Letter: The public deserves accountability for the Greenbelt scandel

Below is a letter, made available for publication in local outlets, addressed to local MPPs who supported this government’s land grabs in the Greenbelt.

August 29, 2023 - Simcoe County

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.

Thanks to a thorough investigation by the Auditor General the public now knows that the process that led to your approval of Greenbelt takeouts was “biased” and gave “preferential treatment” to a select few developers, some of whom also attended personal events held by their Premier’s family, as well as having been identified as friends by the Premier when asked by the Integrity Commissioner.

We also know that this land grab is likely to result in an increase in asset value for these developers of at least $8 billion.

Moreover, the report stated that environmental standards, if they stood in the way of lands being removed from the Greenbelt, were stripped out of the decision-making process.

The Auditor General also outlined that staff involved were deleting emails and using personal addresses to conduct government business. Deleting records related to government business is quite likely just as illegal now as it was during the gas plant scandal, for which a former chief of staff to the Premier was found guilty.

Now the RCMP is assessing whether it will investigate further and seek criminal charges.

As a coalition of over 45 groups from around Simcoe County, we, and we suspect the rest of your constituents, expect accountability for this betrayal of the public’s trust. Accordingly, we would like you to answer to the following:

  • Your vote to remove these lands went against public feedback submitted via the Environmental Registry, which showed overwhelming opposition to these takeouts. How do you justify this?
  • What did you know about the Greenbelt land grabs before you voted? Did you have knowledge of the process used, and/or of the landowners who would benefit?
  • Why did you support the Greenbelt land grabs when your own Housing Affordability Task Force and Regional Planning Commissioners of Ontario determined that there is more than enough land already available to accommodate future housing?
  • Now that you know the process was flawed, do you support the government’s stance to not reconsider the Greenbelt land removals – the 15th recommendation made by the Auditor General?
  • When in opposition, your party argued that cash for access events led to preferential treatment. Given the cash-for-access and preferential treatment likelihood found with the Greenbelt fiasco, and your own continued use of $1000 a ticket events, has your stance on this changed? If not, will you support legislation to end cash for access fundraising and will you commit to no longer host these types of events?

We believe the public is owed answers regarding these questions. We have already sent you an invitation to attend our Public Forum on the Greenbelt, happening September 12 at 7 pm at Grace United Church in Barrie, at which you can answer these questions.

The public has entrusted you with power to make good decisions on their behalf and we expect you to be accountable to that trust. We look forward to your response.

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This week (really last week, but there’s been a lot happening and we’ve had our hands full!) we talk with Jennifer Van Gennip about affordable housing and the advent of modern homelessness.

Jennifer works with a number of groups that address these issues, including the Simcoe County Alliance to End Homelessness (SCATEH), the Simcoe County Poverty Reduction Task Group (PRTG), Redwood Park Communities, the Down Syndrome Association of Ontario… and this is just to name a few, believe it or not!

Episode links

Shooting The Hippo: Death By Deficit And Other Canadian Myths by Linda McQuaig

A Better World Ahead Means Shaping Emerging Narratives Now, by Kristen Grimm

Push, the Film

Revisionist History

Submission on Proposed Changes to the Provincial Policy Statement, 2019

We have grave concerns about the policy direction under the PPS review. As outlined by the Ontario government, the PPS is “the primary provincial land use policy document guiding municipal decision-making.” So the tone, focus and direction given in this document greatly impacts our communities, our environment and our future.

October 21, 2019

Municipal Affairs and Housing
Provincial Planning Policy Branch
777 Bay Street
13th floor
Toronto, ON M5G 2E5

RE: SCGC Comments on ERO 019-0279

Please accept our submission to the aforementioned review as it relates to the Provincial Policy Statement (PPS). We appreciate your consideration of our comments.
About Simcoe County Greenbelt Coalition
With our 35 member groups from urban, rural and semi-urban communities, we aim to promote community development that is financially, environmentally and socially sustainable, such that provides a net benefit to residents. A major part of this is to recognize the value that natural heritage, agriculture and water gives to our communities, including the numerous benefits and co-benefits of ecosystem services. Ensuring the people of Simcoe County, and Ontario broadly, continue to receive these benefits requires an approach to economic development that is evidence based, transparent and accountable to the public, and with full consideration of the long-term impacts that communities will either have to deal with or benefit from.

