Earlier this year, I…

Earlier this year, I submitted comments to the ERO on a proposed amendment to the Greenbelt Plan regarding growing the size of the Greenbelt (ERO # 019-4485). That proposal claimed that its objective was to “grow the size and quality of the Greenbelt” and that the government would neither “consider the removal of any lands from the Greenbelt” nor make any policy changes to reduce “existing protections in the Greenbelt.” With the release of the Proposed Amendments to the Greenbelt Plan on November 4, I feel that not only were Ontarians lied to, but also that my concerns and those of so many others who participated in the earlier consultation were ignored.

The Greenbelt was established in 2005 to protect farmland and natural heritage from urban sprawl and climate change and to encourage the growth of healthy, liveable communities in urban areas in which people could live where they worked and played. The lands included in the Greenbelt area were carefully selected for their ecological significance and sensitivity to form a connected system of protected land that would protect the biodiversity and farmland in it. These protections were meant to be permanent.

The proposed amendments to the Greenbelt Plan and Greenbelt Area Boundary not only violate those protections and numerous repeated promises by this government that the Greenbelt would not be touched, they also threaten the wellbeing and security of Ontarians.

Faulty Premise
Before I proceed, though, the very premise underlying the proposal to open up parts of the Greenbelt (that the lands are required to provide 50,000 new homes out of an anticipated 1.5 million new homes required for projected growth in the GTHA) is untrue. There are more than 86,000 acres of land currently available for development in urban and peri-urban areas in the GTHA alone. This land, along with changes in zoning policies restricting gentle densification within municipalities, is sufficient to meet the housing needs of our growing population—and it would make available housing of various shapes and sizes to meet the needs of people of varying income levels, ages, and stages in life. Even the government’s own Housing Affordability Task Force stated earlier this year that “a shortage of land isn’t the cause of the [housing crisis]. Land is available, both inside the existing built-up areas and on undeveloped land outside greenbelts” (10) and that the solution was simply to “make better use of land” (10) through changing zoning rules and “adding density” (4) within urban boundaries. Further, a 2020 report published by the Canadian Federation of Municipalities entitled Sustainable Land Use Practices in Canadian Municipalities: A Snapshot, intensification of urban areas is one of the top municipal best practices to sustainably address affordable housing needs and growth. So, the suggestion that Greenbelt land is required to meet the housing needs of the anticipated population growth is, in fact, untrue—meaning this proposal to amend the Greenbelt Plan is based on false premises and should therefore be dropped.

Promised Protection
After being caught on tape in 2018 stating that he would open up the Greenbelt for developers, Doug Ford and his government have repeatedly promised that the Greenbelt would not be touched. The current proposal to carve out 7,400 acres of the Greenbelt is a violation of that promise. Further, the suggestion by the government that parts of the Greenbelt can be opened up and new land added in a type of “land swap” reflects a deep misunderstanding of how ecosystems function, how biodiversity thrives, and how water systems flow and work. As mentioned previously, the lands that were put in the Greenbelt were carefully selected to protect the ecosystems and biodiversity within the lands, to prevent further fragmentation of farmland (which reduces productivity and farming viability), and to stop urban sprawl. Adding new parcels of land (if truly new—and initial findings suggest some of the land proposed to be added was already protected, already public parks, or undevelopable land) to the Greenbelt, while welcome, would never replace the value and significance of the land already in the Greenbelt. We should not be giving up Class 1 farmland and natural assets (such as wetlands, fields, and woodlands) to housing. And the promise of protection for any new lands added would be questionable, as Greenbelt lands (including those that the government would like to offer up to developers) were meant to be permanently protected. Overall, the proposals to open up parts of the Greenbelt and change boundaries would violate the integrity of the whole Greenbelt and all that it offers Ontarians.

Threats to Our Wellbeing and Security
If the COVID crisis did nothing else, it made all of us aware of the importance of access to green spaces for our health and of access to local food. The Greenbelt provides these things. People need green spaces for the ecosystem services they provide us but also as places to visit and be active (including hiking, biking, skiing, and touring). They provide us with opportunities to improve our physical and mental wellbeing. Recent COVID-related border closures and food shortages also increased our understanding of the need to have local food sources. Food security will be increasingly important as Ontario grows. The proposals to open up parts of the Greenbelt threaten to reduce and destroy both access to local food and local recreation and tourism opportunities.

The Greenbelt also plays a critical role in cleaning our air and water and in preventing flooding. Allowing housing to be built on Greenbelt land will come at the expense of lost natural infrastructure that protects us from the harmful effects of air and water pollution and the costly effects of flooding. As a whole, according to the Greenbelt Foundation, the Greenbelt provides $3.2 billion in ecosystem services such as the ones mentioned above. Parcelling out parts of the Greenbelt for housing would undermine and reduce the benefits provided by the Greenbelt. Further, according to the Auditor General of Ontario’s 2022 report, “all Ontarians who live in a developed area—regardless of proximity to a waterbody, like a river or creek—may be at risk of an urban flood” (1). Removing sections of the Greenbelt would only increase that risk for Ontarians living on, near, or downstream from the Greenbelt.

The climate crisis has also heightened our awareness of the significance of farmland and natural heritage to mitigate and adapt to the effects of climate change. The Greenbelt is key to helping our province deal with the challenges of climate change, including flooding, droughts, heat-island effects, pollution, extreme weather events, and extreme temperatures. Planning for and enabling uncontrolled sprawl by opening up the Greenbelt is irresponsible and goes against the province’s own greenhouse gas (GHG) reduction commitments. How is the province supposed to reduce GHG emissions by its meager goal of 30 percent from 2005 levels by 2030 if it induces urban sprawl into the Greenbelt and forces people out into car-dependent neighbourhoods built of houses that furthermore, as a result of Bill 23, do not even have to meet municipal efficiency codes? Climate change is considered the biggest threat of our time. Why is the government even considering opening up the Greenbelt when that land has a key role in protecting our province from increased GHG emissions and vulnerability to the impacts of climate change?

Housing Goals Can and Must Be Met Without Opening Up the Greenbelt
The proposals to amend the Greenbelt Plan and amend the Greenbelt boundary reflect a deep ignorance of the purpose and significance of the Greenbelt as a whole in preserving critical farmland, protecting biodiversity, protecting our drinking water, serving as a carbon sink, protecting us from extreme weather events, cleaning our air and water, and providing us with local jobs and food, among the many benefits and services it provides Ontarians. The Greenbelt is not a “regulatory burden[]” and opening it up for development is not “a balanced approach to smart growth,” as suggested by the proposals. While adding land to the Greenbelt is welcome, it cannot come at the expense of opening up other areas of the Greenbelt for development. Carving into the Greenbelt will only destroy ecosystems and biodiversity within them, reduce farmland productivity and availability to feed Ontarians, drive further urban pressures onto the environmentally sensitive Greenbelt, encourage costly and harmful urban sprawl, set a dangerous precedent for future development to occur in the Greenbelt, and put the health and wellbeing of Ontarians at risk.

Our province can meet its housing goals without opening up the Greenbelt. Land-use experts, municipal best practice, and even the government’s own Housing Task Force have shown that if we use the land within urban boundaries more effectively, we can accommodate growth and create vibrant, affordable, and non-exclusive neighbourhoods that integrate businesses, parks, housing, people, and accessible public transit. The Greenbelt must not be opened. It belongs to all Ontarians and should not be at the disposal of developers. Full stop.