Coalition response to province passing Bill 23

Media Statement

November 28 - Simcoe County

Today, local Conservative MPPs voted to pass Bill 23 against the best advice from municipalities, Conservation Authorities, farming organizations, housing advocates, environmentalists, planners and civil society. Make no mistake, the changes in Bill 23 do not address the housing affordability crisis, rather they will simply put more money into the pockets of billionaire developers at the expense of Ontarians and the natural resources we depend on.

This legislation was passed despite massive opposition from citizens across Ontario, including here in Simcoe County, who want the housing affordability crisis addressed while we address social and environmental crises. Rallies over the past weeks have been held in dozens of communities, outside MPPs offices, and many more wrote letters and contacted their MPP by phone and email asking them to stop Bill 23.

At the rallies many local citizens came to protest for the first time because they felt that the concerns of the vast majority of Ontarians, as well as experts in housing, planning, and the environment, are not being heeded by this government. These people believe in the value of public participation, in the power of people – in democracy – and so do we.

Despite the fact that this bill has been passed, the power and unity shown around the region – and province as well – will not be dying out any time soon. In fact, the number of people who came to the rallies, who wrote letters to the editor and emails to their MPP, are a clear sign that people are awakening to the self-interested ideology of this government. Ontarians have seen fully and clearly that this government is willing to break faith with the people of Ontario and the things that have benefited us all, our healthcare, our education, our labour strength, and our environmental stewardship.

Our region is full of strong and caring people, and we are creating a movement that will overcome these challenges to build a positive future together. No bill or undemocratic dealings such as this will stop that.

A democracy is a tool of the people.

We will continue to wield it.

We will continue to build and unify for the long term.

Most importantly, we will remember who led with the people in mind and those who were beholden to deep pockets.

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Community supported, advocacy for a safe and secure future.

Governments have failed to act to protect our communities and the futures of our children and grandchildren, and they continue to treat our environment as if it’s incidental to life, rather than a foundation for it.

We need strong community organizations to fight for our future, now more than ever.

Please consider donating to support our work. It’s people like you who make us possible.

Subscribe to Our Newsletter

We send out a once-monthly newsletter full of information on what’s happening in Simcoe County and beyond, including information on how you can take action to protect the health of your community.

Highways are the gateway drug for sprawl and the Bypass is a perfect example. 

Press Release

FOR IMMEDIATE RELEASE

Province rushing Bradford Bypass shows more concern for politics than Lake Simcoe, climate or affordable housing

Bradford – This morning the province announced that it is awarding a contractor for the early works construction for the Bradford Bypass.  These early works are allowed to begin before studies are completed, thanks to an exemption the province gave itself last October. Mulroney announced that construction of the bridge over Yonge Street could begin later this year.

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Rendering of what a four-lane highway bridge could look like crossing the East Holland River. Credit Simcoe County Greenbelt Coalition.

Gord Miller, the former Environmental Commissioner of Ontario, characterized this provincial exemption in a recent webinar, saying:

“This is a violation of international standards. It’s widely recognized that when you’re doing an assessment of an initiative you don’t start until you’ve at least measured all of the impacts to the best of your ability so you can make a rational decision. They are clearly violating that.”

“Highways are the gateway drug for sprawl and the Bypass is a perfect example. Developers own over 3000 acres of land around this highway waiting for the greenlight to destroy more farmland and wetlands.

York Region is planning on destroying 24,589 acres of farmland for new development by 2051, and the Bypass would facilitate the worst of this sprawl in East Gwillimbury.

Supporting the Bypass is contrary to building compact and affordable housing, a healthy Lake Simcoe, a productive agriculture sector and climate action,” says Claire Malcolmson, Executive Director of the Rescue Lake Simcoe Coalition. 

Although no one in the government has confirmed the price of the highway, estimates show that Ontarians will be paying anywhere from $800 million to $2.2 billion for this 16 km, 400 series highway. 

