December 20, 2004
Greenbelt Task Force

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

Re:  Draft Greenbelt Plan

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 

Overview

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 Horseshoe.

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.

Disclaimer

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.

The Niagara / 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 the Greenbelt 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.

• COPE 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

       Point 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 flawed because:

•   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 is inappropriate. 
  
• 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.

3.0 GEOGRAPHIC SPECIFIC POLICIES IN THE PROTECTED COUNTRYSIDE

 3.1 Agricultural System and 3.2 Natural System

 

• COPE 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 animal health.

4.0 GENERAL POLICIES FOR THE PROTECTED COUNTRYSIDE

4.2    Infrastructure

• The 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.  
• COPE 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.
• COPE 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.
• Paragraph 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.
• If 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.
• COPE 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 the report.

• Paragraph 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.
• COPE 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. 

5.0  IMPLEMENTATION

5.2 Municipal Implementation of Protected Countryside Policies 

• COPE 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.

5.7  Monitoring / Performance Measures

• 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.

  5.8    Greenbelt Advisory Council

• COPE 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. 

  IN CLOSING

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.

Sincerely,

Susan McMaster and Dave Bailey

Co-Chairs

Citizens Opposed to Paving the Escarpment

 

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