RE: Comment on Proposed…

RE: Comment on Proposed Amendments to the Greenbelt Plan (ERO 019-6216, 019-6217, 019-6218)

Dear Minister Clark:

I am writing to provide feedback in response to the Ministry of Municipal Affairs and Housing’s Proposed Amendments to the Greenbelt Plan, as posted on the Environmental Registry of Ontario for consultation (ERO number: 019-6216).

I do not support removing lands from the Greenbelt Area and I do not support the proposed amendments to the Greenbelt Plan (ERO 019-6216), or to the Greenbelt Area boundary regulation O. Reg. 59/05 (ERO 019-6217), or to the Proposed redesignation of land under the Oak Ridges Moraine Conservation Plan O. Reg. 140/02 (ERO 019-6218).

Established under the Greenbelt Act, 2005, the Greenbelt is a broad band of protected land that currently includes over 800,000 hectares of land in the Greater Golden Horseshoe. It is covered by the policies of the Greenbelt Plan, as well as the Oak Ridges Moraine Conservation Plan and the Niagara Escarpment Plan. Collectively, these plans identify where major urbanization should not occur. The plans provide permanent protection to the agricultural land base and the ecological and hydrological features, areas and functions within the Greater Golden Horseshoe and beyond.

While I support efforts to address the affordable housing crisis in Ontario, I do not support your proposal to remove about 7,400 acres in 15 different areas from the Greenbelt, which was created to protect environmentally sensitive regions from development. Especially since 14,000 hectares of non-Greenbelt land was released for development.

The government’s proposal contradicts its previously stated public commitments to protect the Greenbelt; it undermines the importance of green space and the impact of climate change; and it does not solve Ontario’s housing crisis or realistically acknowledge the issues that have led to the crisis.

The Greenbelt protected area must remain protected, it must not be cut, and lands must not be moved.

Current Proposal Contradicts Previous Commitments

The current proposals directly contradicts previous government statements on protecting the Greenbelt.

In March 2022, your Ministry held a consultation on Proposed Amendment to the Greenbelt Plan - Growing the size of the Greenbelt (ERO 019-4485), which stated that the Key Principles for Expanding the Greenbelt include:

No removal or land exchanges proposed: “This proposal is about growing the size and quality of the Greenbelt, and the government will not consider the removal of any lands from the Greenbelt.”
No policy changes proposed that would reduce existing protections in the Greenbelt

And in February 2021, when confirming plans to expand the protected area by adding a moraine south of Toronto and a series of urban river lands, you are quoted as saying:

"I want to be clear: we will not in any way entertain any proposals that will move lands in the Greenbelt, or open the Greenbelt lands to any kind of development.”

The Ministry’s news release, Ontario Takes Steps to Grow the Greenbelt, on February 21, 2021, further supports the government’s statements not to develop the Greenbelt:

"The Premier has been steadfast in his commitment to protect the Greenbelt and our government will not consider any proposals to remove or develop any part of it."

Protecting the Environment

The Greenbelt was created to protect agricultural and environmentally sensitive lands in the Greater Golden Horseshoe area from development and it should remain that way. It is vital to the well-being of our province, our environment, and our citizens.

It safeguards the resources that clean our air and water, reduces flood risks, provides a home for wildlife, and ensures Ontario communities have greenspace.

The Greenbelt is an important source of local food and its agricultural activities are an important contributor to the economy. In 2020, the Greenbelt's agri-food sector generated an estimated $4.1 billion in GDP and close to 59,000 jobs (source: Understanding How Greenbelt Agriculture Feeds the Regional Economy and Greenbelt Farmers)

In addition to the agri-food contributions, the Greenbelt is also home to some of the world’s most fertile soil and represents some of our most productive growing regions, which is critical to preserve, especially in light of food security concerns.We need the Greenbelt for our collective resilience.

The Greenbelt’s forests help clean and have a role in helping to mitigate climate change, as trees capture and store carbon, and they also provide habitat for birds and other species, while wetlands filter our water. The Greenbelt is home to 78 at-risk species, and important habitats - forests, wetlands and grasslands.

