Citizens Opposed to Paving the Escarpment
P.O. Box 20014
Brant Postal Outlet
Burlington, ON, L7P 0A4
September 24, 2004
Growth Plan for the Greater Golden Horseshoe
Ministry of Public Infrastructure Renewal
Smart Growth Secretariat
777 Bay Street,
16th FloorToronto, Ontario
Re: Growth Plan for the Greater Golden
Horseshoe Discussion Paper
Dear Sir or Madam:
Having reviewed the Places to Grow 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 growth planning in the Golden Horseshoe area. COPE
is a grassroots group formed in opposition to the poorly thought-out
Mid Peninsula Highway 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
are fully considered
These comments are preliminary.
In general, we support the guiding vision of a "Greater
Golden Horseshoe that will be a great place to live in 2031."
We support the Ontario government’s intention to formulate a "strategy
for building strong communities and improving the quality of life
for the people of Ontario…" and to bring "real, positive
change that will lay the foundation today for how we live tomorrow."
We are pleased with the recognition that the Niagara
Escarpment and the Oak Ridges Moraine need protection and we strongly
support the emphasis on developing public transit as a priority in
order to combat the ever-increasing problem of urban sprawl and traffic
gridlock. These problems are the result of poor planning in the past
and reflect our society’s habit of building new roads with little
thought. We believe transit will negate or drastically reduce the
need for new highways or economic corridors, as they appear to be
renamed, in the Growth Plan discussion paper.
COPE believes that if Ontario continues on its current
path, we will one day wake up to discover that our green-space and
the Niagara Escarpment, as we’ve known it, is gone forever.
It must be noted that the planned growth and recommendations,
as outlined in this discussion paper are fuzzy, mercurial and require
rigorous description to avoid future abuse. It appears that the Mid
Peninsula Highway has been included in the plan but disguised as an
"economic corridor." It is disturbing to note the highway’s
inclusion based on the biased and faulty work completed by the Ministry
of Transportation in their work on this project thus far. Despite
good intentions, there is no provincial priority among competing major
land-use such as the growth areas or the Greenbelt. Therefore, this
submission should not be construed as a blanket endorsement of the
Where to Grow
- The problems with existing maps need to be addressed.
There are areas indicated as urban which should be rural. Current
agricultural land considered class 1 and 2 has not been included
in the Hamilton area. These assumptions and exclusions do not
bode well for future planning nor the supposed commitment to supporting
strong rural communities. Furthermore, bad information from the
onset will lead to poor results.
- The amount of land identified as urban over the next 30 years
is excessive with unclear boundaries. A clear planning rationale
for projected urban land needs must be provided.
- Rather than reacting to anticipated growth, the question of
how much growth the area can sustain needs to be addressed. Uncontrolled
growth can have a devastating environmental and economic impact
on society. The need for interaction with the Federal government
on immigration policy and settlement location is clear. The
growth area could be expanded to include such places as Thunder
Bay, North Bay and Sudbury, which could support considerable amounts
of growth with the appropriate infrastructure investment.
- The assumption that jobs created by future economic growth
will be "good jobs" is uninformed and unsubstantiated.
Employment at a big box store or a fast food restaurant is not
a good job. Furthermore, the emphasis on "economic corridors"
indicates that we will be relying more on importation of goods,
which has historically meant the loss of good jobs to other geographical
- The source of food, water, natural heritage systems, green space
and natural resources needs to be thought of as more than an enhancement
to the 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. Although not clearly stated,
it appears that "demonstrated life cycle costing" will
be a positive step in this direction. 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.
- COPE supports intensified growth within existing urban boundaries
IF growth is focused along EXISTING corridors. The economic
corridor from Niagara to Burlington 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 concept of "compact
Infrastructure to Support Growth
- The emphasis placed on "focusing highway investment to
trade corridors" as specified on page #35, is disturbing.
The indication that the building of highways has been predetermined
is clear. Furthermore, the Niagara / Burlington economic trade
corridor indicated on Map #6 IS the Mid Peninsula Highway option
"C". For this ministry and the current provincial
government to accept the shoddy work of the Ministry of Transportation
on the Mid Peninsula Highway as valid and worthy of inclusion
in this plan from commencement is disturbing.