This leads opponents to declare that this is a waste of funds that could be better spent elsewhere.

Bill Foster, founder of Forbid Roads Over Green Spaces says, “We are in the sixth wave of the pandemic and our healthcare and education systems are in dire need of investment. 

A destructive highway through the Greenbelt that will pollute Lake Simcoe, a regional economic driver,  is a wasteful and dangerous way to spend limited tax dollars. 

We could save a very small portion of the province a few minutes in driving time or we could provide better healthcare, more nurses, better senior care and more childcare spaces. 

The fact that two Greenbelt highways – the Holland Marsh Highway and Highway 413 – are Premier Ford’s major election planks,  speaks volumes about his priorities to me.” 

Opponents are gravely concerned about how adding more fossil fuel infrastructure will exacerbate the climate crisis.

Margaret Prophet, Executive Director of the Simcoe County Greenbelt Coalition, “Yesterday, the International Panel on Climate Change outlined how important it is to reduce transportation emissions and how urban areas need to lessen their investment in car dependent infrastructure.  Yet, today, we get a doubling down on a Greenbelt destroying highway that clearly contradicts the spirit of what climate scientists are telling us we need to do. 

It’s clear there’s no intention here to tackle climate change seriously.  We’re still pulling from a 1950s playbook of economic development that created all of this mess to begin with. 

This highway is destructive and costly and it will lock in a style of development that will negatively impact our collective health forever and decision makers don’t seem to care.”

Background

IPCC Report about Transportation (See 10.3)

How Could We Invest This Money Differently?

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Arial photo of the Holland Marsh, with Lake Simcoe in the distance. Credit Jeff Laidlaw.

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Community supported, advocacy for a safe and secure future.

Governments have failed to act to protect our communities and the futures of our children and grandchildren, and they continue to treat our environment as if it’s incidental to life, rather than a foundation for it.

We need strong community organizations to fight for our future, now more than ever.

Please consider donating to support our work. It’s people like you who make us possible.

Subscribe to Our Newsletter

We send out a once-monthly newsletter full of information on what’s happening in Simcoe County and beyond, including information on how you can take action to protect the health of your community.

Statement on Province’s Consultation to Expand the Greenbelt

The Province is opening consultations on growing Ontario’s Greenbelt. SCGC, along with 90 other organizations, plus a number of prominent individuals, have released a report in response.

For immediate release:

Steve Clark, Minister for Municipal Affairs and Housing, announced this morning that the province is opening a consultation about Greenbelt expansion.  Specifically, it was suggested that the Greenbelt be grown over Urban River Valleys and to protect the Paris-Galt Moraine.

The Simcoe County Greenbelt Coalition and allies across the region and province have strongly advocated for the expansion of the Greenbelt since 2017. In fact, over 90 groups including prominent individuals such as David Crombie released a report earlier today which outlines five requirements the provincial government must follow to ensure that Greenbelt expansion improves the environmental and financial health of Ontarians:

  1. Retain all lands currently protected within the Greenbelt;
  2. Build on the science and public consultation carried out during the recent boundary expansion review;
  3. Simultaneously address public health, local food security, water security, climate resilience, biodiversity conservation and economic prosperity;
  4. Acknowledge that there is more than enough land available to both expand the Greenbelt and build complete communities in the Greater GoldenHorseshoe;
  5. Consult meaningfully with Indigenous communities.

Margaret Prophet, Executive Director of the Simcoe County Greenbelt Coalition says, “In early 2018, we participated in the province’s consultation to expand the Greenbelt into Simcoe County.  It was clear then that our aquifers, forests, shorelines and wetlands needed to be off limits to sprawl. 

At that time, the province agreed and proposed expansion plans were ambitious for this area.

Three years later, the only thing that has changed is that the threats have increased as policies that protect our natural spaces from sprawl and protections for endangered species have weakened considerably. 

