Grow Ontario's Greenbelt
The provincial government is seeking input on how and where to grow the Greenbelt until April 19th.
Simcoe County was listed as one of the priority areas to expand the Greenbelt in 2018. Our wealth of shorelines, forests, wetlands and moraines, makes Simcoe County a prime candidate to ensure large swath’s of Ontario’s natural heritage, farmland and water are protected.
With urbanization pressures and the health of Lake Simcoe declining, now is the time to ask the government to include Simcoe County and the remainder of the Lake Simcoe shoreline into an expanded Greenbelt.
Clicking the button above will open a draft email with pre-filled text. Feel free to use what we’ve provided, or edit and compose to your heart’s content.
If you’d like to read our joint submission with the Rescue Lake Simcoe Coalition to the ERO you can find it here.
The Greenbelt provides...
About the Greenbelt
The Greenbelt was created in 2005 to:
- Prevent further loss of farmland and natural heritage;
- Restrict urban sprawl;
- Work with the Growth Plan to develop vibrant communities where people can live, work, and play.
All of these pressures are particularly acute in Simcoe County.
This is why more than 100 community groups, including the Simcoe County Greenbelt Coalition and Ontario Greenbelt Alliance, asked the province to nearly double the size of the Greenbelt to add 1.5 million acres of land containing vital water resources.
In Simcoe County this includes almost 300,000 hectares of land covering the Lake Simcoe watershed, the Oro Moraine, the Nottawasaga River Watershed and the Minesing Wetlands, which supply and purify clean drinking water for most residents of the county.
The Greenbelt and Climate Change
More recently, it has become clear that the Greenbelt plays an important role as part of a natural solution to climate change.
By absorbing carbon from the air it helps mitigate greenhouse gas emissions, and by slowing and absorbing water it helps adaptation efforts that address the impacts of climate change, such as flooding.
By growing the Greenbelt we can increase these benefits in a way that also enhances our collective health and wellbeing.
The Greenbelt also helps ensure that the way we develop our communities is done prudently. By putting a check on sprawl it encourages development of complete communities, within which people can live, work, and play without having to commute elsewhere. This benefits taxpayers as the cost of sprawl, including infrastructure maintenance, as well as externalities associated with increased pollution and environmental degradation, are reduced.
The Greenbelt is permanently protected countryside of almost 2 million acres that protects key water sources, local foodlands, and green spaces for future generations.
It is the world’s largest permanently protected Greenbelt.
Since its creation ten years ago, it has become very popular with Ontarians – 93% voiced approval in a 2014 study carried out by Environics, with 74% feeling it was very important to continue to grow the Greenbelt.
The Greenbelt protects over 533,000 acres of forests, lakes, wetlands, rivers and streams, saving us $2.3 billion in water filtration, flood mitigation and drinking water treatment.
Further, it protects the habitat of 78 species at risk and protects the land of over 5,500 farms.
Simcoe County is the largest jurisdiction geographically in the Greater Golden Horseshoe, and is anticipated growth to 667,000 people by 2031.
This will put intense pressure on municipal leaders and staff in terms of how our communities develop to handle this growth.
We have a responsibility to protect the things that make Simcoe County a great place to live and play and that strengthen our local economies.
Provincial studies show that our two main watersheds in Simcoe are no longer able to keep up with our population growth and that Barrie, Bradford, and Midland/Penetanguishine may not have the quantity of groundwater needed to support their residents in the future.
Frequent beach closures, water restrictions and water bans indicate that our water systems need more effective protection before it’s too late.
The Greenbelt would strengthen the policies that protect of our water (hydrologic) systems, natural heritage, and our farmland. The Greenbelt plan ensures:
- Simcoe’s water systems will be protected, including areas that are not adequately protected through current Simcoe County policies such as Lake Couchiching, Severn River and Georgian Bay.
- Communities can continue to grow responsibly. Simcoe County (minus the cities of Barrie and Orillia) has enough land designated to grow until at least 2031 and also has an oversupply of land to accommodate an additional 150,000 people beyond this date. Greenbelt protection would limit costly sprawl and ensure future growth is concentrated where infrastructure and jobs already exist.
- The health of our forests, streams and wetlands will be protected so that they can continue to support Simcoe’s $600 million tourism and recreation industry.
- Simcoe’s 2,189 operating farms (StatsCan 2011) and agricultural communities will be protected so that they can continue to provide local food and generate jobs.
In Simcoe County, the Study Area outlined by the previous government is shown as shaded, and the Bluebelt Area, based on key hydrological features, is represented in blue/green. (You can find a larger version here.)
In 2015 the Advisory Panel for the Coordinated Review of the Growth Plan, Greenbelt Plan, Oak Ridges Moraine Conservation Plan, and Niagara Escarpment Plan, chaired by David Crombie, reported to the government their recommendations for how Ontario should grow in the coming several decades.
The recommendations of this report form the basis of the argument that expanding the Greenbelt is one of the best ways to ensure our children and their children can continue to access the green spaces and healthy environment many of us did when we were children.
