Comments on Proposed…

Comments on Proposed Amendments to the Greenbelt Plan
ERO number 019-6216:

These proposed amendments to the Greenbelt Plan need to be put on hold until a full environmental assessment is done and a full assessment is done of the need for this Greenbelt land to be removed for housing. In addition, there needs to be proper public consultation and input from all municipalities and conservation authorities affected by the proposed amendments. The government must follow the Precautionary Principle on such an important decision.

The Greenbelt was set aside by all political parties years ago for the benefit of current and future generations of Ontarians. Any changes to it must undergo a rigorous transparent assessment. This proposal has far-reaching impacts that will be felt for generations to come. Following the Precautionary Principle, which the Ontario courts have upheld for important environmental matters, the current and future residents of Ontario deserve these amendments to the Greenbelt Plan to be put on hold until a full assessment of all the issues is done. Once the land is paved over for housing, we can never get it back.

Many issues have already been raised by local residents, academic researchers, community groups, conservation authorities, politicians and staff at all levels of government, and by urban planners.

For example, the following are just some of the issues that have been raised:

-- Earlier this year, Ontario's government-appointed Housing Affordability Task Force said a shortage of land isn't the cause of the province's housing crisis. "Land is available, both inside the existing built-up areas and on undeveloped land outside greenbelts." There is over 10 times as much land ready for housing development in communities where people already live. Why the rush to remove land from the Greenbelt?

-- A former provincial planner who was one of the architects of the Greenbelt, said in an interview that he worries the land swap sets a precedent for other developers to push to have their lands removed as well.

-- A Vaughan city councillor said she has received calls from developers who own land in other parts of the Greenbelt looking for municipal support to open up their properties as well. The councillor remarked that this is only the start and that there will be a flood of Greenbelt landowners lobbying to have their land removed. This sets a dangerous precedent.

-- In the recent report "Value-for-Money Audit: Land-Use Planning in the Greater
Golden Horseshoe" by the Office of the Auditor General of Ontario:
"Effective land-use planning ensures that lands, which are finite resources, are used and developed to meet the current and future needs of communities and the people who live in them, while safeguarding valuable resources such as agricultural lands, wetlands, forests, and distinctive natural features and landscapes." The overall conclusion in the Auditor General's report: "Our audit concluded that the Ministry of Municipal Affairs and Housing does not have effective procedures and systems in place to ensure that land-use planning in the Greater Golden Horseshoe is consistent with good land-use planning practices, the purposes and objectives of the Planning Act, and the Growth Plan for the GGH."

-- The Auditor General also said that Ontario is not doing enough to prevent urban flooding, a problem that is expected to worsen in the coming years with extreme rainfall events due to climate change. The findings are part of the 2022 Auditor General's Report, which points to the province's failure to clarify its commitments to manage urban flooding and a failure to adequately support municipalities to effectively tackle the problem. The Auditor General says it isn't just a problem for the three per cent of Ontarians who live near rivers. All Ontarians who live in cities, towns and smaller communities may be at risk of flooding and that not addressing the problem will be costly. The report recommends improving urban flood risk mapping and better protecting green and natural spaces such as wetlands.

-- The conservation authorities were not consulted about flood risks and biodiversity loss due to removing these lands from the Greenbelt.

-- Municipal and regional governments were also not consulted about removing these lands from the Greenbelt. Their urban planners are saying they'd much rather focus housing growth within existing urban areas, closer to existing infrastructure.

-- The United Nations is forecasting a world-wide food shortage in 2023. Climate change is reducing crop yields around the world and the problem is only going to get worse. We need the Greenbelt farmlands, some of the best in Canada, not only for our own food security, but we owe a duty of care to help feed the world.

-- The Duffins Rouge Agricultural Preserve lands in Pickering which are slated to be removed from the Greenbelt are adjacent to the Rouge Urban National Park. The lands bordering the Park are significant to the wildlife and biodiversity of the Park. There needs to be a proper environmental assessment on the impact on the Park. There should not just be an arbitrary straight line drawn north-south along the Markham/Toronto-Pickering border. In a Tweet on November 16, 2022, the Toronto and Region Conservation Authority (@TRCA_HQ) said "The Province's proposed removal of nearly 4,700 acres of protected agricultural lands in Pickering, could result in unplanned urbanization negatively impacting efforts to protect Petticoat & Duffins Creek & nearby Rouge National Urban Park."

-- Biodiversity loss from removing these lands from the Greenbelt needs to be assessed. We are in the midst of an accelerated biodiversity loss worldwide. Canada is hosting COP 15, the United Nations Biodiversity Summit, over the next couple of weeks. From a spokesperson for the Convention on Biological Diversity, "The food we eat comes from biodiversity, the water we drink comes from biodiversity. The air we breathe [comes from biodiversity]." The ultimate goal is to stop biodiversity loss and build a sustainable relationship with nature in response to unprecedented rates of declining nature and species extinction. The new target under the draft agreement is the much-talked about 30 by 30 goal: preserving 30 per cent of land, freshwater and oceans by 2030. Canada has already committed to that pledge. The latest figures show Canada has only conserved 13.5 per cent of its land and freshwater and 13.9 per cent of marine territory.

-- First Nations peoples have not been consulted. Mississaugas of Scugog Island and other First Nations have said that the government did not consult with Indigenous communities while developing Bill 23 and were not consulted about removing lands from the Greenbelt. Indigenous rights for consultation are enshrined in the Constitution Act under Section 35. The Constitution Act requires provincial governments to consult with Indigenous peoples before passing legislation that would directly affect their communities.