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Earthroots’ Response to Bill 135
The Greenbelt Draft Plan

EBR Registry Number PF04E0006


Prepared by: Andrew Athanasiu


Earthroots is an Ontario-based environmental advocacy organization founded in 1986 with a mandate to protect wilderness, wildlife and watersheds through research, education and action. Earthroots has been involved in preserving greenspace in Southern Ontario for many years. Our organization and its members have been involved in working to protect the Oak Ridges Moraine and the Niagara Escarpment since 1999. As a result, we have taken a keen interest in all of the provincial government’s recent initiatives aimed at curbing urban sprawl in the greater Toronto area and throughout the Golden Horseshoe.

Earthroots contends that urban sprawl is the most critical environmental problem currently facing the greater Toronto area. The proliferation of low-density, automobile-oriented development over the past forty years has transformed Toronto into a vast urban region, stretching from Niagara to Clarington, from Lake Ontario to Lake Simcoe. In the process, much of the area’s greenspace and agricultural land has been paved over or severely degraded.

The problems arising from unbridled growth have been well documented. Historically, however, little has been done at the government level to tackle the problem. It is within this context that Earthroots welcomes the initiatives put forth by the Ministry of Municipal Affairs contained in Bill 135: The Draft Greenbelt Plan. Our organization feels that the provincial government is the only body capable of tackling urban sprawl in the Toronto region, due to myopic planning decisions that are sometimes made at the local level, and welcomes its return to the land use planning process.

Earthroots supports the government’s stated aims of protecting environmentally sensitive areas and agricultural lands. There are a number of truly positive measures contained in Bill 135 that are a good first step towards controlling unsustainable development patterns in the greater Toronto area. However, with an additional 4 million people expected to move to the region in less than 30 years, we feel that the Draft Greenbelt Plan is inadequate at this crucial juncture.

The Greenbelt’s scope must be expanded to address the realities of development in the Toronto region. The borders of the government’s green belt are, approximately, the Oak Ridges Moraine and the Niagara Escarpment. Given that these barriers are well within the functioning borders of the GTA, Bill 135 will do little to stop urban sprawl. Fast growing areas such as South Simcoe, especially the area surrounding Barrie); Kitchener-Waterloo; and Wellington are not currently included in the plan despite the fact that many residents of these regions already commute to Toronto daily. Earthroots feels that this omission will unintentionally promote ‘leapfrog’ development into areas just outside the greenbelt. Already, recently announced developments of unprecedented size in Bond Head and Alliston have shown that our concerns are warranted.

Recommendation: The greenbelt area should be expanded to include South Simcoe, Waterloo County, and Wellington County

Within the greenbelt area itself, there are far too many loopholes and opportunities for development that would be detrimental to the stated aims of Bill 135 for Earthroots to support this legislation in its current form.

Section 3.4.2 of the plan allows for the ‘modest growth’ of Towns and Villages located within the greenbelt area at the 10-year review period. While Earthroots is encouraged that the plan will not allow this growth to occur in areas designated as part of the Natural Heritage System we still find this portion of the bill to be problematic. Earthroots has, and will continue to oppose certain developments regardless as to whether an area is deemed ‘environmentally significant’ or not. New urban development --especially if it is done at a low density-- puts more cars on the road that, in turn, require invasive infrastructure and produce air pollution. While our organization believes that this provision is intended to allow small developments only, the term ‘modest’ leaves far too much room for interpretation. It is our fear that some towns, in search of development fees, may take advantage of this lack of clarity.

Recommendation: Section 3.4.2 should be amended to include appropriate limits to the extent to which towns and villages can expand.

Section 3.4.4 allows for the construction of new resort developments along shorelines in the greenbelt area. While Earthroots understands the importance of the tourism industry to the Golden Horseshoe area’s economy, we find this provision troubling. Developers and local officials could misinterpret the term ‘resort’, and proceed with developments that do not conform to the spirit of this provision. For instance, many ‘adult lifestyle’ communities are called ‘resorts’ even though they contain year-round residents. As the plan allows for new developments built under this section to be serviced with new municipal sewer and water services, the potential for a new, large-scale development within the greenbelt is certainly there.

Recommendation: Section 3.4.4 should be amended to include a more thorough definition of the term ‘resort’.

Section 4.2 allows for new infrastructure to cut through the entirety of the greenbelt with little restriction. Of particular concern to Earthroots is the Draft Plan’s endorsement of the Mid Peninsula Highway and the 407 East Extension. While not houses, highways are certainly another form of major development that is detrimental to the environment. These highways could, respectively, go through the Niagara Escarpment and the Oak Ridges Moraine, paving over precious greenspace and severing wildlife corridors in the process. As well, these new highways would further facilitate ‘leapfrog’ development outside the greenbelt area.

Recommendation: section 4.2 should be amended to exclude new highways from being built in the greenbelt area.

Section 4.3 allows for the extraction of a number of renewable and non-renewable natural resources. Earthroots is concerned that this section allows for forestry and mining activities to take place in the greenbelt with little restriction. It is Earthroots’ position that wooded areas of any kind in the greater Toronto area are a scarce and therefore significant natural feature, and should therefore be given reasonable protection within this greenbelt. This section allows for mining operations to occur within virtually every portion of the greenbelt. While Earthroots applauds the government’s restriction of these activities in significant wetlands and significant habitat of threatened or endangered species, Earthroots strongly opposes these activities from taking place in other key natural areas and significant woodlands. In general, our organization feels very strongly that the inclusion of forestry and mining activities with little restriction is antithetical to the function of a greenbelt.

Recommendation: section 4.3 should be amended to exclude commercial forestry activities from all areas of the greenbelt where these activities were not already taking place prior to the development moratorium enacted under Bill 27 of December, 2003. Further, Earthroots recommends that any commercial forestry activities should be gradually phased out within the greenbelt. This section should also be amended to exclude mining operations from all key natural areas and significant woodlands.

These recommendations have been made as a result of careful analysis and guidance from Earthroots’ supporters. Although the nature of this submission is largely critical of the plan, our organization is quite supportive of a greenbelt around the greater Toronto area. These recommendations are meant to strengthen the existing plan, and in no way should be taken as a desire to abandon the process. Earthroots congratulates the government for taking on this challenge and encourages them to take the time to create a plan that all Ontarians can be proud of for generations to come.