The full report can be found here.
In the updated section of the Greenbelt Plan, section 220.127.116.11 clearly outlines that the Greenbelt does not further restrict on-farm uses:
“All types, sizes and intensities of agricultural uses and normal farm practices shall be promoted and protected and a full range of agricultural uses, agriculture-related uses and on-farm diversified uses are permitted based on provincial Guidelines on Permitted Uses in Ontario’s Prime Agricultural Areas. Proposed agriculture-related uses and on-farm diversified uses shall be compatible with and shall not hinder surrounding agricultural operations.”
In fact, the Greenbelt Plan (section 18.104.22.168) emphasizes the primacy of agriculture over non-agricultural uses explicitly stating that other land uses should not negatively impact agriculture:
“Where agricultural uses and non-agricultural uses interface, land use compatibility shall be achieved by avoiding or, where avoidance is not possible, minimizing and mitigating adverse impacts on the Agricultural System, based on provincial guidance. Where mitigation is required, measures should be incorporated as part of the non-agricultural uses, as appropriate, within the area being developed.”
This puts the onus on other land owners to work with existing agricultural operations rather than forcing farmers to adapt to development, aggregate or infrastructure, potentially negatively impacting the farms’ viability as has been the case in the past.
The Greenbelt Plan (section 3.1.5) attempts to elevate agriculture's importance by encouraging planning exercises to include opportunities to support and enhance the agricultural sector through various means. These include developing a regional agri-food sector, creation of agricultural advisory committees, minimizing land use conflicts and protecting agricultural resources.
Regarding how the Greenbelt might impact activities on private farmland, section 22.214.171.124 of the Greenbelt Plan states:
“New buildings or structures for agriculture, agriculture-related and on-farm diversified uses are not subject to the policies of section 126.96.36.199”.
These activities, rather, are subject to section 3.2.5 (specifically 188.8.131.52), which states:
“...new buildings and structures for agricultural, agriculture-related or on-farm diversified uses are not required to undertake a natural heritage or hydrologic evaluation if a minimum 30 metre vegetation protection zone is provided from a key natural heritage feature or key hydrologic feature. In addition, these uses are exempt from the requirement of establishing a condition of natural self-sustaining vegetation if the land is and will continue to be used for agricultural purposes.”
The Greenbelt is effective at stopping the loss of farmland to development. Since its inception until 2014, zero hectares of farmland has been lost to development in the Greenbelt, proving its effectiveness in preserving agricultural land for food production.
Conversely, outside of the Greenbelt, 7,500 hectares of farmland has been lost to development in that same time frame.
As recognized by the Ontario Federation of Agriculture, “land capable of supporting agricultural activity is a strategic non-renewable resource worthy of preserving” and the preservation of this land is in “all of society's best interest.”
If Simcoe County wants to preserve this land base to ensure a strong future agri-food economy, then providing the most effective land protections seems both visionary and pragmatic.
Within the Protected Countryside designation of the Greenbelt, as outlined in section 184.108.40.206, non-renewable resource activities (including mineral aggregate) are permitted and subject to all other applicable legislation.
So, it is possible for aggregate to be located close to market and continue operations depending on the location of the operation within the Greenbelt.
However, the increased standards of the Greenbelt on aggregate operations, in certain areas, should be viewed as a net benefit to the community.
As stated in section 220.127.116.11, when a new non-renewable resource activity is proposed within the Natural Heritage System, key areas are protected from these activities, including significant wetlands, habitat of threatened or endangered species and significant woodlots.
The language in this part of the plan clearly prohibits “new mineral aggregate operation and no new wayside pits and quarries, or any ancillary or accessory use” (18.104.22.168 (a)).
Considering the widespread degradation of our key habitats, these standards allow municipalities to stand behind provincial policy to protect locally important environments.
As the Environmental Commissioner noted in his 2006/2007 report:
“The inherent conflicts between aggregate production and the protection of natural areas arise because many of the highest quality aggregate deposits in Southern Ontario are found in areas of great ecological and social significance.”
The Greenbelt would reduce conflicts in these areas and preserve the ecological integrity of our most sensitive spaces.
In prime agricultural areas, new applications must include an agricultural impact assessment as well as consider how the connectivity of nearby agricultural systems will be maintained or improved.
No longer is the onus on the farmer to adapt to new aggregate operations including increased truck traffic, noise or air quality.
Rather, the responsibility lies with the aggregate operation to consider its impact on agriculture and adapt its practices accordingly.
The aggregate industry has historically been both environmentally and socially problematic.
As the Environment Commissioner notes, cited above, this is due, in part, to the conflict between resource extraction needs and sensitive ecological areas, inherent within the activity.
Additional issues suggest work remains to be done to ensure a healthy balance between resource extraction activities and the health of the ecosystems and communities they are situated within.
These issues include a history of non-compliance with the Aggregate Resources Act.
According to figures gathered by the MNR, 100 out of 121 operations surveyed were non-compliant. This is incommensurate with the notion that aggregate activities are an “interim use” that, upon completion of required rehabilitation activities, are restored to pre-existing features or natural functions. Most operators, the report concluded, are “not conducting progressive or final rehabilitation as required.”