- One of the strategies to assist implementation is to "streamline
the environmental assessment process, particularly for the transit
initiatives". This approach raises great concerns for several
reasons. The approach circumvents completing a proper and full
environmental assessment, which shows the same lack of respect
to the environment demonstrated in the past. Also, the intent
to "streamline" the environmental assessment process
is NOT limited to the creation of public transit. We interpret
this as an indicator that to do the same for highways exists.
COPE expects nothing less than a full and complete environmental
assessment be completed for the economic corridor indicated
on map 6. This includes completing a proper needs assessment AND
considering ALL OPTIONS first.
- On page 27, it states that the "environmental impact can
be mitigated or minimized." There is no reference to prevention
or avoidance. Now is the time to aim higher and aim to avoid adverse
affects to the environment, not just "minimize them."
- Historically, the Ministry of Transportation has focused on
roads as the only mode of transportation. This needs to be addressed.
Their lack of vision is killing us. The Growth Plan states that
we are in a "new era in community planning" which means
breaking the old pattern of thinking. The outdated thinking
of the Ministry of Transportation must be addressed.
- COPE agrees strongly with the idea to support public transit
for the region’s long-range infrastructure requirements and believes
this commitment needs to be expanded to rail for transportation
of goods as well. 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 of the
- 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 highways
such as the proposed Mid Peninsula Highway renamed as an "economic
corridor" in this Growth Plan. This appears to be an attempt
to circumvent the purported intent of the Greenbelt and the Growth
Plan at the onset. The priorities for growth planning and Greenbelt
protection must be clear for building more highways is contrary
to providing for a healthy environment and populace.
- 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,
new highways won’t be necessary. If municipalities developed communities
that fostered living and working locally, commuter traffic would
be markedly reduced.
- Build more environmentally friendly transportation alternatives
FIRST – before building more highways. Consideration for
return on long-term investment must be a factor – rather than
choosing the cheapest method at the time. The impact of a highway
is far-reaching and historically, has not been fully accounted
for when considering expense.
- A demonstrated need for the MID PENINSULA HIGHWAY was never
established. 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 Mid Peninsula
Highway / Economic Corridor) upon the rest of the region.
- Any transportation planning in the Greater Golden Horseshoe
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.
- To further protect environmentally sensitive areas in the
Golden Horseshoe, those such as the Parkbelt West Lands should
be permanently transferred to the authority of the
Niagara Escarpment Commission or included under the
protective umbrella of the Greenbelt Protection Act.
Protecting What is Valuable
- COPE recommends that the air we breathe be given a priority
as a natural resource. We view it as rather important. It
is also an issue that has been glossed over in the Growth Plan.
There have been an increasing number of reports describing the
adverse effects poor air quality has on our health as well as
the costs to medically treat those affected. Highways and the
resulting particulate matter, especially from diesel, aggravate
pulmonary diseases. This further demonstrates the need to banish
future highways from the Golden Horseshoe.
- During the Mid Peninsula Highway public consultations, Dr. Pengally
criticized the Ministry of Transportation for using air quality
data in their Needs Assessment that was approximately 30 years
out of date. Current tests and data must be used and incorporated
in any needs and environmental assessments conducted on future
infrastructure planning to measure the environmental and economic
- Food, water and green space aren’t enhancements to our society;
they are fundamental to our existence and a life necessity and
must be recognized as a priority in future planning.
- 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 any
plan protects our green space with a permanency that will stave
off those who view it as a source for future development and profit.
- COPE supports the Growth Plan’s 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
- Farming as a profession is endangered. The Growth Plan must
reflect respect for all farmers, not just those in specialty areas.
The map depicting farmland did not recognize much of the class
one and two land in the Hamilton area. This needs to be
corrected. With the crumbling of the farming infrastructure
due to haphazard development, our ability to feed ourselves as
a society is reduced. Not only does this undermine our sovereignty,
it increases reliance on food importations – inducing a need for
transportation that did not originally exist.
