Proposal ERO 019-6216 should…

Proposal ERO 019-6216 should not be adopted.

1.) There has been an absence of meaningful consultation with First Nations, as publicly admitted by Minister Clark. Proposed amendments to the Greenbelt Plan will have profound impacts on treaty lands across Ontario.

From your own Ontario Government websites:

“Ontario, as the Crown, has a legal obligation to consult with Aboriginal peoples where it contemplates decisions or actions that may adversely impact asserted or established Aboriginal or treaty rights.”

“The Crown has a duty to consult with Aboriginal peoples when the following conditions occur:
The Crown has knowledge, real or constructive, of the existence, or potential existence, of an Aboriginal right or treaty right; and The Crown contemplates conduct that might adversely affect the right in question.”

Canadian courts have affirmed that governments have a duty to consult Indigenous people on projects affecting their rights or on their territories. It is obvious that the provincial government has not worked to incorporate traditional indigenous knowledge in these proposals. As this is a federal requirement, adopting ERO 019-6216 without consultation could open up the project to federal impact assessment.

Finally, from the Greenbelt Plan itself:

“The First Nations and Métis communities within the Great Lakes region are essential partners. They have a unique relationship with the land and its resources. Ontario, including the area covered by the Greenbelt Plan, is largely covered by a number of Treaties that provide for treaty rights. In addition, Aboriginal communities may have Aboriginal rights within the Plan area. Ontario recognizes the unique role that Indigenous peoples have had and will continue to have in the growth and development of this region. Through their historic relationship with the lands and resources, Indigenous communities have gained traditional knowledge that is of significant value to the planning decisions being made today.”

2.)According to your own study, Report of the Ontario Housing Affordability Task Force, February 8, 2022, (page 10) it is outdated zoning rules that are causing the housing crisis.

Your study states:

"Too much land inside cities is tied up by outdated rules."

"Most of the solution must come from densification. 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."

"Allowing more gentle density also makes better use of roads, water and wastewater systems, transit and other public services that are already in place and have capacity, instead of having to be built in new areas."

And finally,
"But a shortage of land isn’t the cause of the [housing] problem. Land is available, both inside the existing built-up areas and on undeveloped land outside greenbelts."

Opening up Greenbelt lands to development to solve the housing crisis is a not supported by the current government’s own research and recommendations.

3.)Removal of Greenbelt land protections in order to open up natural heritage areas to development will increase fragmentation of habitat.

Habitat fragmentation occurs when large blocks of habitat are cut into smaller pieces by development such as roads or housing. The remaining blocks of habitat may be too small to sustain populations of a number of species and the fragmentation often results in barriers to species movement.

Fragmentation also leads to biodiversity loss:

“A synthesis of fragmentation experiments spanning multiple biomes and scales, five continents, and 35 years demonstrates that habitat fragmentation reduces biodiversity by 13 to 75% and impairs key ecosystem functions by decreasing biomass and altering nutrient cycles. Effects are greatest in the smallest and most isolated fragments, and they magnify with the passage of time. These findings indicate an urgent need for conservation and restoration measures to improve landscape connectivity, which will reduce extinction rates and help maintain ecosystem services.”

Swapping acres for acres does not reflect the complexities of local ecosystems, natural corridor systems, nor the species that rely on them for survival. Merely mapping additions and subtractions to the Greenbelt lands do nothing to take into account the distinctiveness of the habitats involved nor the quality of the habitats being exchanged.

4.) Removal of Greenbelt land protections will increase fragmentation of protected countrysides.

Allowing fragmentation is in direct opposition to the listed vision 1.21. of the Greenbelt Plan which : “protects against the loss and fragmentation of the agricultural land base and supports agriculture as the predominant land use”
as well as the 1.2.2 Protected Countryside goals which includes: “c) Protection of prime agricultural areas by preventing further fragmentation and loss of the agricultural land base caused by lot creation and the redesignation of prime agricultural areas".

Ontario farmland is a precious commodity which we should be preserving for our current and future food security.

The proposed amendments to the Greenbelt plan are in direct opposition to the recorded vision and goals, as well as the spirit of the Greenbelt Plan. Adoption of these amendments does not respect the legal obligation the Ministry and the Government of Ontario have to meaningful consultation with First Nations as set out by both the provincial and the federal government guidelines. These amendments are not supported by the Ontario Housing Affordabilty Task Force.