Comments on Proposed…

Comments on Proposed Amendments to the Greenbelt Plan, November 4, 2022 (ERO number 019-6216)

The proposed removal and subsequent development of 7500 acres (3035 hectares) from the Greenbelt Plan will:
1. degrade and in some cases destroy vital provincial scale wildlife corridors;
2. negatively impact and destroy over 2000 acres of valleys, woodlands, wetlands, meadows and watercourses;
3. develop and destroy over 5000 acres of largely prime farmland and lands designated Niagara Peninsula Tender Fruit and Grape Area;
4. encourage car-dependent urban sprawl at a time when we should be encouraging intensification in transit-oriented existing urban areas if we are to meet our climate targets.

The government is proposing to remove17 areas from the Greenbelt Plan including one area within the critically sensitive Oak Ridges Moraine. The majority of the 7500 acres being removed are all in one area that is located on highly sensitive and ecologically important lands in the City of Pickering. This triangle of land at its widest point extends east-west for five kilometres between the Rouge River and Duffins Creek Watersheds, and stretches south to north for 7.8 kilometres from just north of Finch Avenue to Highway 407. It supports thousands of acres of largely prime farmland, numerous valleys, woodlands, wetlands and the entire critical headwater reaches of Petticoat Creek. These lands have major provincially designated wildlife corridors designed to provide east-west connections between the Rouge, Petticoat and Duffins Creek watersheds and north-south connections along the river valleys that connect Lake Ontario to the major east-west corridor of the Oak Ridges Moraine. The southern portion of this area also supports a highly sensitive band of wetlands and woodlands that is a recharge and discharge area on the former sandy beach of Glacial Lake Iroquois, a large version of today's Lake Ontario.

Of the 17 areas that are proposed for removal from the Greenbelt Plan,14 of them will be within lands the Province has designated as natural heritage systems or wildlife corridors that were supposed to be off limits to subdivisions and commercial or industrial development. The removal of areas from these wildlife corridors will result in negative impacts to their ecological functions and to the natural areas within these corridors and decreased opportunities for these lands to become parkland with public trails to be used by the citizens of Ontario. The proposed removals will result in parts of these wildlife corridors being reduced in width by one-third to two-thirds, including major valley corridors in the Rouge and Humber watersheds. These corridors were designed by provincial ecological experts to provide for a connected system of natural areas across the Greenbelt Plan and on the Oak Ridges Moraine. The largest corridor is a minimum of 2 kms wide across the 160 kilometre length of the Oak Ridges Moraine, our largest east-west corridor in southern Ontario. The Moraine's aquifers are the source for all our major rivers flowing south to Lake Ontario and north to Lake Simcoe and the Kawartha Lakes. In the Greenbelt Plan, these major river corridors are a minimum of 600 metres with smaller side tributaries 300 metres wide. The aim is to encourage over time restoration of more woodlands and wetlands between the existing natural areas in these corridors so they can function as more fulsome wildlife areas that can support Ontario's diverse animals and plants, including its sensitive woodland, wetland and meadow species . These corridors will also over time support public parklands with a connected network of public trails. We are currently experiencing a shortage of parkland around the GTA's urban centres that are easily accessible for outdoor passive enjoyment. Since COVID, many of our existing parks have experienced over a 200% increase in use resulting in negative impacts to their vegetation, wildlife and trails. With the added growth of the GTA's population we will need many more parks to ensure the public can enjoy nature and at the same time have healthy natural areas and wildlife.

The government's addition of a portion of the Paris/Galt Moraine to the Greenbelt Plan is to be commended. This addition should not just have a countryside designation, and a rural settlement designation for the hamlet of Brisbane. It should also have a natural heritage system designation that connects up the natural areas into fully connected broad corridors as was done for the Greenbelt Plan and Oak Ridges Moraine Conservation Plan.

The addition of the Paris/Galt Moraine to the Greenbelt Plan should not be done at the expense of removing 7500 acres of vital Greenbelt areas within the GTA and Hamilton. I am opposed to any removal of lands from the Greenbelt Plan and strongly support a much greater expansion of the Greenbelt Plan to include all of the surrounding Greater Golden Horseshoe. The province has already designed a connected natural heritage system of wildlife corridors for this expanded area. They now need to be protected from development that could break up these connected systems into isolated patches to the detriment of its wildlife and the public that will use them for outdoor enjoyment. The argument that these areas had to be removed from the Greenbelt to accommodate the promise of 1.5 million homes over the next 10 years is false. These homes can be accommodated in our existing urban areas by means of intensification and in the existing white belt. There is no need to take land out of Greenbelt.

