Office of the Auditor General of Ontario
Special Report 
on Changes to 
the Greenbelt
August 2023 

Office of the Auditor General of Ontario
To the Honourable Speaker of the Legislative Assembly
In my capacity as the Auditor General, I am pleased to transmit my Special Report on Changes 
to the Greenbelt under Section 12(1) of the Auditor General Act.
Bonnie Lysyk, MBA, FCPA, FCA, LPA
Auditor General
August 2023
Toronto, Ontario 

© 2023, King’s Printer for Ontario
Ce document est également disponible en français.
An electronic version of this report is available online at auditor.on.ca
Cover photograph credit:
top: Claire Foran
middle: North Country Media House
bottom: © iStockphoto.com/jimfeng
ISBN 978-1-4868-7251-0 (Print, 2023 edition) 
ISBN 978-1-4868-7252-7 (PDF, 2023 edition) 

Table of Contents
Reflections .........................................................................................................5
1.0 Summary.....................................................................................................7
Overall Conclusion ....................................................................................14
2.0  Background.............................................................................................18
2.1 History of the Greenbelt......................................................................18
2.2 Ontario’s Housing Strategy and the Greenbelt.................................... 23
2.3 Changes to the Greenbelt Boundary in 2022..................................... 24
3.0  Audit Objective and Scope ................................................................27
4.0  Detailed Audit Observations ............................................................31
4.1 Government-Imposed Greenbelt Removals Proceeded Without 
Evidence They Were Needed to Meet Housing Goals...........................31
4.2 The Selection of Land Sites for Removal from the Greenbelt 
was Biased and Lacked Transparency.................................................32
4.3 The 2022 Greenbelt Boundary Changes Were Inconsistent 
with the Greenbelt Plan’s Vision and Goals, and Deviated from 
Previous Processes.............................................................................39
4.4 The Proposal to Cabinet Did Not Clearly Explain How Land Sites 
Were Identified, Assessed and Selected for Removal from the
Greenbelt ...........................................................................................40
4.5 Most of the Land Removed from the Greenbelt May Not Be Ready 
for Housing Development in Time to Meet Government Goals .............42
4.6  Government’s Exercise to Alter the Greenbelt Did Not Factor
in Financial Impacts or Costs, or Clarify Fiscal Responsibilities ...........46
4.7  Government Did Not Factor Environmental and Agricultural
Implications into Greenbelt Boundary Changes, Which Are Expected
to Result in Adverse Impacts ..............................................................45
4.8 The Public and Municipalities Were Not Effectively Consulted on 
the Greenbelt Boundary Changes.......................................................58 

iv
4.9 Indigenous Communities and Leaders Say the Province Failed 
to Properly Consult Them on Greenbelt Changes...............................61
4.10 No Formal Framework Established to Monitor Whether Developers 
Are Fulfilling Government Conditions on Greenbelt Land Removals ...63
4.11 Developers and Their Representatives Lobbied for Removal of 
12 of 15 Greenbelt Sites in the Few Months Leading up to Site 
Removals .........................................................................................64
4.12 Potential Contravention of the Public Service of Ontario Act, 2006
by the Housing Minister’s Chief of Staff ............................................65
4.13  Risk of Additional Non-Compliance by Political Public Service Staff
with Public Service of Ontario Act, 2006...........................................67
4.14  Use of Personal Email Accounts Contrary to Public Service
Cybersecurity Guidelines...................................................................67
4.15 Record-Retention Policies for Political Staff Communications 
Needs Reinforcing ............................................................................67
Appendix 1: Timeline of Key Events................................................................... 69
Appendix 2: Typical Application Process for a Proposed Development ................75
Appendix 3: Select Amendments Enacted by Bill 23, the More Homes Built 
Faster Act, 2022 ................................................................................................76
Appendix 4: Maps of Land Sites Removed from or Re-designated within 
the Greenbelt.....................................................................................................78
Appendix 5: Audit Criteria.................................................................................. 86
Appendix 6: Ownership of Land Sites Removed from or Re-designated within 
the Greenbelt.....................................................................................................87
Appendix 7: Reporting Relationships of Political and Non-Political Staff............. 90
Appendix 8: Recommendations for the Secretary of the Cabinet and Chief of 
Staff in the Office of the Premier........................................................................91
iv 

had decided to open specific land sites in the Greenbelt 
for housing development. 
We found that how the land sites were selected was 
not transparent, fair, objective, or fully informed. It 
also can be shown that there was sufficient land for the 
target of 1.5 million homes to be built without the need 
to build on the Greenbelt. 
In conducting our work, we learned about the exer￾cise that was used to recommend the removal of lands 
from the Greenbelt for housing. It was seriously flawed 
and was dismissive of effective land-use planning. We 
also became aware of how non-elected political staff, 
and developers and their lobbyists, can undermine the 
technical and operational work of the non-political 
public service in provincial ministries, and the work 
of municipalities and conservation authorities. We 
further concluded that fair, transparent and respect￾ful consultation with the people of Ontario did not 
take place.
In its haste to promote housing development, the 
government sought to remove (or re-designate) land 
sites from the Greenbelt without gathering and using 
complete information and without effectively lever￾aging the expertise of provincial experts in land-use 
planning, Indigenous communities, or the municipal￾ities and conservation authorities that would have to 
address the impact of the changes. Direct access to the 
Housing Minister’s Chief of Staff resulted in certain 
prominent developers receiving preferential treatment. 
About 92% of the approximately 7,400 acres ultimately 
removed from the Greenbelt are five land sites put 
To maintain public trust and confidence, government 
and its ministries need to show that they are transpar￾ent in decision-making, and that they act fairly in the 
interests of all Ontarians. Not only do the people of 
Ontario care about what is done, they equally care 
about how things are done. 
Land-use planning is the process that guides deci￾sions about where, and what type of development can 
occur—for example, where to build homes, factories, 
hospitals, schools, roads and other essential infrastruc￾ture—and where different types of development should 
not occur. Effective land-use planning ensures that 
land, which is a finite resource, is used and developed 
to meet the current and future needs of communities 
and the people who live in them, while safeguarding 
valuable resources such as agricultural lands, wetlands, 
forests, and important natural features and landscapes. 
In 2007, the Housing Ministry at that time won a pres￾tigious national planning award from the Canadian 
Institute of Planners for its Greenbelt Plan and recogni￾tion of excellence in natural systems planning.
There is no doubt that significant population 
growth in southern Ontario is compelling grounds for 
government to prioritize residential construction. This 
is all the more reason for the Province to ensure that 
effective and efficient land-use planning occurs. 
In June 2022, the Premier provided the Minister of 
Municipal Affairs and Housing (Housing Minister) with 
the direction to “complete work to codify processes for 
swaps, expansions, contractions and policy updates for 
the Greenbelt.” By December 2022, the government 
Bonnie Lysyk
Auditor General of Ontario
Reflections 

6
for removal was seriously flawed, we recommended 
that the government re-evaluate its 2022 decision to 
change the Greenbelt boundaries now that it has the 
benefit of the information contained in this report. 
While the people of Ontario deserve prompt action to 
solve societal problems like those generated by a need 
for housing, this does not mean that government and 
non-elected political staff should sideline or abandon 
protocols and processes that promote objective and 
transparent decision-making based on sufficient, accur￾ate and timely information.
Appendix 8 contains 15 recommendations resulting 
from our work.
In completing our report, we received full co￾operation from the Secretary of the Cabinet, the Senior 
Director and General Counsel of the Cabinet Office, 
the Chief of Staff to the Premier, the former Deputy 
Minister and staff from the Housing Ministry, and the 
Deputy Minister and staff from the Ministry of Natural 
Resources and Forestry.
Thank you to my dedicated team of profession￾als who worked diligently with me to complete this 
important report so that I could table it for the Legisla￾tive Assembly as my final report as Auditor General 
of Ontario. 
Sincerely,
Bonnie Lysyk, MBA, FCPA, FCA, LPA
Auditor General of Ontario
August 2023
Toronto, Ontario
forward by two developers (which included a land site 
associated with a third developer) who had access to 
the Chief of Staff in September 2022. 
In essence, the Housing Minister’s Chief of Staff 
instructed the non-political public service staff in the 
Housing Ministry to conduct an exercise that limited 
their site-selection assessment to land sites mostly 
identified by the Chief of Staff, who also limited staff’s 
time to assess the sites, and adjusted the assessment 
criteria, including eliminating the consideration of 
agricultural and environmental factors, which facili￾tated the selection of these specific land sites. What 
occurred here cannot be described as a standard 
or defensible process. Ultimately, the government 
approved the removal of these land sites from the 
protection of the Greenbelt even though these limita￾tions constrained the information the Province used 
in its decision-making. As we point out in our report, 
the actions taken in 2022 were distinctly different 
than processes used in the past to amend Greenbelt 
boundaries.
Why was such a significant decision made so fast 
and without obtaining defensible information by fol￾lowing normal land-use planning practices? How 
could agricultural and environmental impacts not be 
considered in decision-making about the Greenbelt? 
This situation demonstrates the need for non-political 
public servants, including Deputy Ministers, to have a 
formal process empowering them to raise objections 
when, in their opinion, proper information-gathering 
and decision-making protocols are disregarded.
Leaders who show a willingness to explain decisions 
or have them reviewed help demonstrate transparency, 
fairness and equity. Given that both the Premier and 
the Housing Minister communicated to us that they 
were unaware that the pre-selection of Greenbelt lands  

7
Ministry of Municipal Affairs and Housing
Special Report on
Changes to the Greenbelt
communicated objective in adjusting the Greenbelt 
boundary was to allow for construction of a minimum 
of 50,000 new homes to help build 1.5 million homes 
across Ontario over 10 years by 2031. 
The proposed 2022 Greenbelt boundary changes, 
which came after multiple government promises to 
protect the Greenbelt, quickly became a contentious 
issue with the public, in the media and in the Legis￾lature. During the 30-day public consultation period 
required under the Environmental Bill of Rights Act, 
1993, the Ministry of Municipal Affairs and Housing 
(Housing Ministry) received over 35,000 public 
responses, overwhelmingly opposed to any removals 
or land swaps in the Greenbelt. The government went 
ahead and amended the Greenbelt Plan (through Order 
in Council 1745/2022) and Greenbelt Area bound￾ary (by filing Ontario Regulation 567/22 under the 
Greenbelt Act, 2005), exactly as proposed, on Decem￾ber 14, 2022. The next day, the Province also repealed 
the Duffins Rouge Agricultural Preserve Act, 2005 and 
the additional protection it provided this preserve of 
prime agricultural lands and natural features located in 
northwest Pickering (also part of the Greenbelt). 
On January 11, 2023, the Auditor General of 
Ontario received a joint letter from all three Ontario 
Opposition Party leaders requesting a value-for-money 
audit and an assessment of the financial and environ￾mental impacts of the government’s decision to remove 
lands from the Greenbelt. Among the concerns raised 
in the letter, the opposition leaders said “the removal 
of protections from these lands has instantly shifted 
1.0 Summary
With Ontario’s population increasing, housing afford￾ability and availability have become more pressing 
issues impacting communities of all sizes across the 
province. Premier Doug Ford told Ontarians that the 
province has a housing crisis it did not have four years 
ago and that his government wanted to make sure 
houses were built. The Ontario government announced 
on November 4, 2022, that it was proposing to alter the 
boundary of the Greenbelt, an area of about 2 million 
acres of protected farmland, wetlands and woodlands 
encircling the Greater Golden Horseshoe region. The 
Greenbelt was created in 2005 to permanently protect 
productive farmland and natural features from uncon￾trolled urban development. 
The Minister of Municipal Affairs and Housing 
(Housing Minister) announced that about 7,400 acres 
would be removed from the protections of the Green￾belt Plan on 15 land sites. To meet the legislative 
requirement that the total land area in the Greenbelt 
Area cannot be reduced, about 7,000 acres of land 
in the Paris Galt Moraine (southwest of the Town 
of Erin) was proposed to be added to the Greenbelt 
Plan’s Protected Countryside designation and about 
2,400 acres of land was proposed to be added to the 
Greenbelt Plan’s Urban River Valley designation. (See 
Figure 2 for the additions and removals of Greenbelt 
lands in 2022 and previous years and Section 2.1.2
for Greenbelt Plan designations.) The government’s  

8
about 58% of the acreage removed, land sites where 
this developer’s companies would likely be developers 
(see Figure 7). Owners of the 15 land sites removed 
from the Greenbelt could ultimately see a collective 
$8.3 billion increase to the value of their properties, as 
shown in Figure 9. (See Appendix 1 for a timeline of 
events.) 
Restrictions and limitations on the process were 
requested by the Housing Minister’s Chief of Staff 
when he advised the Deputy Minister of Housing 
that the project required higher information-security 
measures. The Deputy Minister then had confidential￾ity agreements put in place for the Greenbelt Project 
Team (a small team of non-political public servants). 
This effectively precluded the possibility of substantive 
input from other provincial ministries, municipalities, 
conservation authorities, Indigenous communities, 
subject matter experts and the general public. This 
exercise did not include any analysis of financial or site￾specific environmental and agricultural impacts. 
Our main findings were:
• According to the government’s Housing 
Affordability Task Force, the Housing Min￾istry, and the Chief Planners of the three 
affected regions, the removal of Greenbelt 
lands was not needed to meet the govern￾ment’s housing goals. The 2022 report of the 
Ontario government’s Housing Affordability 
Task Force, which the government has publicly 
cited as the source of its goal to build 1.5 million 
homes over 10 years, concluded that a shortage 
of land is not the cause of the province’s housing 
challenges. The report also said that the Green￾belt’s land and other environmentally sensitive 
areas should continue to be protected. Further, 
the Chief Planners in the regions of Durham, 
Hamilton and York—which are home to all 15 
land sites removed from the Greenbelt—told us 
that Greenbelt land was not needed to meet the 
current housing targets assigned to them by the 
Housing Ministry. These Chief Planners also told 
us that there is sufficient land outside the Green￾belt in their regions that is already serviced (or 
can be more easily serviced) to meet the housing 
targets assigned to them in October 2022 by a 
wealth to property owners, who have likely benefited 
substantially from the rezoning of this land from 
undevelopable land to developable land.” We initiated 
our work on January 18, 2023.
Although the government met the requirement 
of not reducing the total area of the Greenbelt, as 
required in the Greenbelt Act, 2005, we determined that 
the way the government assessed and selected lands 
for removal from and addition to the Greenbelt was not 
publicly transparent, objective or well-informed, and 
was inconsistent with the vision, goals and processes 
of the Greenbelt Plan, as well as previous amendments 
to the Greenbelt boundary. Further, we noted that 
opening the Greenbelt was not needed to meet the 
government’s goal of building 1.5 million homes over 
10 years.
Rather than have the Housing Ministry’s public 
service conduct a rigorous and comprehensive assess￾ment of Greenbelt boundary change requests, as 
had been done in 2017, as part of a scheduled and 
co-ordinated review of Ontario’s land-use plans, the 
government embarked on a project (the Greenbelt 
Project) that was substantially controlled and directed 
by the Housing Minister’s Chief of Staff, whom the 
Housing Deputy Minister believed was working under 
the authority of the Housing Minister and the Pre￾mier’s Office. Typically, a Chief of Staff works under the 
authority of a minister and the Premier’s Office. Con￾sequently, the Ministry’s non-political public service 
staff believed that directions or instructions provided 
by the Housing Minister’s Chief of Staff were provided 
under the authority of the Minister and the Premier’s 
Office. The Premier’s Chief of Staff appointed the 
Housing Minister’s Chief of Staff, who began work with 
the Housing Ministry on July 4, 2022.
The Housing Minister’s Chief of Staff provided 
all but one of the sites that were ultimately removed 
from the Greenbelt, at least nine of which came from 
requests made by a few select developers and their 
representatives, who contacted him personally. As 
noted below, about 92% of the acreage removed from 
the Greenbelt was land sites passed on to the Housing 
Minister’s Chief of Staff from two developers (which 
included a land site associated with a third developer). 
One of these developers provided the information for  

Special Report on Changes to the Greenbelt 9
2022, 14 were brought into the project by the 
Housing Minister’s Chief of Staff and one was 
identified by the Greenbelt Project Team.
• About 92% of the acreage ultimately removed 
from the Greenbelt was five land sites passed 
on to the Housing Minister’s Chief of Staff 
from two developers (which included a land 
site associated with a third developer). The 21 
land sites provided by the Chief of Staff included 
two proposals (Sites #1 and #9 in Figure 4) 
that were handed to him in packages by prom￾inent developers on September 14, 2022 at a 
dinner function held by the Building Industry 
and Land Development Association. Shortly 
thereafter, one of the same developers provided 
the Housing Minister’s Chief of Staff with addi￾tional information and requests to remove three 
other proposed sites (Sites #4, #12 and #13). 
Together, these five proposed sites accounted 
for 92% of the acreage ultimately removed from 
the Greenbelt and opened for development in 
December 2022. Housing Ministry staff believed 
that the priority sites for removal were Sites #1, 
#4 and #9.
• Assessment criteria provided by the Housing 
Minister’s Chief of Staff were altered and 
facilitated the removal of land sites from the 
Greenbelt. The Housing Minister’s Chief of Staff 
provided the initial criteria for the Greenbelt 
Project Team to use to assess whether potential 
sites had available or planned infrastructure ser￾vices (including roads, transit, utilities, schools 
and emergency services). The Greenbelt Project 
Team informed the Chief of Staff that they could 
not assess infrastructure availability or servicing 
within the three-week time frame without con￾tacting municipalities. Ultimately, the Greenbelt 
Project Team proposed to the Housing Minister’s 
Chief of Staff, and he agreed, that rather than 
assessing existing and planned infrastructure 
availability and servicing capacity for each land 
site, the Greenbelt Project Team would merely 
confirm whether these land sites were adja￾cent to an existing developed urban area. See 
Figure 6.
different division (separate from the Greenbelt 
Project Team) in the Housing Ministry. The 
Housing Ministry division confirmed that it allo￾cated these targets to municipalities without the 
knowledge that lands from the Greenbelt would 
be opened for housing development.
• The Chief of Staff of the Housing Ministry 
was given the responsibility by the Premier’s 
Office to direct a project to change the Green￾belt’s boundary. The Chief of Staff directed 
the Housing Ministry’s Deputy Minister to set 
up a small team of non-political public servants 
who worked within the Housing Ministry (the 
Greenbelt Project Team) to assess certain sites 
to remove from the Greenbelt. The Greenbelt 
Project Team was restricted to a three-week time 
limit and were prohibited, by a confidentiality 
agreement, from speaking to anyone else about 
their work. Over the three-week period, the 
Housing Minister’s Chief of Staff provided the 
Greenbelt Project Team originally with eight—
and then an additional 13—sites to review, while 
asking them to suggest other sites to consider. 
Further, when the Greenbelt Project Team 
required more detailed information on the land 
sites they were asked to assess, it was the Chief 
of Staff who then reached out to the developers 
or their representatives for that information. 
Given the small size of the Greenbelt Project 
Team, the degree of confidentiality, narrow 
project scope and tight timelines, the team was 
able to identify just one additional site (Site #11 
in Figure 4) for consideration, about which they 
had more detailed information as a result of a 
litigation matter—and no additional research 
was undertaken to look for other candidate sites. 
As a result, even though approximately 630 site 
removal requests had been submitted to the 
Housing Ministry since the Greenbelt was estab￾lished in 2005 (see Figure 8), the Greenbelt 
Project Team’s review was limited to 22 specific 
sites, 21 of which were identified and provided 
directly by the Chief of Staff. Of the 15 sites 
ultimately approved for removal in December  

10
not ask for their lands to be removed from the 
Greenbelt. No other sites (other than Site #11, 
recommended by the Housing Ministry) had 
boundary adjustments.
• Internal government decision-making 
material prepared by the Ministry of Housing, 
reviewed by political staff and approved by 
the Housing Minister and the Deputy Min￾ister of the Housing Ministry did not clearly 
describe how the land sites were identi￾fied, assessed and selected for removal. The 
material did not explain that the Chief of Staff 
in the Housing Minister’s Office: identified and 
presented 21 of the 22 land sites for considera￾tion to the Greenbelt Project Team; provided 
the initial criteria that were used to assess the 
land sites for removal; and made the decision to 
drop criteria that certain proposed sites did not 
meet. The materials indicated there would be 
criticism of the basis on which lands were identi￾fied for removal. As a result, public service staff 
within the Cabinet Office and political staff in 
the Premier’s Office, and potentially the ultim￾ate government decision-makers, may not all 
have been aware of these key limitations of the 
Greenbelt Project. We spoke to staff at the Pre￾mier’s Office (including the current and former 
Chiefs of Staff) and Cabinet Office (including 
the Secretary of the Cabinet), who had reviewed 
the decision-making material, and all of them 
expressed different understandings of the 
process than the one that actually took place. For 
example, they said they were unaware that only 
22 Greenbelt sites were assessed for removal 
(rather than all relevant sites in the Greenbelt 
that may have met the criteria) and that almost 
all of the sites assessed were proposed by the 
Housing Minister’s Chief of Staff (rather than 
Housing Ministry staff with expertise in land-use 
planning).
• The public and affected municipalities were 
not sufficiently and effectively consulted on 
the Greenbelt changes, nor was respectful 
and deliberate consideration given to the 
• The Housing Minister’s Chief of Staff made 
the decision to drop the only criterion that 
considered environmental and agricultural 
factors after the Greenbelt Project Team 
determined most of the proposed sites did 
not meet that criterion. One of the initial 
assessment criteria to select sites for removal 
was that the lands could not be in a designated 
specialty crop area or be part of the Greenbelt’s 
Natural Heritage System, which captures areas 
with the most sensitive or significant natural 
features and functions. After the Greenbelt 
Project Team determined that all eight of the 
initial sites did not meet that initial criterion, 
the criterion was later dropped by the Housing 
Minister’s Chief of Staff. The Greenbelt Project 
Team continued to identify the presence of 
specialty crop and Natural Heritage System 
designations on proposed sites for the awareness 
of decision-makers. In total, 13 of the 15 land 
sites ultimately removed from the Greenbelt con￾tained land designated for specialty crops and/
or Natural Heritage System lands. See Figure 4.
• Four of the 22 site selections considered by 
the Greenbelt Project Team were altered so 
that they could still be chosen for removal.
One initial criterion for removal was that the 
selected land site be on the edge of the existing 
Greenbelt Area. The Greenbelt Project Team 
determined that eight of the 22 sites assessed 
did not meet this criterion for removal, meaning 
that their removal would create isolated pockets 
of housing development within the Greenbelt. In 
response, the Greenbelt Project Team provided 
suggestions on how the sites could be altered to 
meet the criterion. The Housing Minister’s Chief 
of Staff subsequently directed the Greenbelt 
Project Team to make the necessary changes to 
four (Sites #6, #7, #8 and #9 in Figure 4) of 
the eight sites so that these four sites could still 
meet this criterion. For example, the boundaries 
of two of these sites (Sites #6 and #8) were 
expanded to reach the edge of the Greenbelt, 
which ultimately affected landowners who did  

Special Report on Changes to the Greenbelt 11
comments were addressed in relation to the 
decision to remove land sites from the Greenbelt 
and ultimately no revisions were made to any of 
the proposed land removals.
• Indigenous communities and leaders say the 
Province failed to properly consult them on 
Greenbelt changes. According to First Nations 
leaders we spoke to, the extent and timing of the 
Housing Ministry’s consultation with Indigen￾ous communities was insufficient to meet the 
Province’s Duty to Consult with regards to 
treaty rights and other rights that apply to the 
areas removed from the Greenbelt in 2022. The 
Housing Ministry’s non-political public service 
staff cautioned government decision-makers 
that this was a risk expressed by Indigenous 
communities. 
• The owners of the 15 land sites removed 
from the Greenbelt could ultimately see a 
collective $8.3 billion increase to the value 
of their properties. The Housing Ministry did 
not estimate how much the value of the land 
would increase to the benefit of a select few, if 
the Greenbelt restrictions on development were 
removed. A subsequent estimate we requested 
and obtained from the Municipal Property 
Assessment Corporation (MPAC), which is 
responsible for calculating property values for all 
municipalities in Ontario, indicates that remov￾ing the 15 land sites from the Greenbelt will 
increase their value by $8.28 billion, with the 
value of one area alone—the Duffins Rouge Agri￾cultural Preserve site in Pickering—increasing 
by $6.63 billion (see Figure 9). Those estimates 
were assessed relative to MPAC’s most recent 
full assessment on January 1, 2016, and did not 
account for additional increases in Ontario land 
values between 2016 and 2023.
• The Housing Ministry did not estimate the 
cost to add needed infrastructure to the 
Greenbelt sites proposed for removal, or who 
would pay for it. We found that the Housing 
Ministry’s Greenbelt Project Team did not esti￾mate the potential costs and time requirements 
overwhelmingly negative feedback received.
We found that public consultation required by 
the Environmental Bill of Rights, 1993 (EBR Act) 
was limited by government to the minimum of 
30 days even though the Housing Ministry’s non￾political public service staff cautioned political 
staff and government decision-makers that this 
relatively short period would be criticized by 
municipalities and many stakeholders as being 
insufficient to effectively consult the public. We 
found that: 
• the public consultation was undermined by 
incomplete and inaccurate notices put on the 
Environmental Registry of Ontario (Environ￾mental Registry) by the Housing Ministry, 
limiting the people of Ontario’s ability to fully 
understand and fully comment on the pro￾posed changes and their potential impacts. 
• the Housing Ministry posted notices on the 
Environmental Registry related to the pro￾posed changes to the Greenbelt Plan, the 
Greenbelt boundary and the Oak Ridges 
Moraine Conservation Plan on November 4, 
2022, just 11 days after municipal elections, 
limiting new councils’ ability to provide com￾ments before the consultation period ended. 
The Association of Municipalities of Ontario 
and several individual municipalities asked the 
Housing Ministry for additional time, but the 
consultation period was not extended.
• the Ministry of Natural Resources and Forestry 
subsequently did not effectively consult the 
public on repealing the Duffins Rouge Agricul￾tural Preserve Act, 2005, instead relying on an 
exception notice that did not give the public 
complete information or an opportunity to 
provide comments. 
Nevertheless, the Housing Ministry still received 
more than 35,000 comments that were over￾whelmingly negative, as detailed in Section 4.8.
The Housing Ministry’s non-political public 
service staff did not have sufficient time to carry 
out a comprehensive analysis of the comments 
to fully inform decision-making. None of these  

