COPE's Submission on the Proposed Greenbelt Protection Act

Citizens Opposed to Paving the Escarpment

P.O. Box 20014 , 2211 Brant Street

Burlington, ON, L7P 0A4

July 16, 2004

Greenbelt Task Force

Ministry of Municipal Affairs and Housing
14th Floor, 777 Bay Street
Toronto, Ontario
M5G 2E5

Re: Greenbelt Task Force Discussion Paper

EBR Registry Number PF04E0002

Dear Sir or Madam:

Having reviewed the Greenbelt Task Force Discussion Paper, Citizens Opposed to Paving the Escarpment (COPE), would like to take this opportunity to provide comments on the content and direction being proposed for future development in the Golden Horseshoe. COPE is a grassroots group formed in opposition to the poorly thought-out Mid Peninsula Highway (MPH) proposal. COPE is dedicated to:

  • Preserving the Niagara Escarpment;
  • Ensuring that no new highway corridors are paved across the Niagara Escarpment; and
  • Ensuring that all viable alternatives to the proposed Mid-Peninsula Highway
    are fully considered

Our comments focus mainly on the transportation and infrastructure segments of the discussion paper.


In general, we support the Ontario governmentís initiative to create a permanent greenbelt for the Golden Horseshoe and the recognition that the Niagara Escarpment and the Oak Ridges Moraine need to be protected. We strongly support the emphasis on developing public transit as a priority. We believe this will negate or drastically reduce the need for highways. If Ontario continues on its current path, we will one day wake up to discover that our green-space and the Niagara Escarpment, as weíve known it, is gone forever.


It should be noted that there are recommendations made by the Greenbelt Task Force that are vague and require more rigorous description to avoid future abuse. Therefore, this submission should not be construed as a blanket endorsement of the recommendations. Also, COPE is in the process of reviewing related initiatives such as the Transportation Strategy, the Parkway Belt West Plan and the Growth Management Plan and how they impact the Greenbelt proposal. We already have concerns with the Growth Management Plan maps recently released and the areas defined as urban. Closer scrutiny is required in conjunction with the Greenbelt and transportation planning in general.

Greenbelt Protection Act 2004

  • In addition to the changes from rural to urban land uses, a moratorium is needed on 400 series highways, including the MPH, until a global transportation strategy is developed. As demonstrated in the Greater Toronto Area (GTA), urban sprawl follows highways. To allow the building of highways concurrent to the development of the Greenbelt process will undermine and perhaps nullify the benefits of this initiative.
  • The legislation acknowledges the importance of the study area as a "source of food, water, natural heritage systems, green space, recreation and natural resources." Unfortunately, it is only in relation to enhancement of quality of life. These factors also need to be considered in the economic sense. In the past, economics have been narrowly defined in relation to development. The reality of our social and environmental situation indicates a need to expand this definition to include the full economic impact of our choices. COPE recommends that such things as the impact on health care costs due to increased air pollution, increased taxes required to pay for new infrastructure, ever increasing fuel prices and the cost of replacing ecosystems (services that nature provides free of charge) be included in any economic model.
  • Food, water and green space arenít enhancements; they are fundamental to our existence and a life necessity.

Proposed Greenbelt Study Area

  • Portions of the Greenbelt study area are already urban or identified for urban growth. The remaining area should be included in the study area. A piece meal approach must be avoided or we will return to our current practice of "death by a thousand cuts".

Vision and Goals

  • In general, we support the vision and goals of the Greenbelt. However, the goal "ensuring that infrastructure investment achieves the environmental, social and economic aims of the greenbelt" could have two meanings. If the economics considered for this exercise are restricted to the narrowly defined, habitual approach, than this is a disturbing goal. Economics in the past tend to refer to development that has short-term benefits for the select few but donít factor in all the costs to society as a whole. Please refer to our recommendation under the Greenbelt Protection Act 2004 (second bullet) above.