Specific Comments on Each Greenbelt Removal By Map Number

Map 1
It is proposed to remove a large 1.4 by 1.2 kilometre block of the Greenbelt Plan and a portion of the Oak Ridges Moraine Conservation Plan and convert it into subdivisions. The lands occur in King Township, southwest of Miller's Sideroad and Bathurst Street. This development would occur on a provincially designated wildlife corridor that cuts north-south through this area and on either side of this corridor prime farmland that was supposed to be protected in its original rural and countryside designations. The natural heritage system corridor that will be impacted is aligned along a band of woodlots and wetlands around a tributary of the Holland River. This corridor provides a vital connection between the large core natural area of Glenville Hills on the Oak Ridges Moraine to the south and the Holland Marsh to the north.

Map 2
It is proposed to remove two areas from the Greenbelt Plan that are northeast of Pine Valley Drive and Teston Road in the City of Vaughan. These two areas occur entirely within a natural heritage system corridor that supports a valley of the East Humber River and a population of the endangered fish, the Redside Dace. It would reduce the width of this valley corridor from 350 metres to only 200 meters and bring subdivisions right up to the edge of a sensitive forested valley. It would also reduce the area of public parkland and take away tablelands that would have had a public trail.

Map 3
It is proposed to remove two areas in the City of Richmond Hill northwest of Highway 404 and Elgin Mills Road. Both areas occur entirely in a dedicated natural heritage system that supports a Rouge River valley corridor and a large wetland that is part of the provincially significant Rouge River Headwater Wetland Complex. These removals will reduce the width of this valley corridor from 270 metres to only 100 metres wide and will bring development right up to the edge of the valley and its provincially significant wetland. To develop the eastern property that is being removed from Greenbelt, will require the extension of McCague Avenue right though the middle of this 80 metre wide provincially-protected wetland and over a river that supports a population of the endangered fish, the Redside Dace.

Map 4
It is proposed to remove three areas from the City of Markham that occur entirely in the most protected Natural Heritage System designation.

The western triangle of land proposed for removal is situated northeast of 19th Avenue and McCowan Road. It will reduce by half the width of a major 600 metre wide Little Rouge Creek corridor that provides a critical wildlife link to the Oak Ridges Moraine to the north and the Rouge National Urban Park to the south. This corridor was also supposed to become an important public corridor that will support a trail to connect up with those on the Moraine and in the Federal Park. The removal of this triangle of land will degrade this wildlife corridor and bring subdivisions closer to the edge of this valley and thus restrict the opportunity for a public trail and restored natural areas on the tableland.

The other two areas proposed for removal occur further to the northeast and are situated along a tributary corridor of Little Rouge Creek that connects north to the Oak Ridges Moraine. If removed these two areas will narrow this 200 to 300 metre wide wildlife corridor by a third to a half. It will destroy several wide treed hedgerows and bring subdivisions right up to the edge of this valley and thus restrict the opportunity for a public trail on the tableland.

Map 5
The four additional areas proposed for removal from Greenbelt in the City of Markham also occur entirely in the most protected Natural Heritage System designation.

A western area proposed for removal is situated mid-concession block, northwest of McCowan Road and Major Mackenzie Drive East. The area to be removed is located right in the middle of a large wildlife corridor at the sensitive headwaters for Robinson Creek, a tributary of the Rouge River. This corridor supports a large cluster of provincially significant wetlands, including Robinson Swamp, the largest swamp in all of Markham, This removal will allow a 900 metre-long band of subdivisions to be built on a narrow strip of farmland between highly significant woodlands and wetlands. It would foreclose the opportunity to make this area a large regional park with this intervening narrow band of farmland reforested to make one large natural area that could support many area-sensitive animals. It would be one of the premier parks in the City of Markham. All these benefits would be foreclosed by allowing subdivisions into the heart of this wildlife area.

Further to the east, on either side of Markham Road and north of Major Mackenzie Drive East another three areas proposed for removal will cut into the major Little Rouge Creek valley corridor that provides a critical wildlife link to the Oak Ridges Moraine to the north and the Rouge National Urban Park to the south. It was also intended to become an important public corridor that will support tableland trails to connect up with those on the Moraine and in the Federal Park. The removal of these three areas if approved will result in narrowing this corridor down from 600 metres to 200 metres. It will result in subdivisions coming right up to the edge of this forested valley corridor and preclude or severely limit the possibility of having a public trail on this tableland.

