Growing the Greenbelt could yield a number of unintended consequences.
Wellington County manager of policy planning Mark Paoli spoke to Puslinch councillors on Feb. 7 regarding a proposed Greenbelt expansion study area.
Paoli noted the province’s public consultation document states it is “not consulting on a proposed Greenbelt boundary at this time.”
However the document also states “input received through this consultation will help inform decisions on how to move from a study area to a proposed Greenbelt boundary.”
Currently, only the most southern part of Puslinch (including Morriston) lies within the Greenbelt, but the expansion study area includes the Waterloo and Paris/Galt moraines as well as the Orangeville Moraine.
Paoli explained the expanded study area includes roughly 16,900 hectares in Puslinch.
“If the entire study area was added, the entire township would be included in the Greenbelt Plan,” said Paoli, noting Guelph and Cambridge are adjacent to the study area.
Paoli noted the Paris and Galt Moraine Policy Area and areas approved within Source Protection Plans already exist within the Wellington County Official Plan.
He stated one of the things not widely understood about the Growth Plan are policies regarding key hydrologic areas, which include significant groundwater recharge areas identified in Source Protection Plan Assessment Reports.
Paoli stated settlement expansions can only be considered where justified by land need; they must avoid the natural heritage system and key hydrological areas; and they are subject to provincial approval of a municipal comprehensive review, to be completed by 2022.
He added that outside of settlement areas, large-scale development (by subdivision, vacant land condominium or site plan in key hydrologic areas) is required to demonstrate hydrologic functions will be protected.
Development implications
Paoli stated the permanent protection of prime agricultural areas and prohibition of large settlement expansions typically receive the most attention in discussions of Greenbelt expansion.
In Puslinch, the settlement areas of Aberfoyle and Arkell do not need to expand to achieve the Official Plan growth forecast to 2041, based on current long-term land supplies.
At the same time, Paoli explained, there are policies unique to the Greenbelt Plan that either prohibit or make it more difficult to get approval for small-scale developments, such as:
– farm splits and surplus farm severances in prime agricultural area (the province is proposing to expand prime agricultural area designations within Puslinch); and
– second units not allowed in the natural heritage system (the province’s proposed natural heritage system takes up more than half of the area of the township).
Consultation questions
Among the key questions posed by the province’s consultation document is one about the key considerations for drawing a potential Greenbelt boundary around settlement areas.
Paoli said “consideration of Greenbelt boundary changes should not occur until after the province has approved Growth Plan municipal comprehensive reviews, at which point the community will have a clear understanding of the need for, size and direction of urban expansion in Wellington County and in its neighbouring municipalities.”
The final consultation question asked about other priorities/initiatives the province should consider.
Paoli said the province should consider that the Greenbelt expansion could have the following unintended outcomes:
– reducing the ability of farmers to get approval for small-scale development proposals such as farm splits, surplus farm dwelling consents, or second units; and/or
– causing development pressure to advance outwards from the Greater Toronto Area faster than forecasted.
Paoli stated, “In keeping with the requirements of the Greenbelt Act, 2005, the province would consult with the public, municipalities, conservation authorities, stakeholders and Indigenous communities and organizations on a proposed amendment to the Greenbelt Plan and boundary prior to any changes being made.
“This would provide an additional opportunity to comment on the province’s approach.”
Council comments
Councillor John Sepulis said it is unfortunate some of the information offered by Paoli was not presented as part of an open house on the Greenbelt study area.
Sepulis asked council to endorse the report and forward it to the Greenbelt expansion people as well as to the area’s local MPP.
Councillor Ken Roth agreed, saying, “I have a hard time understanding how many different plans are needed to protect the same thing … and [the province] want more.”
Roth was also concerned with arguments that the study was not taking municipal boundaries into consideration , when it is seems clear that is what is happening.
Councillor Matthew Bulmer said the heart of the issue is the study area itself, which is intended to be based on locations where groundwater resources are under pressure or stressed by current or planned urban development.
“Yet there is no urban development planned in Puslinch,” he said.
However, Bulmer noted there are pressures from adjacent areas such as the cities of Guelph or Cambridge, where there are plans to urbanize the moraine, which are not included in the study area.
If there is an urbanization of the moraine in an adjacent municipality that is not included the study, Bulmer questioned whether the study was in fact politically motivated or driven by the needs of the natural environment.
Bulmer said boundaries either need to be based on the natural environment, or justification presented as to why the study would be based on municipal boundaries.
Paoli added “they are trying to combine land use plans with water resource protection.” He said the south end of Guelph has been approved for development for a long time.
“What this is really about is what is perceived as development beyond those boundaries and in communities surrounding the GTA.”
Paoli agreed that if the Greenbelt is expanded, it would prevent Guelph from expanding beyond its current boundaries.
Bulmer found it interesting that parts of the plans would prevent second residential units on properties.
He noted the township recently revised its policies to allow second units to comply with other provincial policies that encourage second units.
“The Greenbelt would not allow secondary units to accommodate farm help or in-house apartments,” Bulmer said, noting this seems to go against one of the ideas of the Greenbelt: to enhance the viability of farmland.
“It doesn’t seem to fit,” said Bulmer.
He added the proposal does nothing to prevent establishing gravel pits, “which means we can dig up the Greenbelt and truck it away.”
Paoli said infrastructure and aggregates aside, redesignation for agriculture to recreational is not permitted.
That means that while a golf course would not be permitted, the Greenbelt designation would not prevent highway construction, or gravel extraction.
Bulmer said in many ways this does not appear to do much, because adjacent areas are still allowed to develop the moraine.
Mayor Dennis Lever said he views the study area proposal “as a trial balloon to see how much opposition there is to Greenbelt expansion.”
To Lever, it appeared any expansion would do nothing further to protect water resources. He too considered the proposal as not being science-based.
“My concern is that with provincial plans in place, the Wellington County official plan in place … with all these approval processes in place … they think another official layer of approval will help.”
Lever said “a number of groups are working to protect water based on flawed science.
“I can see this causing harm to farm properties.”