12
woodlands from the Greenbelt. Without the 
protection provided by the Greenbelt Plan, these 
natural features are at increased risk of being 
paved over, drained, cut down or polluted. The 
damage or degradation of green spaces can 
increase flooding, impair water quality, contrib￾ute to climate change and reduce biodiversity. 
Environment and Climate Change Canada has 
reportedly identified that at least 29 species 
at risk live, or are likely to live, in the removed 
sites. Although natural heritage features and 
areas on these lands are still subject to the Prov￾incial Policy Statement and ongoing negotiations 
between the Office of the Provincial Land and 
Development Facilitator and landowners/
developers, it is unclear whether this will ensure 
protection of natural heritage features and 
areas. A total of 117 wetlands removed from 
the Greenbelt were within the Duffins Rouge 
Agricultural Preserve lands, 110 of which have 
never been evaluated and are therefore not pro￾tected through the Provincial Policy Statement. 
Despite potential risks, Housing Ministry public 
service staff confirmed there is no plan in place 
to monitor the status and protection of natural 
features on removed lands during future housing 
development.
• There is no formal framework in place to 
monitor and publicly report whether pro￾ponents (landowners and developers) fulfill 
the government’s publicly communicated 
expectations of development on the land sites 
removed from the Greenbelt. On November 4, 
2022, the Ontario government publicly com￾municated its development expectations for 
the 15 land sites removed from the Greenbelt, 
including that proponents (landowners and 
developers) would pay for the infrastructure to 
service the land sites, that construction of new 
homes would begin no later than 2025, and that, 
if developers did not show sufficient progress on 
building homes on these lands, the government 
would begin the process to return these lands 
to the Greenbelt. However, we found that, as at 
to service the 15 land sites removed from the 
Greenbelt with the infrastructure required to 
support housing, nor was it even asked to make 
such a determination. It remains unclear who 
(e.g., owners, developers, municipalities, the 
provincial government, etc.) will ultimately 
bear the full costs to service the land to support 
housing development, including the impact on 
property taxes. Those costs are estimated to be 
in the billions of dollars and are currently being 
negotiated with developers on a site-by-site basis 
by the office of the government’s Provincial Land 
and Development Facilitator.
• The Ministry of Agriculture, Food and Rural 
Affairs (Agriculture Ministry) expects the 
Greenbelt area removals to have significant 
adverse agricultural land impacts. The Agri￾culture Ministry’s non-political public service 
staff have estimated that 76% of the approxi￾mately 7,400 acres removed from the Greenbelt 
was in active agricultural use in 2022. About 
83% of the area removed is classified as Class 1-3 
prime agricultural lands, which is of the highest 
quality and capability for agriculture. Staff deter￾mined that the boundary changes will result in 
a net removal of more than 4,700 acres of land 
designated and protected by municipalities as 
prime agricultural area. They also concluded 
that removing three of the 15 sites (Sites #1, #4 
and #9) from the Greenbelt, making up 91% of 
the total acres removed, is likely to lead to sig￾nificant adverse impacts on agriculture given the 
sites’ large size, existing agricultural uses, and 
connection to nearby farmland. The Agriculture 
Ministry staff conducted additional analysis 
for our Office and estimated that the removed 
Duffins Rouge Agricultural Preserve lands gen￾erated an estimated $14.7 million to Ontario’s 
gross domestic product in 2021.
• Important environmental features on 
land sites removed from the Greenbelt 
face increased risk of damage or degrada￾tion. The 2022 Greenbelt boundary changes 
removed almost 1,000 acres of wetlands and  

Special Report on Changes to the Greenbelt 13
assess the suitability of these lands to offset 
removals, or the environmental or agricultural 
value of protecting these lands. Although the 
Greenbelt Project Team recommended adding 
a larger portion of the Paris Galt Moraine to 
encompass important natural features and agri￾cultural land, the Housing Minister’s political 
staff directed the Team to add a much smaller 
area that was closer to the minimum 1:1 ratio 
necessary to offset removals. The portion of 
the Paris Galt Moraine that was added has its 
western boundary cutting across the moraine, 
without consideration for hydrological, eco￾logical or geological features. Further, the URV 
additions do not result in meaningful protection. 
URVs are typically already protected by existing 
policies, regulations and municipal designa￾tions, are largely undevelopable anyway due 
to their steep terrain and flood risk, and do not 
contribute agricultural land protection—a core 
objective of the Greenbelt Plan. The Housing 
Ministry noted that the agricultural sector, 
including the Ontario Federation of Agriculture, 
believes that it is unacceptable for URVs to be 
included in calculations to maintain the total 
Greenbelt Area if agricultural lands are removed 
for development. 
• There was no specific reason that the removal 
of the 15 land sites, done through changes 
to regulations, had to be included and com￾municated as part of the government’s 
legislative changes in late 2022. The Housing 
Minister’s Chief of Staff imposed a three-week 
time frame on the Greenbelt Project Team to 
complete the project so that the announce￾ment of Greenbelt land removals and additions 
could coincide with the government’s fall 
housing legislation. The removal of the 15 land 
sites occurred through changes to regulations 
(O. Reg. 567/22 amended O. Reg. 59/05 under 
the Greenbelt Act, 2005 and O. Reg. 568/22 
amended O. Reg. 140/02 under the Oak Ridges 
Moraine Conservation Act, 2001) and need 
June 2023, neither the Housing Ministry nor the 
government had further defined their expecta￾tions in order for performance indicators to be 
established and targets set so that progress and 
results can be objectively monitored, measured 
and publicly reported.
• It is still unknown if much of the land of the 
15 sites removed from the Greenbelt will be 
ready for development by 2025 as has been 
cited as a government expectation for these 
sites. The restrictions placed on the Greenbelt 
Project Team by the Housing Minister’s Chief of 
Staff precluded the Greenbelt Project Team from 
confirming how quickly housing could be built 
on the sites, or at what cost. As well, the Green￾belt Project Team did not have information to 
confirm whether servicing was available or pos￾sible in the near term for the sites removed. The 
Durham, Hamilton and York Chief Planners we 
spoke to said it would be challenging to provide 
the selected sites with the municipal infrastruc￾ture and services needed to support housing 
development in the near future. For example, 
Durham’s Chief Planner estimated it will take as 
many as 25 years to have full service for housing 
development on the Duffins Rouge Agricultural 
Preserve, which accounts for 58% of the land 
acres removed from the Greenbelt in 2022.
• The addition of lands to the Greenbelt in 
2022 was not based on natural boundaries 
and protecting environmental functions, 
and the Housing Ministry did not evaluate 
the suitability of adding lands as an offset to 
removals. In 2022, the Province added approxi￾mately 7,000 acres of the Paris Galt Moraine (a 
unique landform that provides drinking water, 
wildlife habitat and agricultural land) and 
2,400 acres of Urban River Valleys (URVs) to 
the Greenbelt to offset removals. Additions to 
the Greenbelt were necessary to offset remov￾als because the Greenbelt Act, 2005 prohibits 
an overall reduction in the Greenbelt Area. 
However, the Greenbelt Project Team did not  

14
Cabinet (including the Premier) to inform the decision 
to change the Greenbelt’s boundary, neither identified 
codified processes nor clearly and correctly explained 
how the proposed land sites had been identified, 
assessed and selected for removal. 
The Housing Minister told us that although he 
became aware in June 2022 that there would eventu￾ally be a new codified process to amend the Greenbelt, 
he was not aware of how the specific land sites covered 
by O. Reg. 59/05 were identified for assessment and 
removal from the Greenbelt. Based on our interviews, 
other political public service staff in the Minister’s 
Office, the Premier’s Office and non-political public 
service staff in Cabinet Office indicated that they were 
similarly not aware of how specific properties were 
identified. Given the high level of public interest that 
any change to the Greenbelt’s boundary was expected 
to carry, the Housing Minister ought to have known 
the process used that would lead to the removal of 
land from the Greenbelt, and ensure that Cabinet and 
the Premier were also made aware of these details. 
The Housing Minister indicated he first became aware 
of the specific land sites proposed for removal on 
October 26 and the Premier indicated he first became 
aware of the specific land sites proposed for removal 
on November 1, prior to a Cabinet meeting held on 
November 2. 
Our audit also concluded that the government did 
not assess financial impacts such as serviceability costs, 
taxation impacts and land value impacts of Greenbelt 
boundary changes. Environmental and agricultural 
risks were not effectively considered prior to proposing 
15 land sites for removal. 
Because the project to remove land from the Green￾belt was designed to be swift and confidential, the 
Housing Ministry was restricted from leveraging the 
expertise of partner ministries, municipalities, Indigen￾ous communities and conservation authorities on 
agricultural and environmental risks while assessing 
sites for removal from the Greenbelt. The Agriculture 
Ministry expects the Greenbelt area removals to have 
significant adverse agricultural land impacts. Staff in 
the Agriculture Ministry determined that the bound￾ary changes will result in a net removal of more than 
not have been part of any combined legisla￾tive changes in late 2022. Because Greenbelt 
boundary amendments are made by regulation, 
changes can be made—with sufficient public 
consultation under the Environmental Bill of 
Rights, 1993—independent of the Legislative 
Assembly’s schedule of legislative business.
Overall Conclusion
Our audit concluded that the lands removed from the 
Greenbelt in December 2022 were not chosen using an 
objective and transparent selection process. Although 
the government communicated that it was removing 
land from the Greenbelt to support its goal of building 
1.5 million housing units over the next 10 years, there 
is no evidence this land is needed to reach that goal. 
We found that in June 2022, the Minister of Muni￾cipal Affairs and Housing was assigned, through a 
mandate letter, to “codify processes” to amend the 
Greenbelt. However, it was the Housing Minister’s 
Chief of Staff who identified specific land sites and 
provided them to the Greenbelt Project Team to assess 
for their expedient removal from the Greenbelt. At 
least 92% of the acreage removed from the Greenbelt 
was from five land sites passed on from two develop￾ers (which included a land site associated with a third 
developer) who had direct access to the Housing Min￾ister’s Chief of Staff. Housing Ministry staff believed 
that three land sites were a priority for removal from 
the Greenbelt: Duffins Rouge Agricultural Preserve 
lands in Durham Region (Site #1), Book Road in Ham￾ilton (Site #4) and Bathurst-King in York Region (Site 
#9). For details, see Figure 4 and Section 4.2.
The Housing Minister’s Chief of Staff also provided 
the Greenbelt Project Team with the initial criteria 
used to assess the sites for removal. The criteria were 
amended as the process went on and facilitated the 
removal of sites that had land designated as Natural 
Heritage System or Specialty Crops, and sites that were 
not easily serviceable. 
The proposal prepared by the Housing Ministry 
(signed and approved by the Deputy Minister of 
Housing and the Housing Minister), and provided to  

Special Report on Changes to the Greenbelt 15
RESPONSE FROM THE GOVERNMENT
(Chief of Staff, Office of the Premier)
On behalf of the Premier’s Office, I appreciate the 
opportunity to provide a general response to your 
recommendations regarding the Government of 
Ontario’s political public service in implementing 
our more than ten week initiative to grow the 
Greenbelt by more than 2,400 acres and help 
address Ontario’s mounting housing crisis by 
unlocking lands to build more than 50,000 attain￾able and affordable homes for Ontarians who need 
them.
As you will know, Ontario’s population is 
growing at a dramatic and unprecedented rate, 
with our population growing faster than any 
province or state in Canada or the United States. 
Last year alone, we welcomed more than 500,000 
people to Ontario. That’s more newcomers than 
Texas and Florida, the fastest growing states in 
America, which are roughly double the size of 
Ontario’s total population. With this unparalleled 
level of growth, the need and demand for all forms 
of housing options has never been more extreme, 
compounding Ontario’s already serious housing 
supply and affordability crisis. 
Ontario’s housing supply and affordability crisis 
most acutely impacts newcomers and young people, 
who are unnecessarily priced out of the dream of 
home ownership. It also negatively impacts every 
Ontario resident, including those who are fortunate 
enough to already own a home, as it drives up the 
cost of goods and services, threatens existing jobs 
and businesses, discourages new job creation and 
investment, and erodes our sense of community and 
social welfare. As others have pointed out, failing to 
address the housing supply and affordability crisis 
threatens Canadians’ so-far unwavering support 
for immigration, particularly at a time when our 
economic success depends on welcoming skilled 
newcomers to fill critical labour gaps. 
That’s why our government has taken action as a 
leader in Canada and the first Ontario government 
4,700 acres of land designated and protected by 
municipalities as prime agricultural area. Important 
environmental features on land sites removed from the 
Greenbelt face risk of damage and degradation now 
that they are no longer protected under the Greenbelt 
Plan. Changes to the Greenbelt’s boundary removed 
almost 1,000 acres of wetlands and woodlands from 
the Greenbelt; these natural features risk being paved 
over, drained, cut down or polluted. As well, Environ￾ment and Climate Change Canada has reportedly 
identified that at least 29 species at risk live, or are 
likely to live, in the removed sites. 
During this audit, we also noted that political 
public service employees place significant reliance 
on information provided by third parties with vested 
interests who have access to these employees. In the 
situation we reviewed, this practice contributed to a 
non-transparent exercise and preferential decision￾making without the benefit of sound information and 
recommendations that could have been received from 
the Housing Ministry, the Ministry of Natural Resour￾ces and Forestry, the Ministry of Agriculture, Food and 
Rural Affairs, and the Ministry of the Environment, 
Conservation and Parks. 
Although the government publicly communi￾cated its expectations for land sites removed from the 
Greenbelt in December 2022—including that the site 
proponents would pay, upfront and in full, for the 
infrastructure to service the lands, and that construc￾tion of new homes would begin on these lands no later 
than 2025—we found that the Housing Ministry and 
the government have not further defined these expect￾ations so that they can be measured, nor have they 
established performance indicators to do so. 
Throughout this report we refer to 91%, 92% and 
93% as percentages of acreage removal. Each percent￾age is accurate in each context. Ninety-one percent 
refers to Sites #1, #4 and #9; 92% relates to Sites #1, 
#4, #9, #12 and #13; 93% refers to seven land sites, 
Sites #1, #3, #4, #9, #12, #14 and #15. These land 
sites are identified in Figure 4.
Fifteen recommendations are provided in 
Appendix 8.  

16
approvals and implementation achieved by the end 
of 2023 be met. If these conditions are not met, the 
government will return these lands to the Greenbelt 
without hesitation.
Our government continues to believe that build￾ing more homes is one of the most pressing and 
urgent challenges facing our province and we will 
not relent in our commitment to build a minimum 
of 1.5 million homes in 10 years, including by deliv￾ering attainable and affordable homes on the lands 
unlocked from the Greenbelt. 
Under the leadership of Premier Ford, our 
government believes in and pursues continuous 
improvement in everything we do to better serve 
the people of Ontario. We acknowledge that this 
initiative has moved quickly as speed is necessary 
when responding to a crisis. That said, and while 
the initiative is trending well toward achieving its 
overall objective of rapidly building thousands of 
new attainable and affordable homes, we recognize 
there are areas for improvement.
We have thoughtfully considered where the 
report recommendations can assist with strength￾ening processes as we move forward and continue 
our work to respond to Ontario’s housing crisis. In 
this respect we accept in-principle fourteen of the 
fifteen recommendations.
We agree that there is always an opportunity 
to improve the way that the political public service 
works together to establish, implement, and deliver 
for the people of Ontario through enhanced gov￾ernment policies and programs. I will confer with 
the Secretary of Cabinet and Minister’s Office staff 
regarding recommendations in your report per￾taining to administrative and operational elements, 
including how political and non-political public 
servants work together, to consider appropriate and 
practical ways of improvement for the benefit of all 
Ontarians.
We accept your recommendations regarding 
the need to enhance awareness and adherence to 
proper records retention and stakeholder engage￾ment policies by political public servants. We have 
in decades to establish a real plan to address this 
crisis with the creation of Ontario’s Housing Supply 
Action Plan. Working together with municipal part￾ners and the federal government, we are ensuring 
that Ontario can continue to be a thriving and wel￾coming province of opportunity where all people 
and families can afford to have a roof over their 
heads and a place to call their own, a place to call 
home. 
Last year, our government commenced an 
initiative to support the accelerated construction 
of thousands of new housing options while also 
growing the Greenbelt. This initiative swapped long 
identified and municipally requested non-sensitive 
areas of Greenbelt land with other newly desig￾nated Greenbelt areas, supporting the construction 
of at least 50,000 new homes in growing com￾munities while expanding the total Greenbelt area 
by more than 2,400 acres. Critically, this initiative 
impacted non-publicly owned lands and established 
conditions to ensure that billions of dollars worth 
of community benefits such as new roads, parks, 
transit, water, and health-care infrastructure, as 
well as significant non-profit housing contributions, 
among other anticipated public benefits, are fully 
funded by the landowners and builders–not Ontario 
or municipal taxpayers. 
As our government indicated at the outset of 
this initiative: the Office of Ontario’s Provincial 
Land and Development Facilitator (PLDF), which 
is staffed by non-political public servants, will be 
assessing site agreements against the government’s 
requirement that all necessary local infrastructure 
upgrades are funded entirely by the proponents. 
Without this requirement being met, the Minister 
of Municipal Affairs and Housing will not approve 
development moving forward.
At the same time, in recognition of the need to 
quickly build homes to house Ontario’s growing 
population, the PLDF will also require site agree￾ments to specify that the government’s conditions 
that new home construction begins on these lands 
by no later than 2025, with significant progress on  

Special Report on Changes to the Greenbelt 17
The Ontario Public Service, including myself 
and the Deputy Minister Team, will be working 
to support the government on implementation 
of all the recommendations the government has 
accepted. 
On behalf of the Deputy Ministers, the non-par￾tisan public servants who worked on the Greenbelt 
Cabinet Submission and myself, we have appreci￾ated having the opportunity to provide factual 
information and perspectives on the work that was 
undertaken over a 10-week period to support one of 
the government’s mandated priorities. 
In the course of our work together over the past 
years, I have shared with you how enormously 
proud I am of Ontario Public Service staff and the 
work they do to serve 15 million Ontarians. Each 
day, and in every meeting and interaction I have 
with staff across the public service, I observe public 
servants operating with a high degree of profession￾alism, competence and integrity in their respective 
specialty fields, and a true desire to support and 
protect our democratic principles including those of 
equity and fairness. 
At the same time, the Ontario Public Service 
strives each day to improve, and there are 
important insights in your report on how we can 
effectively support and serve governments, regard￾less of party, to deliver programs and services to the 
people of Ontario who we are so honoured to serve. 
There are recommendations in your report 
that relate to the administration and operations of 
the public service, including documentation, the 
role of Deputy Ministers, the use of confidentiality 
agreements, and the process to support Cabinet 
decision-making and sign-off. 
I will be using your report and its recommen￾dations to the public service, in consultation with 
Deputy Ministers, with a view to augmenting the 
substantive and vital work the Ontario Public 
Service currently performs in supporting govern￾ment decision-making and delivering effectively on 
priorities.
There are also recommendations that pertain to 
the respective roles and responsibilities of Deputy 
confirmed the enhancement of mandatory new 
staff onboarding and recurring all-staff information 
and training sessions delivered in partnership with 
the Office of the Integrity Commissioner of Ontario. 
We also accept your recommendation to implement 
an attestation process to confirm the exclusive use 
of government email platforms. Furthermore, we 
accept your recommendation regarding the Office 
of the Integrity Commissioner of Ontario and a 
request for his determination regarding this matter 
has been sent.
To your recommendation regarding roles and 
responsibilities of political public servants (such as 
Chiefs of Staff to Ministers) and non-political public 
servants (such as Deputy Ministers), I will work 
with the Secretary of Cabinet and Cabinet Office 
to review our existing role and responsibility docu￾ments describing the relationship between political 
and non-political public servants in policy and oper￾ational matters.
Additionally, we accept your recommendation 
regarding a comprehensive overall review of the 
Lobbyists Registration Act, 1998 (LRA), Members’ 
Integrity Act, 1994, (MIA) and Public Service of 
Ontario Act, 2006 (PSOA). Both the LRA and PSOA 
have statutory requirements setting out reviews of 
the respective acts, and while the MIA does not, 
we will initiate a review of all three acts in advance 
of the prescribed legislative timelines in a com￾prehensive manner at an independent legislative 
committee to ensure and strengthen regulatory 
oversight. 
Thank you for the opportunity to provide a 
general response. As our government continues to 
fulfill our promise to the people of Ontario to build 
1.5 million homes over 10 years, know that we take 
seriously our obligation to do so in a way that con￾tinues to build public trust and confidence. 
RESPONSE FROM THE SECRETARY
OF THE CABINET
Thank you for the opportunity to respond to your 
report and the recommendations it contains that 
pertain to the Ontario Public Service (OPS).  

18
2.0  Background
Greenbelts have been a planning approach to manage 
urban development and to protect farmland and 
natural areas around the world for decades. A “green￾belt” is a swath of undeveloped “green” land that 
encircles, or “belts”, a city, town or region. Greenbelts 
generally comprise a combination of public and private 
lands on which there are development restrictions. The 
primary objectives of greenbelt policies are to protect 
agricultural land, conserve nature, contain urban 
growth and provide recreational spaces for people.
Used as an approach to urban planning since the 
late 19th century, there are now greenbelts in cities 
all over the world, such as in Ottawa, San Francisco, 
London, Copenhagen, Melbourne and Sao Paolo. 
Greenbelts have been used to protect natural land and 
agricultural land from urban sprawl, and to provide 
city-dwellers with recreational spaces. The Greenbelt 
around Ontario’s Greater Golden Horseshoe is the 
world’s largest greenbelt. 
2.1 History of the Greenbelt
Established in 2005, the Greenbelt Area is approxi￾mately 2 million acres and includes lands in the 
Niagara Escarpment Plan (1985), the Oak Ridges 
Moraine Conservation Plan (2001) and the Greenbelt 
Plan (2005), that surrounds a significant portion of the 
Greater Golden Horseshoe (GGH) region, the densely 
populated and industrialized area centred around 
the City of Toronto. Wrapping around the GGH, the 
Greenbelt encompasses urban development along Lake 
Ontario on both its northern and southern shores (see 
Figure 1).
The Greenbelt was created to help control urbaniza￾tion and sprawl (often characterized by low-density 
residential housing, such as zoning that limits develop￾ment to single detached homes on each residential lot) 
in the GGH region, and to reduce the corresponding 
loss of farmland and natural features. Forests, wet￾lands, streams and other natural features clean the air, 
provide drinking water, provide habitat for plants and 
Ministers and Chiefs of Staff to Ministers. Accord￾ingly, I will be working with the Premier’s Chief 
of Staff to review the information we provide to 
incoming Ministers, their staff and the Premier’s 
Office that outlines the roles and responsibilities 
of Ministers and ministries, and the reporting rela￾tionship of Deputy Ministers who report to, and are 
accountable to, the Secretary of the Cabinet.
I will also continue my ongoing work with the 
Chief of Staff to the Premier to clarify the role 
Chiefs of Staff play for Ministers in carrying out 
each Minister’s directions, and how Chiefs of Staff 
work with the Deputy Ministers and the public 
service on both policy and operational matters. 
These efforts will also include promoting aware￾ness of, and reinforcing the use of, processes that 
are already in place for Deputy Ministers and other 
senior leaders in the public service to raise issues 
and concerns they may have about a process or 
risk. As I have shared with you, in my role as the 
Secretary of the Cabinet I am able to raise issues, 
including those escalated to me, directly with the 
Premier, his Office and Ministers, and I have found 
the Premier, his staff and Ministers to be receptive 
to, and to consider carefully, any issues or concerns 
I have raised. 
Our existing ability to engage in open dialogue 
with elected officials and their staff reflects our 
mutual responsibility to adhere to key principles 
expressed in the Public Service of Ontario Act, 2006, 
which is to ensure that the public service of Ontario 
is effective in serving the public, the government 
and the Legislature, and is non-partisan, profes￾sional, ethical and competent.
Your remaining set of recommendations relate 
to the government and their operations and deci￾sions. I commit to working with and supporting 
the Premier and the Chief of Staff to the Premier as 
they consider your report and will work with them 
collaboratively to implement all of the recommen￾dations they have accepted.
Again, thank you for the opportunity to respond 
to your report. 