Wetlands also protect from flooding, drought and climate change. Wetlands in Ontario’s Greenbelt were estimated to provide $380 million in flood mitigation per year, according to the report Green Infrastructure in Ontario: Economic Impact Assessment (June 2020). As climate change continues to impact our province and increase flood risks, we must protect our wetlands as part of the Greenbelt.

The report goes on to explain that Ontario’s Greenbelt is estimated to provide ecosystem services of about $3.2 billion annually, and that the forest cover provided $18 million worth of health benefits annually.

A previous report, Ontario’s wealth Canada’s future: Appreciating the Value of the Greenbelt’s Eco-Services, quantifies the annual value of the ecosystem services provided by the Greenbelt at an estimated $2.6 billion, which would be over $40 billion since the establishment of the Greenbelt. The report goes on to explain:

The Greenbelt’s wetlands and forests hold the greatest value, worth over $2.3 billion. Wetlands are worth an estimated $1.3 billion per year ($14,153/hectare) because of their high value for water regulation, water filtration, flood control, waste treatment, recreation, and wildlife habitat. Forests provide key services worth $989 million each year because of their importance for water filtration services, carbon storage services, habitat for pollinators, wildlife, and recreation. The Greenbelt’s agricultural lands total value is also substantial at an estimated $329 million per year including cropland, idle land, hedgerows, and orchards. Key values include the pollination value of idle land and hedgerows, the storage of carbon in soils, and the cultural value of agricultural lands.

Proposing to cut the Greenbelt, add lands elsewhere, or exchanging unprotected land for protected land, threatens the stability of the Greenbelt and the important benefits the Greenbelt provides to Ontarians, the environment, and our economy.

The Greenbelt protected area must remain protected, it must not be cut, and lands must not be moved.

Ontario’s Housing Crisis

A housing plan must not come at the expense of the environment.

The housing crisis in Ontario is complex with many causes. While supply is an important factor, it is not the only factor.

Ontario’s affordable housing crisis is not new, but has become more severe, especially over the past few years with home prices up by 44% in 2021 since 2018, according to Generation Squeeze Lab’s Report.

Speculation has been a significant issue with homes increasingly being treated as an investment, like stocks and bonds, instead of a basic human right to shelter.

It is also important to focus on creating affordable housing, which would help stabilize rental markets and ease competition.

Some other options to consider may include:

Eliminating the land transfer tax for first-time buyers or increasing the existing rebate;
Managing unregulated rent increases;
Implementing progressive property taxation, which would disincentivize property flipping and renting out properties to the highest bidder;
Stronger restrictions on foreign investment;
Requiring beneficial owners of real estate to identify themselves to land title authorities, and to make that information transparent and publicly available, to address opaque ownership concerns and other conditions that make real estate markets vulnerable; and
Identifying appropriate and non-protected land to create new supply while holding developers accountable.

It was also recently reported that Ontario has dedicated 14,000 hectares of land for urban development in municipalities in the Greater Toronto and Hamilton Area, showing that land is already available (CBC News, November 12, 2022).

And it is important to note that the Greenbelt was created to restrict urban sprawl, and the government’s current proposal would create more sprawl. Any new housing should be built where there are existing roads, parks, transit, schools, and not on protected land.

There is no single solution to addressing Ontario’s housing crisis and restoring affordability, but trading off environmental protection and conservation is not the answer.

Conclusion

The Greenbelt protected area must remain protected – it is vital to the well-being of our province, our environment, and our citizens — and it must not be cut and lands should not be moved. I do not support the proposed amendments to the Greenbelt Plan (ERO 019-6216), or to the Greenbelt Area boundary regulation O. Reg. 59/05 (ERO 019-6217), or to the Proposed redesignation of land under the Oak Ridges Moraine Conservation Plan O. Reg. 140/02 (ERO 019-6218).

Thank you for your consideration.