Facts on Growing the Greenbelt

Find information on a number of issues relating to 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.

What are you interested in learning more about?

The Greenbelt is a prime example of a 'natural solution' to climat change.

A recent letter, signed by a number of important public figures, outlines why this:

By defending, restoring and re-establishing forests, peatlands, mangroves, salt marshes, natural seabeds and other crucial ecosystems, large amounts of carbon can be removed from the air and stored.

You can read the rest of the letter here

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 municipality in the Greater Golden Horseshoe, with anticipated growth to 667,000 people by 2031. 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.

The Greenbelt was created, largely, to protect farmland from loss to development, and in particular to urban sprawl.

Within the Greater Golden Horseshoe (GGH), where the Greenbelt is located, farming contributes roughly $11 billion and 38,000 jobs to the Ontario economy. Development pressure is also extremely high in this region, with the population expected to grow by an additional several million people by 2041.

Nearly half of Ontario's best farmland is located in the GGH. The Greenbelt is meant to ensure that this farmland remains available for productive agriculture into the future.

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 (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 including 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 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”.

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 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, 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, 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.

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 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.”

The Greenbelt is one of four land-use plans used by the government of Ontario to determine how land is used. The Greenbelt can be thought of as the flip-side of the Growth Plan. Where the Greenbelt tells us where growth would have negative consequences, the Grwoth Plan tells us where it's smart to grow.

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.

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.

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).)

As one of four land-use planning documents used by the Government of Ontario to determine how and where development happens, the Greenbelt Plan works in conjunction with the Growth Plan, as well as requiring conformity in local Official Plans.

The Greenbelt Plan, along with oher higher tier plan such as the Growth Plan, allows municipalities to focus development, more accurately plan for infrastructure, reduce unnecessary over-sizing to provide for future urban expansions in all directions, thus reducing capital spending and development charge expenditures.

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.

Greenbelt would provide that level of protection thereby reducing municipal costs.

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.

Concerns have been expressed about how the Greenbelt may impact private property, and specifically the ability of the individual to do what they want on their property.

Have a look through the below topics for answers on specific issues. We will point out, however, that generally the rights of individuals to do what they want is limited according to the negative impact their activity may have on others.

In this regard the Greenbelt is no different.

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.

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).

Answers regarding how the Greenbelt Plan fits within Ontario's legislative framework.

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 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.

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 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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