Submission to Greenbelt Expansion Consultation by David Neumann

David Neumann, former MPP, Mayor, Councillor and Alderman for Brantford has generously agreed to share his submission to the Environmental Registry of Ontario (ERO Registry #019-3136 Consultation on Growing the Size of the Greenbelt). Comment submissions are due April 19, 2021 at 11:59PM. We encourage everyone to submit comments! A simple-to-use quick comment submission form is available – you can copy and paste your own comments into the message, or use the pre-written comment provided in the form. More detailed information about submitting comments is available in this post

Submission by David Neumann:

To the Environmental Registry and the Minister of Municipal Affairs and Housing:

I congratulate the Ontario Government on offering consultation on growing the Greenbelt at this time. I participated in the 2015 review and at that time our primary request was to add the Paris Galt Moraine to the Greenbelt. We had almost 100 people attend the MMAH sponsored 2015 open house at the Brant Park Best Western Inn. There was a strong consensus to add the Paris Galt Moraine to the Greenbelt. After all, the Oak Ridges Moraine was included in the initial Greenbelt designation as a way of preserving the fresh water needs of the Toronto GTA+ area.  The Grand River Valley is the largest river watershed in all of Ontario (including GGH)  Urban areas and farmers in the valley of our Heritage River and its tributaries, need the assurance that our future will be secure in the knowledge that fresh water is protected for future generations. Even though the inclusion of the Paris Galt Moraine was recommended in the Crombie Report, our request for adding the Paris Galt Moraine to the Greenbelt was not implemented as supported in the 2015 review. 

Expanding the Greenbelt west will support Groundwater communities in the Waterloo and Wellington region, including the Region of Waterloo and cities such as Brantford, that are dependent upon the Grand River. We need to see the highest level of protection for natural and hydrological features and farmland.  As a result of dependence on groundwater, some municipalities have adopted stronger protection policies that should continue and prevail, if they are to be included in the Greenbelt. We would ask the province to allow these higher levels of protection to remain in place for any area that is added to the Greenbelt. Indeed, Municipalities anywhere in the Greenbelt should be allowed to create levels of protection that are higher than those included in the Greenbelt.


Question 1: What are your thoughts on the initial focus area of the Study Area of the Paris Galt Moraine?

The Paris Galt Moraine should be added to the Greenbelt. Protecting this water system, including headwaters and all hydrological features, means securing a water source for at least 800,000 people. I would encourage the Province to be more ambitious in its approach to expanding the Greenbelt. If it intends to protect precious farmland and natural areas from development and safeguard the countless benefits that they provide, such steps must be taken. I urge the province to expand the area of study to the west and include all adjacent areas and important parts of larger ecological systems (i.e., agricultural systems, wildlife corridors, headwaters, etc.). Protecting the entirety of the system means looking beyond political boundaries. A scientific approach demands that systems adjacent to, or vitally connected with the Greenbelt, need to be protected:

  • Orangeville Moraine
  • Waterloo Moraine 
  • Grand River Watershed, including land contiguous with the Greenbelt in Brant County, i.e. lands west of the Hamilton-Brant Boundary.

Question 2: What are the considerations in moving from a Study Area to a more defined boundary of the Paris Galt Moraine?

Yes, definitely, please include the Paris Galt Moraine in the expanded Greenbelt. At the very least, it should include Moraine areas stretching from Guelph through to Cambridge, and then southerly to the northern Brantford boundary with Brant.  

Engagement with Indigenous communities must fulfill constitutional and treaty obligations. The duty to consult is a constitutional obligation that arises from s.35 of the Constitution Act, 1982. It recognizes and affirms Indigenous and Treaty rights. Indigenous traditional practices, responsibilities and knowledge systems, must be honoured by ensuring Indigenous voices are heard in any discussions involving expanding the Greenbelt.

A scientific and evidence-based ecosystems approach may require including where the Paris Galt Moraine extends into Norfolk. It may be advisable to connect with Lake Erie’s coastal system as well.