We have grave concerns about the policy direction under the PPS review. As outlined by the Ontario government, the PPS is “the primary provincial land use policy document guiding municipal decision-making.” So the tone, focus and direction given in this document greatly impacts our communities, our environment and our future.

Our general concerns include:

  • Softening of language from “shall” to “should”, such as in policies that relate to transit supportive development and protection of natural features;
  • Use of “market-based housing” when discussing appropriate mix of housing. This approach emphasizes methodology that only considers past and current housing trends. A housing shift is needed to encourage more affordable housing, transit-oriented and sustainable development. Clearly, this is not what the past few decades of development has provided us, and as such, should not be the foundation upon which we build communities of the future. This is particularly true when it comes to providing affordable housing, which largely addresses needs of those who cannot or have difficulty accessing appropriate housing in regular market conditions;
  • Excluding protections of natural heritage features, such as in policies dealing with what considerations municipalities should undertake when determining impacts regarding housing and infrastructure.
  • Lost opportunity for the PPS to clarify the Province’s stand on crucial issues, including the protection of prime farmland, the need to prioritize action to mitigate and adapt to the impacts of climate change, as well as, at a time when many municipalities are struggling financially, a comprehensive plan to foster communities that are both financially and environmentally sustainable.

We have more specific concerns as outlined below:

Aggregate Should Not Trump Environmental Protection

Proposed policy allows mineral aggregate extraction to occur in protected, provincially significant natural features, including wetlands, woodlands, valley lands, wildlife habitats, fish habitats, endangered and threatened species habitats and areas of natural and scientific interest outside of the Greenbelt.

We feel it necessary to remind you that this type of policy adjustment could have large ramifications for Simcoe County residents, our eco-systems, water sources and natural heritage as large aggregate supplies are situated in and around many of our communities, as well as in and around significant groundwater resources and natural heritage areas.

For eight years between 2003-2013 Simcoe County was the largest aggregate producer, by volume, in Ontario. During those years Simcoe County produced 11.64 million tonnes of aggregate, on average, annually. Five municipalities within the County, Clearview, Oro Medonte, Ramara, Springwater and Severn, consistently produce an excess of one million tonnes per year, as seen in Table 1 below.

There are over 100 licensed pits and quarries within Simcoe County, with a total licensed area of 3917.16 ha. It was estimated by the Ontario Geological Survey (2013) that Simcoe has a potential unlicensed resource area of 2404 hectares for sand and gravel with roughly 237.7 million tonnes of aggregate resources. Further, the bedrock-derived aggregate resources that are currently unlicensed is a potential resource area of 27,503 hectares, containing 10,928 million tonnes of aggregate resources. Together, that is roughly 30,000 hectares potentially being dedicated to aggregate extraction.

Although Simcoe County is large, we must keep in mind that 30,000 hectares is roughly half the size of Lake Simcoe. Add into that the associated roads and infrastructure which aggregate operations require and clearly large swaths of land could be dominated by aggregate activity.

Map showing aggregate resources in Simcoe County, Ontario

Most of these deposits and resources are located in the northern part of the county. Although it is less populated than the southern part of the county, it nevertheless has important infrastructure contained within it. The northern part of the county contains most of the connected forest cover, a high percentage of wetlands and many river and stream systems.

Moreover, the population in the northern part of the county is primarily serviced by groundwater wells and has a higher concentration of residents who are similarly serviced by individual private groundwater wells.

Layering the sand, gravel and bedrock resources against source water protection maps shows that most of these identified resources (licensed or unlicensed) are surrounded by or contained within highly vulnerable aquifers – the source of drinking water for most of the population in that region.