Background and Context for the Greenbelt

  • Although the discussion paper describes Ontario as having a solid tradition of land use planning, the record of implementation by different jurisdictions and municipalities has been unbalanced. Amendments, exceptions and exemptions to existing legislation and policies make original intentions impossible to fulfill.
  • The Niagara Escarpment Plan (NEP) and others are referred to as "sophisticated greenbelt models". COPE does not concur with this statement for, as presently implemented, the NEP is subject to the political appointees of the current government. Legislation and an independent commission with the power to enforce provisions must protect the Greenbelt.
  • COPE supports requiring municipalities be held to standards related to maintaining the Greenbelt. Although various levels of governments view themselves as autonomous, citizensí pay their taxes out of one bank account and, for the most part, donít differentiate between governments.
  • When making "critical decisions about land use" not only must action be taken to protect our land, we need to accept that our current policies and practices are unsustainable in conjunction with a healthy living environment. It is imperative that the Greenbelt be protected with a permanency that will stave off those who view it as source for future development and profit.

Environmental and Agricultural Protection

  • COPE supports the Greenbelt recognition that the environment and farmlands must be protected. The building of highways is in conflict with this goal. They sandwich land between corridors and expose them to developmental pressure. Runoff from highways is toxic and contaminates our water and the soil used to grow our food. Particulate matter from trucks is highly toxic and would not only impact the health of humans, but of the animal population as well.
  • The discussion paper states that these areas will be protected by focusing growth "around centres and along corridors to intensify development" as well as the "intensification and redevelopment, including brownfields Ö within urban boundaries." COPE supports this approach IF growth is focused along EXISTING corridors. The MPH would cut a new swath through environmentally sensitive and agricultural / rural land at a distance from existing development. It is designed to induce urban sprawl on virgin land. This is contrary to the stated purpose of the Greenbelt.

Transportation and Infrastructure

  • The discussion paper refers to the ferry service from Rochester to Toronto, highlighting innovative thinking and confirming that transportation doesnít need to be a road. It also highlights the need for all levels of government, including their departments and / or agencies, to work in concert if we are to address our transportation problems. The ferry required co-operation at the federal, provincial and municipal level as well as from various government departments including the Canada Border Services Agency.
  • COPE agrees strongly with the idea to support public transit for the regionís long-range infrastructure requirements. A priority MUST be placed on public transit over other options and the concept of sustainability must be a factor when planning long-term. For example, rising gas prices will adversely impact vehicle usage. We need to build transportation alternatives now. Also, money invested in transit today will be minimal compared to the rising health care costs resulting from more highways over the Niagara Escarpment and other areas on the Greenbelt.
  • The province is taking inventory of existing hydro transmission corridors for possible use for linear transportation and transit, among other uses. Much care must be used in this regard. Many of these corridors dissect the very rural and environmentally sensitive areas we are trying to protect. To place a highway along these lines will once again expose the area to development and undermine the purpose of the Greenbelt.
  • The task force cites five principles to guide the approach to infrastructure on the Greenbelt. In general COPE supports these principles but the language requires strengthening. We have the following concerns:
    • The fact that the Greenbelt Study area is the fastest growing region in Canada further highlights the need for intergovernmental cooperation. It also assumes that the area is able to support whatever amount of growth takes place - meaning we are reacting to Ė not setting the agenda. We need to approach this from a different angle in conjunction with the current approach by determining what amount of growth this area can reasonably support.
    • Principle #4 indicates that when new infrastructure is determined to be necessary, the impact will be minimized. This appears to be a loophole in the plan. It is imperative that need is defined rigorously with protection of the Greenbelt as the clear priority; otherwise this exception will leave greenbelt exposed to development.
  • At times the tasks forceís approach to transportation appears to be in conflict with the environmental principles of the Greenbelt. The paper clearly states that highways will be allowed in the Greenbelt. There is no reference to considering all other options first - including public transit and rail. Furthermore, we understand that a list exists of infrastructure and highway corridors which would be allowed in the Greenbelt. This sounds suspiciously like pre-authorization for the building of infrastructure such as the proposed MPH and an attempt to circumvent the purported intent of the Greenbelt at the onset. The prime objective to protect the Greenbelt must be clear for, as described above, to build more highways is contrary to the stated goals and purpose of the Greenbelt.
  • COPE understands that expansion of existing highways may be required after a clear need has been determined, however, COPE is calling for NO NEW Highways on the Niagara Escarpment. If transit and other transportation options are managed properly, highways wonít be necessary. If municipalities developed communitiesí fostered living and working locally, commuter traffic would be markedly reduced.
  • The paper also states that infrastructure will only be "in areas where there is a demonstrated need." The MPH drastically failed this test in that the need for the highway was never actually determined. The project commenced based on the assumption that a highway would be built. It is imperative that rigorous standards be set around determining need and infrastructure assessment to avoid the pushing of isolated agendas (such as the MPH) upon the rest of the region.
  • COPE supports the review and strengthening of the environmental assessment process. It is clearly necessary to avoid abuse that has taken place in the past as demonstrated by the use of scoped environmental assessments for extensive infrastructure projects. The purpose of the review must be clearly stated at the commencement.
  • Consider more environmentally friendly transportation alternatives FIRST Ė before building more highways. Consideration for return on long-term investment must be a factor Ė rather than choosing the cheapest method at the time. As described elsewhere in this paper, the impact of a highway is far-reaching.
  • Any transportation planning in the Greenbelt area and Southern Ontario must be conducted within a global, comprehensive transportation plan, which places a priority on public transit and more environmentally friendly modes of transportation.
  • If a transportation corridor is cut through any part of the Greenbelt, any lands along the route must be exempt from urban development and growth.