Question 3: What are your thoughts on the initial focus area of adding, expanding and further protecting Urban River Valleys?

I commend the suggestion to include the Urban River Valleys of the Greater Toronto Area. Urban River Valleys (URVs) are an established means of connecting residents in the Greater Toronto Area to the Greenbelt. Expanding the designation of URVs could be a way of connecting communities dependent on groundwater to the headwaters that recharge their drinking water sources. I suggest that URVs be further protected by ensuring that the Greenbelt includes headwater areas , thus establishing direct connections with downstream urban communities. It is recommended that the expansion of URVs incorporate connections to the Paris Galt Moraine through the Speed and Eramosa Rivers in urban areas. 

This concept should also be extended to the urban areas in the Grand River watershed. Over the years, the City of Brantford, working with the Grand River Conservation Authority (GRCA), has moved to bring many of the lands along the river into public ownership. This was done to provide greater access to the river, including the provision of extensive hiking trails.  Volunteers of the Brantford Waterways organization over the years raised money and encouraged citizens to engage in such initiatives. The Grand River valley and its tributaries should be included in any expansion of the Urban River Valleys concept. Government actions and decisions should include the expansion of the concept of Urban River Valleys into the Grand River Valley. Riverway lands are important to be included in Greenbelt designation as a way of protecting access to the river and its tributaries. Protecting these waterway lands also helps to preserve and enhance wildlife corridors.

I urge the government to expand this protection area, as this will support green infrastructure such as wetlands, floodplains, and riparian edges. These are key ecological features preventing downstream areas from flooding and erosion. These features protect habitat, promote biodiversity, provide healthy outdoor recreation, and support the regional trail system.  

Question 4: Do you have suggestions for other potential areas to grow the Greenbelt?

Yes. Address the needs of the Grand River Valley. The Grand River is a designated Heritage River. An environmental or ecological designation needs to be added. The Grand River watershed was once a largely forested landscape. Early settlers cut thousands of trees to create farmlands and to find and use wood for buildings houses and barns and commercial structures. Unfortunately, this loss of trees led to extremes events, such as low water levels and extreme floods. By the time of the 1930s droughts, things had reached a crisis. Low water levels in the summer created an urgent situation, requiring action. Not surprisingly, Brantford, a city that used river water for its public and municipal water needs decided to take action. Brantford’s community and business leaders invited representatives from other communities throughout the watershed, to attend a meeting in Brantford to address this crisis. The story is summarized here:

In other words, leadership by Brantford’s initiative got support that led to the creation of the first river watershed-based conservation authority. Later, Ontario created legislation to create similar authorities in many if not all watershed areas. The authority managed the river, and projects such as construction of up-river dams, were undertaken. Snow meltwater and spring rainwater could be retained in a reservoir and released gradually in times of low water levels. By the way, moraines do this naturally. The trees do this too, but the forests had largely been removed. There was a time when the province required all farms to have a woodlot. This was helpful, but contiguous wooded areas are much preferred to woodlots isolated from one another.

Communities and volunteers are helping today by supporting initiatives to plant native species trees. This is often done in collaboration with the GRCA. It will never restore the number of trees that existed before the settlers cleared the lands, but planting trees does help stabilize ground water, and can prevent flooding.

We can build our ecologically strong future in the Grand River Valley by –

• Providing clean air, water storage and filtration

• Building resilience to climate change

• Nourishing rural communities

• Preventing invasive species, flooding, and soil erosion

• Supporting conservation and biodiversity recovery

• Promoting downstream communities and ecological sustainable economic activities

• Supporting and securing the agricultural and agri-food sectors

• Enhancing community well-being through access to recreation and locally based tourism

Question 5: How should we balance or prioritize any potential Greenbelt expansion with the other provincial priorities mentioned below?

