SCGC Comments on Draft Amendments - Coordinated Review

Our submission to the Co-ordinated Land Use Review.

You can download the submission, here: SCGC_Oct_31_submission.pdf 


Simcoe County Greenbelt Coalition


The Simcoe County Greenbelt Coalition (SCGC) is a not-for-profit organization that is comprised of close to 30 various organizations from across Simcoe County including naturalists, land conservancies, ratepayers, environmentalists, farmers and First Nations. The mandate of the SCGC is to promote and encourage expansion of the Greenbelt further into Simcoe County to balance the growth of our communities with water protection and land preservation. We applaud the government for undertaking such a thorough review and submit our recommendations for consideration.

Greenbelt Expansion

Considering the immense growth pressures on Simcoe County, large reliance on groundwater resources and pervasive nature of water systems throughout the county, the SCGC with its various member organizations, recommend that the Greenbelt be expanded to include all of Simcoe County and its supporting ecosystems. See Appendix 1 for source water mapping that we feel supports this call.

We also support calls to grow the Greenbelt in other key areas of the Greater Golden Horseshoe including but not limited to: 

  • Moraines and groundwater recharge areas in the Grand River watershed that provide clean drinking water to 80% of local residents. These moraines include the Paris-Galt, Waterloo and Orangeville Moraines. Significant headwaters features including the Luther Marsh, important headwater areas and source water protection areas in Brant County, as well as the Grand River as a key river valley connection between these important and vulnerable water supplies.
  • Headwaters of rivers that flow through Peel, York, Durham and Toronto and reduce flooding for millions of residents. This includes the Carruthers Creek, Duffins Creek, Rouge River, Don River and Humber River.
  •  The Lake Iroquois shoreline, which includes many features, that provides important groundwater functions and helps sustain groundwater baseflow.

Further, we would like the province to consider additional recommendations for Greenbelt expansion consultation: 

  • Ensure that areas identified to grow the Greenbelt are also included in the consideration of the water resources systems, natural heritage system and agricultural system.
  • Adhere to firm timelines in your process of identifying, mapping, consulting and finalizing areas to grow the Greenbelt. We believe a draft map should be presented publicly for consultation on the Environmental Registry by January 2017, with final mapping completed and final amendments integrated by late spring 2017.
  • Ensure transparency and full public involvement in local consultations regarding potential Greenbelt expansion. 

Strengthening the Greenbelt

Finally, in order to ensure the integrity of the Greenbelt as it is considered to be expanded, we offer the following recommendations to strengthen the Greenbelt:

  • Settlement area boundaries should be frozen in the Greenbelt. Infill development should be prioritized before greenfield development for Growth Plan areas.
  • Improvements and strengthening of aggregate and infrastructure policies within the Greenbelt including restricting aggregate in the Greenbelt and not allowing infrastructure exemptions in the Greenbelt. Further, commercial water taking (e.g. water bottling) should not be allowed in the Greenbelt.
  • Large scale fill operations should not be permitted in the Greenbelt.
  • To ensure long term integrity of the Greenbelt, a sunset clause for grandfathered development applications should be included.
  • Many times, the implementation of land use plans is where it is weakened. We strongly support the province taking a strong lead in enforcement and monitoring of various provincial plans. This would include data taking, creation of benchmarks and outlining metrics to determine best practices and what “successful implementation” looks like. Further, the province should consider financial incentives to encourage municipalities to adhere to provincial plans and efficient land use.
  • Better protection for alvars and savannahs.
  • Do not allow any land swaps or land removals from within the Greenbelt.
  • Do not allow settlement boundary considerations and applications every 5 years. This will become a death by a thousand cuts and threatens the very purpose of a permanently protected Greenbelt.

Growth Plan Recommendations

The implementation of the Growth Plan will have serious implications to the Greenbelt. With effective implementation and strong policies, the Greenbelt will be allowed to flourish for generations. Without this, the threat of killing the intent and spirit as well as function of the Greenbelt will be ever present. As such, we offer the following recommendations:

  • Update growth forecasts using 2016 census data. Accordingly, until this is done and mapping of agricultural systems and natural heritage systems is complete, we feel a moratorium on settlement area expansions is in order.
  • Density targets and intensification targets should be maintained as drafted. However, lower density and intensification targets for municipalities that do not have an urban growth centre should be eliminated. Best practices suggest that we need to use our land more efficiently – allowing a selected few to not meet this target weakens the integrity of the ask and makes the process inequitable.
  • Consider adopting policies of “net benefit” in order for applications to proceed. Further, consider the comparison of removing carbon sinks (e.g. pastures, wetlands, forests) with the construction of carbon emitters (e.g. increased traffic/cars, removal of recharge areas, increase of impermeable surfaces, factories etc.) in the approval process.

Other Important Recommendations 

  • Stronger incorporation and recognition of indigenous rights, traditional knowledge and ensuring informed and prior consent when it comes to land use, watershed protection and development applications. This includes stronger protection of ancestral lands from development as well as providing legal vehicles for indigenous communities to say no without fear of reprisal.
  • The Niagara Escarpment is a world recognized bio-sphere. This global treasure deserves the utmost protection. Therefore, we support calls to expand the Niagara Escarpment.
  • Reform the OMB so that local planning decision, assuming they fall within provincial policies and support community interests, are not all under the purview of the board. Municipalities need to be able to make important community decision without fear of reprisals via lawsuits or OMB.
  • Include policies that allow communities to deny applications based on areas where water resources are under threat or stressed. This would include PTTW, extractive industries, development and energy. Without this type of policy, we knowingly jeopardize our future.

We appreciate the opportunity to submit our comments for your consideration. We applaud the province on many of the proactive policies it has drafted that strengthen agriculture, water preservation and build stronger, smarter communities. Now is the time to ensure we are leaving a proud legacy. Now is the time to take bold actions that will ensure that legacy.


Margaret Prophet

Sandy Agnew

Co-chairs, Simcoe County Greenbelt Coalition

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