Recent studies estimate that there is enough land for development.
The Neptis Foundation found there to be 103,200 hectares of Designated Greenfield Area (DGA), defined as "the area within a settlement area that is not built-up area," in the Greater Golden Horseshoe.
Another estimate finds 31,400 hectares in the Greater Toronto Hamilton Area (note the different area sizes)(Note: The MGP study distinguishes between "vacant" and "committed" DGA. The Neptis study looks at DGA as defined in Places to Grow (see above).)
The Greenbelt Plan (section 22.214.171.124) details how any site alterations or development on lands within the designated Natural Heritage System must demonstrate there are no negative impacts to areas of any key hydrologic or natural heritage features.
Further, due to the requirement that there must be consideration for the connectivity of these features, limits are placed on the size of the developable area as well as policies that prohibit the removal of natural features.
Property owners within what has been designated as a natural heritage system who want to alter the site or build will be subject to policies that are intended to limit negative impacts to watersheds, natural heritage and agricultural systems, and to thereby preserve and enhance the benefits they provide.
This does not mean that private property owners are restricted from any activity, but there is rigour where impacts to water, other agricultural lands, and natural heritage may be realized.
This is often heard from land-owners who want to sell their land to developers and property speculators.
The goal of the Greenbelt is to preserve the non-renewable resource that is prime agricultural land. Being able to grow food locally benefits us all, and this is exactly what the Greenbelt helps to ensure.
The Greenbelt does not lower farmer to farmer sales value.
Farmland prices have steadily increased in the Greenbelt at 10% or more annually (total 41% over 4 years) according to MPAC.
Moreover, farms in Waterloo that are already protected by a regional Greenbelt, with policies modeled after the provincial Greenbelt Plan, have been shown to have the highest farm revenues in the province ($410,210 Waterloo vs. $304,977 provincial average).
The Greenbelt protects water on a landscape scale including quality and quantity considerations, whereas Source Water Protection Plans were designed to assess threats of water quality and quantity for municipal wells.
As noted in the Annual Report (2014) of the Auditor General of Ontario, “Private wells or intakes that serve one residence are currently excluded from source protection planning.
An estimated 1.6 million people in Ontario rely on private wells for their drinking water supply.”
Accurately mapping and understanding where all of these private wells are located is cost prohibitive and would take considerable time.
A recent critique of Ontario’s source water protection regime points out:
“The Ontario experience suggests that source protection legislation...may not be a cost-efficient means to achieving drinking water security. As of September 2014, the Ontario government had dispensed $241.3 million (CAD) on source protection of which only $38 million (CAD) went to implementation, which had barely begun.”
A more cost-efficient and effective method would be to apply Greenbelt designation over rural areas identified by the Source Water Protection Plans, including aquifers and recharge areas to ensure activities that could threaten water supply or quality (i.e. site alteration or development) are restricted.
Since most jurisdictions in Simcoe County, including Springwater Township, rely on finite groundwater resources for municipal water supply, protection of areas that allow groundwater to be recharged is key to the future health of our water supply.
By not allowing “development or site alteration” in these areas, as a Greenbelt would do, the quality of these complex recharge areas is protected.
Current policies that govern these areas now, such as the PPS, do not ensure protection; indeed, as of a few years ago only “1.2% of the total land area of source water protection areas will be protected by significant threat policies.”
First, the Greenbelt Plan requires “conformity” of municipal planning documents versus “consistency” with PPS:
"Within the Greenbelt Area, there may be other provincial, federal or agency plans, regulations or standards that also apply. An application, matter or proceeding related to these plans, regulations or standards shall conform with the Greenbelt Plan. However, where the plans, regulations or standards are more restrictive than this Plan, the more restrictive provision shall prevail." (Source)
Second, the language in the Greenbelt for protection means “no development or site alteration”, whereas in the PPS the level of protection is “no negative impact”, which can be widely interpreted and has led to continued degradation.
The Greenbelt includes higher minimum protection standards on more features, such as all wetlands and smaller forest plots, mandates a 30m buffer, and protects key natural and hydrological features through site alteration or development thresholds including streams, springs and seepage areas. This would strengthen the protective measures for all of these sensitive systems.
Section 5.3 of the Greenbelt Plan states:
“Despite the policies in the Greenbelt Plan, there is nothing in this Plan that limits the ability of decision-makers on planning matters to adopt policies that are more stringent than the requirements of the Plan, unless doing so would conflict with any of the policies or objectives of the Plan. With the exception of the policies of section 4.6, official plans and zoning by-laws shall not, however, contain provisions that are more restrictive than the policies of sections 3.1 and 4.3.2 as they apply to agricultural uses and mineral aggregate resources respectively.”
Thus the Greenbelt plan does not restrict municipalities from adding more protective measures, unless for aggregate or agriculture. Having provincial plans support protective measures at the local level reduces challenges to said policies and thereby reduces municipal costs and red tape.