One of the main concerns about aggregate extraction is its effect on surface and groundwater. Extraction changes the slope of the land and water drainage patterns. This is a change that is effectively impossible to revert back to an original state, making any claim of full rehabilitation highly unlikely

Further, aggregate resources within an aquifer store the water. If you remove the aggregate the water storage capacity of that aquifer is significantly damaged and reduced. A case study conducted in Minnesota found that while impacts on water were not found in every quarry and pit, declines in aquifer levels were a common occurrence.

Map showing aggregate resources in Simcoe County, overlaid with Highly Vulnerable Aquifers.
Map showing aggregate resources in Simcoe County, overlaid with Highly Vulnerable Aquifers (shown in red).

Farmland is also impacted by aggregate operations. The quarries and pits and their related infrastructure fragment farmland and the rural economy.

As seen below, the aggregate resources identified in Simcoe County also tend to be surrounded by high class farmland.

Ontario is already losing over 150 acres of farmland per day. Deregulating aggregate to get into areas that jeopardize our local food systems is short-sighted and only further stunts the sustainable economic development of rural communities. Aggregate can provide jobs, but only for a period of time. Agriculture, properly conducted, can provide jobs, as well as food security, climate change mitigation, and cultural benefit year after year after year.

County of Simcoe Aggregate Resources Layered Against Soil Classes
County of Simcoe Aggregate Resources Layered Against Soil Classes.

Allowing aggregate to expand and initiate operations in highly sensitive areas such as significant forests, wetlands, valleylands and ANSIs is unconscionable considering that there is no evidence to support a need for increased access to supply.

OSSGA contends that less regulation, such as what is proposed in the PPS and Growth Plan, is needed to increase supply due to a large, expected population growth. We believe that this is an intentionally misleading premise.

First, the demand that OSSGA insists is there is not much more than what they already produce. OSSGA estimates 3.84 billion tonnes of aggregate will be needed by 2041. Per year that works out to 174 million tonnes of aggregate annually, which is only 10 million tonnes more than their average annual production. In some recent years, the industry has produced over 200 million tonnes of aggregate – obviously the capacity to produce more already exists.

This needed increase also assumes that demand for aggregate will not decrease or stabilize. Over 50% of aggregate in Ontario goes towards the building of roads. As we continue to build our communities up, as opposed to sprawling out, the construction of new roads and highways (which, as noted, is where the majority of the aggregate goes) will mean less demand for aggregate. It is quite possible that these changes alone could mean that aggregate demand may only stabilize and hence an increase in production may not be needed at all.

The rationale for the proposed amendment within the PPS rests on the assumption that natural areas destroyed by pits or quarries will eventually be rehabilitated, as required by law. However, it fails to acknowledge that aggregate operations are often open for decades, or that legal requirements to rehabilitate sites are often poorly enforced and routinely ignored. It also fails to account for the loss of significant and/or at-risk animals and plant species and their habitats in the meantime. This loss is likely permanent, too, as sites are rarely returned to their original state.

The poor record of rehabilitation of aggregates operations has been thoroughly covered in past reports of the Environmental Commissioner of Ontario, which have revealed that:


  • Remove new policies that would allow aggregate extraction in sensitive areas ( and those that would allow extraction in prime agricultural areas (
  • Include policies that require aggregate to provide evidence of net need for new pits/quarries or expansions.

Protections for Wetlands Must be Retained or Enhanced

Wetlands are vital to maintaining water supply and water quality, and to enhance landscape and community resilience in an era of climate change as they play a critical role in flood attenuation and act as carbon sinks. They also provide habitat for many of the province’s most imperiled plants and animals. A 2009 study commissioned by the Ministry of Natural Resources estimated that the ecosystem services provided by wetlands in southern Ontario alone were over $51,614,795,000 per year. According to the authors, ecosystem services such as these “are the foundation of human well-being and they also represent a significant part of the total economic value of our landscape and economy.”

South and east of the Canadian Shield (Ecoregions 6E and 7E) at least 72% of wetlands have been lost to development, with losses exceeding 90% in some areas. We are therefore very concerned about the proposed policy 2.1.10:

2.1.10: Municipalities may choose to manage wetlands not subject to policy 2.1.4 and 2.1.5, in accordance with guidelines developed by the Province.

