Facts on Growing the Greenbelt

Find information on a number of issues relating the the Greenbelt below. 

We've tried hard to make sure everything is backed up with facts (definitely more facts needed nowadays!), and sources are provided via links throughout the text.

If there's something you think should be included, please drop us a line and we'll do our best to find well-sourced, reasoned information on it.

The Greenbelt Plan and Private Property

The Greenbelt Plan and Agriculture

The Greenbelt does not further restrict on-farm uses

The Greenbelt Plan supports and enhances the agricultural sector

The Greenbelt Plan and activities on private farmland

The Greenbelt and property value

Additional points

The Greenbelt and Aggregate

Safeguarding Sensitive Environments

Ensuring the health of water systems

Considering impacts on agriculture

Additional points

Implications on settlement boundary expansion and growth management

Municipal Official Plans already have to conform with the Growth Plan

There is enough land for housing

New Growth Plan policies already put tight restrictions on settlement boundary expansions

The Greenbelt Plan, together with the Growth Plan, helps provide planning certainty

Greenbelt designation helps municipalities plan with long-term certainty

Greenbelt designation helps guard against challenges to land use designations

Greenbelt designation helps inform and provide certainty for private sector investment

The Greenbelt Plan supports and works with other plans and policies

Builds on Source Water Protection Plans to protect private well owners

Protects significant recharge areas as mapped in Source Water Protection Plans

The Greenbelt has a stronger policy framework

Municipalities are empowered to increase local protections beyond Greenbelt protections

Considering climate change projections and technical limitations, the time to protect our water is now

The multi-barrier approach to protecting water

The Greenbelt Plan and Private Property

The Greenbelt Plan (section 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.

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The Greenbelt Plan and Agriculture

The Greenbelt does not restrict on-farm uses:

In the updated section of the Greenbelt Plan, section 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 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 supports and enhances the agricultural sector:

In addition, the Greenbelt Plan (section 3.1.5) has also tried to elevate agriculture's importance by encouraging planning exercises to include opportunities to support and enhance the agricultural sector through various means including developing a regional agri-food sector, creation of agricultural advisory committees, minimizing land use conflicts and protecting agricultural resources.

The Greenbelt Plan and activities on private farmland:

Regarding how the Greenbelt might impact activities on private farmland, section 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 added).

These activities, rather, are subject to section 3.2.5 (specifically, 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 and property value.

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).

Additional points:

Beyond these points, the Greenbelt has added benefits to agricultural systems:

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.

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The Greenbelt and Aggregate

Within the Protected Countryside designation of the Greenbelt, as outlined in section, 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.

Increased standards on aggregate safeguards our most sensitive environments.

As stated in section, 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” ( (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.

Increased standards to ensure health of our water systems.

In addition, any new application for aggregate mining outside of these sensitive habitats, as listed above, has increased obligations to demonstrate how the connectivity of water systems and natural heritage will be maintained before, during, and after aggregate extraction, as well as an obligation to show how the water resource systems will be protected or enhanced (section Mandating consideration for the long-term health of our water resources is a net benefit to the community and environment at large.

Greenbelt policies ensure aggregate operations consider their impact on agriculture.  

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.

Additional Points

Finally, we note that 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 ensure a healthy balance between resource extraction activities, and the health and viability of the ecosystems and citizens they are situated within and take place next to. These issues include a history of non-compliance with the Aggregate Resources Act, with, according to figures gathered by the MNR, 100 out of 121 operations non-compliant, as well as a frequent failure, incommensurate with the notion that its activities are an “interim use”, to return to sites pre-existing features or otherwise natural functions, with “most operators ... not conducting progressive or final rehabilitation as required.”

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Implications on settlement boundary expansion and growth management

Municipal Official Plans already have to conform with the Growth Plan.

The policies within the Growth Plan determine where growth will occur. The most recent Growth Plan clearly prioritizes growth to primary settlement areas as outlined in Growth Plan section 6.3.4.

There is enough land for housing

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).)

New Growth Plan policies already put tight restrictions on settlement boundary expansions.

A municipality, through its municipal comprehensive review, has a high threshold to justify settlement boundary expansions, including proving that the growth cannot be accommodated. Section of the Growth Plan states:

A settlement area boundary expansion may only occur through a municipal comprehensive reviewwhere it is demonstrated that:

based on the minimum intensification and density targets in this Plan and a land needs assessment undertaken in accordance with section, sufficient opportunities to accommodate forecasted growth to the horizon of this Plan are not available through intensification and in the designated greenfield area:

i. within the upper- or single-tier municipality, and

ii. within the applicable lower-tier municipality;

Similarly, there are requirements to demonstrate consideration and concern for life cycle costs of infrastructure, future water supply and preservation of natural heritage and agricultural systems, among many others. So even without the Greenbelt settlement area boundary expansions are a rigorous exercise.

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The Greenbelt Plan, together with the Growth Plan, helps provide planning certainty.

Greenbelt designation helps municipalities plan with long-term certainty.

This allows municipalities to focus development, more accurately plan for infrastructure, reduce unnecessary over-sizing to provide for future urban expansions in all directions, thus reduce capital spending and development charge expenditures.

Greenbelt designation helps guard against challenges to land use designations.

Currently, there is no protection against challenges to the underlying designations that would influence or guide decisions relating to settlement area expansions through future municipal comprehensive review processes. In the absence of provincial level protection for such areas, municipalities are left to potentially re-litigate the same issues over and over again. A Greenbelt would provide that level of protection thereby reducing municipal costs.

Greenbelt designation helps inform and provide certainty for private sector investment.

Better long-term infrastructure planning can also reduce both up-front costs and development charges, while focused development activity potentially would lead to more timely recovery of front-ending expenditures.

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The Greenbelt Plan supports and works together with Source Water Protection plans, the Clean Water Act, Natural Heritage and Ag Systems mapping, the Endangered Species Act, and the Growth Plan.

The Greenbelt can build on Source Water Protection Plans to protect private well owners.

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.  

The Greenbelt can protect significant recharge areas as mapped in Source Water Protection Plans.

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.”

The Greenbelt has a stronger policy framework.

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.

Municipalities are empowered to increase local protections beyond Greenbelt protections.

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.

Considering climate change projections and technical limitations, the time to protect our water is now.

As noted by the Council of Canadian Academics Expert Panel on Groundwater, “Our technical ability to map capture zones and time-of-travel zones necessary for source water protection plans is still developing, and there is a tendency to err on the conservative side when delineating these zones.” Therefore, a landscape level of protection is likely better suited to ensure that the entirety of capture zones is protected. Also, since local conservation authorities have projected that municipal and private wells could run dry and would need to find new sources of water, erring on the side of permanently protecting all features that contribute to our water quality and quantity is not only pragmatic but essential.

The multi-barrier approach to protecting water.

The Greenbelt Plan is an additional layer in the multi-barrier approach to water protection recommended by Walkerton Inquiry, the addition of which has been shown to provide stronger legal protections for water and wetlands compared to jurisdictions elsewhere in Ontario. The Greenbelt follows a thread that arcs back to Walkerton, where the death of seven people and illness of more than 2300 others, many of whom continue to suffer with ailments associated to drinking water infected with Escherichia coli, when groundwater was contaminated by seepage from manure on a nearby farm.

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