    Natural Resources

  • COPE recommends that the air we breathe also be included as a natural resource. We view it as a rather important one. There have been an increasing number of reports describing the adverse affects poor air quality has on our health as well as the costs to medically treat those affected. Again, highways and the resulting particulate matter, especially from diesel, aggravate pulmonary diseases. This further demonstrates the need banish highways from the Greenbelt.

Culture Recreation and Tourism

  • To build a highway such as the MPH is counterproductive to supporting the ideals in the Greenbelt plan around culture, recreation and tourism. The proposed route bypasses tourist areas in the Niagara region including the Falls and wine country. Also, it is ironic to boast about being home to a World Biosphere Reserve then dissect it with a swath of pavement.

  • Reference is made to the importance of the health of communities. COPE recommends that this be expanded to include the health of the people in those communities.

Administration and Implementation

  • Considering the current battle in Ontario to stop paving our green space and curb urban sprawl, to call Ontarioís land-use planning as successful is open to debate. The uncoordinated approach to date is what has made a comprehensive plan, such as the Greenbelt initiative, necessary.
  • It appears that, although from a visionary perspective the Greenbelt is a good initiative, the door has been left ajar to allow for development on environmentally significant lands. This becomes increasingly apparent under the section describing elements of protection. There are plans to develop and implement legislation and policies as a framework for the Greenbelt, including as well as maintaining and expanding current arrangements such as those under the NEC. The obvious exclusion is reference to enforcement. This could mean bolstering the enforcement of existing legislation, including enforcement measures in any new legislation and ensuring that the appellate tribunal has the expertise, integrity as well as the authority to uphold the plan.
  • Furthermore, in terms of maintaining the integrity of the Greenbelt, reference is only made to monitoring performance standards and a 10-year review. Part of any successful plan is not only monitoring, but also taking corrective measures. The room to enforce and take corrective measures is a necessary element of success and should be included in this plan.
  • COPE supports the option that the Greenbelt be administered by a separate body similar to the NEC, which includes, but not limited to, representatives from the NEC, ORMCP, the yet to be formed Agricultural task force as well as representatives from the regions containing the Greenbelt. COPE further recommends that candidates from these organizations or regions have a proven track record of promotion, conservation and stewardship; that they be the guardians of the integrity of the plan.

Next Steps

  • Unfortunately, COPE received the invitation to participate in the workshops after the transportation and infrastructure workshop had taken place. Feedback we received from other participants indicated that this complex and pivotal topic didnít receive the in-depth look it needed. As such, COPE requests to participate in any future discussion, workshops or committees struck to further define transportation and infrastructure planning.
  • The province is in the process of developing a transportation strategy that will support improved public transit and identify critical investments. COPE requests to be part of this process as well.

In Closing

It appears there is room for the proposed Mid Peninsula Highway and highways in general to undermine the Greenbelt initiative if we allow ourselves to revert to our old, outdated way of thinking about transportation. We believe the intent of the task force is to preserve the Greenbelt, including the Niagara Escarpment, and lead us in a new direction of planning for growth while respecting the environment and the voiceless treasures that sustain us. We hope that the foresight and will exists to protect the Greenbelt from the destruction that will result from more highways.

COPE looks forward to continued involvement and consultation on this important initiative. We wish to be part of a process that puts us on a path to a future in which the province boasts a first class public transit system, a world-class green infrastructure and a thriving economy.



Susan McMaster and Dave Bailey


Citizens Opposed to Paving the Escarpment

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