We have seen development applications threaten provincially significant wetlands, floodplains, pristine forests all while our local lakes and rivers become increasingly sick. 

We have reports from local Conservation Authorities that predict with a changing climate, we may see sources of water run dry and may not be able to keep up with current demand. 

So if this government is truly serious about protecting Ontarians it is time to be genuine with that and ambitiously expand the Greenbelt to stop greed from threatening our water supply with overzealous sprawl.”

Map showing where the Greenbelt should be grown to, and where the government is proposing growth, outlined in yellow.
Map showing where the Greenbelt should be grown to, and where the government is proposing growth, outlined in yellow.

The Message to the Government is Clear

The message to the government is clear: our water and environment is a shared heritage and should not be sacrificed to benefit a few; water is core to our identity as Ontarians; the Greenbelt has been successful in protecting landscapes and water for over 15 years; and people care about their communities and want to see them succeed in a way that ensures they continue to be healthy and vibrant into the future. 

We feel that includes expanding the Greenbelt over landscapes that provide drinking water and help us adapt to climate change.

We look forward to continuing to build a better Simcoe County and working with the government to recognize that if they are true to protecting Ontarians into the future, their Greenbelt expansion need to grow accordingly.

How Can You Get Involved?

  1. Submit a comment to the ERO Posting.
  2. Share your concerns on social media.
  3. Sign up to our newsletter to stay informed on developments with growing the Greenbelt and limiting sprawl.

Links to Further Reading

Help us grow the Greenbelt.
Take action to help grow Ontario's Greenbelt and protect our environment for the future.
Click Here

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Dear MPP Downey, MPP Dunlop and MPP Mulroney,

In December of 2022, you and your cabinet colleagues signed off on removal of 7400 acres of Greenbelt lands.

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Open Letter - Ramara Must Officially Rescind Request for MZO

Ramara has requested a MZO for developments in the Rama Road Corridor. Without an official letter from the municipality rescinding that request it remains in play.

Dear Mayor and Council.

As you are aware, we have grave concerns about the power of Minister’s Zoning Orders (MZO) – how they cut out public consultation and undermine the role that environmental studies play in ensuring developments don’t result in a net loss of value to the public, being two key issues.

The use of a tool that is as blunt and powerful as a MZO is especially concerning in places where landscapes and watersheds are shared, with their ecosystems or flows extending beyond a single jurisdiction.

Image showing the watersheds in and surrounding Lake Simcoe and Simcoe County.
Image showing the watersheds in and surrounding Lake Simcoe and Simcoe County.

Return to the Planning Process

To ensure development provides a benefit to the community, by which we mean both our human communities and the natural communities that we are a part of and rely upon, it is crucial that they meet a high level of rigour in determining their ‘fitness’ in a given location. Projects such as what is proposed for the Rama Road Corridor must, at minimum, meet the requirements set out under the Planning Act process.

MZOs Cause Inconsistency and Confusion

Confusion remains, however, regarding whether a MZO has been requested by Ramara for projects in the Rama Road Corridor. Our coalition was relieved to hear, during the Orillia special meeting this week, that Ramara does not want to proceed with a MZO request.

It is important to be very clear that the Township of Ramara has initiated a MZO request, and that until and unless Council officially rescinds this request with a letter to the Minister, this request stands.

Ramara Has Requested a MZO

The fact that Ramara has initiated a MZO request, which is all that is required since there is no formal application process outlined under Section 47 of the Planning Act for MZOs, is evidenced by the following:

First, a motion was passed by the Township of Ramara on November 2, 2020. In item 6.1 of the agenda council passed a motion to allow Mayor Clarke to sign a letter to accompany the Rama Road Economic Employment District package. Although the letter does not mention a MZO application in its body, within the package the request for a MZO for this project was bluntly stated:

“The municipality is requesting that the Minister ​enact​ a Minister’s Zoning Order for the three proposed developments in order to commence the growth and development within the Rama Road Corridor.”1Township of Ramara. Minutes of the Committee of the Whole Meeting Dated: Monday, November 2, 2020.​ ​(Emphasis added.)

