Ontario Water Guardians Urge New Support for the Greenbelt and the retention of the existing Provincial Policy Statement

Consistent with the Provinces's extension of the deadline for comments on the proposed amalgamation of the Provincial Policy Statement and the A Place to Grow Act until August 4, which can be seen at Review of proposed policies adapted from A Place to Grow and Provincial Policy Statement to form a new provincial planning policy instrument. | Environmental Registry of Ontario, we too are extending this petition.

The Coalition agrees with almost every other organization in the province that this amalgamation will be a disaster. Our full comments can be seen below, and we request support for the four recommendations in the petition on the right that will be sent to Minister Clark and the Growth Planning Secretariat, with a copy to your local MPP.

RE: ERO 19-6813 - Review of proposed policies adapted from A Place to Grow and Provincial Policy Statement to form a new provincial planning policy instrument

The Coalition of Ontario Water Guardians seeks to maintain and improve water security in the province in order to help safeguard our ecological integrity, public health, social equity, and economic vitality. As such, we perceive an overarching need for a sustainable lens that treats land and water as one, and offer the following comments and recommendations on this posting.

First, we are concerned when land use planning is being pursued in crisis mode, as it is now in Ontario under the Province’s own statements. We therefore support the broad range of sectors that have offered their comments about:

• the abolition of regional planning and restrictions to the mandate of conservation authorities;
• land conversion that will turn expanses of natural heritage and even areas of the Greenbelt into housing and expressways;
• significant reductions of agriculture land and indeed threats to the future of farming;
• autocratic amendments to municipal official plans that will create sprawl communities that will both exacerbate the climate crisis and increase the potential of municipal fiscal insolvency due to reduced development charges;
• a weak framework for attainable and affordable housing; and;<.li>
• the absence of any meaningful public and First Nations’ consultation on most land use planning initiatives over the last five years.

In particular, we are deeply troubled about the Premier’s recent comments about the Greenbelt. When recorded in a meeting a few years ago that he would open the Greenbelt to development, he quickly retracted, stating “Unequivocally, we won’t touch the Greenbelt...I’ve heard it loud and clear; people don’t want me touching the Greenbelt. We won’t touch the Greenbelt.”

Since then, the Premier has led efforts to repeal the law establishing the Duffins Rouge Agricultural Preserve, supported other Greenbelt carveouts, and endorsed multi-lane expressways through the Greenbelt. And earlier this month he stated “Let’s just be honest, the Greenbelt was a failed policy, a flawed policy from the Liberal government. It was just a big scam as far as I’m concerned.”

Clearly, the Premiere has been unable to offer clear and consistent leadership on the Greenbelt.

We believe this has severely damaged public trust in the government’s commitment to the Greenbelt, and we urge the Province to issue a clear vision for the future of the Greenbelt and the continued protection of its water, natural heritage, and agricultural lands.

Secondly, with respect to water security, we find no merit in amalgamating the Provincial Policy Statement with A Place to Grow, especially given additional confusing and incomplete efforts in this regard.

Well-known examples of this include unimplemented aspects of the Clean Water Act; the lack of implementation of some aspects of Ontario’s flood protection regime; highly-contentious amendments to the Ontario Wetland Evaluation System, and; reductions to the mandate of conservation authorities.

We also perceive, however, that there has been inadequate analysis and discussion on drinking water, storm water, and sanitary sewage given the anticipated growth in population, the expansion of municipal boundaries into sensitive headwater areas and agricultural lands, and changes to the traditional level of financial support from development fees that would normally pay for municipal infrastructure. Potential negative outcomes could dwarf the impact of the Walkerton catastrophe.

In the face of these issues, many aspects of the posting are inadequately addressed with a bullet but lack any sense of how municipalities might in fact be able to deliver them. Moreover, the proposed Provincial Planning Statement remains blank, as of May 21, on Natural Heritage, the proposed new s 4.1.

We therefore believe that the Province needs to withdraw ERO 019-6813 and retain the existing Provincial Policy Statement.

Afterward, should the government want to proceed to amend the Provincial Policy Statement, it should do so only by providing reports on its performance indicators, as required for a major review, and engage in extensive consultation with First Nations, municipalities, conservation authorities, the agricultural and other sectors, and of course civil society.

Finally, one other aspect of this initiative begs comment: the fact that the Province is essentially ignoring the Great Lakes, which will be impacted by the cumulative effects occurring in its watersheds.

Key aspects of this involve the absence of any meaningful Provincial presence at the Great Lakes Public Forum in November 2022 at Niagara Falls, recent mis-steps on a proposed intra-basin transfer without adhering to the protocols of the Great Lakes–St. Lawrence River Basin Water Resources Compact, and confusion over the changing roles of conservation authorities regarding Great Lakes.

As a result, we support the intent of the Township of Archipelago to ask the Great Lakes and St Lawrence Cities Initiative to express its concerns about the impact of Bill 23 while also calling for the reinstatement of many of the environmental protections that were abandoned in that bill.

In summary, we re-state our four recommendations below, which will be cited on a petition to be posted on the internet for public support:

1. Given the severe damage to the public trust caused by the Premier’s changing positions on the Greenbelt, we urge the Province to issue a clear vision to protect and indeed expand the Greenbelt;
2. The Province needs to withdraw ERO 019-6813 and retain the existing Provincial Policy Statement;
3. Further consideration on amending the Provincial Policy Statement must include both the required reports of indicators on the performance of the PPS and extensive consultation; and,
4. We support the intent of the Township of Archipelago to ask the Great Lakes and St Lawrence Cities Initiative to express its concerns about the impact of Bill 23 while calling for the reinstatement of many of the environmental protections that were abandoned in the bill.