Comment on the Co-ordinated Review of the Growth Plan for Greater Golden Horseshoe, Greenbelt Plan, Oak Ridges Moraine Conservation Plan and Niagara Escarpment Plan

Richard StrombergManager
Ministry of Municipal Affairs and Housing
Ontario Growth Secretariat
777 Bay Street
Toronto ON M5G 2E5
Phone: (416) 325-7377
Toll Free Phone: (800) 665-1120
RE: EBR registry number 012-3256
2015 Co-ordinated Review of the Growth Plan for the Greater Golden Horseshoe, Greenbelt Plan, Oak Ridges Moraine Conservation Plan and Niagara Escarpment Plan
Dear Mr. Stromberg:
I am deeply concerned about threats to Ontario’s world-renowned Greenbelt, Oak Ridges Moraine and Niagara Escarpment. These areas protect agriculture and environmental assets, provide clean water, and support healthy communities and strong local economies.
The Greenbelt and the areas it encompasses, including the Niagara Escarpment and the Oak Ridges Moraine, are special natural landscapes that must be preserved for the benefit of present and future generations. The Greenbelt provides $2.6 billion per year in ecological services — such as water filtration, flood control, climate stabilization, waste treatment, wildlife habitat, and recreation—according to a study done for the David Suzuki Foundation.
Local food production in the Greater Golden Horseshoe is essential to maintaining a prosperous economy that generates good local jobs and healthy communities. The food and farm sector in the region contributes $12.3 billion in direct economic activity, and $35 billion annually to Ontario’s economy through the multiplier effect. The food and farm sector in the region now employ more workers than the auto industry.
Ontario will lose these benefits if the province does not take action to coordinate, strengthen and expand the Greenbelt Plan, Oak Ridges Moraine Conservation Plan, Niagara Escarpment Plan, and the Growth Plan for the Greater Golden Horseshoe.
Even though Ontario has received praise for constructing one of the world’s largest greenbelts, the loss of farmland is accelerating. The province loses 350 acres of farmland every day according to data compiled by Ontario Farmland Trust using 2011 Census of Agriculture data. Far too often municipalities consider our farmland to be development lands in waiting. At current rates of farmland loss, Ontario has the potential to lose food self-sufficiency within the next 25 years.
In order to maintain food security and rural economies, Ontario must take bolder action to protect farmland and source water regions. The province must address the issue of leapfrog development. We need to maintain the existing Greenbelt and expand its borders. New development should take place within existing urban boundaries, and transit should be prioritized over new highway construction, which facilitates sprawl.
We must also ensure that areas outside the existing Greenbelt (but included in the Growth Plan)—particularly in the Waterloo, Brantford and Simcoe County areas—that are facing pressure for growth receive the balanced planning and ecological protection they require. Since 80 percent of the farmland and natural systems in southern Ontario remain unprotected, Ontario must provide permanent protection for prime farmland across the province.
The province must close loopholes that threaten protected areas. Far too often development projects such as the Midhurst Mega-development and the York Energy Hub/Holland Marsh Peaker Plant receive special deals to proceed. The placement of highways, aggregate mines, pipelines, large energy projects, contaminated soil fill, and major urban infrastructure projects should not take place in the Greenbelt and in protected areas. Cumulative impacts from increased development are degrading Ontario’s water quality, our natural systems and biodiversity.
I strongly urge the Ontario government to take this opportunity to further protect our clean water resources, farmland and natural heritage for present and future generations.
Specifically, I urge you to work to:
1. Stop sprawl from eating our farmland

  • Do not remove land from the existing Greenbelt boundaries. The only changes to existing boundaries in the 2015 review should be to expand the Greenbelt’s borders;
  • Permanently protect prime land starting with a 10-year moratorium on new rezoning applications that involve non-farming development on prime farmland;
  • Protect farmland by moving class 1 and 2 soils currently in the whitebelt to the Greenbelt, especially since the Neptis Foundation study showed that there is more land designated by municipalities for development in the whitebelt than will be needed for generations;
  • Stop sprawl and inappropriate development—including but limited to highways, energy infrastructure, pipelines, and urban services—in the Greenbelt, Oak Ridges Moraine and Niagara Escarpment that will destroy prime farmland, woodlands, wetlands, as well as wild animals and plants at risk of extinction;
  • Prioritize the preservation of farmland, natural heritage and clean water over aggregate extraction;
  • Support access to local food by opposing plans to develop a new airport on prime agricultural land near Pickering;
  • Expand buffers to protect farming from urban development;
  • Allow farm operations to include appropriately scaled value-added local food operations where there is adequate on-site water and septic services;
  • Pay farmers for producing environmental good and services that benefit society.

