April 19, 2021 Ontario…

April 19, 2021

Ontario Ministry of Municipal Affairs and Housing

Re: Consultation on growing the size of the Greenbelt
Environmental Registry of Ontario Posting No. 019-3136

Submitted by email to greenbeltconsultation@ontario.ca

Dear Minister Clark;

On February 17, 2021, the Ontario Ministry of Municipal Affairs and Housing (MMAH) posted a regulatory proposal on Ontario's Environmental Registry (ERO): Consultation on growing the size of the Greenbelt. The project number is 019-3136 and the public comment period is 61 days from February 17, 2021, until April 19, 2021.

This proposal seeks "feedback on ways to grow the size and further enhance the quality of the Greenbelt, with a priority of:

i. A study area of lands focussed on the Paris Galt Moraine, which is home to critical groundwater resources
ii. Ideas for adding, expanding and further protecting Urban River Valleys."

Links to the following two related files were provided: Paris Galt Moraine Study Area Map and Urban River Valleys Map and two associated links: Greenbelt Plan and A Place to Grow: Growth Plan for the Greater Golden Horseshoe.

In response to MMAH's request for the public's feedback, my responses to the discussion questions are as follows:

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

• I recommend avoiding fragmenting natural heritage and agricultural systems. For example, why exclude the area around St George and southeast of Cambridge and the regions between Eden Mills and Guelph and Guelph, Cambridge and Breslau? These excluded areas include valuable farmland as well as hydrologic systems serving the headwaters of the Paris-Galt Moraine.
• The headwaters of the Paris-Galt Moraine comprise a hydrologic system incorporating the Grand River watershed. The Province should consider including the Grand River watershed in the study area.
• While many municipalities within and south of the Greenbelt rely on water from Lake Ontario, municipalities within the Grand River watershed rely on groundwater. These areas beyond the Paris-Galt moraine boundary interconnect through an aquifer system and other groundwater/surface water connections within the Grand River watershed and need to be protected rather than excluded

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

• The Provincial maps provided for this consultation suggest the Province possesses additional information unknown to the public related to the protection of water resources. This information identifying key hydrologic areas and features crucial to municipalities implementing watershed planning and other Growth Plan and Greenbelt plan policies needs to be shared.
• Municipalities, conservation authorities and other stakeholders have compiled additional information and data that may not have been considered for this review. Ideally, the Province, municipalities, conservation authorities and other stakeholders should collaboratively share their data and information to ensure the most current data is used to:
 develop standardized water resource and natural heritage system maps for inclusion in municipal Official Plans, and
 determine the Greenbelt’s expansion to protect best and enhance the Paris-Galt moraine's water resources, natural heritage attributes, and other significant areas.
The Province should gather and condense all this information and data into a useable format for all to use.
• Greenbelt Plan policies may supersede local municipal Official Plans, rendering reduced protection to sensitive features and areas. The Greenbelt Plan policies need to defer to the most protective policies for sensitive features and regions, whether in the Greenbelt Plan or a municipal Official Plan.

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

• Our urban river valleys should be protected as essential linkages between the Greenbelt and Lake Ontario and natural heritage systems.
• Given the multitude of current provincial, municipal and conservation authority policies and regulations and protections afforded to urban river valleys, would it be worthwhile to consolidate these various policies and rules into one all-encompassing standard?

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

• Covid has generated a demographic shift in human settlement within Southern Ontario associated with employees working from home. The increasing exodus from larger metropolitan areas to smaller urban areas beyond the Greenbelt requires re-evaluating other regions for Greenbelt protection. The Grand River Watershed, with its associated urban river valleys, is one of these regions.
• This watershed connects with the headwaters of the Paris-Galt Moraine and is a significant groundwater source relied on by the population living within this watershed.
• The Grand River Watershed contains prime agricultural land as well as significant heritage landscapes requiring protection.