Map 6
By far the largest area being proposed for removal from Greenbelt is located on a triangle of highly sensitive and ecologically important lands on the northwest side of the City of Pickering. Its widest point in the south extends east-west for five kilometres between the Rouge National Urban Park and Duffins Creek valley, and stretches south to north for 7.8 kilometres from just north of Finch Avenue to Highway 407. These lands are designated protected countryside with a network of natural heritage system corridors. They support thousands of acres of largely prime farmland, and in the extensive natural heritage system there are numerous valleys, woodlands, wetlands and the entire critical headwater reaches of Petticoat Creek. There are major provincially designated wildlife corridors designed to provide east-west connections between the Rouge, Petticoat and Duffins Creek watersheds and north-south connections along the river valleys that connect Lake Ontario to the major east-west corridor of the Oak Ridges Moraine. The southern portion of this area also supports a broad band of wetlands and woodlands that is a highly sensitive recharge and discharge area on the former sandy beach of Glacial Lake Iroquois, a large version of today's Lake Ontario. It is critical to the health of the Rouge River, Petticoat Creek and Duffins Creek Watersheds that these lands be protected from development. Their development, kilometres away from the developed portions of the City of Pickering to the south, will only encourage urban sprawl.

Map 7
This area removes a 600 to 900 metre block from an 800 meter wide band of protected countryside in Greenbelt that demarcates the eastern border of Ajax and Whitby. This protected band of farmland provides a critical physical and visual break between the two municipalities. It also provides a connection between the large lakeshore park of Lynde Shores with its coastal wetlands and woodlands and, to the north, the very large block of woodlands and wetlands along the former beach of Glacial Lake Iroquois. This removal will result in this corridor being reduced for almost a kilometre to only a 200 metres wide strip from its former 800 metres.

Map 8
This 1 km long by 200 to 400 metre wide area proposed for removal from Greenbelt is situated in the Municipality of Clarington northwest of Hancock Road and Nash Road. The northern third contains a designated Natural Heritage System that supports a large provincially significant treed wetland and on the designated protected countryside to the south there is farmland and two woodlots. This entire area is in a highly sensitive groundwater recharge and discharge area that is part of the former beach of Glacial Lake Iroquois, a larger version of today's Lake Ontario. Such an ecologically sensitive area should not be turned into a subdivision. It would entail the destruction of a large provincially significant wetland that is supposed to be protected from development.

Map 9
The large area proposed for removal from Greenbelt is located in the City of Hamilton south of Garner Road West and between Shaver Road and Fiddlegreen Road. It covers and area of one and a half concession blocks that are 3 by 2.5 kilometres in size. The middle of this area is a dedicated natural heritage system that captures a series of large woodlots and wetlands along a sensitive headwater tributary of Big Creek. To either side of this wildlife corridor there is prime farmland. Its development into a subdivision ill result in the loss of prime farmland and a sensitive headwater natural area.

Map 10
This area proposed for removal from Greenbelt is situated in the City of Hamilton with Regional Road 65 on the northside and between Ferris Road and Upper James Street. It covers a rectangle of 500 metres by 1.2 kilometres. The lands are designated Protected Countryside and Niagara Peninsula Tender Fruit and Grape Area in recognition of the importance of the Niagara Peninsula for these specialty crops. It is largely in farmland. Natural features include four tributaries of the Welland River with a few wetlands along them and a woodlot. Development of this area, which is not next to an urban centre, will only encourage urban sprawl and result in further loss of lands that can support specialty crops.

Map 11
The rectangular area of 700 by 300 metres proposed for removal from Greenbelt occurs in the Town of Grimsby. It is situated in a block on the northside of Highway 8 between Kelson Avenue North and Oak Road North. The lands are designated Protected Countryside and Niagara Peninsula Tender Fruit and Grape Area in recognition of the importance of the Niagara Peninsula for these specialty crops. In addition to this farmland, the area also supports a watercourse and a small woodlot. Development of this area, which is not next to an urban centre, will only encourage urban sprawl. It will also bring subdivisions right up to the edge of the Niagara Escarpment Planning Area and result in further loss of lands that can support specialty crops.