ontario chiefs there appears a disconnect on the government’s responsibility to consult and engage in listening, i.e., a responsibility of reconciliation. https://chiefs-of-ontario.org/chiefs-of-ontario-and-first-nations-oppos…

c) How does the legislation promote co-ordinated land use planning across watershed and regional municipality boundaries when the proposal (in line with the related provisions of recently passed Bill 23) greatly diminishes opportunities for co-ordination. The Greenbelt as an intact entity was established to be respectful of watershed boundaries. The proposal before us violates PPS policy 1.2.1 whereby “a co-ordinated, integrated and comprehensive approach should be used” amongst municipalities and other agencies (Conservation Authorities) in “managing natural heritage, water, agricultural . . . resources.”

d) Justification analysis should be completed as a component of the land use change. Again, a violation of being ‘consistent’ with the PPS is evident as the Province’s Affordability Housing Task Force indicated that “a shortage of land isn’t the cause of the problem … land is available.” The Task Force further advised that “Greenbelts and other environmentally sensitive areas must be protected, and farms provide food and food security. Relying too heavily on undeveloped land would whittle away too much of the already small share of land devoted to agriculture.” (p. 10)

e) I am not aware of the environmental impact assessment studies that are normally required when land use changes are proposed in proximity to significant natural heritage features that the Greenbelt lands contain. A systems analysis on wetland complexing to consider the impacts to flora/fauna are necessary to mitigate feature and associated ecological function damage. I’m not aware of information being provided to document these impacts. Conservation ON and the CA watersheds containing lands/waterways of the existing Greenbelt have unanimously expressed alarm of the proposal.

Niagara Conservation https://www.youtube.com/watch?v=0eToADFbAsk

Hamilton Conservation https://conservationhamilton.ca/dear-premier-ford-lets-reconsider-bill-…

Conservation Halton https://www.conservationhalton.ca/conservation-halton-board-urges-premi…

TO and Region CA https://trca.ca/news/trca-response-more-homes-built-faster-act-proposed…

Kawartha Lakes CA - https://www.thepeterboroughexaminer.com/local-kawartha-lakes/news/2022/…

Grand River CA https://www.grandriver.ca/Modules/News/index.aspx?newsId=987bfae5-6474-…

Credit Valley CA https://cvc.ca/conversations/proposed-changes-in-bill-23/

Lake Simcoe CA https://www.lsrca.on.ca/Shared%20Documents/board/Bill%2023%20-%20Specia…

Conservation Ontario https://conservationontario.ca/about-us/watershed-views-blog/blog/a-wat…

Nature Ontario https://ontarionature.org/greenbelt-lands-at-stake-blog/

The Big Tent opposition letter https://yourstoprotect.ca/wp-content/uploads/sites/3/2022/11/Big-Tent_-…

In moving forward with development on environmentally sensitive Greenbelt lands, the proposal is a violation of the PPS Natural Heritage section 2.1; specifically violation of 2.1.8 is evident where detailed environmental impact analyses have not been completed to document that no “negative impacts on the natural features or on their ecological functions” will occur on “adjacent lands”.

f) How does the removal of prime farmland uphold PPS Policy 2.3.1. “Prime agricultural areas shall be protected for the long-term use for agriculture.” The Ontario Federation of Agriculture does not support what the government is proposing. The ag system is impacted, and the tenants of good planning are undermined. See OFA statement on protecting farmlands within the Greenbelt https://ofa.on.ca/ofa-presents-to-ontario-standing-committee-on-bill-23/

g) I am unaware of any municipal partners within the geographic area of the existing Greenbelt that supports what the government proposes to do. This is legislation not enacted in good faith and diminishes the public interest in good planning. The proposition of this note to you is not taken from a NIMBY perspective or even the more dismissive anti-public engagement sentiment by Minister Clark of BANANA. Instead, I am interested in building a resilient Toronto centred region with considerations given to sustainable human and natural communities.

AMO representing municipalities across Ontario questions the need for the loss of Greenbelt lands as outlined by this proposal: https://www.amo.on.ca/sites/default/files/assets/DOCUMENTS/Submissions/…

h) The government needs to consider its concern for the provision of new housing in conjunction with all of the priorities of good planning as outlined in the PPS. It clearly states in Policy 4.2 that all aspects of the PPS need to be considered in proper planning for the public good, i.e., the PPS shall be read in its entirety and all relevant policies are to be applied. . .

i) As a normal component of land use planning changes, the provision of a comprehensive review document is required to justify the alterations to existing policy. While the government can choose to ignore its own policy, this is a draconian measure that undermines integrity of our (so-called) democratic system.

In conclusion, do not remove lands from the Greenbelt as there is nearly universal disapproval by concerned citizens and organizations across Ontario. The lands are not needed to meet the Ford government’s aggressive desire to have new housing built in the province (ON Affordable Housing Task Force report, Feb. 2022). The proposal is not reasonable as it sets a dangerous precedent for additional future land withdrawals, and it represents poor planning and NOT in the public interest.

Thanks.