Special Report on Changes to the Greenbelt 19
Figure 1: The Greenbelt as of December 19, 2022, after the Most Recent Removals
Source: Ministry of Municipal Affairs and Housing 

20
contributed to the development of the Agricultural 
System of the Greenbelt, a land designation within the 
Greenbelt Plan with policies to protect a continuous 
land base for agriculture (see Section 2.1.2 for more 
information on the Greenbelt’s designations).
Making use of an established approach to natural 
heritage management that was used for the ORMCP (as 
well as in other jurisdictions in Canada and the United 
States), the Ministry of Natural Resources and Forestry 
(Natural Resources Ministry) developed the Green￾belt’s Natural Heritage System, which captures areas 
with the most sensitive or significant natural features 
and functions. Areas with the highest concentrations 
of natural features were clustered together into 16 
core areas, which were then used to develop linkages 
to allow for the spread of plants and the movement of 
animals between the core areas and to natural areas 
outside of the Greenbelt.
The Housing Ministry also collaborated with 
partner ministries and stakeholders to assess several 
other factors needed to develop the overall boundary 
and Greenbelt systems, including: water quality, areas 
important for groundwater and surface water flow, spe￾cies-at-risk habitats, Niagara Tender Fruit and Grape 
Lands, and future urban land needs for housing and 
economic growth.
2.1.2 The Greenbelt Plan (2017)
On February 28, 2005, the Ontario Legislature passed 
the Greenbelt Act, 2005 (Greenbelt Act) with the intent 
to permanently protect approximately 2 million acres 
of productive farmland and natural features from 
uncontrolled urban development. This area repre￾sented the world’s largest Greenbelt and included the 
Niagara Escarpment, the Oak Ridges Moraine and large 
areas of rural land. The Greenbelt Act provided govern￾ment with the authority to define the Greenbelt Area 
(see Figure 1 for a map of this area as of December 19, 
2022) and to create the Greenbelt Plan. The Plan was 
updated in 2017 as part of a required 10-year review.
Since its approval in 2005, the Greenbelt Plan’s 
vision has stated that the Greenbelt is a broad band of 
permanently protected land established to: 
animals, and give people opportunities for recreational 
activities. The GGH region also has some of Canada’s 
most important and productive farmland. The Green￾belt Plan derives its authority from the Greenbelt Act, 
2005 and is administered by the Ministry of Municipal 
Affairs and Housing (Housing Ministry). See Appen￾dix 1 for a timeline of events.
2.1.1 Formation of the Greenbelt’s Boundary
In June 2004, the Ontario Legislature passed the 
Greenbelt Protection Act, 2004 to establish a study 
area for determining the boundary and layers for a 
greenbelt and to pre-emptively suspend development 
outside urban settlement areas in key parts of this area 
for the duration of the review. One of the key object￾ives for the Greenbelt was to include lands that were 
already permanently protected through the Niagara 
Escarpment Plan (NEP) (see Section 2.1.3) and Oak 
Ridges Moraine Conservation Plan (ORMCP) (see 
Section 2.1.4). These two provincial plans provide dir￾ection for the use and management of land and water 
aimed at protecting the ecological and hydrological 
features within these areas. 
The process to write the Greenbelt Protection Act, 
2004 began in February 2004, when the Minister of 
Municipal Affairs and Housing established a task force, 
consisting of 13 external stakeholders and subject 
matter experts, to gather information and develop 
recommendations for creating the Greenbelt. The task 
force subsequently provided the Housing Ministry with 
a report that included recommendations on how to 
identify lands for protection. Building on the recom￾mendations of the task force, the Ministry collaborated 
with partner ministries, municipalities and other stake￾holders to develop a draft plan and boundary for the 
Greenbelt. 
The Ministry of Agriculture, Food and Rural Affairs 
(Agriculture Ministry) developed a methodology for 
identifying and designating prime agricultural areas, 
where rural areas are scored based on several factors, 
including soil capability, connectedness with sur￾rounding agricultural areas, and area in agricultural 
production. The resulting maps from this process  

Special Report on Changes to the Greenbelt 21
Protected Countryside to the Great Lakes. Generally, 
the public lands in URVs are already subject to existing 
provincial and municipal restrictions on development. 
For Greenbelt lands located within the NEP or the 
ORMCP, the more protective policies in those specific 
plans take precedence.
Under the Greenbelt Act, the Housing Ministry 
is to initiate a review of the Greenbelt Plan every 10 
years, at the same time as the scheduled review of 
the NEP (see Section 2.1.3) and the ORMCP (see 
Section 2.1.4). During this review, the Minister is to 
consult with any affected public bodies (including 
the Natural Resources Ministry, the Niagara Escarp￾ment Commission and the Greenbelt Council) and the 
council of each municipality included in the Greenbelt 
Area, ensuring the public is given an opportunity to 
participate in the review. The last co-ordinated review 
of Ontario land-use plans was initiated in 2015 and 
completed in 2017. The next review is scheduled to 
begin in 2025.
The Greenbelt Council is a government advisory 
agency that was established under the Greenbelt Act. 
The act requires the Housing Minister to appoint a 
Greenbelt Council. The mandate of the council is to 
provide advice to the Housing Minister about land-use 
planning matters related to the Greenbelt Area. 
2.1.3 The Niagara Escarpment Plan
The Niagara Escarpment Plan (NEP) was established 
in 1985 under the Niagara Escarpment Planning and 
Development Act to serve as the environmental land-use 
plan for the Niagara Escarpment, a prominent ridge 
that extends 725 kilometres through southern Ontario 
from the Bruce Peninsula to the New York State border, 
with unique environmental and landscape features. 
The purpose of the act and the NEP is to protect and 
maintain the Niagara Escarpment and its vicinity “as a 
continuous natural environment,” and to ensure that 
only compatible development occurs. 
The NEP establishes a framework to sustainably 
manage compatible development, protection and 
public enjoyment of the Niagara Escarpment. The NEP 
applies to 21 of the 110 municipalities in the GGH. 
None of the Greenbelt amendments made in 2022 alter 
• protect against the loss and fragmentation of the 
agricultural land base and support agriculture as 
the predominant land use;
• give permanent protection to the natural herit￾age and water resource systems that sustain 
ecological and human health, and that form the 
environmental framework around which major 
urbanization in south-central Ontario will be 
organized;
• provide for a diverse range of economic and 
social activities associated with rural com￾munities, agriculture, tourism, recreation and 
resource uses; and
• build resilience to and mitigate climate change.
In 2007, the Housing Ministry won a prestigious 
national planning award from the Canadian Institute 
of Planners for its Greenbelt Plan and recognition of 
excellence in natural systems planning.
The Greenbelt Plan (2017) outlines specific land-use 
planning policies for areas located within its “Protected 
Countryside,” which is the technical designation of the 
majority of land area within the Greenbelt with specific 
policies restricting urban development. Similar to the 
NEP and the ORMCP, the Greenbelt Plan divides lands 
within the Protected Countryside into the following 
three key policy areas: 
• Agricultural System: agricultural land; spe￾cialty crop areas; rural land; and agricultural 
infrastructure, services and assets.
• Natural System: natural heritage system, the 
water resources system and key hydrological 
areas, key natural heritage features (such as 
wetlands, significant woodlands and signifi￾cant valleys); key hydrologic features (such as 
streams, lakes and wetlands) and groundwater 
sources; and areas that serve as ecological link￾ages between these features.
• Settlement Areas: cities, towns, villages and 
hamlets that have areas of concentrated develop￾ment and lands that have been designated for 
development.
The Greenbelt Plan (2017) also includes specific 
policies for Urban River Valleys (URVs), which are 
only applied to publicly owned lands within the main 
corridors of river valleys that connect the Greenbelt’s  

22
In the 1970s, these DRAP lands were expropriated 
from landowners by the Ontario government as part 
of a larger area to support a nearby proposed federal 
airport. The airport was never built, and in 1999 the 
provincial government, the Regional Municipality 
of Durham and the Town of Pickering entered into a 
Memorandum of Understanding to enable the same 
DRAP lands to be sold to the original landowners 
and tenant farmers at agricultural prices (which are 
substantially lower than developable land prices). As 
a condition of sale, each purchaser agreed to grant a 
conservation or agricultural easement—a legal agree￾ment intended to protect the lands in perpetuity by 
attaching restrictions to a given property that limit the 
landowner to agricultural and conservation uses. For 
further protection of the lands’ use, in 2003 the then 
Housing Minister issued a Minister’s Zoning Order 
restricting use of lands in the DRAP to agriculture.
In February 2005, the Ontario government finalized 
the Greenbelt Plan and designated the DRAP lands as 
part of its Protected Countryside. The Greenbelt Plan 
states that the Rouge River watershed (which con￾tains both Rouge National Urban Park and part of the 
DRAP) is of particular significance within the Protected 
Countryside, and that these lands “serve as a vital eco￾logical corridor linking Lake Ontario to the Oak Ridges 
Moraine.”
According to the Ministry of Natural Resources 
and Forestry, in March 2005, without consulting the 
Ontario government, the Town of Pickering released 
the easements it held on two-thirds of the properties 
that had been purchased in the DRAP. In response, the 
Ontario government enacted the Duffins Rouge Agricul￾tural Preserve Act, 2005 (DRAP Act), which provided 
legal effect to the easements despite any action taken 
to release them, and approved the Central Pickering 
Development Plan in 2006, which further protected the 
DRAP lands from development.
2.1.6 Greenbelt Boundary Changes Between 
2005 and 2021
Between 2005 (when the Greenbelt was established) 
and 2021, the Greenbelt’s boundary was amended 
twice. The first instance occurred in January 2013, 
the NEP or its plan area. See our 2022 report on Con￾serving the Niagara Escarpment for information and 
findings about this act and plan. 
2.1.4 Oak Ridges Moraine Conservation Plan
The Oak Ridges Moraine (Moraine) is an environment￾ally sensitive, irregular ridge in south-central Ontario 
that stretches 160 kilometres from the Trent River 
to the Niagara Escarpment, covering approximately 
470,000 acres. Formed 12,000 years ago by glaciers, 
the Moraine comprises rolling hills, river valleys 
and wetlands. Located north of and parallel to Lake 
Ontario, the Moraine divides the watersheds draining 
south into western Lake Ontario from those draining 
north into Georgian Bay, Lake Simcoe and the Trent 
River system.
Established under the Oak Ridges Moraine Conserva￾tion Act, 2001, the Oak Ridges Moraine Conservation 
Plan (ORMCP) was created to provide land-use and 
resource-management planning direction to provin￾cial ministers, ministries, agencies, municipalities, 
landowners and other stakeholders on how to protect, 
maintain, improve and restore the Moraine’s ecological 
and hydrological features and functions. According 
to the ORMCP, the Moraine’s unique concentration of 
environmental, geological and hydrological features 
make its ecosystem vital to south-central Ontario. The 
Moraine, the Niagara Escarpment and the Greenbelt 
Plan’s Natural Heritage System together form the foun￾dation of south-central Ontario’s natural heritage and 
green space systems. The ORMCP applies to 32 of the 
110 municipalities in the GGH. A portion of one of the 
sites removed from the Greenbelt in 2022 (Site #9) 
was re-designated as a “settlement area” under the 
ORMCP.
2.1.5 Duffins Rouge Agricultural Preserve 
(DRAP)
The Duffins Rouge Agricultural Preserve (DRAP) 
includes about 4,700 acres of prime agricultural lands 
and natural features located in northwest Pickering. It 
is located immediately adjacent to the Rouge National 
Urban Park, Canada’s only national urban park. 

Special Report on Changes to the Greenbelt 23
especially important for the GGH, which contains 3% 
of Ontario’s total land area but 69% of its population. 
The GGH has one of the highest rates of biodivers￾ity among Canadian regions and includes the Niagara 
Escarpment (a UNESCO World Biosphere), as well as 
some of the most productive farmland in the nation. 
At the same time, the region is the engine of Ontario’s 
economy; between 2013 and 2017, the GGH gener￾ated one-quarter of the entire country’s gross domestic 
product. 
Having in place robust land-use planning processes 
is important because decisions about development 
have far-reaching impacts on the economy, human 
health and the natural environment. In Ontario, 
normal land-use planning processes involve policy 
direction at the provincial level and co-ordination 
between multiple ministries and municipal decision￾makers. The Planning Act requires municipalities to 
craft Official Plans which set out a long-term vision (up 
to 25 years) for how the municipality wants to evolve 
and how it intends for the land to be used. 
when approximately 630 acres of provincially owned 
Urban River Valleys in the Glenorchy Conservation 
Area in Oakville were added to the Greenbelt Plan (see 
Figure 2).
The second instance was in July 2017, when, fol￾lowing the Ministry’s review of the Greenbelt Plan 
(required every 10 years under the Greenbelt Act), the 
Ontario government added 24,958 acres of land to the 
Greenbelt and removed 17 areas of land totalling 371 
acres, resulting in a net increase of about 24,587 acres 
(see Figure 2). 
In both instances, the Ministry received input from 
partner ministries and engaged with municipalities, 
Indigenous communities, landowners and developers, 
and key stakeholders. In the case of the 10-year review 
of the Greenbelt, which included removal of lands from 
the Greenbelt, the Ministry conducted a series of public 
consultation opportunities at various stages during a 
27-month review period, one of which was held for 
approximately six months. The Ministry received about 
490 requests to remove land from the Greenbelt at that 
time, and assessed each of them using an approach 
and guidelines that only considered removing areas 
where development plans had already been approved 
prior to the creation of the Greenbelt and making 
minor boundary refinements. These refinements con￾sidered updated natural heritage mapping information, 
opportunities to restore natural features that may have 
become degraded, and how refining the Greenbelt’s 
boundary may affect the overall integrity of the Green￾belt’s Natural Heritage System.
2.2 Ontario’s Housing Strategy and
the Greenbelt
2.2.1 Land-Use Planning in the Greater Golden 
Horseshoe
Land-use planning is the strategic planning process 
that guides decisions about where and what type of 
development can occur—and where different types 
of development should not occur. As explained in 
our 2021 audit report, Land-Use Planning in the Greater 
Golden Horseshoe (GGH), this planning process is 
Figure 2: Additions and Removals of Greenbelt Lands, by 
Type and Acreage (1,000)
Source of data: Ministry of Municipal Affairs and Housing
Protected Countryside removed
Protected Countryside added
Urban River Valleys added
-10
-5
0
5
10
15
20
25
30
2013 2017 2022
Acres 
Year 

24
greater density on existing parcels of land allocated 
for development. The Task Force noted that a shortage 
of land was not the cause of the housing affordability 
problem and that there was sufficient land available 
for development outside of protected areas (citing the 
Greenbelt as an example). The Task Force also com￾mented that the Greenbelt and other environmentally 
sensitive areas must be protected in order to ensure 
that farms continue to provide food and food secur￾ity. The report states: “Land is available, both inside 
the existing built-up areas and on undeveloped land 
outside of greenbelts.”
The provincial government adopted the Task Force 
report as its primary housing strategy in March 2022, 
and the Ministry began tracking progress against the 
Task Force report’s 55 recommendations.
The Province has committed to getting 1.5 million 
new homes built over the next 10 years and passed 
Bill 23, the More Homes Built Faster Act, 2022 on 
November 28, 2022, which made significant changes 
across various pieces of provincial legislation including 
to the Planning Act, the Conservation Authorities Act, 
the Ontario Heritage Act and the Ontario Land Tribunal 
Act, 2021 to support the implementation of its housing 
strategy (see Appendix 3).
2.3 Changes to the Greenbelt
Boundary in 2022
2.3.1 Initial Proposal to Cabinet to Amend the 
Greenbelt’s Boundary
On November 2, 2022, material prepared by the 
Housing Ministry in response to the instruction pro￾vided by the Housing Ministry’s Chief of Staff, and 
signed by the Housing Minister and the Deputy Minis￾ter of the Housing Ministry, was presented to Cabinet. 
It was used to obtain approval to initiate public con￾sultation on the government’s plan to amend the 
Greenbelt’s boundary by:
• removing or re-designating 15 land sites from 
the Greenbelt (totalling approximately 7,400 
acres). The 15 sites are comprised of 22 distinct 
sections of land, including two sections of land 
The Official Plans take an average of 17–51 months 
to develop and review. This is a multi-step process that 
involves budgeting, demographic studies, a calcula￾tion of land budget (amount of land needed in relation 
to growth projections), review and feedback from the 
Housing Ministry and other ministries, time for dis￾cussion, approval and adoption by town and regional 
councils as well as input from the locally affected 
public. The Ontario public is to be consulted via the 
Environmental Registry of Ontario before the Minister 
approves an Official Plan. 
Typically, municipalities are responsible for 
reviewing and approving or rejecting development 
applications from landowners and developers. As 
shown by Appendix 2, a proposed development 
follows an 11-step application process during which 
advice and input from municipal staff, external agen￾cies, councillors and the public is sought. The Planning 
and Development Committee of a municipality issues 
a report that contains a recommendation for approval/
refusal by City Council. The decision can be appealed.
In addition, the Housing Minister can issue a Min￾ister’s Zoning Order (MZO) to override the normal 
land-use planning process, including municipal deci￾sions. MZOs are not required to be consistent with 
the Provincial Policy Statement, conform to provin￾cial plans, or follow the usual municipal planning 
processes. 
2.2.2 Housing Affordability Task Force 
Recommends Improving Land-Use Efficiency
In December 2021, the Ontario government formed 
the Housing Affordability Task Force (Task Force), 
with a mandate to provide the Housing Minister with 
solutions to Ontario’s current housing crisis. The Task 
Force concluded in its final report (published in Feb￾ruary 2022) that Ontario needs to build 1.5 million 
new homes over the next 10 years to fill the projected 
housing gap with more affordable choices to catch up 
to the rest of Canada and to keep up with population 
growth. 
The Task Force’s recommendations primarily 
focused on improving land-use efficiency by requiring  

Special Report on Changes to the Greenbelt 25
develop detailed plans to build housing and 
move forward with the project quickly. It is the 
government’s expectation that construction 
of these new homes will begin on these lands 
by no later than 2025, and that significant 
progress on approvals and implementation be 
achieved by the end of 2023.
• It is the government’s expectation that the pro￾ponents (i.e., those who submitted a proposal 
to remove land from the Greenbelt and utilize 
it for housing) would fully fund necessary 
infrastructure upfront.
• If these conditions are not met, the govern￾ment will begin the process to return the 
properties back to the Greenbelt.
The Housing Ministry conducted a 30-day consul￾tation period on the Environmental Registry, which 
is the minimum required (for further details, see 
Section 4.8). The Housing Ministry also engaged with 
a small number of the affected Indigenous commun￾ities in November 2022 (see Section 4.9).
2.3.3 Final Decision to Amend the Greenbelt 
Boundary
Following the 30-day public consultation period, the 
Housing Ministry sought final approval from Cabinet 
to amend the Greenbelt Plan, Oak Ridges Moraine 
Conservation Plan and Greenbelt boundary regula￾tion. According to the Housing Ministry, it received 
over 35,000 comments during the consultation period 
from members of the public, municipalities, Indigen￾ous communities and other stakeholders (including the 
environmental, development and agricultural sectors). 
On December 14, 2022, 10 days after the conclu￾sion of the public consultation period, the Housing 
Ministry filed O. Reg. 567/22 under the Greenbelt 
Act, 2005, and O. Reg. 568/22 under the Oak Ridges 
Moraine Conservation Act, 2001, which implemented 
the proposed Greenbelt Area boundary amendments 
for 15 land sites, and Cabinet approved Order in 
Council 1745/2022 to amend the Greenbelt Plan. The 
government made no changes as a result of the public 
consultation process. 
that were re-designated to Settlement Area 
(these are collectively referred to as “removals” 
throughout this report); 
• amending the Oak Ridges Moraine Conserva￾tion Plan (O. Reg. 140/02 under the Oak Ridges 
Moraine Conservation Act, 2001) to re-designate 
lands on one of the sites;
• adding a portion of land in the Paris Galt 
Moraine (in Wellington County) to the Greenbelt 
Plan, totalling approximately 7,000 acres; and
• making 13 additions/expansions to the Urban 
River Valley Areas in the Greenbelt, totalling 
approximately 2,400 acres. 
The material noted that the rationale for remov￾ing land from the Greenbelt was to support the 
government’s More Homes Built Faster Act, 2022. The 
Minister’s Office estimated that approximately 50,000 
new housing units would be constructed on the areas 
proposed to be removed from the Greenbelt.
2.3.2 Environmental Registry Notice and 
Consultation Period
Under the Environmental Bill of Rights, 1993 (EBR Act), 
the Housing Ministry is required to give notice on the 
Environmental Registry of Ontario (Environmental 
Registry) of changes to acts, regulations, policies or 
instruments that are environmentally significant, and 
to hold a minimum of 30 days of public consultation 
on the changes. On November 4, 2022, the Housing 
Ministry posted notices on the Environmental Regis￾try stating:
• Ontario is expected to grow by more than 
2 million people by 2031, including approxi￾mately 1.5 million people in the GGH region. 
• To accommodate that growth and support the 
building of more homes, the government is 
proposing to remove or re-designate 15 areas of 
land totalling approximately 7,400 acres from 
the edge of the Greenbelt Area that are serviced, 
or adjacent to services, and will be used to build 
housing in the near term.
• Should these lands be removed from the 
Greenbelt, the landowners will be expected to  

26
Of the 15 land sites removed from the Greenbelt’s 
development protection, at nearly 4,300 acres the 
largest site is the Duffins Rouge Agricultural Preserve 
(DRAP), accounting for approximately 58% of the 
more than 7,400 total acres removed. The Province 
made three additional decisions relating to the DRAP 
which, together, removed the primary legal protections 
from development within the DRAP overall: 
• On December 14, 2022, the Housing Minister 
filed O. Reg. 566/22 under the Planning Act, 
which revoked a 2003 Minister’s Zoning Order 
(MZO) that had restricted land use on lands in 
the DRAP to agriculture.
• Also, on December 14, 2022, on the recommen￾dation of the Housing Minister, the provincial 
government revoked the Central Pickering 
2.3.4 Land Removals and Re-designations
In December 2022, as noted previously, 15 land sites 
were removed entirely from the Greenbelt Plan or 
re-designated as Settlement Area within the Green￾belt, thereby lifting certain provincial restrictions on 
development. In this report, we use the term “land 
site” and “site” interchangeably to refer to a plot con￾taining one or more sections of land that was assessed 
for potential removal. To specify the sites chosen in fall 
of 2022 for removal and re-designation, we number 
them Site #1, Site #2 and so forth. Figure 3 pro￾vides a map pinpointing the 2022 Greenbelt land site 
removals, while more detailed maps are included in 
Appendix 4. Figure 4 provides a summary of land sites 
removed from or re-designated within the Greenbelt.
Figure 3: Locations of the 2022 Greenbelt Land Removals
Source: Ministry of Municipal Affairs and Housing 

Special Report on Changes to the Greenbelt 27
7,000-acre parcel of the Moraine to the Greenbelt, 
asserting that the land was already protected under 
other means.
3.0  Audit Objective and Scope
On January 11, 2023, the Auditor General received 
a joint letter from all three Ontario provincial oppos￾ition party leaders requesting a value-for-money audit 
and an assessment of the financial and environmental 
impacts of the government’s decision to remove lands 
from the Greenbelt. Among the concerns raised in 
the letter, the opposition leaders said “the removal 
of protections from these lands has instantly shifted 
wealth to property owners, who have likely benefited 
substantially from the rezoning of this land from 
undevelopable land to developable land.” 
The objective of our audit was to determine whether 
the Province of Ontario:
• effectively assessed the financial and environ￾mental impacts of Greenbelt boundary changes, 
and associated changes in legislation and provin￾cial plans;
• made objective, transparent and informed deci￾sions; and
• established mechanisms to measure and publicly 
report on whether changes to the Greenbelt’s 
boundary meet the Province’s stated objectives.
In planning for our work, we identified the audit 
criteria (see Appendix 5) we would use to address our 
audit objective. These criteria were established based 
on a review of applicable legislation and regulations, 
policies and procedures, internal and external studies, 
and best practices. Senior management at the Ministry 
of Municipal Affairs and Housing (Housing Ministry) 
reviewed and acknowledged our objective and associ￾ated criteria.
Our Office began our work expecting to audit the 
Housing Ministry’s processes and procedures around 
the selection of lands for removal from the Greenbelt 
and documentation on the financial and environmental 
implications that justified their selection. However, 
for certain areas of our work, including key political 
directions, there was no clear documentation and we 
Development Plan, a provincial land use plan 
that had established policies for development in 
a designated area in Central Pickering as well as 
protecting the Duffins Rouge Agricultural Pre￾serve from development.
• On December 15, 2022, the provincial gov￾ernment brought into force the Duffins Rouge 
Agricultural Preserve Repeal Act, 2022 (passed by 
the Legislature on December 8), repealing the 
Duffins Rouge Agricultural Preserve Act, 2005 and 
the protection it offered for the DRAP.
2.3.5 Greenbelt Additions 
O. Reg. 567/22 under the Greenbelt Act added an 
area of land totalling 7,000 acres from the Paris Galt 
Moraine in Wellington County to the Greenbelt, 
designated as Protected Countryside with a Natural 
Heritage System. O. Reg. 567/22 under the Greenbelt 
Act also made 13 additions/expansions of URVs to the 
Greenbelt Plan totalling approximately 2,400 acres. 
See Figure 5 for a map of the areas added to the Green￾belt Plan.
The Paris Galt Moraine is a unique landform that 
spans approximately 150 kilometres, from Caledon to 
an area southwest of Port Rowan, and is as much as 
11 kilometres wide. The Paris Galt Moraine’s rolling, 
hilly terrain is significant because it forms the head￾waters for many rivers and streams, contributes to 
filtration and storage of drinking water, provides wild￾life habitat and supports prime agricultural land. 
The Housing Ministry had sought feedback through 
the Environmental Registry from February to April 
2021 on initial areas to focus on for expanding the 
Greenbelt, including 13 new or expanded URVs and 
a study area for the entire Paris Galt Moraine, and 
received over 6,000 comments. While the comments 
were generally favourable for expanding the Greenbelt, 
municipalities, landowners in and adjacent to the Paris 
Galt Moraine study area, and the development sector in 
general raised concerns about the impact that a Green￾belt expansion in the Paris Galt Moraine area would 
have, including the potential impact on municipalities’ 
ability to accommodate population growth. Wellington 
County was not supportive of adding the particular  