The policy is permissively and vaguely worded and invites an ad hoc approach to wetland management across the province

Further, policies 2.1.4 and 2.1.5 stipulate that site alteration should not occur in wetlands that are deemed significant. The implication of placing management of wetlands not subject to these policies with municipalities is that they are not considered “significant”. This effectively paints all wetlands outside of the significant classification with an extremely broad brush. Since many wetlands have not been evaluated, this generalization is highly likely to cause irreparable damage to wetlands that if evaluated would likely meet the standard required to be classified as significant.

We question why such a policy would even exist based on the substantial amount of science that underscores the importance of wetlands to water quality and quantity, climate and flood resiliency, and habitat for wildlife.

We have come to understand that proposed policy 2.1.10 is intended facilitate wetland offsetting in unevaluated wetlands.

SCGC strongly believes that the precautionary approach – the prudent approach – should govern serve as a formative principle in determining land-use policy. Accordingly, we would argue that all wetlands should be deemed significant until an objective, science based evaluation has occurred that shows a high degree of certainty otherwise.

Furthermore, allowing municipalities to “manage” wetlands as they see fit establishes a scenario in which the treatment of wetlands will be disjointed and inconsistent. Wetland management is key to watershed planning and flood resiliency – both should be declared areas of provincial interest and thus not left in the hands of municipalities with vague wording and non-existant outcomes or targets.

While we strongly disagree with wetland offsetting, if such a policy were to exist it must clearly state the purpose and parameters, including requirements to:

  • Achieve a net gain in wetland area, quality and function;
  • Set clear limits to offsetting, taking into account the type, location, vulnerability and irreplaceability of wetlands, as well as their cultural significance to Indigenous peoples;
  • Implement the mitigation sequence, which positions offsetting as a last resort after first avoiding, then minimizing negative impacts.

To fully appreciate the scope and potential outfall that such a policy could have, we need look no further than Simcoe County. As demonstrated in Figure 4, the amount of unevaluated wetlands, also known as locally significant, in Simcoe County is large and spread throughout the county, with a notable concentration in the northern region.

Unevaluated Wetland Systems in Simcoe County (green)
Unevaluated Wetland Systems in Simcoe County (green).

As mentioned previously, Simcoe County groundwater systems are pervasive throughout the county and supply the large majority of residents and businesses with their water for daily use. Wetlands are a key element of the water recharge and purification system within a groundwater system. Thus, limiting or destroying a wetland’s function impacts local water systems as well as increases flooding risk.

In Figure 5, it is clear that many of these unevaluated wetlands are enveloped by Highly Vulnerable Aquifers and/or Significant Groundwater Recharge Areas.

Layering of wetlands over key water systems Highly Vulnerable Aquifers (red) and Significant Groundwater Recharge Areas (yellow/bright green)
Layering of wetlands over key water systems Highly Vulnerable Aquifers (red) and Significant Groundwater Recharge Areas (yellow/bright green).

No one knows for sure how much change and destruction a groundwater system will tolerate before its function is impaired and therefore unable to provide adequate amounts of potable water. How much risk is the province willing to undertake in the name of aggregate extraction and housing?


  • Remove policy 2.1.10.
  • Declare all wetlands as a matter of provincial interest.
  • Ensure that if wetland offsetting is to be a consideration, it is absolutely as a last resort with no net loss and clear limits.
  • Provide adequate funding to MNRF and/or municipalities so that they can evaluate their wetlands appropriately.

Housing Policies Open Up a Pandora’s Box for Rural and Semi-Rural Communities

New policies allow for greater flexibility for communities to select individual on-site sewage services and individual on-site water when municipal services are not available, planned or feasible in rural settlement areas at the time of Official Plan review or update.

It means that communities can build out in rural areas that, generally, are unable to support complete communities. In Simcoe County in particular, there is a net surplus of development approvals, especially in the more rural areas.