With a motion of council to endorse this package, it most certainly can be considered an official municipal request for a MZO. Further, it doesn’t state it wants to explore a MZO discussion or open up the feasibility of a MZO, but enact one.

Simcoe County Has Backed This Request

Second, a request was made by the Township of Ramara to the County of Simcoe Council to endorse Ramara’s MZO request.

It first went to the Committee of the Whole on November 10, 2020. Mayor Clarke moved a motion “that the County of Simcoe supports the letter dated November 3, 2020, titled Rama Road Economic Employment District.”2County of Simcoe. Minutes of Committee of the Whole Meeting Dated: Tuesday, November 10, 2020.​ As a reminder, this letter accompanies the ​Rama Road Economic Employment District package which explicitly requests a MZO to be enacted.

Screenshot of the section of the Rama Road Corridor Package that requests a MZO.
Screenshot of the section of the Rama Road Corridor Package that requests a MZO.

Next, this recommendation was brought forward to County Council at a Joint Committee of the Whole and Council Meeting on November 24, 2020. From there, Resolution 2020-705 was passed by County Council which resulted in a letter dated December 7, 2020 to MMAH Minister Steve Clark from the County of Simcoe. The body of this letter further outlines that, in fact, a request to enact a MZO was made by Ramara Township AND that County Council supports their request:

Recommendation CCW-132-20

“That the County of Simcoe supports the letter dated November 3, 2020, titled Rama Road Economic Employment District.”

The County of Simcoe is pleased to inform you [Minister Steve Clark] that County Council supports the above proposal within the Rama Road Corridor, in the Township of Ramara, and their request for a Minister’s Zoning Order.”3County of Simcoe. Letter to Minister Clark – Subject: Township of Ramara – Rama Road Economic Employment District: Request for Ministerial Zoning Order (MZO

Only Approval Left Is By Province

Ramara’s MZO request now has two – township and upper tier – of the three approvals it needs to proceed. ​The only approval authority remaining is the province.

Evidently, if Ramara is reconsidering its MZO request for the Rama Road Corridor, then it is clear that the procedural motions that have been put in place need to be rectified.

Officially, regardless of intent, two levels of government have endorsed this MZO request. Saying otherwise is disingenuous to the process both councils have undertaken since November 2, 2020.

Ramara Must Rescind Its MZO Request

Public platitudes about intention do not rectify the official acts of council that have been completed thus far. Therefore, we are requesting that the Township of Ramara rectify this situation officially to align with its comments publicly that a MZO was not applied for. Specifically, the Township of Ramara should reopen the issue before council and pass another motion to send written correspondence to the province directing it to disregard its Rama Road Economic Employment District package and that Council will proceed with these lands through the standard process outlined in the Planning Act, not through a MZO.

Further, since the County of Simcoe is the recognized planning authority in the region, its endorsement of the MZO must also be rescinded. We suggest that a recommendation be made within the Committee of Whole for County Council to notify MMAH that County Council is revoking its support of the Rama Road Corridor MZO letter it sent to Steve Clark dated December 7, 2020. From there, County Council must adopt this recommendation and send formal written correspondence to Minister Clark.

In Conclusion

We hope that the Township of Ramara does not break faith with its public comments in the media and in front of a neighbouring council about not wanting a MZO for these properties. By not officially undoing councils’ actions, this MZO request will still be considered by the province. Further, the developers of this project will still have two levels of endorsement for their projects under a MZO and therefore the province could proceed with the MZO request without further input from either the County or Ramara.

Finally, we must go on record that regardless of the MZO application for the Rama Road Corridor, this project, as it stands, is incompatible with a net benefit for Lake Couchiching, Ontario’s significant wetlands, climate, residents of the Lake Couchiching area or the long-term fiscal health of Ramara Township.

