on the Greenbelt Draft Report
December 20, 2004
Greenbelt Task Force
Ministry of Municipal Affairs
14th Floor, 777 Bay Street
Dear Sir or Madam:
After reviewing the draft
Greenbelt Plan, Citizens Opposed to Paving the Escarpment (COPE) would
like to provide comments on the content and direction being proposed
for future development in the Golden Horseshoe area.
As a grassroots group formed
in opposition to the poorly thought-out Mid Peninsula Highway (MPH)
proposal, our comments focus mainly on the transportation and infrastructure
components of the plan
Although COPE has grave
concerns with the plan regarding the assumption that a Niagara / GTA
Corridor will be built, in general, we support the Ontario
government’s initiative to create a permanent greenbelt for the Golden
To enshrine the concepts of Ecological Value; Ecological
Function, Connectivity, Vegetation Protection Zone and Watershed and
Wellhead Protection in the plan is commendable.
Unfortunately, to then allow the building of highways through
the same area will inherently damage all of the significant features
identified above. The very features
the greenbelt is supposed to protect.
It should be noted that
there are portions in the report 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,
when considering the Greenbelt Plan in concert with the Growth Management
Plan, the concern regarding the continued commitment by this government
to build highways is compounded.
/ GTA Transportation Corridor bears an undeniable resemblance to option
“C” of the Mid Peninsula Highway. The
inclusion of the highway at the onset, when the need has yet to be substantiated,
is very disturbing.
GENERAL COMMENTS AND RECOMMENDTIONS
- COPE recommends that public consultation regarding
Plan be extended to allow for co-ordinate with the Growth Management
Plan. We also recommend that
both plans be considered in concert with the Transportation Master
Plan currently being crafted by the province. To date, COPE has not seen the Transportation
Plan, but we understand that, by its very nature, it will affect infrastructure
planning on the Niagara Escarpment.
- The public and groups such as COPE have had very little
time to analyze and comment on the Greenbelt Plan. Furthermore, the workshops were scheduled
during regular workdays. Without
reasonable notice it is difficult, if not impossible, for citizens
who are otherwise employed, to arrange attendance at these workshops.
- COPE recommends that a moratorium be placed on all 400
series highways, including the Niagara / GTA Transportation Corridor,
until a global transportation strategy is developed that considers
need and all modes of transportation in concert.
recommends that costing be required for infrastructure projects that
consider the full social and environmental economic impact of our
choices. Such things as the
affect 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 natural ecosystems with manmade substitutes
(services that nature provides free of charge) must be included in
any economic model. The TRUE
return on supposed "economic corridors" must be calculated.
- COPE is concerned that the big picture has been
lost in the detail. The
enormous impact infrastructure projects have on our health has not
been addressed in the Greenbelt
Plan, as it should. Our
habit of building highways has cost us in unforeseen ways. The resulting pollution has affected our
environment and our health. We need to ensure that
before building new infrastructure on the Greenbelt, we can answer the question “is
it Healthy for those living in the vicinity and will the project further
degrade the environment?” We
know from various studies that highway pollution has been linked to
respiratory diseases including asthma and heart disease; highway runoff
is toxic to our water supply; and noise pollution is also a serious issue that needs to be considered
in the human health factor.
VISION AND GOALS
one of the goals under Infrastructure and Natural Resources gives rise
to considerable concern because the Greenbelt Plan allows for development
of “permanent infrastructure within the greenbelt”. This is supposedly necessary in order to support
“the fastest growing region in Canada and ..the.. foundation for
our provincial and national economy.”
COPE understands this section to mean that the government is
planning, if not determined, to proceed with the Niagara/GTA Economic
Corridor. The reasoning in support of this corridor is
- Growth as presently forecasted, is
not a given and will depend on international immigration (which is federal
not provincial jurisdiction).
- Close scrutiny of the Mid Peninsula
Highway proposal, of which the Niagara/GTA is the successor, failed
to provide any justifiable economic benefit to the region as a whole,
although local municipal governments have described it as economic benefit. Unfortunately the supposed benefit is focused
on development for perceived short-term gains; no consideration has
been given for long-term implications.
The one-track thought process of these municipal governments
has been unbending, single-minded and pro-development.
To support such ideals in the very goals of the Greenbelt Plan
- The Task Force clearly stated “.. the greenbelt should not be viewed
as a land reserve for future infrastructure needs…” and "the Province
should review the way in which the need for infrastructure is assessed”. The stated intent of the Task Force is
to save the Greenbelt
for future generations; hence, it is not enough to “seek” to minimize
environmental impacts. We MUST
avoid or prevent any environmental impact.
SPECIFIC POLICIES IN THE PROTECTED COUNTRYSIDE
3.1 Agricultural System
and 3.2 Natural System
supports the Greenbelt
Plan's recognition that the environment and farmlands must be protected. However, the building of highways is in
conflict with this goal. They
sandwich land between corridors and expose them to future development.