We firmly believe that a change in the servicing hierarchy to include communal and private servicing would proliferate a sprawling built form. As a result, this sprawling built form spreads municipal and provincial resources thin as there are more roads to maintain, operate, etc. with a small tax base to cover costs of upkeep. Costs related to infrastructure, it should be noted, will almost certainly increase with the impacts of climate change, and so planning should proceed accordingly. Further, sprawl locks in high emission lifestyles for decades, increasing the challenge, already considerable, of meeting the needed, science-based targets of net-zero carbon emissions by 2050.

Another concerning component to this proposal is that communal wells and private wells are not covered under Source Water Protection Plans. Therefore, encouraging growth that knowingly builds water systems not properly protected is a huge risk to public health and abdicates the caretaker role of government.

Including terms such as “market based” housing and extending the planning horizons are also troubling, as noted above. Both of these items only encourage the maintenance of the current housing mix and provide more opportunities for land banking for future greenfield development. Land banking is now thought to be one of the primary drivers of the housing affordability crisis.

It is unclear why this would be considered at a time when we need to fully confront how damaging our built form is to the climate and environment at large.Ontario’s main emission source is from individual transportation and Ontarians are driving more than ever, as noted below.

Ontario population measured against passenger kilometers. Source: Natural Resources Canada
Ontario population measured against passenger kilometers. Source: Natural Resources Canada

The main reason behind our increasing driving trends is how and where we build our communities. Roughly 75% of Ontarians live in car dependent neighbourhoods – places where the distance between daily needs, such as grocery stores, work places, schools, and medical care, is beyond that easily walked, and/or transit is not established well enough to entice people out of their cars.

Unfortunately, that trend is continuing to rise in Ontario as well as across Canada. Consider that between 2006 and 2016, car dependent growth (rural and suburban) accounted for 85% of the population growth in Canada. In the GTA specifically, 83% of growth occurred in car dependent neighbourhoods rather than active cores where walkability and transit are well established.

This has a huge impact on our environment, health, community design, transportation and climate change. Our building patterns set our carbon footprint and climate risk for decades to come. If anything, considering the financial, social and environmental costs of this type of building pattern, the province should be using this opportunity to move Ontario’s growth even more towards more compact development.

Further, changing demographics also need to be considered before proposing policies that promote sprawling growth patterns. Car dependent, rural communities are generally only accessible for people of a certain age, stage and income – namely, middle class and middle age. By 2031, it is estimated that 42% of people in car dependent suburbs around Toronto will no longer have a driver’s license. This means that to effectively “age in place” and to make our communities accessible for all, residents either will have to have options for transit or live in walkable communities.

In Simcoe County, specifically, our communities will need to be better designed for seniors – especially if the province is serious about “aging in place” to deal with long-term care bed backlogs. By 2041, the population of seniors 65 years and older in Simcoe Muskoka is projected to surpass 218,800, which is more than double the number of seniors from 2011.

Figure 7 indicates that all senior age groups will increase in population. The largest increase will occur among the 90+ age group, which will increase by 346% from 4,345 in 2015 to 19,380 in 2041. How will these people be encouraged to “age in place” if we keep building remote, car dependent neighbourhoods? Becoming an age friendly community means ensuring accessibility. Policies such as what is proposed in the PPS encourage low density, car dependent neighbourhoods which will not be sufficient to support our aging population. This only puts more of a strain on our public health system and other supports for seniors.

Senior Population Projections by Age Group 2015-2041
Senior Population Projections by Age Group 2015-2041


  • Maintain policies that encourage development to be on municipal services over communal or private servicing.
  • Include policies that promote age friendly communities such as intensification, access to transit and walkable communities.


The members of SCGC want to see a fair balance between growth and the environment. Further, there needs to be more consideration for our natural environment and water when considering aggregate and growth policies. As a mainly rural/suburban region, we are highly dependent on our groundwater resources, and our economy is inextricably linked to our lakes, farmland and natural environment. Changes to policy, such as what is proposed in the PPS, impact our way of life and our economy.

