Dear Members of the…

Dear Members of the Greenbelt Consultation Team,

I appreciate the government’s commitment to grow the Greenbelt. Please see my answers to the consultation questions below.

Question 1:

• What are your thoughts on the initial focus area of the Study Area of the Paris Galt Moraine?

The Paris Galt Moraine is an ideal area to expand Greenbelt protections. Protecting this water system, including headwaters and all hydrological features, means securing a water source for at least 800,000 people. However, to protect precious farmland and natural areas from development, the Province must be more ambitious in its approach.

I urge the province to expand the area of study West and include all adjacent areas and important parts of larger ecological systems (i.e. agricultural systems, wildlife corridors, headwaters, etc.). A scientific approach demands all natural systems adjacent or vitally connected to the Greenbelt need to be protected, including but not limited to:

• the entire Paris-Galt moraine as depicted in the Blackport report (2009)
• headwaters, streams, creeks and wetlands of the Grand River, including land contiguous with Greenbelt in Brant
• Orangeville Moraine
• Waterloo Moraine
• Escarpment Area Moraines such as the Gibraltar and Singhampton Moraines
• The Horseshoe Moraines that flank the Niagara Escarpment to the north near Clearview
• Former glacial lake Algonquin and Iroquois shorelines and plain
• Lake Simcoe Basin
• Headwaters of south flowing stream systems within the inner ring of the GGH (the ‘Whitebelt’) where there are high development pressures (i.e. Humber, Don, and Rouge Rivers and Duffins and Carruthers Creeks)

Question 2:

• What are the considerations in moving from a Study Area to a more defined boundary of the Paris Galt Moraine?

It is essential to engage with Indigenous communities to fulfill constitutional and treaty obligations. The duty to consult is a constitutional obligation that arises from s.35 of the Constitution Act, 1982, which recognizes and affirms Indigenous and Treaty rights. Indigenous traditional practices, responsibilities and knowledge systems must be honoured by ensuring Indigenous voices are key to any discussions involving expanding the Greenbelt.
In addition, we should:
• use a science-based approach to define the boundary
• protect all key hydrologic features and functions
• conduct in-person consultations once suggested boundaries are identified and the pandemic has subsided

Question 3:

• What are your thoughts on the initial focus area of adding, expanding and further protecting
Urban River Valleys?

Urban River Valleys (URVs) should be further protected by ensuring that the Greenbelt includes headwater areas, as well as any direct connections to downstream urban communities. The expansion of URVs should incorporate connections to the Paris Galt Moraine through the Speed and Eramosa Rivers in urban areas. Additionally, the Grand River watershed is the largest river watershed in southern Ontario, and it has been designated as a Heritage River. Therefore, it is important to include the headwaters, streams, creeks and wetlands of the Grand River Watershed as well as all URVs in the Greater Golden Horseshoe.
The Province should also include:
• Lake Simcoe recharge areas including the Severn Sound and Carden Alvar, Waverly Upland, Clearview Township, Holland River
• Lake Iroquois shoreline areas
• The Nottawasaga watershed.

Expanding this protection will support green infrastructure like wetlands, floodplains, and riparian edge – which help to protect downstream areas from flooding and erosion. These features support habitat and promote biodiversity, as well as providing healthy outdoor recreation via the regional trail system.

Riverway lands are important to put into public ownership or to be included in Greenbelt designation as a way of protecting access to the rivers and tributaries. Protecting these waterway lands also help preserve wildlife corridors.
In addition, we should develop clear and easy-to-implement options for property outside the boundary to be added.

Question 4:

• Do you have suggestions for other potential areas to grow the Greenbelt?

I urge the Province to undertake studies and consultations adding areas in the Greater Golden Horseshoe Natural Heritage System, areas in the Bluebelt map, and any other headwater areas not captured in that mapping to the Greenbelt.

Question 5:

• How should we balance or prioritize any potential Greenbelt expansion with the other provincial priorities mentioned above?

The Greenbelt Act should default to the policy offering the highest level of protection for water, natural heritage and farmland protection, including municipal policies.
Additionally, expansion of the Greenbelt will enable these key concepts:

Housing: reduce sprawl development

The Neptis Foundation (2017) found that there is more than enough land already designated for development to meet future housing needs in the Greater Golden Horseshoe (except Toronto and Peel).

Prioritize growing the Greenbelt to reduce land speculation and limit extending expensive urban services into the countryside.

Build complete communities the within current urban settlement boundaries.

Develop brownfields to increase supply of land for employment and housing and to reduce pressures on Greenbelt lands.

Transportation and Infrastructure

Align mobility infrastructure with existing built-up urban areas.

CANCEL projects that encourage urban growth in the protected countryside and prime agricultural areas including the proposed 413 highway, Bradford Bypass, and Niagara Mid-Peninsula Highways.

Update transportation models with post-COVID commuting data, as people are likely to be working from home more often.

Promote complete and walkable communities with public transit.

Minister’s Zoning Orders (MZOs)-protect water, natural heritage and farmland

Do not use MZOs to fast-track development on natural areas and farmland.

Question 6:

• Are there other priorities that should be considered?

Climate Change: Nature-based solutions will help to lessen and adapt to the risks and impacts of climate change. For example, in 2019, the Grand River watershed experienced severe flooding, particularly in Brantford. Natural features reduce flood damage and financial losses.
Pursue a wide-ranging set of new policies to embrace a fair and green recovery and secure regional resilience, thereby protecting ecological integrity, social vitality, and economic prosperity.

Biodiversity: Expanding the Greenbelt will protect biodiversity, particularly species at risk. The Greenbelt will help to protect wildlife corridors, thus reducing habitat loss.

Without wildlife corridors, plants and animals could be trapped in isolated habitats. Without a way out, they might go extinct due to climate changes and other unintended effects of human activity in and around their protected areas.

Review new and existing wildlife corridors to ensure that they would work for all species of concern as the climate changes. For example, a creek that allows fish migration upstream today may dry up as the climate warms. In such cases, mitigate the effect (e.g. by protecting the creek headwaters) and/or find appropriate alternative corridors through Climate Connectivity Research. Implement these protected lands and corridors by adding them to the Greenbelt. See also "Rethinking wildlife corridors in a changing climate" https://wildlife.org/rethinking-wildlife-corridors-in-a-changing-climat…

Health and well-being: The Greenbelt expansion will contribute to clean air and water, the local food economy, access to nature – particularly important during the COVID19 crisis.

Aggregates: Prohibit new aggregate extraction throughout the Natural Heritage System both within and outside the Greenbelt.

I would also like to endorse the positions of

Ontario Nature: https://view.publitas.com/on-nature/expanding-ontarios-greenbelt/page/1

The Ontario Headwaters Institute: https://waterscape.ca/wp-content/uploads/PDF-Version-of-Submission-of-M…