28
Figure 4: Summary of Land Sites Removed from or Re-designated within the Greenbelt Area
Source of data: Ministry of Municipal Affairs and Housing
Proposed sites were initially assessed by the Greenbelt Project Team using the following three criteria. The third criterion was 
discarded for use in qualifying sites for removal:
1. Lands are adjacent to existing settlement areas
2. Adjacent to the edge of the Greenbelt Area boundary
3. Removes no Specialty Crop (SC) or Natural Heritage System lands (NHS)
Site 
#
Site Name and Size 
(% of Total Area Removed) Municipality
Site Housing 
Developer/Landowner
Criteria Met?
1 2 3 Unique Considerations
Durham Region
1 Duffins Rouge Agricultural 
Preserve (DRAP) 
“Cherrywood”
4,288.78 acres (57.86%)
Pickering TACC Development Inc. Yes Yes No Required repeal of the Duffins 
Rouge Agricultural Preserve 
Act, 2005 and the Central 
Pickering Development Plan.
2,161.41 acres of NHS 
(50.40% of site area)
2 Kingston Road and 
Highway 401
133.01 acres (1.79%)
Ajax Buena Vista 
Development Corp.
Yes Yes Yes
3 Nash Road
85.78 acres (1.16%)
Clarington Streamliner Properties Yes Yes No 21.31 acres of NHS (34.18% 
of site area)
City of Hamilton
4 Book Road
1,809.37 acres (24.41%)
Hamilton Fieldgate Homes Yes Yes No Restrictions on housing 
development from airport 
proximity.
316.89 acres of NHS 
(17.51% of site area)
5 Hamilton Mount Hope
162.77 acres (2.20%)
Hamilton Penta Properties Yes Yes Yes
6 Cline Road
73.45 acres (0.99%)
Grimsby DeSantis Homes
Melrose Investments
Valery Homes
Yes No No Removed area was made 
larger than requested to 
stretch it to the edge of the 
Greenbelt. Entirety of removal 
is a Specialty Crop area.
7 502 Winston Road
14.94 acres (0.20%)
Grimsby New Horizon 
Development Group
Yes Yes No Re-designated as Greenbelt 
Settlement Area rather than 
removed.
Entirety of re-designation is 
a Specialty Crop area and 
within the NHS.
8 Barton
9.82 acres (0.13%)
Hamilton 155090933 Ontario Inc. Yes No No Removed area was made 
larger than requested to 
stretch it to the edge of the 
Greenbelt.
Entirety of removal is a 
Specialty Crop area. 

Special Report on Changes to the Greenbelt 29
have chosen to refer this situation of non-compliance 
with the summons issued in accordance with section 11
of the Auditor General Act and under section 33 of the 
Public Inquiries Act, 2009 to the Legislature rather than 
engage in legal challenges with the developers. Should 
new or additional information come to our attention 
after the tabling of this report, the Office of the Auditor 
General of Ontario may consider whether any addi￾tional audit work is merited.
We conducted our work between January 2023 
and July 2023. We obtained written representation 
from the former Deputy Minister of Municipal Affairs 
and Housing, Assistant Deputy Minister of Municipal 
Affairs and Housing and the Deputy Minister of Natural 
Resources and Forestry that, effective August 1, 
2023, they had provided us with all the information 
they were aware of that could significantly affect 
encountered a scope limitation from having to rely 
significantly on verbal representations from the indi￾viduals we interviewed. As well, although we obtained 
large volumes of email messages, we cannot be assured 
that all relevant email messages had been retained by 
the email account owners. 
Finally, while we were able to meet with housing 
developers who benefitted from the 2022 changes 
to the Greenbelt, but with lower acreage removal, 
the housing developers associated with 92% of the 
area that was ultimately removed from the Greenbelt 
refused to meet with us. We then issued summons 
under sections 11(1) and 11(2) of the Auditor General 
Act for them to meet with us. They then sought to fight 
the issuance of the summons in the courts. 
In order to report to the Legislature in a timely 
manner on the work we have performed to date, we 
Site 
#
Site Name and Size 
(% of Total Area Removed) Municipality
Site Housing 
Developer/Landowner
Criteria Met?
1 2 3 Unique Considerations
York Region
9 Bathurst-King
655.26 acres (8.84%)
King Green Lane Bathurst 
Limited Partnership
Yes Yes No 20% re-designated as 
Greenbelt Settlement Area 
rather than removed.
222.99 acres of NHS 
(34.03% of site area)
10 Highway 48
88.34 acres (1.19%)
Markham Wyview Group Yes Yes No Entirety of removal is within 
the NHS.
11 10379 Kennedy Road
36.99 acres (0.50%)
Markham Minotar Holdings Inc.
Beechgrove Estates Inc.
Halvan 5.5 Investments 
Ltd.
Yes Yes No Entirety of removal is within 
the NHS.
12 Leslie-Elgin
15.14 acres (0.20%)
Richmond 
Hill
TACC Development Inc. Yes Yes No Entirety of removal is within 
the NHS.
13 Block 41 Lands
15.6 acres (0.21%)
Vaughan TACC Development Inc. Yes Yes No Entirety of removal is within 
the NHS.
14 11861 and 12046 
McCowan Road
12.81 acres (0.17%)
Whitchurch￾Stouffville
Torca Inc.
Flato Developments
Yes Yes No Entirety of removal is within 
the NHS.
15 19th Avenue and 
McCowan Road
10.58 acres (0.14%)
Markham Flato Upper Markham 
Village Inc.
Yes Yes No Entirety of removal is within 
the NHS.
Total 7,412.64 acres 

30
As part of our audit, we interviewed government 
political staff from the Housing Minister’s Office and 
the Office of the Premier of Ontario, and non-political 
public service staff from the Cabinet Office about their 
involvement in and knowledge of the 2022 project to 
amend the Greenbelt boundary. We also spoke with 
stakeholders, including other ministries, municipal￾ities, conservation authorities, representatives from 
Indigenous communities, environmental organizations, 
housing developers and housing industry lobbyists to 
obtain their perspectives on potential issues related to 
housing development on Greenbelt land and on their 
involvement in the 2022 project to amend the Green￾belt boundary. We also researched other jurisdictions 
to identify best practices for land-use planning and 
issues related to housing.
the findings or the conclusion of this report. We also 
obtained written representation from the Secretary 
of the Cabinet that she provided us with all the infor￾mation that she was aware of that could significantly 
affect the findings or conclusion of this report. We 
further obtained written representation from the Pre￾mier’s Chief of Staff that he provided us with all the 
information he was aware of that could significantly 
affect the findings or conclusion of this report. 
Our work was conducted primarily at the Housing 
Ministry’s head office in Toronto, and we also spoke 
with representatives from the Ministry of Natural 
Resources and Forestry at their head office in Peter￾borough. In addition, we obtained data extracts and 
supporting documentation from these locations.
Figure 5: 2022 Greenbelt Land Additions 
Source: Ministry of Municipal Affairs and Housing
Lake Ontario
Existing Urban River Valley
Protected Countryside
Niagara Escarpment Plan Area
Oak Ridges Moraine Area
Greenbelt Area Boundary
Upper and Single Tier Municipal Boundaries
2022 Greenbelt Additions 

Special Report on Changes to the Greenbelt 31
Ontario over the following 10 years. We found that the 
Housing Ministry had already allocated the entirety 
of the 1.5-million-unit housing target to Ontario’s 
municipalities in October 2022—one month before 
the government’s November 2022 proposal to remove 
land sites from the Greenbelt. The Ministry’s team 
(below Director level) that allocated these housing 
targets confirmed to us that it had no knowledge that 
lands from the Greenbelt would be opened for housing 
development.
The February 2022 report produced by the Task 
Force indicated that “a shortage of land isn’t the cause 
of the problem. Land is available, both inside the exist￾ing built-up areas and on undeveloped land outside 
greenbelts.” Further, the Task Force’s report reinforced 
the point that “greenbelts and other environmentally 
sensitive areas must be protected.”
We reviewed other recent reports on the subject 
and spoke with various subject matter experts across 
Ontario’s municipalities to obtain their views on 
whether land from the Greenbelt is needed to solve 
Ontario’s housing challenges. For example, we spoke 
with the Chief Planners at the three regions where 
all 15 land sites were removed from the Greenbelt 
in December 2022 (Durham, Hamilton and York). 
They informed us that sufficiently serviced (or more 
easily serviceable) land is already available to meet 
the housing targets assigned to them by the Housing 
Ministry. The Chief Planners we spoke to also high￾lighted that the land sites removed from the Greenbelt 
in December 2022 were largely not serviced, were not 
in their servicing plans, and that many of the land sites 
would be challenging to prioritize and service in the 
near future, with some taking potentially 10 or more 
years to accomplish. 
Further, the Association of Municipalities of 
Ontario, which represents Ontario’s 444 municipal￾ities, told us that while it recognizes that housing 
supply is a challenge in Ontario, a shortage of land is 
not the issue. 
Finally, the Regional Planning Commissioners of 
Ontario (RPCO), a group of senior municipal planning 
leaders from across Ontario, released a report in March 
2023 that indicated that large Ontario municipalities 
We conducted our work and reported on the 
results of our examination in accordance with the 
applicable Canadian Standards on Assurance Engage￾ments—Direct Engagements, issued by the Auditing 
and Assurance Standards Board of the Chartered 
Professional Accountants of Canada. This included 
obtaining a reasonable level of assurance. The Office 
of the Auditor General of Ontario applies the Can￾adian Standards on Quality Management and, as a 
result, maintains a comprehensive system of quality 
management that includes documented policies and 
procedures with respect to compliance with rules 
of professional conduct, professional standards and 
applicable legal and regulatory requirements.
We have complied with the independence and 
other ethical requirements of the Code of Professional 
Conduct of the Chartered Professional Accountants of 
Ontario, which are founded on fundamental principles 
of integrity, objectivity, professional competence and 
due care, confidentiality and professional behaviour.
4.0  Detailed Audit Observations
4.1 Government-Imposed Greenbelt
Removals Proceeded Without
Evidence They Were Needed to Meet
Housing Goals
The government’s reported rationale for removing 
or re-designating 15 land sites from the Greenbelt in 
December 2022 was to support its goal of building 
1.5 million homes over the next 10 years. Our audit 
found that the Greenbelt Project Team—the six-person 
team of non-political public servants assembled to 
assess specific land sites in the Greenbelt for possible 
removal—was not asked to assess whether the avail￾ability and suitability of land outside the Greenbelt was 
sufficient for achieving the Province’s housing goals.
As described in Section 2.2.2, the provincial 
government had already adopted the Housing Afford￾ability Task Force’s (Task Force) report as its primary 
housing strategy, including the Task Force’s recom￾mended goal to build 1.5 million housing units in  

32
adjustments to specific sites. The Housing Ministry 
highlighted that a site-specific review carried a much 
higher risk of negative public and stakeholder reaction 
and would be more limited in its potential to meet the 
government’s priorities. 
The Housing Minister’s Chief of Staff informed the 
Housing Ministry on September 16 that the govern￾ment wished to initiate a site-specific review. This 
decision ultimately facilitated a focus on only specific 
developers’ land sites. Housing Ministry staff informed 
us that, at this time, the Chief of Staff also com￾municated three priority sites for consideration that 
included “Cherrywood, a site in King Township, and 
possibly a site near Hamilton airport”—which, through 
our work, we determined most likely to be Sites #1, 
#9 and #4 respectively in Figure 4. Ultimately, these 
three sites accounted for 91% of land removed from the 
Greenbelt in December 2022. 
In the first week of October 2022, the Chief of Staff 
to the Housing Minister instructed the Housing Deputy 
Minister to assemble a small team of six to 10 public 
servants to assess specific land sites in the Greenbelt 
for possible removal from the Greenbelt Area, and to 
identify land that could be added to offset the lands 
removed (see Section 2.1.2). The Deputy Minister 
assembled a team of six people (Greenbelt Project 
Team) that included members of the Housing Min￾istry’s Planning and Growth Division and its Assistant 
Deputy Minister. 
During the process, the Housing Deputy Minister 
believed that the Chief of Staff was working under the 
authority of the Housing Minister and the Premier’s 
Office. Typically, a Chief of Staff works under the 
authority of a minister and the Premier’s Office. Con￾sequently, the ministry’s non-political public service 
staff believed that directions or instructions provided 
by the Housing Minister’s Chief of Staff were provided 
under the authority of the Housing Minister and the 
Premier’s Office.
The Housing Minister’s Chief of Staff imposed 
restrictions by requesting higher security measures that 
limited the Greenbelt Project Team’s ability to follow 
processes that were used previously when conducting 
their work prior to recommending alterations to the 
already have 85% of the 1.5 million housing units in 
their approval pipelines. The remaining 15% of the 
Housing Ministry’s allocation will eventually be in the 
pipeline on non-Greenbelt land. If smaller munici￾palities are taken into account, the entire 1.5-million 
housing unit target will likely be exceeded by housing 
units already in the approval pipeline. The report 
stated: “RPCO continues to not support in principle the 
removal of lands from the Greenbelt as a necessary step 
to address Ontario’s housing needs.”
4.2 The Selection of Land Sites for
Removal from the Greenbelt was
Biased and Lacked Transparency
4.2.1 The Housing Minister’s Chief of Staff 
Directed the Greenbelt Project Team and 
Provided the Initial Criteria Used to Assess 
Greenbelt Land Site Removals
Following the June 2, 2022, general election, the 
Premier directed the Minister of Municipal Affairs 
and Housing (Housing Minister) in a mandate letter 
dated June 29, 2022, to “complete work to codify 
processes for swaps, expansions, contractions and 
policy updates for the Greenbelt.” The mandate letter 
also specified that this should “include a compre￾hensive plan to expand and protect the Greenbelt.” 
The Premier specified the work should be done “in 
Fall 2022.” The Chief of Staff of the Housing Ministry 
was given the responsibility by the Premier’s Office to 
direct a project to change the Greenbelt’s boundary. 
In response, in August 2022, the Housing Minister’s 
Chief of Staff requested information from the Housing 
Ministry’s public service staff on policy options that 
the government could explore for making changes to 
the Greenbelt. (See Appendix 1 for the Timeline of 
Key Events.)
In August 2022, Housing Ministry public service 
staff provided the Housing Minister’s Chief of Staff 
with options on approaches the government could take 
to make changes to the Greenbelt. The two options 
provided by the Housing Ministry’s public service staff 
were to: conduct a system-wide review or to conduct 
a site-specific review that only considered boundary  

Special Report on Changes to the Greenbelt 33
When we asked the current and former Chiefs of 
Staff from the Premier’s Office about the time frame, 
both indicated that no time pressure had been imposed 
by the Premier’s Office to complete the Greenbelt 
boundary changes.
4.2.2 Housing Minister’s Chief of Staff Provided 
the Greenbelt Project Team with All but One of 
the 22 Greenbelt Sites Assessed for Removal 
In the first week of October 2022, the Housing Minis￾ter’s Chief of Staff provided the Deputy Minister and 
the Ministry’s Greenbelt Project Team with an initial 
list of eight land sites that could potentially be removed 
from the Greenbelt, as well as criteria for the team to 
use to assess the sites. (See Section 4.2.4 for a fuller 
description of how the land-assessment criteria were 
chosen and then modified.)
The Housing Minister’s Chief of Staff also asked 
the Greenbelt Project Team to identify any other 
land sites that may meet the criteria for removal. The 
Greenbelt Project Team told us that it advised the 
Housing Minister’s Chief of Staff that a comprehensive 
assessment of other sites would take longer than the 
three-week time duration given by the Chief of Staff 
to conduct the work. As a result, the Greenbelt Project 
Team identified just one additional land site (Site #11 
in Figure 4) to be considered for removal. This site 
was selected because it had already been assessed in 
detail by the Housing Ministry in relation to a litiga￾tion matter. In contrast to what the Greenbelt Project 
Team told us, the Housing Minister’s Chief of Staff told 
us he was under the impression the Greenbelt Project 
Team undertook a review of sites other than those he 
provided.
After beginning its work, the Greenbelt Project 
Team determined that the initial hardcopy informa￾tion the Housing Ministry’s Chief of Staff had provided 
about the eight land sites proposed for removal (Sites 
#1, #3, #4, #9, #12, #14, #15 and one additional site 
that was not selected for removal) was insufficient for 
them to map and assess. The Greenbelt Project Team 
signed confidentiality agreements. While this would 
not have prohibited conversations with outside parties 
Greenbelt boundary. For instance, the Housing Minis￾ter’s Chief of Staff directed the Greenbelt Project Team 
not to disclose information related to the Greenbelt 
Project to any external group, and required the team 
members to sign security attestation forms confirming 
their understanding. We found this limitation ham￾pered the Greenbelt Project Team’s ability to complete 
a thorough analysis of the Greenbelt sites.
The Housing Minister’s Chief of Staff instructed the 
Greenbelt Project Team to complete the site assess￾ment portion of the project within less than four weeks 
of providing the initial site-specific information on 
October 6, 2022 (although the overall project timeline 
was about 10 to 11 weeks) so that the announce￾ment of consultation on the proposed Greenbelt 
land removals and additions could coincide with the 
Government’s fall housing legislation, which would 
be known as Bill 23, the More Homes Built Faster Act, 
2022. Within this three-week window, the Housing 
Minister’s Chief of Staff provided the initial criteria to 
the Greenbelt Project Team (see Figure 6). The Green￾belt Project Team was required to conduct a review of 
land sites to be added and removed, prepare a proposal 
to Cabinet (described in Section 2.3.1) and prepare 
required Environmental Registry notices (described in 
Section 2.3.2). 
The Housing Ministry’s Market Housing Division, 
which generally oversees the implementation of 
housing bills, told us that the provincial government 
intends to release housing bills on at least an annual 
basis, such as one that was introduced in spring 2023. 
Therefore, the 2022 efforts to change the Green￾belt’s boundary could have been delayed to coincide 
with a subsequent housing bill. Moreover, because 
Greenbelt boundary amendments are made by regu￾lation, changes can be made—with sufficient public 
consultation under the Environmental Bill of Rights, 
1993—independent of the Legislative Assembly’s 
schedule of legislative business. There was no specific 
requirement that the removal of the 15 land sites 
through amending regulations (O. Reg. 567/22 under 
the Greenbelt Act, 2005 and O. Reg. 568/22 under the 
Oak Ridges Moraine Conservation Act, 2001) had to be 
part of the government’s legislative changes in late 
2022.  

34
Figure 6: Evolution of the Criteria for Removing Land Sites from the Greenbelt in 2022
Source: Ministry of Municipal Affairs and Housing
Subject Area of Criterion
Initial Criteria Provided by
Housing Minister’s Chief of Staff
Criteria Used to
Assess Sites for Removal
Criteria Included in First Cabinet
Submission1
Criteria Posted in Environmental
Registry Notice and Listed in
Second Cabinet Submission2
Next to an urban area ü Adjacent to an existing (developed) 
urban area
ü Lands are adjacent to existing 
settlement areas3
ü Adjacent to existing 
settlement areas
ü Adjacent to existing 
settlement areas
On edge of the Greenbelt ü On the edge of the existing 
Greenbelt Plan
ü Adjacent to the edge of the 
Greenbelt Area boundary3
ü Adjacent to the edge of the 
Greenbelt area boundary
ü Adjacent to the edge of the 
Greenbelt area boundary
Not part of Natural
Heritage System
or Specialty Crop
designations
ü Lands are not in a specialty crop area 
or part of a natural heritage system
ü Removes no specialty crop or 
Natural Heritage Lands4
Dropped after assessment 
showed that 19 of 22 sites 
did not meet criterion
Lands are serviceable ü Lands must have the following services 
available: municipal and regional roads; 
sanitary trunk mains; regional trunk 
water mains; gas mains, utilities (hydro 
communications)
ü Lands have the potential ability 
to be serviced in near-term with 
local infrastructure upgrades 
to be entirely funded by 
proponents5 ü Areas can connect to the larger regional 
infrastructure system
ü Site has been identified as 
having potential to yield 
housing, with potential ability to 
service in near future5 Lands have characteristics to enable housing to be
built in near-term
ü Capacity exists (or can be made to 
exist) in systems to accommodate 
potential growth
ü Lands proposed for removal 
have the characteristics that 
would enable housing to be 
built in the near-term5
ü Transit infrastructure (i.e., station(s), 
transit route(s) (existing and planned))
ü Schools nearby to accommodate 
growth
ü Police and fire protection services 
currently available
Infill would complete
existing neighbourhoods/
communities
ü Infill that would complete existing 
neighbourhoods and communities 
(nice to have)
Ratio of Greenbelt
additions to removals6
ü Greater than 1:1 offset must 
be achieved to ensure overall 
Greenbelt expansion
1. Cabinet Submission of November 2, 2022.
2. Cabinet Submission of December 14, 2022.
3. These criteria were used instead of assessing whether the lands have the potential to be serviced in the near-term with local infrastructure, and have the characteristics that would enable housing to be built in the near-term.
4. Information included in briefings to the Housing Minister and the Premier’s Office (excluding the Premier) stated that 13 of 15 land sites did not meet this criterion. 
The November 2, 2002 Cabinet submission identified which sites had specialty crop or natural heritage system lands, although it was not used as a criterion for decision-making.
5. These criteria were not assessed by the Greenbelt Project Team.
6. This factor was considered in aggregate throughout the assessment of sites, given the requirement in the Greenbelt Act, 2005 not to reduce the total Greenbelt Area. 

Special Report on Changes to the Greenbelt 35
4.2.3 About 92% of the Acreage Ultimately 
Removed from the Greenbelt Was Land Sites 
Passed on to the Housing Minister’s Chief of 
Staff from Two Developers, Including a Land Site 
Associated With a Third Developer
We asked the Housing Minister’s Chief of Staff how 
he selected the initial eight land sites (described in 
Section 4.2.2) provided to the Greenbelt Project 
Team to be assessed for removal from the Greenbelt. 
The Chief of Staff to the Housing Minister, who was 
appointed by the Premier’s Office in July 2022 to this 
position, indicated that he regularly attends industry 
events and meets with housing developers and their 
representatives, who at times pass along information 
about land that they recommend the Ministry consider 
removing from the Greenbelt. 
For example, the Chief of Staff indicated that while 
attending the Building Industry and Land Development 
Association’s (BILD) Chair’s Dinner on September 14, 
2022, two prominent housing developers approached 
him and gave him packages containing information 
to remove two land sites from the Greenbelt: the 
Duffins Rouge Agricultural Preserve (DRAP) land site 
in Durham Region (Site #1 in Figure 4 and described 
in Section 2.1.5) and the Bathurst-King land site in 
the York Region (Site #9). The Chief of Staff sat at the 
same dinner table with one of these two developers. 
After the event, during the course of the Greenbelt 
Project, the Housing Minister’s Chief of Staff indicated 
that the developer for the DRAP site provided him with 
information and requests to also remove the Book Road 
site in the City of Hamilton (Site #4), Leslie-Elgin site 
in the York Region (Site #12) and the Block 41 Lands 
site in the York Region (Site #13) from the Green￾belt. Altogether, those who had access to the Chief of 
Staff at the September BILD event ended up with land 
removals that accounted for 6,784 acres, or 92% (see 
Figure 7) of the 7,412.64 acres ultimately removed 
from the Greenbelt in December 2022. 
The Housing Minister’s Chief of Staff told us 
that whenever he received any packages, he did not 
immediately open them and review their contents. He 
said that, instead, he kept them in a stack in his office, 
with permission, those conversations did not occur. 
The Chief of Staff subsequently obtained detailed maps 
and other information from the site proponents (i.e., 
the sites’ owners, developers or their representatives) 
including other potential sites for removal and pro￾vided this to the Greenbelt Project Team on five USB 
keys throughout the three-week project.
The Housing Minister’s Chief of Staff then person￾ally reached out to the lands’ proponents throughout 
October 2022, requesting and receiving the additional 
information. Through these exchanges, proponents 
not only provided the requested information but also 
suggested the removal of three additional sites (Sites 
#4, #12 and #13). In all, the Chief of Staff provided 13 
additional sites to the Greenbelt Project Team for con￾sideration (Sites #2, #5, #6, #7, #8, #10, #13 and six 
additional sites that were not selected for removal). By 
the time the selection of land sites for removal from the 
Greenbelt was made at the end of October, 21 of the 22 
Greenbelt sites that were considered for removal had 
been provided directly by the Housing Minister’s Chief 
of Staff. 
The Housing Minister’s Chief of Staff told us that 
nine sites were brought to his attention by developers 
or their representatives (Sites #1, #3, #4, #9, #10, 
#12, #13, #14 and #15); five additional sites were 
identified by another political staff member in the 
Minister’s Office who was working on the Housing Min￾istry’s consultation on its review of municipal Official 
Plans (Sites #6, #7, #8 and two additional sites that 
were not selected for removal); one site was identi￾fied by the Greenbelt Project Team (Site #11); and the 
Housing Minister’s Chief of Staff could not recall how 
and from whom he received information on the addi￾tional seven sites that were part of the 22 sites being 
considered (Sites #2, #5 and five additional sites that 
were not selected for removal). 
Over the course of the project, 93 confidentiality 
agreements were signed (the majority of which were 
signed after sites were recommended for removal), 
including with individuals in various relevant minis￾tries who were involved in consultations or reviewed 
materials as the project developed. 