In times of dwindling water resources, a changing climate and mass biodiversity loss, we want the province to have the will to put forth policies that address these losses – policies that correct our course and move us towards solutions. Unfortunately, we do not see any measurable steps outlined in these policy proposals that will correct our course, only make matters worse. We strongly implore the province to reconsider the direction and vision that it is now offering within the proposed PPS.


Margaret Prophet
Executive Director, Simcoe County Greenbelt Coalition

Growth Plan Submission

Low density development on greenfields or elsewhere is a net cost to society and should be curtailed accordingly. Strategies should be developed and implemented to account for and to factor into decision making the actual cost of sprawl, reflecting its negative impact on the environment, on the social fabric of our communities and neighbourhoods, on our physical health, and on our political economy.

Cordelia Clarke Julien
Assistant Deputy Minister
Ontario Growth Secretariat (OGS)
Ministry of Municipal Affairs and Housing
777 Bay Street, Suite 2304, 23rd Floor
Toronto, ON M5G 2E5

Re: Proposed Amendment to the Growth Plan, ERO 013-4504

Dear Ms. Clarke Julien,

First, as members of the Ontario Greenbelt Alliance (OGA), we support their submission on this consultation and have included their recommendations at the end of this document. In addition, we feel there are unique concerns that our constituency has with the proposed changes, which demand a Simcoe-specific response.

With our 35 member groups from both urban, rural and semi-urban communities, we aim to promote community development that is financially, environmentally and socially sustainable, such that provides a net benefit to residents. A major part of this is to recognize the value that natural heritage, agriculture and water gives to our communities, including the numerous benefits and co-benefits of ecosystem services. Ensuring the people of Simcoe County, and Ontario broadly, continue to receive these benefits requires an approach to land use planning that is evidence based, transparent and accountable to the public, and with full consideration of the long-term impacts that communities will either have to deal with or benefit from.

Density and Intensification Targets

Low density development on greenfields or elsewhere is a net cost to society and should be curtailed accordingly. Strategies should be developed and implemented to account for and to factor into decision making the actual cost of sprawl, reflecting its negative impact on the environment, on the social fabric of our communities and neighbourhoods, on our physical health, and on our political economy.

For Simcoe County, including Barrie and Orillia, the proposed density and intensification targets effectively continue the status quo approach to long term growth planning. Simcoe County would be allowed to keep the intensification and density targets that were established under alternative targets given for its 2008 Official Plan. These changes beg the question – what is the vision that the province has for the communities of Simcoe County? Is it a political vision, changing according to the whims of the government of the day, or is it evidence-based planning, utilizing established best-practices done with the best interests of the public in mind?

Currently, low density sprawl dominates Simcoe County. Densities around the county range from the 50 ppl/hectare to well below that in some of the more rural communities. We know that greater densities are needed to support transit and move communities away from car dependency – a development pattern that is costly, inequitable, unhealthy and results in high carbon emissions. The Ministry of Transportation’s own guidelines for building a transit supportive community suggests that to provide basic bus service, a minimum of 50 people per hectare is needed, otherwise the transit service is inefficient and difficult to sustain economically. Even a bus service supported by 50 people per hectare, such as in Barrie, isn’t the kind of transit that is widely available to all residents or allows enough reliability and flexibility to shift transportation patterns away from single vehicle use toward more efficient modes of mass transit.

The proposed “status quo” targets literally cement a development pattern that increases pollution, inequity and municipal debt for the long term. Simcoe County’s population could increase 96% by 2041 from 2011 level. As Hemson Consulting outlined, this could mean that our region could see as many as 900,000 residents by 2041 with Barrie alone growing to 253,000 people. So how we encourage growth in Simcoe County cannot be predicated on how we’ve grown in the past, but rather needs to be based on how we should build communities of the future. We would prefer that the province recognize the growth that Simcoe County will be facing and help support and usher in policies that ensure this growth is not a burden on our future economy.

