Written by Claire Malcolmson- Executive Director of the Rescue Lake Simcoe Coalition and has a Masters Degree in Planning.
The Mayor of King Township, Steve Pellegrini, has been pushing publicly for a hospital to be built on Ontario’s Greenbelt. This is wrong for healthcare, wrong for King, wrong for the Greenbelt — and it’s illegal.
Someone needs to point out to Pellegrini, and the public, that provincial regulations do not allow a hospital to be built on Ontario’s Greenbelt. True, Premier Doug Ford has taken steps to destroy the Greenbelt by swapping land in and out — he’s on video actually lying before the last election promising he “won’t touch” the protected area.
But even after Ford’s lies, the rules still stand: provincial policy does not allow politicians to grab Greenbelt land for a hospital just because they feel like it’s a good idea. The only way it could happen would be for Ford’s Municipal Affairs Minister, Steve Clark to issue a Minister’s Zoning Order (MZO) and command that the rules be ignored.
Here’s where the law stands: Ontario’s Greenbelt Plan allows for the extension of some infrastructure, but a hospital is not listed as infrastructure in public policy. It falls under the definition of a public service facility or institution.
Ontario’s highest ranking planning policy, the 2020 Provincial Policy Statement (PPS), includes health and educational facilities among public service facilities. But it also says clearly that these facilities belong in community hubs, close to infrastructure, transit and transportation — not in green space that is now unserviced and would have to be paved.
Whoever is behind the push for this hospital in this green location needs to justify how its location is in conformity with provincial law. That’s hard to do, unless the plan is to build more subdivisions on the landowner’s property, and make the hospital part of a “settlement area” as the rules require for building hospitals.
Why not put a new hospital where people actually live and work already, instead of allowing a select group of developers to pave Ontario’s Greenbelt and add to sprawl?
There ought to be public conversations about the right place to put a hospital — not shadowy advocacy or edicts based on Premier Ford’s broken promise to protect the Greenbelt. King does need a hospital, but not on the Greenbelt where Ford, Clark and their developer friends think it should go. Mayor Pellegrini should know this and say so.
58% of the Lake Simcoe watershed’s land is protected by the Greenbelt and its policies, and for this we are grateful.However, Lake Simcoe’s western shorelines in Simcoe County are not in the Greenbelt, nor is the rest of the County. This has contributed to leapfrog development over the Greenbelt and Oak Ridges Moraine and into Simcoe County, particularly in Barrie, Bradford West Gwillimbury, Innisfil, and New Tecumseth.
For example, sprawl removed 37,000 acres of natural and semi-natural space in Barrie between 1971 and 2011.  Between 2006 and 2012, Simcoe County zoned over 32,000 acres of farmland and natural space to sprawl.  Without protective policies like the Greenbelt to keep farmland in production and greenspace preserved, our natural spaces will be under constant threat to urbanization. Case in point, during Simcoe County’s Municipal Comprehensive Review consultation, the County received 79 developer requests to sprawl outside existing boundaries for a potential loss of almost 16,000 acres. 
Moreover, Simcoe County is highly reliant on groundwater for both private and municipal wells. This abundance of water is made possible by our recharge areas, wetlands and aquifers that pepper the region. Unfortunately, these places are also prime areas for new development, aggregate activity, and infrastructure such as highways. In 2006, the Intergovernmental Action Report for Simcoe County saw the threat that rampant urbanization was going to have on Simcoe’s water supply stating, “A number of the municipalities in the study area rely on inland water systems which have been demonstrated to be under strain (for example, the Lake Simcoe watershed has known issues as a result of Phosphorus loadings). Without intervening action, these watersheds’ available potable water and aquaculture are threatened.” 
Despite 15 years of requests to add Simcoe County to the Greenbelt, this has not happened. Meanwhile, we lose and destroy land that purifies and stores our drinking water and prevents flooding.
Public support for the Greenbelt translated into a provincial promise to protect it, which the province has upheld so far. But it’s tenuous. There have been motions from the York Region Councils of Markham  and Vaughan  to either downgrade protections of Greenbelt land next to existing communities or to develop in the Greenbelt.
The province has put the 830-acre North Gwillimbury Forest into the hands of the Lake Simcoe Region Conservation Authority, in the Greenbelt within the lake-side municipality of Georgina.  This is a welcome move, but it did not add any land to Southern Ontario’s protected areas. The forest was protected through a legal battle fought by resident and activist Jack Gibbons, who created the North Gwillimbury Forest Alliance, and fundraised more than $500,000 to fight the Town of Georgina, the Region of York and the LSRCA until it was ultimately protected. The credit goes to Jack, generous donors, and the citizens who insisted that a Provincially Significant Wetland should be protected.
Finally, the province had some great ideas for Greenbelt expansion, which would have protected the Paris-Galt Moraine, a vulnerable aquifer in the Waterloo area, among other things. Unfortunately, the only idea they acted on was to extend the Greenbelt into already protected urban river valleys. Critics said in a media statement: “Proposed Provincial Greenbelt “expansion” does nothing for farmland and natural areas that need protection while new highways threaten the existing Greenbelt.”  It could be described as more of a re-branding of protected greenspace than meaningful policy change.
Until April 19th the Province of Ontario is listening to ideas about growing the Greenbelt, and I want to encourage people to share at least some basic thoughts about it with the government. Did you know that the campaign that resulted in getting the Lake Simcoe Protection Act started with an unsuccessful bid to have Simcoe County included in the Greenbelt? Way back in 2005 we were worried about the impacts of heavy development pressures on Simcoe County, and that has not changed. How can Greenbelt policy help alleviate some of those impacts?
The Lake Simcoe Protection Act, 2008, and Plan apply to the watershed area, outlined in the map above. Within that area, where the Greenbelt applies today in York and Durham Regions, the “countryside” is protected. In Simcoe County, where there is no Greenbelt, not so much. These farm land areas are facing intense development pressure.