36
properties, and providing the Greenbelt Project Team 
with 21 of the 22 land sites to consider for removal, 
the Housing Minister’s Chief of Staff also provided the 
team with the initial criteria for discussion for use to 
assess the lands for potential removal.
These draft criteria, which the Housing Minister’s 
Chief of Staff provided to the Greenbelt Project Team 
on October 6, 2022, initially included criteria related to 
the location of the land in the Greenbelt and whether 
the sites already had, or were near, available municipal 
services (including roads, transit, utilities, schools and 
emergency services), or had developed plans to build 
the infrastructure. In addition, these criteria included 
provisions intended to protect the Natural Heritage 
System and specialty agricultural crops in the Green￾belt. See Figure 6 for a listing of the initial criteria. 
During its work in October 2022, the Greenbelt 
Project Team provided regular updates (at least once 
per week) to the Housing Minister’s Chief of Staff, 
which included the team’s assessment of how closely 
each of the land sites met the specific criteria. The 
Greenbelt Project Team typically received information 
from the Chief of Staff between the update meet￾ings, including additional sites to consider, eventually 
assessing 22 sites in total. In the course of this work, 
the Greenbelt Project Team determined that 20 out 
of the 22 land sites considered for removal (or 13 out 
of the 15 ultimately removed) either did not meet all 
adding new packages to the stack as he received them 
from developers and their representatives. He also 
noted that he did not tell the developers and land￾owners that the government was considering removing 
land from the Greenbelt, but would consider the 
requests if it decided to do so. 
The Housing Minister’s Chief of Staff provided hard￾copy information from packages he received on eight 
sites to the Greenbelt Project Team on October 6, 2022. 
At that time, the information provided did not include 
Site #13. However, it did include information on Sites 
#14 and #15, which was received by email directly 
from the representative of two developers. Of the eight 
folders containing information related to the land sites 
to be assessed for removal by the Greenbelt Project 
Team, seven sites (Sites #1, #3, #4, #9, #12, #14 and 
#15) were ultimately chosen for removal. These seven 
land sites accounted for 93%, or about 6,900 acres, of 
the 7,412.64 acres of land removed from the Greenbelt 
in December 2022. The eighth site was not chosen 
for removal because it did not meet the assessment 
criteria.
4.2.4 Criteria to Assess Land Were Altered and 
Facilitated Their Removal
In addition to directing Housing Ministry public service 
staff to conduct a site-specific review of identified 
Figure 7: Housing Developers for the Most Land (by Area) Removed from the Greenbelt in 2022
Prepared by the Office of the Auditor General of Ontario
Site Housing Developer Site # Municipality Site Name, Acreage % of Total
TACC Development Inc. 1 Pickering Duffins Rouge Agricultural Preserve
4,288.78 acres 
57.86
12 Richmond Hill Leslie-Elgin
15.14 acres
 0.20
13 Vaughan Block 41 Lands
15.60 acres
 0.21
TotalTACC Development Inc. 58.27
Fieldgate Homes 4 Hamilton Book Road
1,809.37 acres
 24.41
Green Lane Bathurst 
Limited Partnership
9 King Bathurst-King
655.26 acres
8.84
TotalTop Three Developers 91.52 

Special Report on Changes to the Greenbelt 37
designated Specialty Crop lands. Figure 6 shows how 
the criteria for assessment evolved. Ultimately, based 
on the Greenbelt Project Team’s assessment, 13 of the 
15 land sites removed from the Greenbelt contained 
Natural Heritage System lands and/or were designated 
as Specialty Crop lands.
In addition, alterations to boundaries and/or land 
designations were made to proposed sites so that they 
would better align with the criterion that required 
sites to be on the edge of the existing Greenbelt. This 
criterion was designed to prevent the creation of new 
pockets of urbanized areas within the Greenbelt’s pro￾tected boundaries. In its work, the Greenbelt Project 
Team determined that the removal of eight of the 22 
sites would have created isolated pockets of housing 
development within the Greenbelt. In response, the 
Greenbelt Project Team provided suggestions on 
how the boundaries and/or designations of land on 
these sites could be altered to meet this criterion. The 
Housing Minister’s Chief of Staff subsequently directed 
the Greenbelt Project Team to make changes to the 
maps for four of the sites. The changes made were as 
follows:
• The boundaries of two of the land sites (Sites #6 
and #8 in Figure 4) that were not on the edge 
of the Greenbelt were expanded beyond the 
original area proposed for removal in order to 
connect with the Greenbelt’s edge. This affected 
other landowners who did not request that their 
lands be removed from the Greenbelt.
• Two sites (Sites #7 and #9 in Figure 4) were 
re-designated from Protected Countryside to 
Settlement Area within the Greenbelt Area (for 
Site #9, the re-designation was within the Oak 
Ridges Moraine Conservation Plan, specifically), 
effectively allowing for housing development to 
occur within the Greenbelt Area boundary.
Ultimately, based on the Greenbelt Project Team’s 
final assessment, the Housing Minister’s Chief of Staff 
gave direction to proceed to seek Cabinet approval for 
the proposed removal of 15 of the 22 land sites. 
Of the seven sites that were assessed but not pro￾posed for removal from the Greenbelt, three did not 
meet the criterion to be on the edge of the Greenbelt, 
criteria, or the team could not determine whether the 
sites met certain criteria because of the three-week 
time frame and the restrictions on whom they could 
consult.
For instance, the Greenbelt Project Team informed 
the Housing Minister’s Chief of Staff that they could 
not assess infrastructure services within a three-week 
time frame and without contacting external parties, 
such as municipalities, to obtain or confirm details 
on existing and planned infrastructure services. The 
Greenbelt Project Team proposed to assess how easily 
the land sites could be serviced and connected to exist￾ing infrastructure by instead determining whether the 
sites lay adjacent to a developed urban area. The Chief 
of Staff accepted this limitation and simplified the 
criteria.
As another example, most of the 22 land sites 
considered for potential removal failed the only 
environmental and agricultural criterion, namely, that 
the site did not contain land designated as Specialty 
Crop or Natural Heritage System lands. This criterion 
was intended to consider the presence of the Natural 
Heritage System and specialty agricultural crop lands 
(see Section 2.1.2) in the Greenbelt. In fact, the Green￾belt Project Team determined that 19 of the 22 land 
sites were indeed part of the Natural Heritage System 
and/or had land designated as Specialty Crop lands 
and therefore did not meet this criterion.
In mid-October, the Greenbelt Project Team com￾municated to the Chief of Staff that many of the 22 
land sites did not meet the environmental/agricul￾tural criterion for removal. He provided direction to 
drop this criterion. The exclusion of this criterion was 
not mentioned in the Housing Ministry’s information 
provided to Cabinet, nor was it listed in the Housing 
Ministry’s proposal notice posted on the Environmental 
Registry of Ontario. However, on October 26, the Min￾ister of Housing was informed by Housing Ministry 
officials that lands being proposed for removal included 
acreage that was subject to Natural Heritage System 
and Specialty Crop designations. On October 27, the 
same information was presented to the Premier’s Office 
staff. On November 2, Cabinet materials identified 
which sites contained Natural Heritage System and/or  

38
late 2022) to remove land from the Greenbelt between 
February 2005, when the Greenbelt was established, 
up until the end of the public consultation to amend 
the Greenbelt boundary in late 2022. (See Figure 8
for the number of removal requests received by the 
Housing Ministry related to the Greenbelt.) However, 
the Housing Ministry’s Greenbelt Project Team only 
assessed 22 land sites for removal, 21 of which were 
provided by the Housing Minister’s Chief of Staff. The 
Ministry did not assess any of the 130 requests received 
during the public consultation to amend the Greenbelt 
in 2022. Had they considered removing any of the land 
stemming from these requests, the Ministry would have 
had to post their potential removal on the Environ￾mental Registry for a minimum of an additional 30 
days as required under the EBR Act as well as details of 
the related regulatory change.
As discussed in Section 2.1.2, the Greenbelt was 
established to give permanent protection to agricul￾tural land and natural features that sustain ecological 
and human health in the GGH area. However, accord￾ing to the Housing Chief of Staff, this Greenbelt 
removal project was intended to be the first of many 
future rounds to remove land from the Greenbelt; other 
landowners would have an opportunity to request that 
and site removal for the other four would have required 
approvals under the Niagara Escarpment Plan or 
legislative changes deemed outside the scope of the 
Greenbelt Project. Although these seven sites were not 
proposed to be removed from the Greenbelt in 2022, 
political staff in the Minister’s Office advised us they 
were pursuing the possibility of having one site in Pick￾ering (Tribute Homes) to be made available for housing 
development through other means.
The Greenbelt Project Team provided briefings to 
the Housing Minister and other political staff in the 
Minister’s Office (on October 26 and November 1, 
2022). At these meetings, the Housing Minister 
reviewed the sites proposed for removal, and we were 
advised that the Minister agreed with the Green￾belt Project Team’s suggested minor changes to the 
boundaries of Site #11 (see Figure 4) to exclude a 
provincially significant wetland. The Greenbelt Project 
Team also provided briefings to the Premier’s Office 
political staff (on October 27 and 31, 2022) on the 
removal of land from the Greenbelt. However, these 
meetings did not include the Premier.
The Premier stated that he did not know which 
land sites were going to be removed before he was 
briefed and shown the lands sites for removal on Nov￾ember 1, 2022, a day before the proposal was provided 
to Cabinet for approval on November 2, 2022. He also 
indicated that he had not had any conversations with 
developers or their representatives about the govern￾ment’s changed plans to remove land sites from the 
Greenbelt, nor did he instruct political or non-political 
staff to have certain land sites removed from the 
Greenbelt.
4.2.5 Government Has Not Been Publicly 
Transparent About How It Is Carrying Out 
Greenbelt Land Removals
As noted in Sections 4.2.2 and 4.2.3, the 2022 project 
to remove land from the Greenbelt was not open to all 
landowners. The Housing Ministry received approxi￾mately 630 requests (including the 130 requests 
received during the public consultation period in 
Figure 8: Number of Removal Requests Received by 
the Housing Ministry Related to the Greenbelt Area
Source of data: Ministry of Municipal Affairs and Housing
Time Frame
Estimated Number 
of Requests 
Received1
As of 2017 
(at 10-year review) 490
January 2018 to November 2022 10
November to December 2022
(during Greenbelt Environmental 
Registry consultation)
130
Total 6302
1. Estimated based on Housing Ministry request logs, net of identified 
duplicate requests (e.g., multiple requests for same property at different 
times or by different individuals). Excludes 32 requests received prior 
to 2005.
2. Estimated number of removals also includes proposed land-swaps and re￾designations. 

Special Report on Changes to the Greenbelt 39
boundary. In particular, the Greenbelt Act explicitly 
prohibits any amendment that would reduce the total 
land area of the Greenbelt Area. 
The Greenbelt Plan, established in 2005 by order of 
the Lieutenant Governor in Council under the Green￾belt Act, sets out the vision and goals of the Greenbelt 
and provides additional policy direction regarding the 
processes and principles for growing the Greenbelt 
Area.
Notably, while the Greenbelt Act implicitly allows 
for some lands to be removed from the Greenbelt Area 
(provided that other lands are added to ensure the 
total land area of the Greenbelt Area is not reduced) 
the Greenbelt Plan repeatedly states that the Greenbelt 
is to provide “permanent” protection to the natural fea￾tures and areas and agricultural lands included in the 
Greenbelt. The Greenbelt Plan also states that the Prov￾ince must lead a process, working with municipalities, 
conservation authorities and other key stakeholders, to 
identify potential lands to be added and to consider the 
ecological and hydrological significance of potential 
lands and their connection with existing agricultural 
and natural features in the Greenbelt.
We found that the 2022 amendments to remove 
land from the Greenbelt were inconsistent with the 
processes and principles that are set out in the Green￾belt Plan for amending the Greenbelt boundaries. In 
sharp contrast to previous Greenbelt amendments, the 
2022 undertaking to identify lands to be removed was 
not based on the guiding factors, vision and goals set 
out in the Plan and did not involve collaboration with 
key stakeholders. 
The process used in 2017 for amending the bound￾ary of the Greenbelt involved: 
• land removals of approximately 370 acres (see 
Figure 2) in areas where development was 
already approved and in progress before the 
Greenbelt’s creation or where more precise 
measurements of the Natural Heritage System 
could allow for minor refinement of the bound￾ary without affecting environmental features; 
• an expert advisory panel to provide recommen￾dations that were used to guide the amendment 
process and ensure decisions aligned with 
the objectives of the Greenbelt Plan, such as 
their land be assessed for removal in future rounds; 
and this was an initial attempt to put in place a con￾tinuous process that would be evaluated and revised 
based on lessons learned. While the Chief of Staff of 
the Premier’s Office confirmed the intention was to 
continue with future land removal from the Greenbelt 
and that the 2022 process to alter the boundaries of 
the Greenbelt had not been intended to be a one-time 
exercise, the Premier’s Office’s political policy staff and 
the Housing Minister told us that there is no current 
intention to prepare for a second round of land site 
removals, and that the government’s focus was on fol￾lowing through with the housing development of the 
areas already removed from the Greenbelt in 2022.
The provincial government has not transparently 
communicated with the public about how, if or when 
it may be carrying out future land removals from the 
Greenbelt. The housing developers, industry represent￾atives and lobbyists we spoke to during the course of 
our work told us that they had received no messaging 
from the government about plans for future removals. 
These same housing developers (including a few who 
directly benefitted from the land removals in 2022, see 
Section 4.6.1), and industry representatives, recom￾mended that any future process to remove land from 
the Greenbelt be transparent and open to all eligible 
landowners.
We noted that the last time land was removed from 
the Greenbelt was in 2017, as part of a required review 
of the Greenbelt Plan (described in Section 2.1.6). In 
contrast to what occurred in 2022, in 2017 the Housing 
Ministry engaged in a public consultation that began in 
2015 and that, among other things, elicited requests for 
lands to be removed from the Greenbelt. The Housing 
Ministry assessed all of the approximately 500 requests 
it had received to that date before making decisions to 
post any proposed Greenbelt boundary amendment.
4.3 The 2022 Greenbelt Boundary
Changes Were Inconsistent with the
Greenbelt Plan’s Vision and Goals,
and Deviated from Previous Processes
The Greenbelt Act, 2005 (Greenbelt Act) sets out the 
legislated process for amending the Greenbelt Plan and  

40
While the proposal did identify several risks relating 
to the limitations of the project and the Housing Min￾istry’s involvement, the identified risks did not provide 
sufficient detail for decision-makers to understand the 
nature of the project. Some of the risks stated in the 
proposal were:
• Over 700 requests were submitted by land￾owners to remove land from the Greenbelt, and 
the government may face criticism for a lack of 
transparency in how the sites were selected for 
assessment.
• The Housing Ministry’s assessment of site poten￾tial for infrastructure serviceability consisted of 
a review of a visual map of the proposed sites 
to assess their proximity to already-developed 
areas and whether they were on the edge of the 
Greenbelt.
• The Housing Ministry noted there was a risk 
that municipalities will be unable or unwilling to 
provide servicing to the land sites proposed for 
removal from the Greenbelt.
We spoke with the Premier, the Housing Minister and 
political staff in the Premier’s Office (including the 
current and former Chiefs of Staff) as well as public 
service staff in the Cabinet Office (including the Sec￾retary of the Cabinet), who reviewed the Greenbelt 
proposal that was ultimately provided to Cabinet. They 
expressed different understandings of the site-selection 
process than what actually took place. Their various 
understandings were as follows:
• either all or most of the land sites assessed for 
removal were proposed by Housing Ministry 
staff, rather than political staff in the Housing 
Minister’s Office, as described in Section 4.2.2;
• the Housing Ministry controlled the develop￾ment of the criteria used to assess sites for 
removal (see Section 4.2.4);
• additional sites in the Greenbelt that may have 
met the criteria were considered, rather than 
just 22 sites as described in Section 4.2.4; and
• the 15 land sites ultimately removed from the 
Greenbelt could be serviced in the near term. 
Political staff in the Premier’s Office told us that 
the Housing Minister’s Office was “certain” that 
avoiding fragmenting farmland and using a 
broader “systems approach” to protect natural 
features as well as important linkage areas; 
• a technical working group with partner minis￾tries to determine whether and where boundary 
refinements to the Natural Heritage System were 
appropriate based on the available data; and
• a review process during which the Housing Min￾istry also engaged with stakeholders, experts 
and partner ministries to identify the natural 
features and functions of areas being considered 
for removal, including land use, surface and 
groundwater features, significant wildlife habitat 
and linkages, wetlands, species at risk and prime 
agricultural land.
Further, while the 2022 amendments resulted in a 
net expansion to the Greenbelt of about 2,000 acres, 
the removal of 7,400 acres of lands is contrary to the 
overarching purpose of the Greenbelt Plan—to provide 
for the permanent protection of agricultural land and 
natural areas and features.
4.4 The Proposal to Cabinet Did Not
Clearly Explain How Land Sites Were
Identified, Assessed and Selected for
Removal from the Greenbelt
The proposal the Minister and Deputy Minister of 
Municipal Affairs and Housing provided to Cabinet to 
alter the Greenbelt’s boundaries did not clearly explain 
how the land sites were identified, assessed and 
selected for removal. Specifically, it did not explain that 
the Chief of Staff in the Housing Minister’s Office:
• identified and presented 21 of the 22 land sites 
for consideration to the Greenbelt Project Team. 
Instead, the proposal informed decision-makers 
that the “Government” had identified the land 
sites, which was intended by the author to 
communicate that political staff rather than non￾political staff had identified the land sites;
• drafted the initial criteria that were used to 
assess the land sites for removal; and
• made the decision to drop criteria that certain 
proposed sites did not meet (see Figure 6).  

Special Report on Changes to the Greenbelt 41
that non-political public service staff and Housing Min￾ister’s Office political staff did not flag these issues to 
the Secretary of the Cabinet or to the Premier’s Office 
during the course of the work. 
We were advised by the Secretary of the Cabinet 
that there are commonly used processes in the develop￾ment of information for Cabinet decision-making to 
share awareness of project and/or policy risks, limita￾tions and other concerns, or to confirm a common 
understanding of approach and direction beyond the 
ministry, including with Cabinet Office and the Pre￾mier’s Office. In this respect, we were advised that the 
non-political public service and/or political staff do, 
for example, convene “multi-corner” meetings whereby 
ministry non-political public service staff, Minister’s 
Office political staff and the Premier’s Office political 
staff collectively review initiatives/projects and discuss 
approaches to policy/project work and related risks 
and mitigations.
We noted that, even though it is a best practice 
to consult with the Secretary of the Cabinet (who 
oversees all Deputy Ministers) on politically sensitive 
matters, the Deputy Minister did not choose to do so 
in this case. She was not restricted by political staff 
from doing this. On reflection, she indicated that in 
the future she would consult with the Secretary of the 
Cabinet on politically sensitive matters. 
Ontario has no process in place to transparently 
identify and address instances where senior public 
service ministry staff are not in agreement or have con￾cerns with the direction provided by a minister. In the 
United Kingdom, the HM Treasury’s handbook, Manag￾ing Public Money, sets out four standards by which all 
public money must be handled: regularity (compliance 
with legislation or agreed-upon budgets); propri￾ety (meeting the high standard of public conduct, 
including robust governance and transparency); 
value-for-money (achieving a good-quality outcome 
for the cost); and feasibility (likelihood of successful 
implementation).
If a situation arises in which a British minister 
decides to pursue a course of action that the account￾ing officer (comparable to a Canadian Deputy 
Minister) believes fails at least one of these criteria, the 
the proposed land sites could be serviced in the 
near term. 
In their submissions to the Integrity Commissioner 
(as noted in the January 18, 2023 public report of the 
Integrity Commissioner), the Housing Minister and 
the Premier advised that “the selection of the affected 
lands was made by public servants who were subject 
to an enhanced confidentiality protocol and that the 
[Housing] Minister was briefed and accepted the pro￾posal only a few days before he presented it to Cabinet 
and the government made its announcement shortly 
thereafter.”
We asked the Deputy Minister whether she had 
communicated any concerns to the Housing Ministry’s 
Chief of Staff or the Housing Minister about the Green￾belt Project to amend the Greenbelt’s boundary. The 
Deputy Minister responded that this project used to 
identify, assess and select land for removal was a gov￾ernment decision. The Deputy Minister noted that the 
Housing Ministry’s concerns and risks were identified 
in the information given to government decision-mak￾ers. However, as noted above, the identified risks did 
not make explicit the limitations and bias of the process 
used. In the opinion of the Deputy Minister, political 
staff understood that most of the land sites were pro￾vided by the Housing Minister’s Chief of Staff, who 
took direction from the Minister and Premier’s Office. 
The Deputy Minister noted that if she had thought that 
this was not understood she would have clarified this at 
the time. 
We were informed that the Housing Minister was 
made aware through discussions and meetings with 
the Deputy Minister of the Housing Ministry that there 
was work being conducted related to the mandate 
letter issued in June 2022 that gave direction about the 
Greenbelt.
Throughout the project, the Housing Ministry’s 
non-political public service staff received instructions 
provided by the Housing Minister’s Chief of Staff. 
While non-political public service staff in the Housing 
Ministry highlighted the risks of considering only 
specific land sites for removal and the limitations of the 
criteria being used to assess lands for removal from the 
Greenbelt during the 10 to 11-week period, we noted  

42
challenges to provide many of these sites with the 
infrastructure required to support housing. They indi￾cated that there would need to be significant capital 
expenditures to add or upgrade the infrastructure 
needed, and noted that some land sites could take 10 
years or longer to fully service. The Chief Planners also 
noted that they would have to re-prioritize and revise 
their existing regional plans because they had not con￾templated housing development on these land sites. 
Appendix 2 sets out the typical process for a proposed 
development. 
The Region of Durham has developed preliminary 
estimates of the costs and length of time to provide 
necessary infrastructure to service housing develop￾ment in the Duffins Rouge Agricultural Preserve lands. 
These estimates include major capacity upgrades, such 
as water and sewage treatment plant expansions, and 
a road and transit network, expected to be rolled out 
over a 25-year time frame. The Region estimates that 
the cost of this infrastructure is to be from $1 billion to 
$2 billion and is relying on the provincial commitment 
that the housing developer would bear this cost—in 
line with the government’s public messaging. In addi￾tion, the Region noted that facilities and other services 
for policing, health care and social services would be 
needed to create a complete community, the total costs 
of which are estimated to be more than $300 million. 
As regards the Bathurst-King land site, York Region 
told us that infrastructure capacity upgrades were 
needed to prepare the site for housing development. 
Although, at the time of our audit, the Region had not 
estimated the cost and time frame to complete these 
upgrades, the Region noted the upgrades could take as 
long as 10 years. 
We also spoke to the City of Hamilton about the 
land sites removed from the Greenbelt in this region 
and noted some of these sites would require con￾siderable infrastructure to prepare them for housing 
development. In addition, the City of Hamilton noted 
that one of the sites—Book Road (Site #4), which 
accounted for nearly 25% of all land removed from 
the Greenbelt in 2022—is located in an area partially 
restricted from residential development because of 
its proximity to the Hamilton International Airport 
accounting officer is required to write to the minister 
expressing concern and requesting written direction 
to proceed. Upon receipt of ministerial direction in 
the UK, the accounting officer is required to comply 
with that direction, and a copy of the letter is to be 
shared with the Treasury, the Comptroller and Auditor 
General, Parliament’s Public Accounts Committee and 
the public. This process provides for transparency and 
accountability for government decisions that are being 
made contrary to advice from the public service. 
4.5 Most of the Land Removed from
the Greenbelt May Not Be Ready for
Housing Development in Time to Meet
Government Goals
Contrary to public communication, we found that the 
Housing Ministry’s Greenbelt Project Team did not 
analyze whether the sites proposed for removal from 
the Greenbelt could support housing development 
in the near future. Operating under a confidentiality 
agreement, the Greenbelt Project Team was prevented 
from contacting partner ministries and external parties 
such as municipalities (see Section 4.2), conservation 
authorities and developers, and could not assess the 
existing or planned infrastructure availability and ser￾vicing capacity for the sites.
Servicing land with required infrastructure to 
support housing includes the provision of, at minimum, 
utilities (e.g., water, sewage, electricity), road net￾works, and supporting services in the vicinity such 
as schools, hospitals, fire stations and police stations. 
Typically, housing developers pay for and provide the 
necessary utility connections from the main municipal 
utility lines to the development areas, while the muni￾cipalities pay for and provide services related to overall 
capacity (e.g., water treatment plants, water pumping 
stations) and supporting services. The costs of these 
latter services can be recovered from housing develop￾ers to varying degrees. 
We spoke with the Chief Planners from the regions 
of Durham, Hamilton and York, where all 15 of the 
selected Greenbelt land removals are located. The 
planners told us their regions would face significant  