If the province allows the proposed targets to stand, and allows Simcoe County communities to build mostly as they have for the past few decades, a pattern of growth will proceed that values development of spread out lots with single-detached homes with larger lawns over the preservation of farmland, more expensive road and water infrastructure over ecosystem services, longer commutes and higher fossil fuel emissions over active transportation, increased inequality and poorer health outcomes over a healthy economy. This will negatively impact our economy by reducing our ability to rely on the many benefits provided by clean water, farmland, and green spaces. This effect could be seen clearly over one decade ago as outlined in the Intergovernmental Action Plan (2006):

“Unique growth and development challenges exist in Simcoe County and the Cities of Barrie and Orillia (study area). South Simcoe and Barrie, in particular, are experiencing increased development pressure, and are expected to continue to have rapid growth. A number of the municipalities in the study area rely on inland water systems which have been demonstrated to be under strain (for example the Lake Simcoe watershed has known issues as a result of phosphorous loadings). Without intervening action, the available potable water and aquaculture of these watersheds are threatened.”

This quote has aged well and could easily have been written today instead of over one decade ago. The effects of ill-managed growth continues to wreak havoc on our water systems.

The impacts are also seen in our loss of farmland and greenspace. According to Statistics Canada, Barrie’s footprint grew 550% over the past 40 years mostly gobbling up farmland and semi natural space for a total loss of roughly 150 km2. Neptis Foundation determined that from 2006-2012, Simcoe County zoned 13,000 hectares of green space (mostly farmland) to designated greenfield areas – the most in the Greater Golden Horseshoe. This despite the fact that they were experiencing a fraction of growth compared to York, Waterloo and Peel and with an existing oversupply of land for development. Under the current proposals to the Growth Plan, this pattern of low density development will continue. Unbelievably, it is proposed to continue while we know that the province loses hundreds of acres of farmland per day to development; while Lake Simcoe struggles to assimilate urbanization to the detriment of its ecology and dependent industries; while we know that the assimilative capacity of the Nottawasaga River has already been maxed and while Simcoe County already sits on an excess amount of land zoned for development and employment.

Where is the balance in this approach? Where are the limits that ensure that communities are growing sustainably? Where are the aspirational policies that support the economies and communities of the future?

Density and Intensification Recommendations

  • Density targets from the 2017 Growth Plan should be upheld without alternative targets for DGAs.
  • Intensification targets should be considered based on current population and future growth potential. For example, Orillia (pop. 31,166) will be held to a higher minimum intensification target than two larger and faster growing communities of Bradford (pop 35, 325) or Innisfil (pop. 33,079). Why?
  • Communities that are rural and with low growth projections should also be encouraged to infill their development to provide a range of housing and to best utilize minimal tax revenues. Intensification should not be seen simply as a panacea for city centres. It is important to smaller communities too.
  • Remove the opportunity for lower alternative targets. Allow municipalities to exceed targets if they so choose.
  • Unless the province wants to ensure car dependency in most of Simcoe County’s larger city centres for the near term, there must be more support and information about the benefits of intensification and density. At the current rate, very few communities in Simcoe County will have the density to feasibly support transit. Provincial planners should be working with communities, both urban and rural, to help them communicate and calculate the benefits of intensification vs. sprawl. This would go a long way to change our damaging development patterns.

Rounding Out and Settlement Area Expansions

Allowing “rounding out” of rural settlement areas and allowing for settlement boundary expansions up to 40 hectares outside of an MCR – even if a municipality has an excess of lands – does not promote efficient use of land, nor does it prioritize intensification, which is a more efficient and equitable way to grow.

We would like to know the policy rationale for these suggestions. What is the cumulative impact on our communities, many of which are already financially unsustainable, in almost inescapable infrastructure deficit, low growing or experiencing population loss? How is loosening the proper growth management policies and resulting investments in new infrastructure going to help already struggling communities?

“Rounding Out” Recommendations

  • Rounding out should only be considered if infill development within the built boundary and does not require new infrastructure;
  • Rounding out should provide a full life cycle cost accounting to ensure that the expansion is financially feasible for the community;
  • Rounding out should not exceed the population allocations for the municipality for 2041 forecasts.