Simcoe County must plan for a population of 555,000 and 198,000 jobs by 2051 up from a population of 307,050 today. Despite there being a projected oversupply of 75,000 homes permitted to be built in Simcoe County to 2031, planning and permitting will go on because that’s what the province has ordered. The problem is that both construction and development negatively affect Lake Simcoe’s phosphorus loads, which in turn worsens water quality. In it’s 2010 Phosphorus Reduction Strategy, the province analyzed the impacts of development on phosphorus loads, and concluded that there would be additional phosphorus loads, even with the development impact mitigation policies of the LSPP. This is a problem since we are supposed to be cutting phosphorus loads in half to protect Lake Simcoe and its ecosystem.
Municipalities may be welcoming policy alignment between provincial plans, as they have expressed in their comments to the province about the LSPP review. (See my blog on this topic here.) The Greenbelt expansion exercise and the LSPP review, which are happening simultaneously, are both good opportunities for the province to investigate and analyze the effect of some of possible policy choices. They will need to address the issue of having no plan to achieve the LSPP’s 40% “high quality natural cover” target.
The ideal solution could be applying the Greenbelt to the whole watershed, maintaining the LSPP’s shoreline policies, and adding a new designation for the watershed’s “high quality natural cover”. For a more fulsome overview of the “high quality natural cover issue see our report here and the map below.
The Rescue Lake Simcoe Coalition’s intern and planner Mallory Nievas analyzed the strength of policies of the Greenbelt, Growth Plan, Oak Ridges Moraine, Lake Simcoe Protection Plan, and found that the policies of the LSPP are the strongest of the bunch at protecting the shoreline. The policies of the LSPP, Greenbelt and ORMCP are similar when it comes to natural feature protection (forests, wetlands).
Where the Greenbelt differs in a way that would help Simcoe County and Lake Simcoe, is its unique “Protected Countryside” designation, which is meant to protect agricultural land. Non-agricultural uses of land in the Greenbelt’s “Protected Countryside” are allowed “to support a range of recreation and tourism uses such as trails, parks, golf courses, bed and breakfasts and other tourism-based accommodation, serviced playing fields and campgrounds, ski hills and resorts.” Within the Protected Countryside, Town and City boundaries are firm, which reduces the tendency towards expensive to service, low-density, land gobbling, lake polluting, suburban urban form, and promotes denser community building.
Based on analyses outlined above, it’s expected that the watershed’s population will more than double and likely add 20 tonnes of phosphorus to the lake by 2051. The Lake Simcoe Protection Plan target is to lower phosphorus loads from an average of 90 tonnes to 44 tonnes per year by 2045. We are concerned that the province is approving development without any public discussion or consideration of the long term damage it causes to Lake Simcoe. That should concern everyone.
The public has until April 19th to contact the province and encourage them to expand the Greenbelt to Simcoe County.
The Rescue Lake Simcoe Coalition and Simcoe County Greenbelt Coalition’s full comments and submission to the province on Greenbelt expansion can be found here for people’s use in their own submissions.
These features are subject to policies that prevent or tightly restrict development or other land cover change on them. Permitted activities include aggregate extraction, infrastructure development, and stewardship related work.
These features are subject to policies that prevent or tightly restrict development or other land cover change on them. An Environmental Impact Assessment (EIA) is required to demonstrate environmental impacts of permitted activities are minimal and can be mitigated. Level 1 includes mostly features protected by provincial policies: – significant woodlands; – significant valleylands; – Provincially Significant Wetlands (PSWs); – Areas of Natural Scientific Interest (ANSI’s); – Lake Simcoe shoreline; – natural areas abutting Lake Simcoe; – Significant Wildlife Habitat; – Provincial Parks – Natural Areas (Niagara Escarpment Plan); – Core Areas (Oak Ridges Moraine Conservation Plan).
– new aggregate operations, with restoration and environmental impact requirements, low footprint infrastructure that has been proven to have no alternative, non-intrusive recreation, maintenance of existing infrastructure, fish, forest, wildlife management, stewardship and conservation activities, flood or erosion control, retrofits to stormwater facilities.
2. MODERATE POLICY PROTECT- ION
These features are subject to policies that allow some site alterations or land cover change, having met criteria and conditions. Permitted activities include aggregate extraction, infrastructure development, and stewardship related work. Development and site alteration may be allowed, having met criteria and conditions.
These features are subject to policies that allow some site alterations or land cover change, having met criteria and conditions. An Environmental Impact Assessment (EIA) is required to demonstrate that environmental impacts are minimal and can be mitigated. Level 2 includes: Setbacks and vegetation protection zones around protected features such as ANSIs, PSWs, permanent and intermittent streams and lakes; – significant groundwater recharge areas and highly vulnerable aquifers; – linkage areas (Oak Ridges Moraine); – Simcoe County Greenlands linkage areas; – features adjacent to level 1 features.
– new aggregate operations, with restoration and environmental impact requirements. – Having met criteria to demonstrate limited environmental impact: development and site alteration, wind power facilities. – No Environmental Impact Assessment required for: Low footprint infrastructure that has been proven to have no alternative, non-intrusive recreation, maintenance of existing infrastructure, fish, forest, wildlife management, stewardship and conservation activities, flood or erosion control, retrofits to stormwater facilities.
3. NOT PROTECT- ED BY ENVIRON- MENTAL POLICY
These areas are already developed and / or are not subject to environmental protections.
These areas do not contain features that are protected. Level 3 includes: farmland; roads; settlement areas and built up areas. The Greenbelt Protected Countryside designation is included because it does not protect Natural Heritage Features. It does, however, restrict settlement boundary expansions.