I am registering my…

I am registering my opposition to the proposals to open the greenbelt to housing. My reasoning follows:
Need has not been justified:
The need has not been demonstrated for lands to be opened in the greenbelt for housing. The government is ignoring its own commissioned report of the Ontario Housing Affordability Task Force who stated that: “a shortage of land isn’t the cause of the problem. Land is available, both inside the existing built-up areas and on undeveloped land outside greenbelts.”

There are lands within existing urban boundaries that can be intensified or redesignated; there are designated greenfield lands already defined and in progress. In their 2018 report MGP notes that there was still just over 50% (22,700 ha) of the designated greenfield lands vacant in addition to another 42200 ha in the whitebelt, totalling approximately 65,000 ha of land. While all this land is not developable, at between 30-200 u/ha between 1.9 – 12 million homes could be built which more than exceeds the provincial targets.

No criteria for selection:
The province have not provided any criteria for determining the rational behind the parcels being recommended for removal. The ability to provide housing could be applied anywhere in the greenbelt – exactly why it was created in the first place. Any contemplation of removing lands from the greenbelt should be subject to a thorough and transparent evaluation and using criteria established by experts, not developers’ desires and quid pro quos.

Greenbelt lands as a system:
Many of the parcels proposed to be removed are not proximate to other developments (e.g. Map 4) and many are within the natural heritage system boundaries. Impacts from land use change are not confined to the boundaries of the development. Access points, light, noise, human interaction with the remaining natural system, storm water drainage etc., all have the potential to intrude into retained lands and further degrade the greenbelt.
The greenbelt is a system that ensures clean and abundant drinking water, cleans our air, assists in flood management, provides linkages for wildlife, plants and people, and – this can not be replaced by infrastructure or only at significantly higher costs.

The greenbelt is an opportunity:
Development interests see the greenbelt as a barrier to growth but we should see it as supporting our growth and make our communities livable, successful and climate resilient. If we stop seeing it as a barrier and start accepting it as a vital part of the ecosystem there are wonderful opportunities to invest in nature based recreational opportunities. Lands can be acquired for recreational purposes that cannot be accommodated within the growth plan area. With proposed reductions to parkland dedication and denser growth, people need a place to recreate, and that was abundantly clear during the pandemic. Between July 2020 and august 2021 3.7 million people travelled to a greenbelt destination. Visitation to conservation areas increased up to 200%.

A recent study by Green Infrastructure Ontario funded by the Greenbelt foundation looked at the availability of large parks (> 20 ha because they usually provide a greater nature experience and offer longer exercise options) now and into the future with population growth projected in the Greater Golden Horseshoe. They found that the current supply is 8.5 ha/1000 people and without additional investment over that planned, that number will drops significantly to 6.1 ha/1000. To keep that number steady – and many would say it is still not enough – we need to add 32000 ha of large parkland over the next 30 years. The greenbelt is part of the support system of the GGH.

Suspicious locations:
Many of the parcels appear to be in the middle of nowhere and within the boundaries of the natural heritage system. Mapping that was provided with the posting makes it very difficult to determine what features might be impacted or what land uses may be proposed around the location.
With proposed changes to wetland evaluations and compensation, such intrusions suggest houses over floodplains and habitat. This has not been an expectation in Ontario for decades. It is certainly not the expectation for the greenbelt.

Precedent setting:
Once opened, the precedent has been set for future cases to be made such that the initial purpose behind the greenbelt becomes. As no criteria we used or disclosed that supported the selection of these properties it will be very difficult to stem to tide of future requests.

Build on lands that have greater readiness:
Developers must show significant progress on approvals and implementation by the end of 2023 with construction started by 2025. What constitutes significant progress? Why would the province prioritize greenbelt parcels over building opportunities within the areas already designated for growth and servicing – where housing should be achievable more quickly and connected to transportation corridors? If speed is truly an objective of the province, prioritize lands that have servicing and some level of planning designations.

Trading lands:
The province has proposed opening 7400 ha of lands in the greenbelt over 15 parcels and add back about 7000 ha, mostly in the Town of Erin. While adding the Paris-Galt Moraine had been part of previous consultations on the greenbelt, the province had made the decision not to add them. The decision to add this 7,000-acre area into the Greenbelt makes little scientific sense as it only partially covers the Paris Galt Moraine. The hasty decision to add these lands, and without municipal consultation will cause new upheaval, whereas the lands being removed from the greenbelt have been so designated for 17 years where landowners have both certainty and expectations have been set.

The proposal to add 2400 ha of urban river valleys is a nice gesture and recognition of their connection between Lake Ontario and the Greenbelt but functionally they were never lands that would have been built on as they are associated with the major river systems along the north shore of the GTHA and have major constraints with floodplains and valley slopes. These cannot be counted as part of any land swap.