I am an Ontario citizen,…

I am an Ontario citizen, resident and voter and I strongly oppose this proposal that changes the Greenbelt Act Boundary regulation to remove approximately 7000 acres from the Greenbelt Plan area. This is the proposal described in ERO #019-6217.

The removal of these lands from the Greenbelt is unnecessary. There is currently plenty of greenfield land that is not in the Greenbelt, that is already approved for residential development and is ready for immediate development. There is enough of this non-Greenbelt land for at least the next 20 years of building. This land is cheaper to develop because it is close to existing municipal infrastructure and the transit network. Thus, there would be lower infrastructure costs to developers which could be passed along to home buyers (with the resulting possibility of slightly reducing affordability). The bottom line is that the Greenbelt land is not needed to build the homes being proposed under Bill 23. There is no reason to dip into the Greenbelt and no real justification for these proposed Greenbelt Act changes.

The overall rationale that more sprawl homes are needed to solve the housing affordability crisis is grossly misguided. Housing volume does not equate to affordability. If this government truly wants to solve the affordability crisis, they should be focusing on building in greenfields and brownfields, and on increasing density in existing urban areas. Building homes on Greenbelt lands will exacerbate the problem as car-dependent, sprawl homes are more expensive to build and will contribute to even greater environmental degradation. This governments attempt to pair destruction of the Greenbelt with the affordability crisis is deceitful. This proposal has every appearance of being a payback to developer-friends of the Conservative government who bankrolled the previous election campaign with opportunity to make huge profits from land speculation and insider information.

This proposal to “swap lands” goes against the core purpose of the Greenbelt. The stated purpose of the Greenbelt is to protect a continuous, unfragmented belt of natural and agricultural lands around the urbanized Greater Golden Horseshoe. This Greenbelt sustains agricultural production of food for residents of the GGH on high quality agricultural lands and it also protects water quality (including drinking water) and quantity by protecting headwaters and groundwater aquifers that GGH residents rely on. The Greenbelt lands work wholistically as a functional unit. But this proposal intends to start fragmenting the Greenbelt, pulling patches out and adding other patches haphazardly based on convenience (read “convenience” as the holdings of developers who have speculated that this legislation will open up the Greenbelt for development) and not on sound ecology. Fragmented systems suffer irreparable damage to their functions. All pieces of land are not equal. It’s not OK to swap out one piece for another when you are relying on lands to provide significant ecosystem services.

I have reviewed the mapping for all the areas proposed for removal/redesignation and find significant and widespread discrepancies between the proposal description of the ERO posting and reality. Contrary to the claim in the ERO description, most of the land to be removed is designated Greenbelt Natural Heritage System and not Protected Countryside. Almost all the removal areas will fragment the Greenbelt and NHS, which runs against the fundamental purpose for having the Greenbelt. Also, contrary to the claim in the ERO description, none of the removal lands are serviced currently and only
two of the 15 areas are adjacent to a serviced area. Thus, service infrastructure will need to be built for all these removal areas, which makes these lands more expensive and less affordable to build on than existing approved non-Greenbelt lands (which are serviced).

While I applaud the proposal to add the Paris Galt moraine lands to the Greenbelt, it should not be conditional on the removal of other lands.

Since, in this proposal, the addition lands are compensatory for the lands removed, and since the Greenbelt Act states that the Greenbelt should retain the same overall size, I suggest that detail should be added to the Greenbelt Act boundary regulation that explicitly ties the removals and additions together simultaneously in time.

Moreover, the proposed changes to the Greenbelt Act 2005 (described in ERO# 019-6216) provide for the return of removed lands if building is not started on them by a stated timeline. Should this occur, it should not impact or cause removal of any of the Paris Galt moraine or URV lands that were added. I suggest that language be added to this proposed Greenbelt Act boundary regulation to reflect that should some removed lands be returned later, it would not affect the addition lands (i.e., they would not be withdrawn).

In a paragraph describing the conditions/timeframe for development on the removal lands, the ERO description of this proposal states, “If these conditions are not met, the government will begin the process to return the properties back to the Greenbelt.” The government should do much more than begin the process for return to the Greenbelt – it should complete the return and in a timely manner. I suggest that the proposal language be clarified to state that the government will return the land back to the Greenbelt and the timeframe for this return.

To conclude, I strongly oppose the removal of any lands from the Greenbelt as it not justifiable due to the existence of plenty of buildable non-Greenbelt land. I oppose the notion that swapping out one piece of land for another is ecologically sound. And I applaud the addition of the Paris Galt moraine lands although the language of the regulation needs to provide more detail, tighten timelines and to protect added lands even if some removal lands are later returned.

Regards.
4 Dec. 2022