Special Report on Changes to the Greenbelt 43
Ministry assessment, we asked the Municipal Property 
Assessment Corporation (MPAC), which is responsible 
for calculating property values for all municipalities 
in Ontario, to identify the potential financial impact of 
this decision. A summary of MPAC’s estimates of the 
value changes are presented in Figure 9.
MPAC estimated that removing the 15 land sites 
from the Greenbelt has the potential to increase their 
value by $8.28 billion, with the value of the Duffins 
Rouge Agricultural Preserve (DRAP) site alone poten￾tially increasing by $6.63 billion. These estimates were 
based on a valuation date of January 1, 2016, and do 
not account for additional market increases in land 
values between 2016 and 2023. In June 2023, proper￾ties in the land sites removed from the Greenbelt were 
selling for about four times their assessed land value 
per acre before removal. 
As noted in Section 2.1.5, provincial and regional 
governments had entered into a Memorandum of 
Understanding in 1999 to enable the expropriated 
DRAP lands to be resold by the Province to the ori￾ginal landowners and tenant farmers at agricultural 
prices, which were substantially lower than prices for 
developable land. All parties agreed that as a condition 
of sale, each purchaser would grant conservation or 
agricultural easements under the Conservation Land 
Act, which were intended to protect the land and limit 
it to agricultural and conservation uses in perpetu￾ity. Approximately 67% of the acreage of the lands 
owned by current owners in the DRAP was bought 
with this condition between 2000 and 2005, before 
(though an MZO or City zoning change could permit 
development in the restricted area). We confirmed that 
the Greenbelt Project Team was not aware of specific 
municipal restrictions on building housing on this land 
because of the proximity of this land site to an airport 
when it assessed the land site’s suitability for removal 
from the Greenbelt.
4.6 Government’s Exercise to Alter the
Greenbelt Did Not Factor in Financial
Impacts or Costs, or Clarify Fiscal
Responsibilities
4.6.1 Government Decisions to Remove Land 
Sites from the Greenbelt Resulted in Significant 
Financial Gains for Select Landowners
We found that the Housing Ministry did not assess how 
much the value of the Greenbelt land would increase 
if the Greenbelt Plan restrictions on development were 
removed. According to the Housing Ministry, this type 
of financial assessment is not considered when a policy 
decision is made in land-use planning. As a result, 
government decision-makers were not made aware 
in written form that the select few landowners who 
owned these sites stood to collectively benefit from 
the Greenbelt boundary changes by at least $8 billion. 
Figure 7 shows the three housing developers with the 
largest land sites removed from the Greenbelt in 2022.
Rezoning sites in the Greenbelt from undevelop￾able agricultural land to developable land immediately 
increased the lands’ value. In the absence of a Housing 
Figure 9: Estimated Change in Value of Lands Removed from the Greenbelt in 2022
Source of data: The Municipal Property Assessment Corporation (MPAC)
Areas Removed
Size 
(Acres)
Assessed Valuation 
Before Removal 
($ million)1
Estimated Valuation 
After Removal 
($ million)2
Difference in 
Valuation 
($ million)
Lands removed from the Duffins Rouge 
Agricultural Preserve (DRAP) 4,289 82 6,713 6,631
Lands removed excluding the DRAP 3,124 158 1,810 1,652
All Lands Removed 7,413 240 8,523 8,283
1. Based on a valuation date of January 1, 2016 and includes existing tax mitigations for eligible properties (e.g., farmland, conservation land).
2. Assumes the parcels are low-density residential development lands based on a valuation date of January 1, 2016, and does not account for any tax mitigations that 
may be applicable. The actual value impact on individual properties cannot be fully realized until development plans are finalized and actual use is established. 

44
it asked to make such a determination. It is not yet 
clear who ultimately will bear the full costs to service 
the land to support housing development because, as 
of June 2023, no agreements for these 15 sites have 
been finalized. Those costs are estimated to be in the 
billions of dollars. For example, as previously noted, 
the Durham Region’s April 23, 2023, high-level, pre￾liminary estimate for servicing just the Duffins Rouge 
Agricultural Preserve area was $1 billion to $2 billion. 
York Region and the City of Hamilton had yet to 
develop estimates by June 30, 2023.
As described in Section 4.2.2, the Greenbelt 
Project Team was restricted from contacting munici￾palities to obtain relevant information to assess the 
serviceability of the land sites. Instead, the Greenbelt 
Project Team assessed whether infrastructure servi￾ces could be added based on whether the sites were 
located next to a developed urban area. As a result, 
when the Greenbelt proposal was approved, govern￾ment decision-makers had no time to evaluate the 
potential costs and time requirements to service the 15 
land sites. We noted, however, that the Housing Min￾istry’s final documentation regarding amending the 
Greenbelt’s boundaries assumed that there would be 
minimal cost-related impacts on stakeholders and the 
general public.
Further, the Housing Ministry’s notice on the 
Environmental Registry of Ontario (Environmental 
Registry) regarding the proposal to amend the Green￾belt boundary in 2022 stated: “It is the government’s 
expectation that the proponents would fully fund 
necessary infrastructure upfront.” However, during 
our audit we found that the provincial government had 
not publicly clarified if this statement meant that the 
housing developers have been made accountable for all 
of the potential servicing costs (including required cap￾acity upgrades), to what extent municipalities would 
be accountable for these costs, or how much financial 
support the provincial government would provide.
We spoke to the government’s Provincial Land 
and Development Facilitator, who is responsible for 
facilitating negotiations between housing developers, 
municipalities and the Province to reach agreements 
on housing development on these 15 land sites. The 
the Greenbelt was put in place. A further 9% was pur￾chased after the Greenbelt Act was enacted in 2005, 
including 4% between 2018 and 2022. Appendix 6
provides land sales information from 2018 onwards, 
showing when parcels of land were last purchased on 
the sites that were removed or re-designated from the 
Greenbelt Area in 2022.
By repealing the DRAP Act, the Province allowed 
for the removal of the easements and covenants that 
had protected the lands for agricultural use. From 
our work, we know that the Province recognized that 
the release or amendment of covenants or easements 
would allow these lands to be sold at much higher 
developable land prices going forward. The Province, 
and by extension the public, gave up potentially billions 
of dollars in opportunity costs that had been previously 
forfeited in the name of supporting local agriculture 
and protecting the environment. Those profits will now 
flow to the DRAP lands’ private owners and develop￾ers, with no immediate offsetting compensation to the 
public.
We found neither the Housing Ministry nor the 
government took steps to consider the full extent of 
the potential financial gain for property owners, how 
the Province could share in this gain, or how this 
change in land value would affect housing prices and 
progress toward the Province’s housing target. As per 
the Provincial Land and Development Facilitator, if 
landowners of the 15 sites removed from the Green￾belt in 2022 sell the land, the future formal condition 
would be that they sell it to an owner that would start 
housing development by 2025. This formal condition 
has not been documented in any final agreement, as of 
June 30, 2023. 
4.6.2 The Greenbelt Project Team Did Not 
Estimate the Cost to Add Needed Infrastructure 
to the Greenbelt Sites or Who Would Pay for It
Our audit found that the Housing Ministry’s Green￾belt Project Team did not estimate the potential costs 
and time requirements to service the 15 land sites 
proposed to be removed from the Greenbelt with the 
infrastructure required to support housing, nor was  

Special Report on Changes to the Greenbelt 45
to preserve connectivity between these areas and 
support environmental processes that occur across 
a broader landscape. We found, however, that 
the 2022 Greenbelt amendments were made without 
regard for environmental and agricultural risks (see 
Section 4.7.1), were contrary to the Greenbelt Plan’s 
processes and objectives to provide the areas with 
permanent protection (see Section 4.3), and may lead 
to adverse impacts on natural features and agricultural 
lands (see Sections 4.7.2 and 4.7.3). We also found 
that the Province’s decisions in 2022 to add lands to 
the Greenbelt were not based on natural boundaries or 
protecting environmental functions, and the Housing 
Ministry did not assess whether the added lands were 
comparable to the lands removed, thus providing a 
suitable offset (see Section 4.7.5).
4.7.1 Environmental and Agricultural Risks Not 
Assessed in Project to Remove Greenbelt Lands
We found that the 2022 Greenbelt removals were made 
without consideration for, or a clear understanding of, 
the environmental and agricultural risks. The Green￾belt Project Team was unable to assess key site-specific 
and detailed environmental or agricultural risks of the 
Greenbelt removals in the allotted three-week time 
frame and no sites were eliminated from considera￾tion based on potential environmental or agricultural 
impacts. As described in Section 4.2.2, the Housing 
Minister’s Chief of Staff had initially provided the 
Greenbelt Project Team with a criterion for selecting 
lands for removal to protect important environmental 
and agricultural lands (i.e., whether or not land was 
within the Natural Heritage System or a Specialty Crop 
area). However, when the Greenbelt Project Team 
determined that the majority of sites considered for 
removal did not meet this criterion, the Housing Min￾ister’s Chief of Staff directed the team to discard it. 
Though the Housing Ministry noted to Cabinet in Nov￾ember 2022 which of the lands were within the Natural 
Heritage System or contained a Specialty Crop area, 
this criterion was not used to qualify sites for removal.
Because the Greenbelt Project was designed to be 
swift and confidential, the Greenbelt Project Team was 
Provincial Land and Development Facilitator noted 
that although agreements were being negotiated on a 
site-by-site basis, no agreement would be reached if a 
developer did not agree to cover all servicing and infra￾structure costs upfront. The government has publicly 
communicated that if expectations were not met then 
the land would begin to be added back into the Green￾belt. However, the Provincial Land and Development 
Facilitator indicated that as of June 2023 no agree￾ments had been finalized for any site. 
As described in Section 4.5, we interviewed muni￾cipal Chief Planners from the three regions where 
all 15 land sites were removed from the Greenbelt in 
2022. In contrast to the Housing Ministry’s notice on 
the Environmental Registry, they told us that servicing 
many of these areas would require infrastructure cap￾acity upgrades that would demand significant capital 
expenditure and years to complete.
For example, the DRAP lands in the Region of 
Durham, which represent 58% of the acreage removed 
from the Greenbelt in 2022, were identified as par￾ticularly challenging to service (potentially taking up 
to 25 years) and required the most significant capital 
investment and infrastructure capacity upgrades. The 
April 2023 Region of Durham’s high-level preliminary 
estimates noted that servicing the DRAP would require 
major infrastructure upgrades, including expansion 
of water and sewage treatment plants, and road and 
transit networks. 
The government can propose at any point to pub￾licly consult and subsequently return the removed land 
sites to the Greenbelt through regulatory changes. 
4.7 Government Did Not Factor
Environmental and Agricultural
Implications into Greenbelt Boundary
Changes, Which Are Expected to
Result in Adverse Impacts
The Greenbelt Plan was established to permanently 
protect key agricultural lands and natural features 
in the Greater Golden Horseshoe. The Plan estab￾lished large, integrated and inter-connected systems 
of agricultural land and natural features in order  

46
the Greenbelt. For one of the 15 land sites removed 
(Site #11), Ministry staff had ready access to more 
detailed data as a result of a litigation matter, and so 
they provided information to the Minister’s Office to 
exclude a provincially significant wetland from the 
removal of this particular land site.
As of July 1, 2023, the Housing Ministry had not 
requested from partner ministries any further infor￾mation that could be used to consider and address 
environmental and agricultural risks if future develop￾ment proposals are approved. For our audit, it was not 
possible to undertake a comprehensive assessment 
of the environmental impacts of the Greenbelt land 
removals, as these impacts depend on future develop￾ment and how other environmental protections will or 
will not be applied (see Section 4.7.4). However, our 
Office compiled and assessed information and concerns 
from experts in ministries and other organizations 
about the environmental and agricultural risks associ￾ated with future housing development on these lands 
(see Sections 4.7.2 and 4.7.3).
4.7.2 Important Environmental Features on 
Lands Removed from the Greenbelt Face Risk of 
Loss or Degradation 
Overall, 11 of the 15 areas removed from the Greenbelt 
(see Figure 4, Sites #1, #3, #4, #7, #9, #10, #11, 
#12, #13, #14, and #15) contained lands within the 
Natural Heritage System, seven of which (Sites #7, 
#10, #11, #12, #13, #14, and #15) were entirely 
within the Natural Heritage System (see Figure 4 for 
details). Of the approximately 7,400 acres removed 
from the Greenbelt, 2,925 acres (or 39%) were part 
of the Natural Heritage System, equivalent to approxi￾mately 2,200 football fields. Almost 1,000 acres (or 
14%) of the total removals are wetlands or woodlands. 
Without the protection provided by the Greenbelt Plan, 
the removed lands are at greater risk of: loss or deg￾radation of natural features; fragmentation and loss of 
wildlife habitat, including for species at risk; increased 
flooding; and impacts on water quantity and quality. 
Even natural features on lands that are not developed 
can become degraded and adversely affected by sur￾rounding development. Below, we summarize some of 
prohibited from leveraging the expertise of partner 
ministries, municipalities and conservation authorities 
on environmental and agricultural risks while drafting 
the proposed Greenbelt changes before public consulta￾tion. While a small group of senior staff at the Natural 
Resources Ministry (working on the proposed repeal of 
the Duffins Rouge Agricultural Preserve Act, 2005 and 
who had signed the Greenbelt project’s security attesta￾tion forms) were aware that the Housing Ministry 
was working on a proposal to remove Greenbelt lands 
(including lands in the Duffins Rouge Agricultural Pre￾serve), these staff were not provided details, were not 
made aware of other sites proposed for removal, and 
were not asked to provide feedback or input on the pro￾posed Greenbelt changes before they were posted on 
the Environmental Registry on November 4, 2022. In 
the past, an extended and transparent review process 
was used for proposed Greenbelt amendments during 
which all affected parties could collaborate and share 
expertise to inform the decision-making. However, 
in 2022, partner ministries and organizations only 
became aware of the suite of proposed changes at the 
same time and in the same way as the general public: 
from news releases and the posted proposal notices on 
the Environmental Registry.
On November 4, after proposal notices were posted 
on the Environmental Registry for public consultation, 
the Housing Deputy Minister emailed her Deputy Min￾ister colleagues in other ministries notifying them of 
the proposal notices and 30-day consultation period. 
Some partner ministries (the Natural Resources Min￾istry, and the Ministry of Agriculture, Food and Rural 
Affairs) and other experts compiled and sent general 
and site-specific natural heritage, aggregate resources 
and agricultural information to the Housing Ministry 
during the November–December 2022 public consulta￾tion period. While some select high-level information 
was incorporated into the December 14 submission to 
Cabinet, the information provided by subject matter 
experts on potential environmental and agricultural 
risks did not ultimately affect the Greenbelt decisions. 
For 14 of the 15 land sites removed, the Housing 
Ministry did not consider any site-specific environ￾mental data or attempt to avoid removing important 
natural features such as wetlands or woodlands from  

Special Report on Changes to the Greenbelt 47
almost 1,000 acres of wetlands and woodlands have 
now been removed from the Greenbelt (see Figure 10), 
and are therefore at increased risk of loss or degrada￾tion. In some cases (for example, Sites #4, #9, #10 
and #12), wetlands or woodlands have been partially 
removed, with the Greenbelt boundary now passing 
right through these features. In others (for example, 
Sites #1, #3, #11 and #13), the boundary is within 
30 metres of a natural feature still protected within 
the Greenbelt, such that the amended boundaries are 
inconsistent with the Greenbelt Plan’s Natural Heritage 
the identified environmental risks of the 2022 Green￾belt removals.
Wetlands and Woodlands 
Wetlands and woodlands provide important ecological 
functions, such as: flood reduction, water filtration, 
carbon storage and wildlife habitat. The Housing Min￾istry did not attempt to obtain data on the number 
or locations of wetlands and woodlands within the 
15 areas removed during the course of the Greenbelt 
project. According to Natural Resources Ministry data, 
Figure 10: Woodlands and Wetlands on Land Sites Removed from the Greenbelt in 2022
Source: Ministry of Natural Resources and Forestry 
Site 
# Site Name (Municipality)
Total Size 
of Removal 
(Acres)
Woodland 
Area Removed 
(acres)
Wetland Area 
Removed 
(acres)
Unevaluated1
Wetland Area 
Removed 
(acres and %)
Wetlands 
Removed 
(#)
1 Duffins Rouge Agricultural Preserve 
(Pickering)
4,289 373 229 171 (74%) 117
2 Kingston Road and Highway 401 (Ajax) 133 2 – – –
3 Nash Road (Clarington) 86 16 14 0 (0%) 2
4 Book Road (Hamilton) 1,809 234 56 56 (100%) 27
5 Hamilton Mount Hope (Hamilton) 163 2 – – –
6 Cline Road (Grimsby) 73 < 1 – – –
7 502 Winston Road (Grimsby) 15 – – – –
8 Barton (Hamilton) 10 – – – –
9 Bathurst-King (King) 655 542 8 1 (17%) 9
10 Highway 48 (Markham) 88 1 1 1 (100%) 3
11 10379 Kennedy Road (Markham) 37 < 1 – – –
12 Leslie-Elgin (Richmond Hill) 15 < 1 < 1 – 3
13 Block 41 Lands (Vaughan) 16 – < 1 < 1 (100%) 2
14 11861 and 12046 
McCowan Road (Whitchurch￾Stouffville)
13 – – – –
15 19th Avenue and McCowan Road 
(Markham) 11 – < 1 < 1 (100%) 1
Total 7,413 682 308 229 (74%) 1643
1. Wetland area that has not been evaluated to determine provincial significance for protection. Of the remaining 26% of wetland area that has been evaluated, 19% 
was not deemed provincially significant (all located within the DRAP lands) and 7% was provincially significant. 
2. Includes woodland area in the Oak Ridges Moraine Area re-designated to Settlement Area.
3. Individual wetlands are defined by outer boundaries and types of wetland area. Includes 22 wetlands that were partially removed from the Greenbelt.  

48
Assessment Agency of Canada work with Parks Canada 
and Environment and Climate Change Canada to 
develop a proposed approach and scope of a study to 
understand the potential effects, including cumulative 
effects, of past, ongoing and potential future nearby 
development projects on the integrity of the Rouge 
National Urban Park and its management objectives. 
Rouge National Urban Park borders the Duffins Rouge 
Agricultural Preserve and is one of the largest urban 
parks in Canada. In May 2023, the Impact Assessment 
Agency of Canada indicated that a committee would be 
appointed to carry out the study.
Flooding and Water Quantity and Quality
Green spaces, such as wetlands, woodlands, meadows 
and farmland, provide permeable (porous) surfaces 
that help absorb rainwater. Flood risk increases when 
green spaces are replaced with impermeable surfaces 
such as roads, driveways and parking lots. Land-use 
changes can also adversely affect groundwater and 
surface water, which in turn can have impacts on 
drinking-water supplies and natural features that 
depend on these water sources. Seven of the 15 areas 
removed from the Greenbelt are within the Toronto 
and Region Conservation Authority’s (TRCA’s) water￾shed jurisdiction. The TRCA noted that development 
within the Greenbelt removals have the potential to 
increase flooding hazards, and may have negative 
impacts on the groundwater system and functions in 
these areas (see key examples in Figure 12). 
4.7.3 Greenbelt Area Removals Are Expected 
to Have a Significant Adverse Land Impact on 
the Agricultural System
While the total Greenbelt Area was increased by 
the 2022 Greenbelt amendments, Agriculture Ministry 
staff concluded in an internal Information Note that 
the protected countryside area would be reduced, 
and, as a result, overall “the net change in quantity 
and quality of agricultural land would be considerably 
lower.” For example, the net impact of the land remov￾als and additions resulted in a loss of over 4,700 acres 
of land designated and protected by municipalities 
System methodology to allow wildlife to travel between 
habitats. 
Wildlife Habitat and Species at Risk
Many wildlife species depend on intact, connected 
habitat to feed, reproduce and maintain genetic divers￾ity. However, development can break up previously 
connected habitat into smaller, more isolated frag￾ments. Habitat fragmentation can reduce the number 
and diversity of organisms and, in turn, alter species 
communities and ecosystems. Fragmentation can also 
reduce the quality of remaining habitat, as adjacent 
development can introduce pollution, invasive species 
and other threats.
Several expert bodies have identified potential 
risks to wildlife habitat and wildlife corridors, and to 
the species that depend on them, that may result from 
the 2022 Greenbelt removals (see key examples in 
Figure 11). While the purpose of Ontario’s Endangered 
Species Act, 2007 is to protect Ontario’s most vulnerable 
species (e.g., endangered and threatened species), our 
2021 value-for-money audit Protecting and Recovering 
Species at Risk found that the Province’s systems and 
process for approvals now facilitate and enable harm to 
species at risk and their habitats.
As discussed in that report, if the federal Minister of 
Environment and Climate Change is of the opinion that 
a province’s laws do not effectively protect the critical 
habitat of a federally listed species at risk, the federal 
government can issue orders under its own Species 
at Risk Act. For example, to protect the habitat of the 
nationally threatened western chorus frog, the federal 
government issued orders in 2021 with prohibitions 
on residential development in Longueuil, Quebec. The 
federal Minister of Environment and Climate Change 
has commented in January 2023 that, if similar pro￾jects were to be proposed on lands that were part of 
the Greenbelt, he would have a legislative obligation 
to intervene. Staff at Environment and Climate Change 
Canada are reported to have identified that at least 29 
species at risk live, or are likely to live, in the areas 
removed from the Greenbelt.
In March 2023, the federal Minister of the Environ￾ment and Climate Change requested that the Impact  

Special Report on Changes to the Greenbelt 49
Figure 11: Key Risks to Wildlife Habitat and Species at Risk from 2022 Greenbelt Removals
Prepared by the Office of the Auditor General
Site 
#
Site Name 
(Municipality) Wildlife Habitat and Species Identified Potential Risks of Removal
1 Duffins Rouge 
Agricultural 
Preserve 
(Pickering)
4,289 acres
• Land is adjacent to a provincially 
significant wetland complex that is 
“arguably the most ecologically sensitive 
area of [Rouge National Urban Park] 
and is home to dozens of federally and 
provincially endangered and threatened 
species.”1
• 22 species at risk (including the 
endangered red-headed woodpecker 
and butternut tree and the threatened 
Blanding’s turtle) have been reported 
within one kilometre of the preserve.1
• The preserve forms “necessary linkages” to 
adjacent natural areas and creeks, and the 
connection to the Rouge National Urban 
Park is especially important for wildlife 
passage.3
• May cause negative impacts to species at risk in the 
preserve by creating barriers to suitable habitats.1
• May have negative impacts on biodiversity, species at 
risk and fish habitat, as well as the neighbouring park’s 
ecological integrity.2
 (The Assessment Agency of Canada is 
studying the potential effects of development on the park).
• The removal reduced the width of the connection between 
the remaining protected area in West Duffins Creek 
valley and the rest of the Greenbelt to approximately 
45 metres (see Site #1 in Appendix 4.) The width of this 
corridor, which protects only the west side of the creek, 
is inconsistent with the Greenbelt Plan’s Natural Heritage 
System methodology of providing 60 metres on each side 
of a river or creek to protect these valley corridors and the 
habitats they provide.3
• May be detrimental to a currently unimpeded east-west 
corridor between Rouge National Urban Park and the 
Natural Heritage System in Pickering’s Seaton community.4
3 Nash Road 
(Clarington)
86 acres
• Entire area is recognized as a “Wildlife 
Movement Habitat Network,” and includes 
areas designated as “core habitat” and 
corridors that support the movement of 
sensitive plants and animals.5
• A portion of the provincially significant 
wetland within the removal is a candidate 
Life Science Area of Natural and Scientific 
Interest (a provincial designation of 
areas with significant representation of 
biodiversity and natural landscapes).3
• May cause negative impacts on the provincially significant 
wetland area and function, woodland cover, and wildlife 
habitat and movement.5
• May cause negative impacts on a tributary of Black Creek, 
which could increase risks of downstream flooding and 
erosion and further degrade wildlife habitat.5
12 Leslie-Elgin 
(Richmond Hill)
15 acres
• Area straddles a wildlife corridor and 
the Rouge River tributary, which provides 
habitat for species moving north-south 
adjacent to Highway 404.4
• Area contains or is immediately adjacent 
to diverse wildlife habitats, including 
meadows, woodlands, marshes, swamps 
and a sensitive coldwater stream that 
provides important fish habitat.3,4
• The removal reduces the corridor width from 160 to 
90 metres, which is inconsistent with an Ontario Municipal 
Board settlement that requires a minimum width of 
120 metres for the Natural Heritage System for major 
tributaries in this area (such as this Rouge River tributary).4
• An additional road will likely be required on the removed 
lands to support future development, which “would result 
in a loss of [provincially significant wetland] habitat and 
potential impacts to redside dace habitat,” an endangered 
species of minnow.4
13 Block 41 Lands 
(Vaughan)
16 acres
• Identified as a priority area for maintaining 
habitat connectivity for various species that 
depend on forests and wetlands.4
• The removal reduces the corridor from 600 to 265 metres, 
which “would have a significant impact on the intended 
landscape connectivity and the species using the area.”4
1. Feature or risk identified by Parks Canada.
2. Feature or risk identified by Environment and Climate Change Canada. 
3. Feature or risk identified by the Ministry of Natural Resources and Forestry.
4. Feature or risk identified by the Toronto and Region Conservation Authority.
5. Feature or risk identified by the Central Lake Ontario Conservation Authority. 