We appreciate your attention to this matter and look forward to council actions that ensure this MZO application does not proceed.

How Can You Get Involved?

  1. Send a message to Council using our form.
  2. Share your concerns on social media.
  3. Sign up for alerts to stay up to date.

Sign Up to Receive Alerts for Ramara Township

Links to Further Reading

Help us fight MZO requests.
Send a message to your council and MPP, and report MZOs in your community.
Click Here

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A map showing where development is proposed, and showing how it will impact wetlands. Map by SCGC using layers from Simcoe County, the MNRF, and features drawn from the proposal.
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Ramara Council must uphold its duty to the public it serves by acknowledging the MZO request, by rectifying it with a motion that would send a letter to the Minister revoking the MZO request, and re-committing to a planning process done in good faith, with full public participation and due diligence paid to environmental and other necessary studies to ensure no negative impacts.

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A map view of where The Orbit is proposed to be built. Natural features are overlaid.
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The Orbit

In Innisfil, the proponent of a controversial development, The Orbit, has successfully sought backing from council to seek a Minister’s Zoning Order, or MZO, from the province.

If the province grants this request the developer gets a short cut through rules meant to ensure the public is consulted, environmental impacts are studied, and financial consequences understood.

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We send out a once-monthly newsletter full of information on what’s happening in Simcoe County and beyond, including information on how you can take action to protect the health of your community.

Comments on the
Species at Risk Conservation Fund

With the Species at Risk Conservation Fund and broader changes to the ESA, the future of these species is very grim.

This letter was submitted to the Environment Registry of Ontario in response to posting ERO 019-2636, which proposes use of a “Species At Risk Conservation Fund.”

Simcoe County’s Context as a Home to Species-At-Risk

At 4,841 square kilometres, Simcoe County is one of the largest regions in the Greater Golden Horseshoe.

Its vast interconnected water system includes provincially and internationally important water resources: Wasaga Beach, Minesing Wetlands, Matchedash Bay and Wye Marsh.

Geologically diverse, Simcoe is home to over 1500 species of vascular plants, 150 species of nesting birds, 50 mammals and 33 types of reptiles and amphibians1Simcoe County Official Plan (2008). Available at: www.simcoe.ca/planning. It offers specialized vegetation communities adapted to unique habitats such as coastal plains, prairies and savannas, alvars, bogs and fens, the Great Lakes shoreline and the Niagara Escarpment. 

In addition, the county contains provincially significant wetlands, provincially significant Areas of Natural and Scientific Interest and more than 60 species of plants and animals deemed vulnerable, threatened or endangered in Ontario and/or Canada.2Simcoe County Official Plan (2008). Available at: www.simcoe.ca/planning

Extensive tracts of undisturbed forest in the north and east are habitats for forest-dwelling birds and mammals.

All these features combine to provide a healthy habitat for Simcoe County residents, flora and fauna.

Photo of a Golden Eagle, close up. Photo by Craig Hughes.
Photo of a Golden Eagle, close up showing the head. Photo by Craig Hughes.

Our concern is how these sensitive habitats will be treated in future under the potential changes.

In broad strokes, we are strongly opposed to the Species at Risk Conservation Fund for the following reasons:

  • The loss of biodiversity has been shown to put climate action and public health at risk. This fund normalizes and establishes a process to continue biodiversity loss without any opposing policies that stop the losses overall;

  • Funds aren’t required to be applied to affected watersheds, municipalities or Indigenous traditional territories where the harm occurs;

  • Provides a perverse incentive to destroy sensitive habitats;

  • Payment into the fund is an alternative to “overall benefit” approach that the Endangered Species Act was intended to uphold;

  • The funding charge fails to fully calculate the risk and liabilities that arise with the removal of sensitive habitats;

  • No long term government financial commitment that assures conservation efforts will continue outside of pay to slay fees. Will this require MECP to allow more permitting and fee collection to keep this fund financially independent as the Ministry anticipates? If the fund is not financially independent as hoped, will funds be diverted from other conservation programs accordingly?