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

Growth Management
• We need to direct the majority of growth to fully serviced settlement areas to protect our farmland, natural heritage, and water resource areas.
• Municipalities need encouragement to abandon ongoing sprawl and commit to densification. Promoting detached single-family dwellings as our primary housing source is an unsustainable practice that needs to stop. We have to go up rather than out. Skyrocketing infrastructure costs and ensuring our food and water security demand a different approach to urbanization that is realistic, forward-thinking and resilient to the needs of ongoing growth on our agricultural lands, natural heritage areas, and water resources.

Natural Heritage and Water Resource Systems
• We need to identify and earmark every natural heritage and water resource system not already identified that may become future systems integral to our society’s wellbeing.
• Climate change may bring significant changes that impact our water and food security that we best prepare for now rather than too late.

Agriculture
• We cannot continue to take agricultural land for urban settlements ignoring the need to ensure a viable and sustainable food supply for future generations.
• Covid has shown the potential threats to our food and water security that come when nations cease exporting goods to ensure their own nation’s survival first. Every country must ensure it can feed and water its people, using its own agricultural and water resources.

Infrastructure
• Agreed, we need exceptions to allow needed infrastructure within Greenbelt areas, but only after all other avenues have been exhausted.

Are there other priorities that should be considered?

• The Province should commence a policy analysis identifying gaps and benefits between the Greenbelt Plan and Growth Plan, followed by amendments to address the gaps. The amendments to whichever Plan seem the most appropriate should provide greater protection of our water resources, natural heritage, and urban river valleys than is currently offered by the two plans.

• Another priority is coordinating multiple sources of data and information from various government agencies, municipalities, conservation authorities and stakeholders into a standardized set of maps detailing water resource and natural heritage systems to assist municipalities in developing their Official Plans.

• The Province should consider deferral of the Greenbelt expansion allowing municipalities the opportunity first to complete their Municipal Comprehensive Reviews (MCRs) and public consultation processes to bring their Official Plans into conformity with the updated Growth Plan policies. Substantial amendments to the Growth Plan in 2017 incorporated many of the protective policies of the Greenbelt Plan for natural heritage, water resources, and agriculture. Growth plan amendments in 2020 extended the planning horizon to 2051 for mandated growth projections and associated growth strategies. The delayed expansion can then incorporate the strategy coming from the various updated Official Plans to provide a more robust protective policy for the Greenbelt expansion and the Paris-Galt moraine.

In summary, the current Greenbelt plan requires a comprehensive review and area expansion.

The process must encourage collaborative working relationships with various provincial ministries, municipalities, conservation authorities and stakeholders, incorporating current provincial and local information and recommendations, minimizing duplication of effort and cost, and sharing resources and capabilities to develop a standard set of maps. These maps detailing water resource and natural heritage systems are to assist municipalities in developing their Official Plans.

Greenbelt Plan policies may supersede local municipal Official Plans, rendering reduced protection to sensitive features and areas. The Greenbelt Plan policies need to defer to the most protective policies for sensitive features and regions, whether in the Greenbelt Plan or a municipal Official Plan.

While many municipalities within and south of the Greenbelt rely on water from Lake Ontario, municipalities within the Grand River watershed rely on groundwater. These areas beyond the Paris-Galt moraine boundary interconnect through an aquifer system and other groundwater/surface water connections within the Grand River watershed and need to be protected rather than excluded. The Grand River Watershed should be added to the Greenbelt.

Given the multitude of current provincial, municipal and conservation authority policies and regulations and protections afforded to urban river valleys, would it be worthwhile to consolidate these various policies and rules into one all-encompassing standard?

The increasing exodus from larger metropolitan areas to smaller urban areas beyond the Greenbelt requires re-evaluating other regions for Greenbelt protection. The Grand River Watershed, with its associated urban river valleys, is one of these regions.

The Province should consider deferral of the Greenbelt expansion pending receipt and review of all municipal Official Plans due by 2022. The delayed expansion can then incorporate the strategy coming from the various updated Official Plans to provide a more robust protective policy for the Greenbelt and the Paris-Galt moraine.

Thank you for allowing me to share my views on the proposed draft guidance and regulatory changes.

Should you have any questions regarding my comments, please do not hesitate to contact me.

Yours truly,