50
result from recent decisions by the Housing Ministry 
to expand urban settlement boundaries (for example, 
the City of Hamilton and Wellington County) as well 
as proposed changes to provincial land-use planning 
policy that could further reduce restrictions for new 
development on agricultural land and reduce muni￾cipalities’ need to prioritize intensification and meet 
population-density targets. 
The agricultural community and municipalities 
have expressed concerns over the recent removal of 
properties from the Greenbelt due to the precedent 
they create for future removals and increased real 
as prime agricultural area. The Agriculture Ministry 
staff also noted internally that the 2022 amendments 
conflict with one of the Greenbelt Plan’s stated goals: 
to provide permanent protection to the agricultural 
land base.
As of 2021, only about 5% of Ontario’s land area (or 
11.8 million acres) is farmland, which is vulnerable to 
ongoing loss to urban development. The federal Census 
of Agriculture indicated that, from 2016 to 2021, the 
total farm area actively farmed in Ontario declined 
by 319 acres a day, on average. Staff from the Agricul￾ture Ministry noted that additional farmland loss may 
Figure 12: Key Risks to Water Quantity and Quality from 2022 Greenbelt Removals
Prepared by the Office of the Auditor General
Site 
#
Site Name 
(Municipality) Potential Risks
1 Duffins Rouge Agricultural 
Preserve (Pickering)
4,289 acres
• Development is expected to increase flood risk within the area and for downstream lands 
already prone to flooding. Additional studies and flood mapping will be necessary if 
development proceeds in this area, “potentially including long term and costly flood hazard 
remediation projects to protect the downstream lands from the impacts of development.” 
Preliminary reviews show that downstream infrastructure will need to be retrofitted if this area is 
developed.1
• The preserve includes the old Lake Iroquois shoreline, which is a highly sensitive “prominent 
discharge area” where groundwater seeps close to the surface. It “provides one of the key 
sources [of freshwater] for creeks in the eastern half of the Greater Toronto Area,” as well as for 
“highly significant downstream coastal marshes.”2
10 Highway 48 (Markham)
88 acres
• Area removed is partially within and immediately adjacent to a regulatory floodplain, an area 
identified as prone to flooding when water levels rise in nearby river tributaries or streams.1
11 10379 Kennedy Road 
(Markham)
37 acres
• The removal is adjacent to a flooding and erosion hazard area. The TRCA noted that it “would not 
support development within the area" and that "high groundwater could impede development” or 
require lands to be dewatered, which could impact natural features in this area.
• This removal includes land identified as a candidate Life Science Area of Natural and Scientific 
Interest and is only 18 metres from a provincially significant wetland deemed important for 
flood control and groundwater supply in this area, inconsistent with the Greenbelt Plan’s Natural 
Heritage System methodology of providing at least 30 metres around natural features.2
12 Leslie-Elgin (Richmond Hill)
15 acres
• This removal includes a provincially significant wetland that helps regulate water quantity and 
quality in the Rouge River tributary, and protects a sensitive cold-water stream, a water feature 
that provides special habitat to certain fish communities.1
15 19th Ave and McCowan 
Road (Markham)
11 acres
• Area removed is partially within and immediately adjacent to a regulatory floodplain, an area 
identified as prone to flooding when water levels rise in nearby river tributaries or streams.1
1. Risk identified by the Toronto and Region Conservation Authority (TRCA).
2. Risk identified by the Ministry of Natural Resources and Forestry. 

Special Report on Changes to the Greenbelt 51
$14.7 million to Ontario’s gross domestic product in 
2021. 
While the Agriculture Ministry found that the 
removal of the other 10 areas (5% of total area 
removed) will likely have only minor impacts on 
agriculture, this assessment was based largely on 
the annual agricultural production of those lands. 
However, protecting high-quality agricultural land, 
regardless of current agricultural production, preserves 
valuable soil resources, helps to meet future agricul￾tural needs and promotes long-term food security. 
In addition, developing surrounding farmland may 
impact the productivity or future potential of high￾quality agricultural land. For example, the Agriculture 
Ministry staff have noted that three (Sites #6, #7 and 
#8) of the Greenbelt removals (98 acres) are entirely 
within specialty crop areas, which are the highest pri￾ority for protection due to their scarcity, unique soil 
and climate conditions, and ability to support fruit 
and vegetable production. Although these particular 
removals are expected to affect agricultural produc￾tion, the incremental impacts are expected to be 
minor, partially because of previous fragmentation and 
development on the surrounding lands.
4.7.4 Recent Changes to Other Environmental 
Protections May Increase Risks to Natural 
Features Removed from the Greenbelt 
The Housing Minister’s Office has stated that develop￾ments on the removed Greenbelt lands will require 
municipal planning approvals and that the Province 
will require that environmentally sensitive areas be set 
aside and protected before any construction begins. 
Environmental protections for lands removed from the 
Greenbelt will default to the normal land-use planning 
framework, including the Provincial Policy Statement, 
the Growth Plan for the Greater Golden Horseshoe, 
and regulatory and legislative protections (such as 
through the Conservation Authorities Act and Endan￾gered Species Act, 2007). Land-use planning outside of 
the Greenbelt Plan area (or other area-specific provin￾cial land-use plans) is subject to the Provincial Policy 
estate speculation on agricultural land. Removing 
farmland from the Greenbelt for development frag￾ments farmland which can trigger impacts on the 
surrounding agricultural land base. For example, 
paving over farmland and natural features can degrade 
neighbouring farmlands that may be of higher quality, 
through increased soil erosion, changes in water 
storage or increased pollution runoff from urban areas. 
After Greenbelt amendments were proposed on 
the Environmental Registry, Agriculture Ministry staff 
prepared, for their own purposes, a desktop analysis of 
the agricultural implications of the proposed Greenbelt 
changes using existing, readily available information. 
This analysis was sent to the Housing Ministry during 
the public consultation period. Agriculture Ministry 
staff have estimated that 76% of the total land removed 
from the Greenbelt was in active agricultural use in 
2022. About 83% of the area removed is classified 
as Class 1-3 prime agricultural lands, which is of the 
highest quality and capability for agriculture. 
Agriculture Ministry staff concluded that removing 
three of the 15 areas (Sites # 1, #4 and #9) from the 
Greenbelt, making up 91% of the total area removed, 
is likely to lead to significant adverse impacts on agri￾culture given their large size, existing agricultural uses 
and connectedness to the surrounding agricultural 
landscape (see Figure 13). The Agriculture Ministry 
staff determined that two additional removals (Sites 
#2 and #5) are likely to have moderate adverse 
impacts. 
Agriculture Ministry staff further noted that the 
removal of lands in the Duffins Rouge Agricultural Pre￾serve (DRAP) is the most significant removal in terms 
of expected adverse impacts due to its size, agricultural 
production and connectivity with the surrounding agri￾cultural system. According to the Agriculture Ministry, 
the DRAP has been the only “agricultural preserve” in 
Ontario, and the legacy of protecting these lands has 
resulted in minimal non-agricultural development in 
this area, increasing the quality and connectivity of the 
agricultural land. The Agriculture Ministry conducted 
additional analysis for our Office and estimated that 
the removed preserve lands contributed approximately  

52
for natural features, in practice their policies often 
align with the PPS. Moreover, the Province has recently 
directed Natural Resources Ministry staff to undertake 
a number of changes that will limit municipalities and 
conservation authorities’ ability to protect natural fea￾tures (see Figure 14). 
Statement (PPS), which provides policy direction on 
matters of provincial interest.
However, protections provided for natural features 
under the PPS are generally weaker than under the 
Greenbelt Plan. While municipalities and conserva￾tion authorities can implement stronger protections 
Figure 13: 2022 Greenbelt Removals Characterized as Having Significant or Moderate Adverse Agricultural Impacts 
by the Ministry of Agriculture, Food and Rural Affairs
Source of data: Ministry of Agriculture, Food and Rural Affairs
Site 
#
Site Name 
(Municipality)
Active 
Agricultural Use1
(% of Site)
Prime Agricultural 
Land Class 1-32
(% of Site)
Agricultural 
Significance
Assessed as Likely to Have Significant Adverse Impacts on Agricultural System
1 Duffins Rouge Agricultural 
Preserve (Pickering)
4,289 acres
73 92 • Extensive agricultural operations, including 
production of cash crops, nurseries, vineyards 
and vegetables
• 86% of the area classified as the highest quality 
(Class 1) soil2
• Important connections to the surrounding 
agricultural system, including Rouge National 
Urban Park 
4 Book Road 
(Hamilton)
1,809 acres
77 67 • Part of a continuous land base for agriculture to 
the south and west
• Supports diverse agricultural operations 
including cash crops, fruit and vegetable 
production and two livestock operations
9 Bathurst-King 
(King Township)
655 acres
88 83 • Part of a continuous land base for agriculture to 
the west and north
• 83% of the area classified as the highest quality 
(Class 1) soil, supporting cash crop production2
• Includes three livestock operations 
Assessed as Likely to Have Moderate Adverse Impacts on Agricultural System
2 Kingston Road and 
Highway 401 (Ajax)
133 acres
72 100 • 98% of the area classified as the highest quality 
(Class 1) soil, supporting cash crop production2
• Priority area to maintain Greenbelt connectivity 
within the Ajax/Whitby corridor
5 Hamilton Mount Hope 
(Hamilton)
163 acres
90 70 • Entirely in municipal prime agricultural area3
• Land used for pasture, cash crops and sod 
• Priority area to maintain connectivity of the 
agricultural land base
1. Estimates based on Agriculture and Agri-Food Canada’s 2022 annual crop inventory.
2. The Canada Land Inventory divides land into seven classes according to inherent quality and capability for agriculture, as opposed to existing land use. Classes 1-3 
are considered prime agricultural land, which are given the second-highest priority for protection, following Specialty Crop areas.
3. Prime agricultural area designated in the municipality’s Official Plan. 

Special Report on Changes to the Greenbelt 53
Figure 14: Recent and Proposed Provincial Changes that Could Reduce Protections of Natural Features on Removed 
Greenbelt Lands
Prepared by the Office of the Auditor General of Ontario
Ontario Wetland Evaluation System
The Natural Resources Ministry developed this science-based scoring system in 1983 to aid in determining the provincial 
significance of wetlands based on their ecological and societal functions.
Recent Changes
In December 2022, the Natural Resources Ministry made the following major changes to the wetland evaluation system:
• eliminated two categories that allocated points to wetlands for providing habitat to endangered or threatened species for 
reproduction, migration, feeding or hibernation; 
• removed consideration of wetland complexes, which can reduce the total size of the area evaluated, and therefore the points 
scored, for an individual wetland. (A wetland complex is a group of wetland units that are functionally linked to one another and 
located within 750 metres of at least one other wetland in the complex); 
• allowed wetland complexes already designated as provincially significant to be re-evaluated as individual units; and 
• removed the Natural Resources Ministry’s role in oversight of wetland evaluations and final approval of wetland status.
Ecological Offsetting Policy
Ecological offsetting allows natural features to be removed or degraded if these negative impacts cannot be avoided or 
mitigated during development, provided that restoration or creation of natural features occurs elsewhere.
Proposed Changes
The Natural Resources Ministry posted a proposal on October 25, 2022, on the Environmental Registry seeking feedback on 
developing an offsetting policy for natural heritage features. An offsetting policy could include a compensation amount that 
developers pay into a fund used to implement an offset, including construction, monitoring or management of a new or restored 
natural feature. As of July 2023, this proposal was still under consideration.
Conservation Authorities Act
Conservation authorities are mandated under the Conservation Authorities Act to help protect people and property from 
natural hazards, such as flooding and erosion. Conservation authorities have historically protected natural features within 
their watersheds to reduce risks from natural hazards, as well as to promote broader watershed conservation goals, such 
as protecting habitat and increasing resilience to climate change.
Recent Changes
Between 2020 and 2022, the Province made several amendments to the Conservation Authorities Act that limit conservation 
authorities’ abilities to conserve and protect natural features. These changes prohibit conservation authorities from:
• denying a development permit to a development that is authorized by a Minister’s Zoning Order;
• providing municipalities with comments on development applications under certain legislation (e.g., the Planning Act), 
unless related to natural hazards or protecting sources of drinking water;
• requiring developers to obtain permits for certain activities (this will come into effect once the regulation is finalized); and 
• placing conditions on development for reasons other than controlling natural hazards or protecting public safety, thus limiting 
their ability to minimize other negative impacts, such as habitat degradation or pollution.  

54
an additional 19% has been evaluated but not deemed 
provincially significant. As a result, a total of 93% of 
wetland area removed from the Greenbelt in 2022 is 
not protected under the PPS. A total of 117 wetlands 
removed from the Greenbelt were within the DRAP 
lands, 110 of which have never been evaluated.
In its assessment of site-specific environmental 
considerations related to the Greenbelt amendments, 
the Natural Resources Ministry noted that the Natural 
Heritage System for the DRAP lands was based on 
“providing connection linking the wetlands, woodlands 
and streams” to manage waterflow and support wildlife 
movement. It cautioned that “many of these features 
have not been evaluated or assessed given that they are 
provided protection by the [Natural Heritage System] 
and these natural heritage features should not be con￾sidered of less value or significance.”
4.7.5 Greenbelt Additions Were Not Based 
on Natural Boundaries and Protecting 
Environmental Functions
In October 2022, the Housing Minister’s Chief of Staff 
requested that the Greenbelt Project Team identify 
land that could be added to the Greenbelt to offset 
the potential removals with the goal of increasing the 
overall size of the Greenbelt. This offset was necessary 
because the Greenbelt Act, 2005 prohibits a reduction to 
the total area of the Greenbelt. The Greenbelt Project 
Team identified certain Urban River Valleys (URVs) 
and a portion of the Paris Galt Moraine (described in 
Section 2.3.5) to offset the approximately 7,400 acres 
removed, on the basis that the Housing Ministry had 
already assessed these sites and held public consulta￾tions on them in 2021 and had mapping available. (See 
Figure 15 for a map of the Paris Galt Moraine addi￾tion.) The Greenbelt Project Team advised the Housing 
Minister’s Chief of Staff that assessing and mapping 
any other areas was not possible given the project’s 
three-week timeline.
However, the Housing Ministry’s 2021 assessment 
and consultation on potential Greenbelt additions 
were based on fundamentally different circumstances 
In addition, the Housing Minister can issue a Min￾ister’s Zoning Order (MZO) to override the normal 
land use planning process. MZOs are not required to 
be consistent with the PPS, conform to provincial plans 
or follow the usual municipal planning processes. (For 
more information on the Housing Ministry’s use of 
MZOs, see our 2021 report, Land-Use Planning in the 
Greater Golden Horseshoe). Since the release of our 
report in 2021, when we reported that 78 MZOs had 
been issued between January 2000 and August 2021, 
an additional 58 MZOs have been issued up to July 11, 
2023. Prior to 2019, MZOs were used only in special 
circumstances, and were issued about once a year from 
2000 to 2019. The Housing Ministry public service staff 
expect that the Housing Minister intends to use MZOs 
on lands removed from the Greenbelt to expedite 
development.
Despite the potential risks to natural features (such 
as wetland and woodlands) and surrounding lands 
associated with the Greenbelt removals, Housing Min￾istry public service staff confirmed that there is no plan 
in place to monitor the status of natural features on 
these lands or the degree to which they are protected 
during future housing development. 
The recent changes to the Ontario Wetland Evalua￾tion System could make it harder for wetlands to 
achieve provincially significant status, which is how 
they receive formal protection under the PPS. In 
addition, wetlands that are already designated as prov￾incially significant can now be re-evaluated for removal 
of that designation at the request of a municipality 
or landowner with no provincial review or oversight 
of evaluations. Further, the PPS does not require a 
wetland to be evaluated for provincial significance 
before a municipality approves land-use changes that 
could damage or destroy it. Therefore, natural fea￾tures that have not yet been evaluated and deemed 
significant are particularly vulnerable to development 
pressures. 
With respect to the 2022 Greenbelt removals, 7% 
of the wetland area removed is designated as prov￾incially significant. However, the majority (74%) of 
wetland area removed has not yet been evaluated, and  

Special Report on Changes to the Greenbelt 55
areas to grow the Greenbelt, and proposed 13 new 
Urban River Valleys (URVs) and a study area for a Paris 
Galt Moraine addition. The proposal included a list of 
the Ministry’s “Principles for Growing the Greenbelt 
Expansions,” which included “no consideration of 
removal requests or land exchanges.” The principles 
that were used align with the Housing Ministry’s 
“Growing the Greenbelt” document, published and 
sent to municipalities in 2008, which outlined the 
process and criteria for municipal requests to expand 
than the actual 2022 Greenbelt amendment. The 2021 
assessment and consultation were in the context of 
solely growing the Greenbelt, whereas the 2022 deci￾sion was in the context of offsetting the land removals. 
Despite this fundamental change, the Housing Ministry 
did not re-assess the suitability of adding these lands to 
the Greenbelt as a comparable and reasonable offset to 
the removals. 
The Housing Ministry had held a 61-day public 
consultation from February to April 2021 on initial 
Figure 15: Boundary of the Paris Galt Moraine and the 2022 Addition to the Greenbelt
Source: Ministry of Municipal Affairs and Housing
* The orange colour shows the draft boundary of the Paris Galt Moraine prepared by Ministry of Municipal 
Affairs and Housing staff in response to the consultation that occurred in 2021 on an initial study area. 

56
end, in spring 2021, the Housing Ministry conducted 
extensive engagement to gather detailed information 
on the Paris Galt Moraine’s geology, hydrology (distri￾bution and movement of water) and natural features 
to inform the proposed boundary. The Ministry stated 
that there was “consensus across stakeholders and 
partner ministries that any legal boundary of the Paris 
Galt Moraine must be defendable and supported by the 
best available provincial scientific data.”
In the summer of 2021, the government directed 
Housing Ministry non-political public service staff to 
establish a proposed legal boundary for the entire Paris 
Galt Moraine for consideration of its addition to the 
Greenbelt, which would respect both the landform and 
the important functions it provides in regulating water 
quality and quantity. As a result, the proposed bound￾ary was further expanded from the original study area 
to align with the objectives of the Greenbelt Plan by 
incorporating adjacent natural features and prime agri￾cultural land (see Figure 15). 
However, in December 2022, the Housing Ministry 
added only a segment of the Paris Galt Moraine to the 
Greenbelt, representing only about 6% of the moraine’s 
proposed boundary established in 2021. While the 
Housing Ministry relied on the natural boundary of the 
moraine drawn in 2021 for the northwestern boundary 
of the addition, the boundary along the western edge 
bisects the Paris Galt Moraine, following municipal 
concession roads. Although Housing Ministry staff 
initially recommended adding a larger portion of the 
Paris Galt Moraine to encompass important natural 
features and agricultural land, the Housing Minister’s 
Chief of Staff gave direction to proceed with the pro￾posal that only added an area closer to the 1:1 ratio 
necessary to offset the proposed removals (when com￾bined with URV additions; see below). As such, this 
straight boundary was based on adding the minimum 
amount of Paris Galt Moraine land needed to meet 
that ratio, with no consideration of the boundaries of 
hydrological, ecological or geological features. 
In addition, the Housing Ministry’s 2022 decision 
on which particular segment to add was not based on 
the relative environmental or agricultural value of 
the Greenbelt. In keeping with these principles and the 
objectives of the Greenbelt Act, 2005 (Greenbelt Act), 
the Housing Ministry engaged with partner ministries 
and other relevant stakeholders on the 2021 proposed 
additions and carried out an evidence-based process 
for identifying URVs and establishing a boundary for 
the Paris Galt Moraine. This followed a similar process 
to the one used in 2017 to select the 24,932 acres of 
land added. 
In March 2022, the Housing Ministry announced 
that it had been decided not to proceed with expand￾ing the Greenbelt into the Paris Galt Moraine area. 
The rationale provided was that the Ministry needed 
to understand how the proposed addition may impact 
growth in housing and employment areas. The Min￾istry did, however, move forward with the next phase 
of consultation to add 13 URV areas to the Greenbelt, 
and Housing Ministry staff prepared maps for the new 
URVs and boundary amendments.
However, on April 27, 2022, the day that Housing 
Ministry non-political public service staff were 
scheduled to submit the proposal to government 
decision-makers for final approval, they were informed 
that the government was no longer proceeding with 
the Growing the Greenbelt project. Less than six 
months later, in November 2022, the 13 URVs and a 
portion of the Paris Galt Moraine were proposed again 
as Greenbelt additions, but this time in the context of 
offsetting proposed removals. 
Paris Galt Moraine Addition
The Housing Ministry based the boundaries of 
the 2022 Paris Galt Moraine addition largely on the 
goal of meeting a 1:1 ratio to offset the removed Green￾belt lands (in line with the Greenbelt Act requirement 
that amendments cannot reduce the total Greenbelt 
Area), rather than on prior goals of respecting natural 
boundaries and protecting environmental functions 
within the entire moraine.
In 2017, the Province identified the Paris Galt 
Moraine, along with six other areas, as potential Green￾belt additions to protect important water resources in 
the outer ring of the Greater Golden Horseshoe. To that  

Special Report on Changes to the Greenbelt 57
• URVs are considered largely undevelopable 
due to their steep terrain and increased risks of 
flooding and erosion in these areas.
• Most publicly owned lands in URVs are typically 
already protected by existing provincial land-use 
planning policies and conservation authority 
regulations, and through municipal Official Plan 
designations as parks, open space, or recreation, 
conservation and/or environmental protection 
areas.
• The Greenbelt Plan’s policies for URVs are 
weaker than most existing provincial and muni￾cipal policies, as they only encourage protection 
rather than require it, and defer to the protec￾tions provided in municipal Official Plans.
• The Greenbelt Plan’s policies for URVs do not 
apply at all to privately owned URV lands added 
in 2022 or during previous amendments. 
While the Province added the URVs, along with 
Paris Galt Moraine lands, to reach an area equal to or 
greater than the approximately 7,400 acres of remov￾als, numerous stakeholders expressed concerns that 
the URV additions do not contribute to the objectives 
and goals of the Greenbelt Plan, and are inappropri￾ate offsets to balance removals of natural heritage and 
agricultural lands. For example, the City of Markham 
noted that “replacing lands in the Greenbelt intended 
to ensure the persistence of natural features in a con￾nected natural heritage system with other lands that 
already have protection from development, such as 
river valleys, is a clear reduction in the protection 
offered by the Greenbelt Plan.”
Further, due to their urban location and steep 
terrain, URVs also do not help protect agricultural land, 
one of the core objectives of the Greenbelt Plan. The 
Housing Ministry had previously compiled feedback 
from the 2021 consultation on the URVs, and noted 
that the agricultural sector believes that it is unaccept￾able for URVs to be included in Greenbelt Plan area 
calculations to maintain the total Greenbelt area if 
agricultural lands are removed for development. For 
example, the Ontario Federation of Agriculture, which 
represents more than 38,000 farm family members 
protecting these lands. The Greenbelt Project Team 
noted that the particular segment of the Paris Galt 
Moraine added to the Greenbelt was chosen because 
it maintained connectivity with the rest of the Green￾belt, and because it was “less desirable” than areas 
further south on the moraine that might be more suited 
for future housing development and employment 
opportunities.
As noted above, one of the Housing Ministry’s key 
objectives for adding the moraine to the Greenbelt was 
to protect important water resources that contribute to 
drinking water supply in this region and that support 
natural features and wildlife habitat. However, the 
Greenbelt Project Team did not assess the locations 
of key surface or groundwater features or their rela￾tive vulnerability when they proposed which segment 
of the moraine should be added. Furthermore, the 
Greenbelt Project Team did not assess the compara￾tive agricultural value of the 2022 Paris Galt Moraine 
addition. In 2021, the Housing Ministry found that 
some portions of the moraine, particularly northeast of 
Guelph and Rockwood (immediately west of the 2022 
addition), contain higher quality agricultural land than 
others; however, these lands were not added to the 
Greenbelt, in part due to the Greenbelt Project Team 
identifying higher housing and development pressures 
further south along the Paris Galt Moraine. 
Urban River Valley Additions
Our Office found that the 2,400 acres of URVs added 
to the Greenbelt in 2022 do not provide a meaningful 
offset for the natural features and agricultural lands 
removed from the Greenbelt’s Protected Country￾side. The Housing Ministry has acknowledged that 
the designation of URV lands in the Greenbelt Plan is 
largely symbolic and does not carry the same policy 
protections as land designated as Protected Country￾side. Numerous stakeholders asserted that, while 
URV additions may serve to promote education and 
awareness around the Greenbelt, adding them to the 
Greenbelt provides no new protection to the land. 
We found that the URV additions do not result in 
meaningful protection for the following reasons: 