  • Lack of transparency with the public regarding the success indicators of this program including species-specific or cumulative impacts of activities undertaken by proponents. These indicators should be measured and included in public reports.

New Changes Put in Context of Species at Risk in Simcoe County/Lake Simcoe Watershed

As noted in Figure 1, there are several species at risk in one of our watersheds and they are most at risk within Simcoe County communities. The new changes proposed could pose significant threats to Simcoe County’s most vulnerable species and sensitive habitats.

Figure 1: Distribution of provincially rare species (represented as buffered polygons the size of which depend on known location accuracy) arranged by provincial rank (Srank) in the Lake Simcoe watershed.
Figure 1: Distribution of provincially rare species (represented as buffered polygons the size of which depend on known location accuracy) arranged by provincial rank (Srank) in the Lake Simcoe watershed. Source: Vulnerability Assessment for Provincially Rare Species (Species at Risk) in the Lake Simcoe Watershed.

In 2012, MNRF looked at the Lake Simcoe Watershed to assess the vulnerability of species at risk within the Lake Simcoe watershed in light of climate change. Out of the 62 species at risk known in the watershed, 17 were identified as most at risk and therefore high priority for study. As easily seen in Figure 1, these species were most imperilled (red/orange/yellow) in Barrie, Oro-Medonte, Orillia, Innisfil and Bradford West Gwillimbury.

Further, the vulnerability assessment found that two species at risk were going to face devastating futures factoring in climate change – the Redside Dace and the Jefferson salamander. Assessments concluded that in both cases, the current habitat, which is currently under threat, is the only one left that is suitable for them in the entire watershed.

Side by side pictures of a Red sided Dace and a Jefferson Salamander.
Figures 2 and 3, respectively. A Red Sided Dace on the left and a Jefferson Salamander on the right.

Although from two different ecosystems, what these species tell us is all we need to know about how effective current ESA regulations are at protecting species and their habitat.

Urban development is the most significant threat to both of these species as clearly outlined in their recovery strategies.

The Redside Dace requires clean water with forest cover while the Jefferson Salamander requires connected habitat which includes well-functioning wetlands and clean water systems.

However, their habitats continue to be affected by urbanization despite coherent recovery strategies. That we are not only threatening their “officially recognized habitat”, but also degrading adjacent habitats so they have no other habitat options is a scathing assessment of what we are doing to our landscapes and watersheds.

In Conclusion

With the Species at Risk Conservation Fund and broader changes to the ESA, the future of these species is very grim.

We support the submission of Ontario Nature and, like Ontario Nature, stand strongly opposed to the government implementing the Species at Risk Conservation Fund.

Instead, the government should be implementing policy that puts public health first and foremost. This would include stronger protection of sensitive habitats, measures to increase and strengthen biodiversity, preserving places that are known carbon sinks, flooding regulators and climate change mitigators (wetlands, forests).

Unfortunately, these proposals move us further away from forward thinking conservation action that has been the backbone of Ontario’s policy structure for decades.

Additional Resources

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We send out a once-monthly newsletter full of information on what’s happening in Simcoe County and beyond, including information on how you can take action to protect the health of your community.

Open letter to Minister Clark regarding Bill 229 and keeping faith with Ontarians

…if this government is truly committed to these initiatives, by which we mean that they are not being used as cheap politics to deflect from the criticism, fully deserved, that they are receiving with regard to the policy changes noted above, then we expect the following…

This letter was written after the Province passed Bill 229, which came after a huge outcry from the public, from environmentalists, from Conservation Authorities, and from municipalities, among others, and which prompted the resignation of seven members of the Province’s Greenbelt Council.

Dear Minister Clark.
 