Settlement Area Boundary Expansions

Settlement Area Boundary expansions should not be undertaken lightly. As the footprint of the community grows, the density lowers. As we’ve mentioned earlier, this means that servicing the community becomes more expensive, including transit and infrastructure maintenance and repairs. Moving away from evidence-based planning is not necessary and hurts the long term success of communities.

Settlement Area Boundary Expansion Recommendations

  • Expansions should only be considered within an MCR process;
  • Expansions should not be considered if there is an excess of lands. The municipality should de-designate the excess lands before asking for an expansion;
  • The addition of 40 ha to a settlement boundary is reckless and should not be a considered policy. It does not promote evidence based planning. The target seems arbitrary and we question the problem this policy is trying to solve;
  • Rural settlement areas should not be considered for settlement boundary expansions as they should not be receiving significant (if any) growth. This includes hamlets and villages in the Greenbelt.

Lorem ipsum dolor sit amet, consectetur adipiscing elit. Ut elit tellus, luctus nec ullamcorper mattis, pulvinar dapibus leo.aWe recognize that there is more than metrics and numbers when building strong communities that meet the needs of citizens. Our goal is not to be anti-development, rather we seek to encourage community development that meets the needs of the community. This should be the primary objective of all levels of government when they look at planning and development.

Other Ideas to Increase Housing Supply and to Create Stronger Communities

Remove parking minimums for developments. Parking minimums should also not be a mandatory component for infrastructure projects such as hospitals or schools. Parking minimums force more space to be used than necessary and add to the cost of housing.They also severely limit the ability of businesses to expand, and for new business to emerge in urban downtown areas. For infrastructure projects, it requires a large footprint that is generally not found within city centres thereby forcing new hospitals or schools to move to the fringes of a community. This only encourages sprawl and moves services away from people who need it.
Consider hard urban boundaries for all towns and cities within the Greater Golden Horseshoe. Use existing municipal mapping to determine the boundary.

Expand the Greenbelt over areas of hydrological and ecological significance. This would ensure that those areas are protected while putting boundaries delineating where growth can and cannot go. This helps achieve balance between the places we can use to grow and the places we need for our current and future health and prosperity.

Increase data gathering to understand the effectiveness of the Growth Plan. This will allow for implementation and future policy development that is data and evidence driven, ensuring costly mistakes aren’t made and taxpayers realize maximal return. Include data to determine vacancy rates of existing housing, demographics to best prepare for the boomer generation’s exit from the housing market and available land supply that is approved and serviced.

Consider policies that encourage rental development, co-ops and “missing middle” housing. This could be providing DC deferrals so purpose built housing is incentivized.

Link new infrastructure funding to where job growth is projected and give priority to those projects that will support transit, prioritizing infrastructure for active transportation to realize the many co-benefits it provides.

Research the link between different types of development patterns with climate impacts. Consider including carbon emission calculations in development proposals so that the full impact of a development pattern on a community’s long term health can be properly understood.

Stop building new highways on greenfield within the GGH and reconsider highway expansions. Redirect funds earmarked for inefficient car infrastructure toward transit, active transit, and more efficient commercial transportation infrastructure projects that help keep people and goods moving. New highways or wider highways have been shown to only induce demand, and eventually gridlock returns to previous levels. Reducing car traffic to ensure goods can be quickly moved on our existing highway network is a more prudent approach, particularly in light of the fact that transportation accounts for the largest share of Ontario’s greenhouse gas emissions, and the necessity of reducing these emissions in the most cost effective manner. Shifting from built infrastructure that prioritizes the use of cars and trucks toward communities that prioritize people and the ecosystems we rely on for our health, well being, and economic prosperity, which is in no way conflicting with economic sustainability, is the only way to create a future for Ontario that we can all equally rely on.

We thank you for your time and consideration of this submission. Please feel free to contact us if you have any questions or comments. Please find attached below, the recommendations by the Ontario Greenbelt Alliance which we fully support.


Margaret Prophet
On behalf of the Simcoe County Greenbelt Coalition

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