- COPE recommends that urban boundaries not be extended in
any way until the growth plan is finalized. Developers have
raped the Golden Horseshoe at will up to this point. It is now
time to return our communities to the people who reside in them.
Implementation: Moving Forward
- COPE supports requiring all levels of government being held
to standards related to supporting a Growth Plan. Although
various levels of government view themselves as autonomous, citizens
pay their taxes out of one bank account and, for the most part,
don’t differentiate between levels of government.
- Clarification of policy priorities to guide regional
and local planning in balancing competing uses is needed.
- A strong policy framework must be provided for staging
growth areas based on updated and corrected maps.
- Legislate the necessity to develop and build public transportation
as a priority, in the shortest timeframe possible. The use
of rail to transport goods should also be legislated.
- It appears that the door has been left ajar to allow for development
on environmentally significant lands. To truly protect significant
areas, enforcement is needed in addition to plans and policies.
This could mean bolstering the enforcement of existing legislation,
including enforcement measures in any new legislation and ensuring
that a governing body has the expertise and integrity as well
as the authority to uphold the plan.
- 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.
- The short timeframes allowed for planning the Mid Peninsula
Highway were a big issue. Shabby workmanship was pushed through
at breakneck speed. The rules of engagement and implementation
schedule for the Growth Plan must be sufficient and clearly identified.
This must include sufficient time for thoughtful consideration
and maximum citizen involvement. There is a clear need to return
to the fundamentals of planning. The Growth Plan is looking 30
years into the future. Let’s consider our actions wisely from
- COPE requests to participate in any future discussions, workshops
or committees struck to further define transportation and infrastructure
- COPE recommends that a broad based stakeholders group (including
COPE) be created to oversee the Terms of Reference created for
the economic corridor formerly known as the Mid Peninsula Highway.
Now is the time for people and government to honestly engage
in a discussion of Terms of Reference and the project as a whole.
- 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
Questions We Would Like Answered
- In reference to the Mid Peninsula Highway / Economic Corridor,
the Provincial government committed to completing a full environmental
assessment. Briefly, we consider a full Environmental assessment
to mean truly determining the need for a highway/corridor in a
proper needs assessment, considering all options to meeting the
actual need and considering the full environmental impact. How
does the current provincial government define a full environmental
assessment? There is a clear need to review and strengthen
the environmental assessment process. It is necessary to avoid
abuse that has taken place in the past as demonstrated by the
use of scoped environmental assessments for extensive infrastructure
- Is this government committed to completing a new, unbiased,
Needs Assessment for any "economic corridor" considered
under the Growth Plan?
- Although the name has been changed to an economic corridor,
does this government remain committed to conducting a full environmental
assessment for the corridor indicated on map 6?
- Is consideration being given to using alternate sections of
the Environmental or any other Act in an attempt to circumvent
a full environmental assessment for the Mid Peninsula Highway
/ economic corridor?
- What is the status on the original work completed to support
building the Mid Peninsula Highway? Will this faulty and biased
work be used for any purpose of the Growth Plan?
- What is the role of Minister Caplan's initiative under the Places
to Grow Plan in comparison to the Ministry of Transportation?
Are the ministries working in concert?
Although we are pleased to see a commitment to a holistic
approach to growth planning by the province, we are ready to oppose
the building of the Mid Peninsula Highway, even under the guise of
an economic corridor. We intend to hold the government to their commitment
for a FULL ENVIRONMENTAL ASSESSMENT for the highway/corridor and to
break away from the outdated way of thinking about transportation
when planning for the future. We believe we must forge on 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 Niagara Escarpment and Greenbelt from
the destruction that will result from more highways.
The Greenbelt Task Force stated that "the way we
live tomorrow depends on how we plan today." That is why we must
reiterate the need to expand our thinking beyond the outdated highway
mentality of the Ministry of Transportation. We must take sufficient
time to plan for the future AND we must consider ALL factors including
alternatives, pollution, and all costs prior to declaring that the
plan is an economic success.
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 David Bailey
Citizens Opposed to Paving the Escarpment
2002 - 2012 COPE