There has been much attention paid lately to the future of our Conservation Authorities – one of the last regulatory bodies designed to protect our environment. In a response to the public outcry regarding the neutering of Conservation Authorities’ ability to protect water, wetlands and public health, Minister Clark made a series of statements and announcements:

First, was the promise of $30 million dollars to “create, restore and enhance wetlands” across Ontario; 

Second, was a promise to improve the “quality and quantity of the Greenbelt”.  

The timing of these announcements is troubling and does not add to our confidence in the government’s commitment to protecting the environment coming, as it has, on the heels of eight members of the Greenbelt Council quitting in protest over provincial policy changes. Changes that former Toronto Mayor and, until he resigned this past week, Chair of the Greenbelt Council, David Crombie outlined as “high-level bombing”.

But we are willing to accept these announcements in good faith, and we look forward to hearing more about these initiatives. To be very clear, however, if this government is truly committed to these initiatives, by which we mean that they are not being used as cheap politics to deflect from the criticism, fully deserved, that they are receiving with regard to the policy changes noted above, then we expect the following:

  • That no more MZOs will be issued that allow development in provincially significant or locally significant wetlands. It makes no sense to commit to restoring wetlands and putting taxpayer money towards that, while simultaneously destroying or impairing other wetlands. Refusing to do this would be creating a boondoggle for developers, using public money to offset wetland destruction.

  • Any MZO that is issued in the Lake Simcoe watershed will clearly outline how the Lake Simcoe Protection Plan policies will be adhered to, in order to ensure conformity with said policies as MZO conditions.

  • The Lake Simcoe Protection Plan, which will be reviewed in the new year, will be strengthened by building on proven existing policies (e.g. phosphorus loading targets and WWTP moratoriums), demonstrating the government’s commitment to protect the environment with policies that protect more high quality natural cover, including wetlands and forests. This should be a zero loss target and policy structure, meaning that there should be no reduction in the quantity and quality of natural cover going forward. Currently, the target in the LSPP is 40% high quality natural cover – a target that we are failing to meet.

Picture of Lake Simcoe, looking east from Barrie, in the winter time. Photo by Adam Ballah.
Picture of Lake Simcoe, looking east from Barrie, in the winter time. Photo by Adam Ballah.
  • The $30 million Wetland Restoration Fund will be money invested by the Government of Ontario and not “blood money” that comes from developers paying a fee to permit the destruction of wetlands. If it is based on offsetting, this is a “pay to pave” mentality that has been proven disastrous for watershed health in other jurisdictions. Funding wetland restoration through the destruction of other wetlands would be disingenuous to the government’s commitment and breaks faith with Ontarians who rely on wetlands for flood mitigation, drinking water purification and recreation.

  • Growing the Greenbelt includes keeping the existing Greenbelt strong.  We don’t want to see a bait and switch where more Greenbelt is added in exchange for current Greenbelt lands being removed from protection.  The Greenbelt, its farms and communities, contribute $9.6 billion of economic impact and $3.2 billion of environmental services to Ontario every year.  As a region that is growing we will be relying on the services it provides far into the future. Dismantling it through land swaps threatens its ecological functions, and, consequently, its contributions to our collective prosperity and wellbeing.  

  • The province, if it is genuine in its commitment to growing the Greenbelt, will base new included areas on science and public health, not just land ownership. Following such a process means that all source water areas (highly vulnerable aquifers, significant recharge areas, moraines and locally significant wetlands) in Simcoe County should be added to a bigger Greenbelt, at minimum.  Simcoe County residents are highly reliant on groundwater for their daily needs.  If we don’t protect these areas soon, the public’s health is at risk.

We hope that your government is genuine in its commitment to these ends.  We are sure you would agree that using environmental policy as a ploy is dangerous to our public health and erodes faith in our democratic institutions and your governments’ commitment to acting in the best interest of all Ontarians.