Expanding the Greenbelt supports many current priorities: Ontario’s Biodiversity Strategy, Ontario’s Wetland Conservation Strategy and Ontario’s Great Lakes Strategy. Nature, water, and farmland are the foundation of social and economic well-being. Protecting these natural assets helps to strengthen other provincial priorities. Growing the Greenbelt will strengthen Sustainable Development Goals, while enhancing the security of vital natural systems. The protection of valuable farmland and the strengthening of natural and water resource systems must be seen as priorities. These are finite, irreplaceable, and invaluable resources with respect to community and ecosystem health. We need to have strong resilience to reduce climate change with its potentially disastrous outcomes. Growing the Greenbelt will help to ensure a workable balance between development and natural heritage.

Infrastructure to support housing needs of communities in the GGH can be met within lands already designated for development. Aside from Toronto and Peel, growth in all other municipalities has been less than projected. There is a big surplus of land available for development. In 2017, The Neptis Foundation estimated that the total supply of unbuilt land (125,560 hectares) will easily accommodate housing and employment to 2031 and beyond. Rather than developing on sensitive farmland and in natural areas, the province should encourage building complete communities of gentle density (ones that are people friendly, easily walkable, climate change resilient, and with jobs nearby). Development should happen inside the boundaries of our existing towns and cities. Rejuvenated brownfields that are close to existing infrastructure should be the priority location for commercial and industrial development.

Question 6: Are there other priorities that should be considered?

Yes. Ontario should engage in meaningful consultation with Indigenous peoples, while respecting treaty rights. The Duty to Consult must be followed. This requirement is clearly outlined in the 1701 Nanfan Treaty, 1784 Haldimand Proclamation Treaty and the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP) for which Free Prior Informed Consent (FPIC) is required by the Crown for all activities past, present and future. While the federal government has attempted to delegate consultation to provincial and municipal levels, full, deep, and meaningful consultation must be fulfilled. That has been confirmed by Supreme Court Decisions, and is borne out by International Conventions. Matters pertaining to activities, policies or land planning within the 1784 Haldimand Deed Lands fall under the purview of the Six Nations of the Grand River Elected Council, in particular their Lands Research and Consultation Department (SNGREC). The Haudenosaunee Confederacy of Chiefs asserts jurisdiction for matters pertaining to outstanding land claims. Furthermore, the Grand River Notification Agreement must be followed. 

Clean and fresh water is essential for health and human survival. On February 2, 2021, the Grand River Source Protection Area Approved Assessment Report highlighted water quality issues regarding water supply in Ohsweken (Six Nations of the Grand River). Primary water quality concerns identified were related to colour, total dissolved solids, and aluminum in the surface water from the Ohsweken Intake point were identified.

The level of protection should stand. and municipalities in the Greenbelt should be able to raise the bar on protecting land, water, and natural heritage, if they so choose. Ontario needs to recognize and support the better quality of protection that exists in some jurisdictions (e.g., the Region of Waterloo). For example, Municipalities within the Greenbelt must be given the authority to establish policies that are more restrictive on mineral aggregate extraction than those outside the Greenbelt Plan, as is the case in other GGH municipalities. One suggestion is that mineral extraction should be prevented from going below the water level.

 Ontario’s Special Advisor on Flooding noted in 2019, that there is increasing frequency and intensity of extreme rainfall events (as in the Grand River flooding of February 2019). To mitigate this tendency for increased flooding frequencies, tree planting should be encouraged and supported. Natural features such as wetlands, aquifers, and moraines assist greatly in reducing associated flood damages and financial losses. 


David E. Neumann

Brantford, Ontario

On City council as Alderman, Mayor and Councillor for almost 20 years

MPP for Brantford for one term


In principle, I support the submissions of area associations and coalitions: 


  1. Brant Land Trust
  2. Langford Conservancy
  3. Sustainable Brant / Better Brant, a coalition of residents from Brantford and Brant
  4. CELA Canadian Environmental Law Association
  5. National Farmers Union, local branch 


1.  Ontario Greenbelt Alliance

2. Ontario Headwaters Institute

3. Ontario Nature

4. Ontario Farmland Trust