2. Protect our water

  • Protect source water regions by preventing development in source water areas;
  • Require complete and up to date watershed plans by all municipalities across all four plan areas;
  • Increase the size of buffers along watercourses in urban areas;
  • Require a water budget, a conservation plan, a monitoring plan and a stewardship strategy for improving water quality;
  • Ensure the timely approval of Storm Water Risk Assessment Reports and management plans and the complete mapping of infiltration zones and vulnerable aquifers across the entire Greenbelt;
  • Work with the Ministry of Environment and Climate Change to revise the Permit to Take Water process to prioritize drinking water and agriculture over other uses in granting water taking permits;
  • Monitor cumulative impacts for water quantity and water quality, including the capacity to receive sewer effluent by receiving bodies;
  • Stop contaminated soil from being dumped near Ontarians’ sources of food and water.  

3.  Look at a map to improve natural heritage protection

  • Freeze urban boundary expansions for 10 years;
  • Increase intensification targets in Urban Growth Centres;
  • Grow the Greenbelt by supporting connections to adjacent agricultural and natural heritage areas, especially those with key ecological and hydrological value to the Greater Golden Horseshoe such as the Paris Galt Moraine, the Oro Moraine, the Waterloo Moraine, Lake Gibson, and the Lake Iroquois Shoreline;
  • Designate as Greenbelt lands, the urban river valley lands where the Municipal Council has adopted a resolution to include lands in the Greenbelt including: the City of Mississauga, the Town of Oakville, the City of Guelph, the City of Toronto;
  • Make regional growth allocations consistent with existing sewer, water, road, and transit capacity;
  • Map all natural heritage systems and class 1,2 and 3 agricultural lands in the Greenbelt and Growth Plan areas;
  • Use the mapping to identify and designate extensions of systems beyond the plan area;
  • Ensure that the Niagara Escarpment Plan area boundaries are based on updated natural heritage data;
  • Provide one definition for natural heritage across all four plans;
  • Protect, restore and enhance the ecological integrity of natural heritage systems and hydrological systems within the Greater Golden Horseshoe;
  • Do not allow any new or the expansion of existing pits and quarries in core natural heritage and prime agricultural areas or below the water table;
  • Existing aggregate operations should only continue and new projects should only be considered (outside of key areas) if they have comprehensive rehabilitation plans in place, including a timeline for pit closure and dedicated funds to ensure rehabilitation that maximizes natural heritage values;
  • Require the recycling of aggregate and asphalt, not in in core natural heritage and prime agricultural areas, but rather directed to industrial (indoor) areas in urban areas where air quality and noise issues can be controlled.

4. Build strong, livable communities where we can live, work, play and travel

  • Do not build new highways in the Greenbelt, Oak Ridges Moraine and Niagara Escarpment;
  • Prioritize investments in public transit and highway maintenance over new highways;
  • Increase and electrify Go Train service and better co-ordinate Go Train services with local transit;
  • Provide local infrastructure to support expansion of Go Trains by increasing parking spaces and making connections to active transportation routes;
  • Revise Growth Plans to ensure that municipalities balance population growth with employment growth;
  • Create walkable, cycling neighbourhoods in cities and towns that are linked by transit;
  • Expand trails system in the region and require municipalities to develop trail master plans;
  • Require recreation uses in protected areas to be low impact;
  • Change the definition of public infrastructure to incorporate green infrastructure.

5. Fight climate change

  • Strengthen the Environmental Assessment process to require that “need” be established, take into account climate change impacts, and require more public input into the EA process;
  • Require that provincial and municipal growth plans contain a Climate Action Plan to reduce GHG pollution and climate adaptation plans in order to support more resilient communities;
  • Require analysis of the effects of upstream and downstream GHG emissions on the province’s GHG reduction targets of all new infrastructure projects (e.g., pipelines, highways, subdivisions) built in the Greater Golden Horseshoe.

6. Get the investment formula and governance right

  • Close loopholes and address policy gaps to better achieve the goals and visions set out in each of the four plans;
  • Provide better enforcement of the four plans, and monitor implementation of the plans;
  • Provide better coordination of the four plans;
  • Develop a mechanism to provide oversight of municipalities and Conservation Authorities to ensure consistent interpretation, monitoring and evaluation of the four plans;
  • Revise existing Growth Plan policies to assign responsibility for the identification and protection of a regional natural heritage system across the Greater Golden Horseshoe to the Minister of Municipal Affairs and Housing;
  • Although outside the scope of this review, I strongly urge the government to significantly overhaul or eliminate the Ontario Municipal Board; its decisions have a major (often negative) impact on the areas directly affected by the joint review;
  • Shift taxes from labour and productivity to resource use, pollution levies, and land value levies in order to create incentives to use land and resources more efficiently, reduce pollution, create disincentives for sprawl and ensure that developers pay for the real cost of growth;
  • Increase royalty rates and levies for aggregates, water taking, and mining in the region.

Ontario has a historic opportunity with this join review to implement stronger protections for the places we love for present and future generations. I appreciate the government’s efforts to seek public comment and engagement on these important issues.
On behalf of Green Party of Ontario members and supporters, I want to thank you for your time and consideration of our recommendations. I’m happy to answer any questions or provide additional information.
Mike Schreiner
Green Party of Ontario