Ultimately, it is in no one’s interest that a government fails – such an event has real life consequences for the people of Ontario, including to their health and wellbeing. We are committed to helping where we can to find success in the above noted expectations, but we will not betray our knowledge and understanding, born by evidence, of the actions required to create a more just, prosperous, and sustainable Ontario.  We will be watching closely to ensure that you stick to the commitments you have made and do so in a genuine manner. 

Bill 229 - Additional Resources

Community supported, advocacy for a safe and secure future.

Governments have failed to act to protect our communities and the futures of our children and grandchildren, and they continue to treat our environment as if it’s incidental to life, rather than a foundation for it.

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This is a comment that was posted by SCGC board member Phil Brennan on Ontario’s Environmental Registry regarding the Forest Sector Strategy


In today’s world, more than ever, good forest management needs to reflect a balance between different uses and needs of the forest.  

You do not double industrial output without making provisions for education and research (we must have ecological reserves to study and compare growth with our silvicultural practices); make effective provisions for biodiversity; build into the planning process strong provisions for mitigating climate change (planting trees has limited potential and it is wiser to take care of what we have); including provisions that are supported by experts for the sustainable management of wildlife and fish; building in protections and future growth potential for tourism; effective protection of natural heritage; including strong provisions for species-at-risk (e.g. caribou habitat); and, incorporating the social needs of affected communities through transparent consultation.

Specifically, I have the following concerns:

  1. The commitment to sustainability must specifically address all the points above throughout the development of the final strategy.  Window dressing is not acceptable. 
  2. Any plan to reduce so-called red tape needs to specifically chart the pros and cons of the existing and proposed changes to legislation – if the Class EA for Forestry is to be replaced in whole or part – how will the new rules insure that the public has the same opportunities to affect change as in the current assessment approach. Transparency here is critical.  If there is an intention to change the ‘area of the undertaking’ this must be clearly articulated in any proposal and needs public scrutiny.
  3. The pros and cons of changing from the current FRI based inventory approach need to be documented in a scientific and professional document for the public,  including the provision of clear information on the new remote sensing technology that is proposed and the manner in which it is verified on the ground. 
  4. It is not at all clear how the proposal will provide for additional wood supply certainty.  That’s what the current forest planning manual and requirements has already been designed to do.  
  5. While I applaud any logical efforts to increase the sustainable harvest, the challenges around this need to be more specifically articulated.  The reality is that for economic reasons we have lost pulp mills, sawmills (quality is a factor here), and board mills.  Ontario has been looking for ways to use its surplus birch and poplar supplies for decades.   Even on the private lands, particularly in Southern Ontario, the challenge is utilizing poor quality trees, not saw logs due to a long history of high grading.
  6. Increasing growth potential in our forests suggests a more intensive forest management and greater utilization of lower value material on harvested sites.  This suggests spending more money on forest management and it is not at all clear where that money would come from.  On private land,  the Ontario government  walked away from more intensive forestry work under the Woodlands Improvement Act and the Forestry Act in the last two decades to save money – hard to imagine us going back to programs like that in the near future under our current budget challenges. 
  7. Forest fires and insect and disease attacks, particularly in older forest tracts can be expected to have a significant impact on all uses of the forest and harvesting  and this needs to be addressed in developing new targets for the harvest in Ontario.  We must learn from the Australian situation. With these things in mind, I support the development of a rigorous and professional ‘Provincial Climate Change Impact Assessment’ and having it factored into moving forward with forest management and wood supply solutions in Ontario. 
  8. The document notes that Ontario has developed its own provincial policy as an alternative to the federal output-based pricing system to reduce carbon emissions in the section on maximizing the use of mill by-products to fight climate change.  Everyone who knows anything about fighting climate change knows that the Ontario approach is very weak and expected to fail.    If Ontario wants to use climate change arguments as part of its strategy to increase industrial output, you now need to have credible experts document the proposal.  
  9. The proposed Forest Sector Advisory Committee must include NGO’s that represent the interests of the non-timber industry for any strategy to be implemented properly. 

Thank you for this opportunity to comment.

Phil Brennan

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