Runoff from highways and particulates in truck exhaust are
highly toxic to water and soil and impact negatively on human and
POLICIES FOR THE PROTECTED COUNTRYSIDE
first paragraph of this section states that infrastructure, including
“provincial and municipal roads and highways – is fundamental to economic
well-being, human health and quality of life in southern Ontario
and the Greenbelt.” In fact, as we learn more about the residual
effects of highways, we know that they adversely affect human health.
COPE believes it is presumptuous to state that a road /
highway is fundamental to human health.
We recommend that this misguided statement be removed.
understands that the government has to resolve gridlock. We agree,
it is logical to maintain existing infrastructure and some expansion
of existing corridors may be required.
However, to consider new transportation corridors before exhausting
all other alternatives is contrary to the original recommendation
of the Greenbelt Task Force, which put the emphasis on alternatives
first and new corridors as last resort.
The final report appears to be more favourable to new highways
than the previous discussion papers.
COPE recommends that strong wording reflecting the government's
support of alternate modes of transportation (public transit, rail,
marine, etc.) FIRST, be enshrined in this document to clearly express
the government’s priority and commitment.
is calling for NO NEW Highways on the Niagara
Escarpment. If transit and other transportation options are managed
properly, highways won’t be necessary.
4.2.1 General Infrastructure Policies
- COPE recommends that the definition of “essential”
be clearly defined.
one states that infrastructure “approved under the Ontario Environmental
Assessment Act, … the Canadian Environmental Assessment Act, or similar
environmental approval is considered essential and is permitted within
the Protected Countryside…” The
Mid Peninsula Highway proposal drastically failed the test to determine
need. In fact, the data from the Ministry of
Transportation's own Needs Assessment indicated that other options
were preferable to resolving the supposed congestion problem in the
Niagara region. These
more environmentally friendly and cheaper options were ignored.
It is imperative that rigorous standards be set around determining
need for an infrastructure project, to avoid thrusting isolated agendas
(such as the MPH) on the rest of the region.
Environmental Assessment Acts are to be used for this purpose, those
making the submissions must NOT be allowed to circumvent the intent
of the law through creative interpretations of definitions and use
of sections of the Acts in situations not intended by the legislation. COPE recommends the review and strengthening
of the environmental assessment process.
recommends a statement enshrining the government’s commitment to completing
full environmental assessments for infrastructure proposals such as
the Niagara / GTA Corridor should
be included in the plan and legislation.
Paragraph four (second point)
cites specific examples of future transportation needs including the
Niagara / GTA Corridor. We believe it is extremely inappropriate for
specific examples to be cited in the Greenbelt Plan before establishing
need and completing a full environmental assessment.
COPE strongly recommends that reference to the Niagara
to GTA corridor, as well as other specific corridors, be removed from
five outlines specifications for location, construction and expansion
of infrastructure projects. Point
two states: “proposals will
seek, where practical, to maximize existing capacity and coordination
with different infrastructure services so that new urban development
is not encouraged within the Protected Countryside.”
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. To simply state development is not
encouraged is insufficient. In
situations such as Flamborough, where amalgamation with the City
of Hamilton was forced upon the township, it leaves
the area open to the developmental abuse by the City of Hamilton. This was not the stated intent of amalgamation
nor the Greenbelt Plan; yet the possibility exists.
recommends that any transportation planning in the greenbelt 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.
5.2 Municipal Implementation of Protected Countryside
Monitoring / Performance Measures
recommends strengthening the wording pertaining to the participation
of municipalities throughout the entire document. Too often, weak words such as “encouraged”
are used when “must” would be more appropriate. Unfortunately, not all municipal governments
are able or wish to see beyond immediate development. Such municipalities need to be held accountable,
not given loopholes to continue down a path of destruction of the
Niagara Escarpment with shortsighted development. Our current policies and practices are
unsustainable in conjunction with a healthy living environment and
future economic prosperity. It
is because of the existence of municipalities with varying degrees
of understanding for the real cost of development, that it is so important
that the Greenbelt be registered
in law. We have lost so much
already to the wants of the few at the cost of the many.
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.
supports the option that the province establishes an Advisory Council.
COPE recommends that the requirement for candidates to possess
a proven track record of promotion, conservation and stewardship and
be guardians of the integrity of the plan, be ensconced in the charter
of the council.
It appears that the government is determined to build the former
Mid –Peninsula Highway
– renamed the Niagara/GTA Corrid or – even before the need for the highway
has been established. This undermines
the Greenbelt initiative, which
clearly calls for innovative thinking and a new approach to transportation.
We believe the intent of the task force is to preserve the greenbelt,
including the integrity of the Niagara Escarpment, and to 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 the will exists to protect the greenbelt from the destruction which
more highways will cause, and that the recommendations put forth in
this submission are given serious thought.
Susan McMaster and Dave Bailey
Citizens Opposed to Paving the Escarpment
2002 - 2012 COPE