Recent findings from Ontario’s Integrity Commissioner are a timely reminder of why we need to place clear guardrails in this year’s legally mandated review of the Greenbelt Plan. Without strict terms of reference that forbid removal of current Greenbelt land or weakening of its current protections, Ontarians have reason to worry the review process will be little more than a new way to enable the same kinds of “land-swaps” that were the subject of the scathing Auditor General’s report and which remain the subject of an RCMP investigation.
At its core, the ongoing Greenbelt scandal is about the government stripping away permanent protection from Greenbelt land at the request of sprawl developers, all while falsely representing the removals (and other opening of farmland, forests and wetlands to sprawl) as part of a strategy to increase housing supply.
These claims were disingenuous because the Ontario government already knew at the time that there was a huge amount of undeveloped land (roughly 350km2 in the Greater Toronto and Hamilton Area alone) already designated for building within towns and cities, all of which had been sitting unused for years. In fact, housing supply experts and advocates actually warned that Greenbelt removals and settlement boundary expansions would result in fewer homes built, not more.
The Integrity Commissioner’s latest findings reveal some of the illegal tactics lobbyists used to disguise the fact that their clients’ financial interests – and not any actual need for more development land for housing- were actually the impetus for trying to dismantle the Greenbelt. Lobbyists broke the law by omitting from mandatory public filings the fact that their meetings with government officials – including with the Premier, were actually requests to take apart the Greenbelt. This made it much easier for the public to accept false claims by the government that the notion of removing land from the Greenbelt was genuinely part of a plan to increase housing supply.
Review Process Guardrails
The Greenbelt Act’s mandatory 10-year review process is supposed to be a mechanism to identify and fix weaknesses in the Greenbelt’s protective policies and add additional land where needed. But the review process, including public hearings, written submissions, and consultations with municipal governments, could easily be co-opted as a way to give more land to well-connected speculators.
To prevent this any consultations about Greenbelt boundaries – and the boundaries of special protected zones within the Greenbelt, should be restricted, right from the outset, to adding land and increasing protection.
Removing land from the Greenbelt (or shifting Greenbelt land to less-protective categories) should be entirely off the table, and the review should not accept submissions that request such removals.
The Greenbelt Review should be explicitly mandated to recommend measures that increase the certainty that both natural heritage features and agricultural land will continue to be used for those purposes. Any submissions, requests or recommendations that would make it easier or more permissible to convert farmland, forest, wetlands or hedgerows to other uses or to reduce their agricultural or habitat value, should be explicitly excluded from consideration.
These restrictions must apply to consultations with municipalities, as the government has already shown how it exploits “requests” from municipal politicians as cover for backtracking on its promises to curb sprawl.
The review should be explicitly directed to conduct in itself in a manner which restores and maintains public confidence – and confidence among landowners and agricultural tenants, in particular – that none of the land in the Oak Ridges Moraine Area, Protected Countryside or the Niagara escarpment will ever be made available for any development or activities that don’t maintain, improve or restore its ecological and hydrological functions or agricultural use.
What the review must do
Rather than using the Greenbelt Review to repeat its attempt to dismantle it, Ontario’s new Minister of Municipal Affairs and Housing should use it to repair the damage his two most recent predecessors have caused, fixed vulnerabilities revealed over the past 10 years, and strengthen the Greenbelt’s mandate to reflect its vital role in solving new problems.
- In particular, the Greenbelt Review should be charged with closing loopholes, including:
- Gaps that have been exploited to allow new uses, like major new highways and parts of new sprawl subdivisions (e.g., access roads, stormwater retention ponds) that destroy the environmental or agricultural values of Greenbelt lands.
- Ambiguities that have allowed land speculators to destroy hedgerows and other features of environmental value on tenant farms they’re hoping to eventually convince the government to remove from the Greenbelt
- The Greenbelt Review should also be charged with expanding the Greenbelt Plan Area, and the Agricultural System and Specialty Crop Areas to reflect its role in preventing any reduction in Ontario’s overall agricultural land base and maintaining our ability to feed ourselves in the face of United States use of “economic force” to threaten Canada’s sovereignty.
- That expansion mandate should encompass: Countryside on the outskirts of city and town settlement boundaries that has become vulnerable since the government’s repeal of the Growth Plan for the Greater Golden Horseshoe, and Provincial Policy Statement, and their controls on suburban sprawl.
- Farmland, forest and hand on the outer edges of the current Greenbelt Plan Area that are now, or are likely to become, targets for leapfrog sprawl associated with the GTHA.
- Fingers or patches of non-Greenbelt land that, if converted to residential, commercial, or industrial uses, would partially or completely surround Greenbelt farmland or habitat, and potentially undermine its viability.
- The Greenbelt Review should be tasked with expanding the Greenbelt Plan Area to protect water supplies for all of the Greater Golden Horseshoe and Southwestern Ontario, with a particular emphasis on the groundwater recharge areas for municipalities and agricultural lands that depend upon groundwater.
Environmental Defence is committed to protecting and expanding the Greenbelt. We’ll be keeping an eye out for when the review process kicks off and continue our work to advocate for closing loopholes and protecting our farms, forests and wetlands and planning for better, more livable cities and towns.