58
relating to the 2022 Greenbelt changes did not describe 
the environmental implications of the proposals or 
provide an assessment of the environmental, social and 
economic consequences of implementing them. On the 
contrary, the notices simply informed the public that 
the anticipated regulatory impact of the proposals was 
“positive.” They did not, for example, identify that 13 
of the 15 land sites (the two exceptions are Sites #2 
and #5) proposed to be removed from the Greenbelt 
contained Specialty Crops and Natural Heritage System 
lands, the removal of which could impact wetlands, 
species at risk and flooding, as outlined in Section 4.7.
In addition, one of the Environmental Registry 
notices listed the criteria the Housing Ministry said it 
had used to evaluate land sites for removal from the 
Greenbelt (see Figure 6), including whether:
• the lands have the potential ability to be ser￾viced in the near-term with local infrastructure 
upgrades to be entirely funded by proponents; 
and
• the lands proposed for removal have the charac￾teristics that would enable housing to be built in 
the near-term.
However, as described in Section 4.2, we found 
that the Greenbelt Project Team was not able to assess 
whether the land sites met these criteria. Also, as we 
outlined in Section 4.5, Chief Planners confirmed to us 
that most of the land removed from the Greenbelt may 
not be ready for housing development for many years. 
4.8.2 The Government Did Not Meaningfully 
Consult the Public about the Greenbelt Changes, 
Analyze or Respond to Feedback
We found that the Housing Ministry did not make suf￾ficient efforts to consult the public in a meaningful way 
or to analyze all of the comments received from the 
public consultation process required by the EBR Act. 
The Housing Ministry did not make any changes to 
the proposed removals to address any of the concerns 
raised during the consultation.
The Housing Ministry posted notices on the 
Environmental Registry concerning amendments to the 
across the province, has commented to the Ministry 
that URVs “do not contribute to the Greenbelt Plan’s 
objectives, vision and goals of providing permanent 
protection to the Agricultural Land Base. In no circum￾stance should ‘greenbelting’ the [URVs] be considered 
an acceptable means of maintaining the Greenbelt’s 
total land area in order to balance the loss of protected 
agricultural lands to development.” 
4.8 The Public and Municipalities
Were Not Effectively Consulted on the
Greenbelt Boundary Changes
4.8.1 Public Consultation on Greenbelt 
Changes Was Undermined by Incomplete and 
Inaccurate Notices
On November 4, 2022, the Housing Ministry posted 
notices on the Environmental Registry of Ontario 
(Environmental Registry) relating to the proposed 
Greenbelt amendments, and provided a 30-day public 
consultation period. The notices outlined proposals to: 
• amend the Greenbelt boundary regulation;
• amend the Greenbelt Plan; 
• re-designate land in the Oak Ridges Moraine 
Conservation Area; and 
• revoke a 2003 Minister’s Zoning Order limiting 
land use in the Duffins Rouge Agricultural Pre￾serve (DRAP) to agriculture.
The Ministry had earlier, on October 25, 2022, 
posted another notice related to the DRAP, proposing 
to revoke the Central Pickering Development Plan.
We found that some of the information in these 
notices was incomplete and inaccurate—limiting the 
public’s ability to fully understand and comment on 
the proposed changes and their potential impacts. To 
meet the EBR Act’s purposes, notices should describe 
a proposal and its environmental implications in suf￾ficient detail to enable Ontarians to provide informed 
comments. In addition, under the EBR Act, notices that 
provide a regulatory impact statement are required to 
include a preliminary assessment of the environmental, 
social and economic consequences of implementing the 
proposal. However, we found that the proposal notices  

Special Report on Changes to the Greenbelt 59
The 30-day consultation period relating to amend￾ing the Greenbelt’s boundary was significantly shorter 
than the consultation periods provided by the Min￾istry for past changes to the Greenbelt. For example, 
the 2017 amendments to the Greenbelt (described in 
Section 2.1.6) went through three consultations over 
a 27-month period, ranging in duration from 47 to 174 
days in length. 
We also found that the 30-day consultation period 
was particularly challenging for affected munici￾palities. The Housing Ministry posted notices on 
the Environmental Registry related to the proposed 
changes to the Greenbelt’s boundary on November 4, 
2022, just 11 days after municipal elections. Some 
municipal councils were not sworn in until weeks after 
the election date, limiting their ability to provide com￾ments related to these notices by December 4, 2022, 
when the consultation period ended. For example, the 
Durham Regional Council, which governs the region 
with the majority of the proposed Greenbelt land 
removals, was not sworn in until November 30, 2022, 
and first discussed comments relating to the Greenbelt 
proposal notices on December 14, 2022—after the con￾sultation period had already ended. Similarly, the York 
Regional Council was not sworn in until November 17, 
2022, and first considered comments relating to the 
Greenbelt proposal notices on December 15, 2022. 
The Association of Municipalities of Ontario, and 
several individual municipalities, including the cities 
of Toronto and Oshawa, asked the Housing Ministry 
for additional time to review, analyze and provide 
comments on the proposed changes to the Greenbelt’s 
boundary. Nevertheless, the consultation period was 
not extended.
Although the consultation period was limited to 
just 30 days, the Housing Ministry received more than 
35,000 comments in response to proposal notices for 
the 2022 amendments to the Greenbelt boundary. This 
number of comments is among the highest submitted 
on any proposal notice posted on the Environmental 
Registry in the past four years. The EBR Act requires 
the Housing Minister to take every reasonable step 
to ensure that all relevant comments received are 
Greenbelt’s boundary, and provided a 30-day consul￾tation period, the minimum time required under the 
EBR Act. The EBR Act requires the Housing Minister to 
consider providing more than the 30-day minimum for 
public consultation based on factors like the complex￾ity of the proposal, the level of public interest and the 
period of time the public may require to make informed 
comment. To satisfy this requirement for proposed 
Greenbelt amendments, the Housing Ministry had 
developed internal guidance for the Housing Minister’s 
Office in 2020 that advised that public consultation 
for such amendments include “posting on the Environ￾mental Registry for a minimum of 45 days.”
We found that 30 days of public consultation was 
provided even though the Housing Ministry was aware 
that 30 days was insufficient to effectively consult the 
public. Before posting notices on the Environmental 
Registry to initiate the public consultation process, the 
Housing Ministry’s non-political public service staff 
expressed concerns to political decision-makers about 
the proposed length of the consultation. Specifically, 
the Housing Ministry anticipated broad criticism on 
the consultation approach and the limited paths for 
engagement, and expected that many stakeholders, 
including municipalities, would not be able to provide 
comprehensive responses in a 30-day window. The 
Housing Ministry was also concerned that the con￾densed timeline increased the risk that owners of lands 
being added to the Greenbelt as part of the Paris Galt 
Moraine addition would not even be aware that their 
lands were being added to the Greenbelt and that 
there would be insufficient time for staff to meet with 
landowners. 
The Housing Ministry cautioned that the proposed 
timelines to finalize changes to the Greenbelt’s bound￾ary immediately after the consultation period were 
“very aggressive” and would not allow for substantive 
changes to the proposal. The Housing Ministry noted 
that any analysis of comments by staff could only be 
high-level and likely only include a cursory review 
of submissions by impacted property owners and not 
a submission-by-submission review of the received 
comments. 

60
any of the proposed land removals as a result of public 
consultation.
4.8.3 The Public Was Not Effectively Consulted 
on the Repeal of the Duffins Rouge Agricultural 
Preserve Act, 2005
On November 16, 2022, the Minister of Municipal 
Affairs and Housing introduced a bill in the Legislature 
to, among other things, repeal the Duffins Rouge Agri￾cultural Preserve Act, 2005 (DRAP Act), as described 
in Section 2.3.4. However, we found that the Ministry 
of Natural Resources and Forestry (Natural Resources 
Ministry), which was responsible for the DRAP Act, did 
not consult the public on this proposal.
The EBR Act requires a minister to consult on pro￾posals to amend or repeal environmentally significant 
acts, unless an exception under the EBR Act applies. In 
this case, the Natural Resources Minister deemed that 
an exception applied, on the basis that the environ￾mentally significant aspects of the proposal to repeal 
the DRAP Act had already been considered in the 
public consultation process to amend the Greenbelt’s 
boundary. Accordingly, on November 22, 2022, the 
Natural Resources Ministry posted an exception notice 
on the Environmental Registry explaining that consul￾tations had been undertaken or were under way on the 
Housing Ministry’s Environmental Registry notices for 
the 2022 proposal to amend the Greenbelt’s boundary, 
and included links to those notices. 
We found, however, that none of the Environmental 
Registry notices to amend the Greenbelt’s boundary 
referred to the DRAP Act by name, any of the agricul￾tural and conservation easements protected under it, or 
its potential repeal. Therefore, members of the public 
who reviewed those notices could not have known from 
their content that the DRAP Act was also going to be 
repealed.
Moreover, the exception notice stated that there 
would be no additional environmental impacts that 
would result from the proposed repeal of the DRAP 
Act that had not already been outlined in the proposal 
notices to amend the Greenbelt’s boundary. However, 
considered when making decisions about the proposal. 
We found that, consistent with the warnings it had 
provided to government, the Housing Ministry’s Green￾belt Project Team could not complete a comprehensive 
analysis of all the comments it received in time to fully 
inform decision-making. Instead, the Greenbelt Project 
Team only summarized the main themes. The team 
noted that this constraint was because of the limited 
time it had to review the large number of comments 
received.
Feedback received on the proposals was over￾whelmingly negative, and many commenters included 
similar feedback on related proposals (for example, on 
Bill 23, the More Homes Built Faster Act, 2022). Themes 
included: concerns for protection of environmental and 
agricultural lands; opposition to land swaps and per￾ceived partisan approaches to Greenbelt amendments; 
and demands for policies to address the affordability of 
housing and densification of existing settlement areas. 
There was also criticism of the short timeline of the 
consultation.
Affected conservation authorities expressed oppos￾ition to the proposed removals and were unsupportive 
of the approach taken to the Greenbelt amendments. 
Agricultural groups were also opposed, with many 
requesting a complete withdrawal of the proposal. 
Their concerns were mainly about the loss of viable 
agricultural land and the impact that the proposed 
changes would have on the agricultural system. The 
building and development sector was supportive of the 
proposal, with most of these commenters expressing 
interest in more opportunities for Greenbelt removals. 
Environmental groups were extremely critical. They 
opposed a land-swap approach, and identified a wide 
range of potential negative impacts related to the loss 
of agricultural lands, loss of biodiversity and increased 
sprawl at a cost to the environment. See Section 4.7.2
for some of the key environmental risks raised.
The Housing Ministry communicated to the gov￾ernment that the feedback it received on the proposal 
notices relating to amending the Greenbelt’s bound￾ary was overwhelmingly negative. Nevertheless, the 
Housing Ministry stated that no changes were made to  

Special Report on Changes to the Greenbelt 61
formal agreements governing the relations between 
First Nations or other Indigenous peoples and Can￾adian governments. Historical and modern treaties 
define ongoing rights and obligations on all sides, and 
may address:
• title or rights to land;
• rights to use and manage lands and resources, 
such as hunting and fishing rights;
• self-government; and
• economic, cultural and social rights.
The Supreme Court of Canada has consistently 
confirmed that the Crown must act honourably in dis￾charging its Duty to Consult, and that fulfilment of the 
duty must be meaningful.
The Greenbelt Plan specifies that “this Plan must be 
implemented in a manner that is consistent with the 
recognition and affirmation of existing Aboriginal and 
treaty rights under section 35 of the Constitution Act, 
1982. The Ontario government shall consult with First 
Nations and Métis communities on decisions concern￾ing the use of Crown land and resources that may affect 
Aboriginal and treaty rights within the area of the 
Greenbelt Plan.” 
Greenbelt Removals and Indigenous Treaty Lands
The majority of the land removed from the Green￾belt in 2022 is covered by the 1923 Williams Treaties 
and multiple treaties with the Mississaugas of the 
Credit First Nation (MCFN). Rights under these treat￾ies include harvesting rights in certain areas (such as 
rights to hunt, fish, trap and gather). After lengthy 
litigation about the terms and implementation of 
the Williams Treaties, the Government of Canada, 
the Province of Ontario and the Williams Treaties 
First Nations (Alderville First Nation, Beausoleil First 
Nation, Chippewas of Georgina Island, Chippewas of 
Rama, Curve Lake First Nation, Hiawatha First Nation 
and Mississaugas of Scugog Island) reached a settle￾ment agreement in 2018 that reaffirmed continuing 
treaty harvesting rights, entitled each First Nation to 
add up to 11,000 acres of land to their reserve land, 
and provided an apology and financial compensation to 
the First Nations.
neither the exception notice nor the Greenbelt proposal 
notices communicated to the public that there were 
any environmental impacts at all, even though the 
Greenbelt Project Team knew that the DRAP land site 
contained approximately 2,600 acres of Natural Herit￾age System lands. 
Through our work, we determined that the govern￾ment was aware that development on these lands could 
negatively affect agriculture and natural heritage fea￾tures, and that the natural heritage system in the DRAP 
lands connects to other natural heritage systems in the 
Greenbelt and surrounding area.
Because of the Natural Resources Ministry’s use of 
the exception notice, the public did not have complete 
information or an effective opportunity to provide 
comments on the proposal to repeal the DRAP Act. 
Moreover, the Housing Ministry did not consider all 
of the comments it received on the Greenbelt propos￾als (see Section 4.8.2). On the basis of the exception 
notice, the Natural Resources Ministry did not consider 
any of the comments submitted on the Greenbelt pro￾posals prior to the enactment of the DRAP Act’s repeal 
on December 8, 2022.
4.9 Indigenous Communities and
Leaders Say the Province Failed to
Properly ConsultThem on Greenbelt
Changes
According to First Nations leaders we spoke to, the 
extent and timing of the Housing Ministry’s consulta￾tion with Indigenous communities was insufficient to 
meet the Province’s Duty to Consult with regards to 
treaty rights and other rights that apply to the areas 
removed from the Greenbelt in 2022.
Duty to Consult and Accommodate Obligations
The “duty to consult and accommodate” refers to the 
Crown’s, including Ontario’s, constitutional obliga￾tion to consult with and accommodate the concerns 
of Indigenous peoples where it contemplates deci￾sions or actions that may adversely impact asserted or 
established Indigenous or treaty rights. Treaties are  

62
that while they received a notification letter from the 
government, they received no meeting requests, and 
there was no attempt to conduct risk mitigation. MCFN 
noted that consultation should begin when the thought 
of a strategic idea is created, and notice should be given 
at the earliest opportunity.
We also met with the elected council of the Six 
Nations of the Grand River, who told us that the legal 
Duty to Consult and accommodate must occur prior 
to changes being passed if First Nations’ interests are 
to be addressed. However, they expressed that they 
were not consulted nor engaged in this process, and 
that effective consultation would begin when an idea 
for land-use changes is first formulated, not after a 
decision is made. Representatives we spoke to told us 
that these Greenbelt removals also go against their 
Nation’s climate change initiatives and that the process 
undertaken by the Housing Ministry fails to meet their 
environmental standards. 
Overall, members of First Nations we met with told 
us that the Province does not seem open to discussing 
the adverse impacts of Greenbelt removals to treaty 
lands and rights, and that, should development occur 
on these lands, the removals could have profound 
impacts on treaty rights, especially in terms of har￾vesting crops such as wild rice. We were told that, in 
order to meet the Duty to Consult, the Crown must go 
beyond notice of an intended decision, ensuring that 
each impacted Indigenous community is given ample 
time to review the matter and provide comment, and 
that the Crown must consider the concerns of each 
impacted Indigenous community. Moreover, we were 
told that development on these lands removed from 
the Greenbelt did not prepare communities for major 
climate change risks, such as loss of ecosystems and 
flooding. 
Another First Nation mentioned it is important to 
protect biodiversity and water resources across the 
Greenbelt and the Oak Ridges Moraine, and that more 
development compromises the environment. Some 
First Nation members we spoke to felt that there was 
insufficient time to consult on these Greenbelt amend￾ments, and the process was not meaningful, as the First 
Nation did not feel it could influence the decision at 
Specific First Nations Perspectives
In the course of our audit work, we spoke with rep￾resentatives of four First Nations affected by the 
Greenbelt changes, namely the Mississaugas of the 
Credit and the Alderville First Nation (in person), the 
Mississaugas of Scugog Island (MSIFN) and the Six 
Nations of the Grand River (virtually). We met the 
Chiefs of three of the First Nations, the elected council 
of one First Nation, as well as, in some cases, other 
members of each community. All First Nations that we 
met with reiterated that they were unsupportive of 
the removals from the Greenbelt and that the process 
undertaken by the Housing Ministry did not represent 
effective or meaningful consultation.
According to the First Nations representatives that 
we spoke to, the Province’s decision to remove certain 
lands from the Greenbelt for housing triggers the Duty 
to Consult and accommodate, as housing develop￾ment on treaty lands may impact the First Nations’ 
harvesting rights. Moreover, the terms of the Williams 
Treaties Settlement allow each of the First Nations 
party to the treaty to add 11,000 acres to their reserve 
lands, which could be acquired from Canada, Ontario 
or private landowners. All First Nations that we spoke 
to also stressed the importance of consultation occur￾ring before action is taken that may impact Indigenous 
rights and treaty lands, not during or afterwards.
The Chief and other members of the Mississaugas 
of the Credit First Nation told us that treaty rights are 
being disregarded, and that the government’s Duty 
to Consult obligation was not fulfilled in relation to 
the 2022 Greenbelt removals. They told us that there 
is a high standard to meet for consultation with them 
due to the size of their lands and since many removals 
affect their treaty lands, and that a 30-day comment 
period cannot replace a consultation process since the 
obligation is with the government to consult, not with 
First Nations. Members of the community told us there 
was neither sufficient consultation nor a meaning￾ful opportunity to examine potential impacts. They 
asserted that this process should ideally involve a com￾plete assessment of impacts to MCFN rights, and should 
consider risks, mitigative measures or accommoda￾tions. The Chief and community members explained  

Special Report on Changes to the Greenbelt 63
land was already removed from the Greenbelt. While 
the Housing Ministry wrote to the MCFN and offered 
to meet with them in November 2022, as of June 30, 
2023, the MCFN and Housing Ministry had not yet met. 
The MCFN told us that the Housing Ministry has not 
attempted to engage with their community on potential 
impacts to MCFN rights and risk mitigation. MCFN told 
us that poor consultation has resulted in a situation 
where the Ontario government’s decisions are vulner￾able to challenge, including costly and lengthy court 
proceedings to protect their rights. 
4.10 No Formal Framework
Established to Monitor Whether
Developers Are Fulfilling Government
Conditions on Greenbelt Land
Removals
Although the government publicly communicated its 
expectations for housing to be built on the land sites 
removed from the Greenbelt in December 2022, we 
found that a performance measurement framework 
has not been developed to monitor whether developers 
will be able to start housing before 2025 and continue 
to build on this land. Moreover, the Province has not 
fulfilled a commitment to develop, monitor and report 
on performance indicators to measure the effectiveness 
of the Greenbelt Plan’s policies themselves in achieving 
the goals in the Greenbelt Plan.
The government’s expectations related to the land 
sites removed from the Greenbelt in December 2022 
were communicated publicly through the Ministry’s 
notice on the Environmental Registry of Ontario and 
included stipulations that: 
• the government would begin to return lands 
back to the Greenbelt should developers not 
show sufficient progress on building homes on 
the removed lands;
• the proponents would pay, upfront and in full, 
for the infrastructure to service these lands;
• the removed lands would result in at least 
50,000 housing units; and
• construction of new homes will begin on these 
lands by no later than 2025, and significant 
all. Moreover, it was raised that First Nations under the 
Williams Treaties have a right to 11,000 acres of land to 
be added to their reserve lands, and that these Green￾belt removals may impact those prospects.
Extent of Ministry Consultation with First Nations
The extent of the Housing Ministry’s consultation 
with First Nations communities consisted of: sending 
emails to 12 First Nation Chiefs and Indigenous leaders 
in November 2022 with links to information about 
the 2022 Greenbelt boundary amendment proposals 
that were posted on the Environmental Registry of 
Ontario during the public consultation period (Nov￾ember 4 to December 3, 2022); inviting First Nations 
communities to contact a Ministry Director to discuss 
or provide feedback or meet with them; having virtual 
meetings with three First Nations; and sending another 
email in December 2022 informing the First Nations of 
the Greenbelt amendment decision. 
Several First Nations communities responded to 
the Housing Ministry’s letter, opposing the removals of 
lands from the Greenbelt and criticizing the Ministry 
for failing to consult in a meaningful way. Among the 
concerns raised were that the removals will have an 
adverse impact on Indigenous and treaty rights. This 
is because the proposal would remove the permanent 
protection for natural heritage and water systems 
that sustain ecological health. Removing lands from 
the Greenbelt would reduce the lands available to the 
First Nations to exercise their treaty harvesting rights, 
inhibit the movement of wildlife, potentially frag￾ment or destroy wildlife habitat, and lead to potential 
loss of many of the species the First Nations rely on. 
Indigenous leaders also told the Ministry of their strong 
objections to the lack of prior notice of the proposed 
Greenbelt changes and the Ministry’s failure to request 
meaningful consultation with them. They also noted 
that the Ontario government’s constitutional Duty 
to Consult with Indigenous governments must occur 
before, not after, action is taken that could affect their 
rights and lands.
The Housing Ministry met (virtually) with only two 
of the seven Williams Treaties First Nations, and one 
of those meetings took place in January 2023, after  

64
Furthermore, both the 2005 Greenbelt Plan and 
the 2017 updated Greenbelt Plan include provincial 
commitments to develop, monitor and report on per￾formance indicators to measure the effectiveness of 
the Plan’s policies. To this end, in 2015, the Housing 
Ministry released a report titled Performance Indica￾tors for the Greenbelt Plan – Part 1, 2015 with a partial 
set of performance indicators, including indicators for 
the Niagara Escarpment Plan and Oak Ridges Moraine 
Conservation Plan. This report found that the rate of 
housing construction outside the settlement areas had 
tripled over time, and less growth proportionally was 
occurring within settlement areas. In other words, 
development was spreading over a larger area over 
time rather than being concentrated in select areas. 
The Housing Ministry committed in the 2015 report 
to future reporting on Greenbelt Plan performance 
indicators on infrastructure, rural communities, the 
agricultural economy, aggregates, tourism, recreation 
and cultural heritage. However, no subsequent reports 
have been publicly released.
4.11 Developers and Their
Representatives Lobbied for Removal
of 12 of 15 Greenbelt Sites in the Few
Months Leading up to Site Removals
As the events laid out in Section 4.2 detail, political 
staff working in the Minister’s Office selected and 
ensured the removal of specific parcels of land from the 
Greenbelt Area. 
We found that 12 of the 15 parcels of land chosen 
for removal from the Greenbelt had been, as noted by 
the Housing Minister’s Chief of Staff, requested for 
removal by developers or their representatives. Many 
of these individuals had advocated for the removal in 
emails and in-person meetings within a few months 
prior to their removal. For example, one lawyer repre￾senting three housing developers emailed the Chief of 
Staff on September 27 and 29, 2022, providing site￾specific details for the land they sought to develop. 
About 92% of the land that was ultimately removed 
from the Greenbelt was requested to be removed by the 
developers the Chief of Staff dined with at the Building 
progress on approvals and implementation will 
be achieved by the end of 2023.
However, we found that as of June 2023, the 
Housing Ministry and the government have not further 
defined these expectations so that they can be meas￾ured, nor have they established performance indicators 
to do so. 
As noted in Section 4.6.2, the Office of the Provin￾cial Land and Development Facilitator is responsible for 
facilitating negotiations between housing developers, 
municipalities and the Province for the 15 land sites 
removed from the Greenbelt in 2022, with the goal of 
reaching a signed and binding agreement. The Prov￾incial Land and Development Facilitator identified the 
framework that the negotiation and agreements are 
being conducted under, including that:
• progress milestones will be built into the 
development agreements on a site-by-site basis, 
and at a minimum, will include substantial com￾mencement of construction of services for the 
initial phase of development on every site by 
2025;
• infrastructure and related costs will be paid by 
developers in full and upfront; and
• a minimum number of housing units is to be 
included in each development agreement, and 
this number is being negotiated on a site-by-site 
basis. As of July 2023, the Provincial Land and 
Development Facilitator projected that the gov￾ernment’s minimum target of 50,000 housing 
units will be met. 
However, as of June 2023, agreements had not been 
finalized for any of the 15 land sites removed from the 
Greenbelt in 2022. Under the Helping Homebuyers, Pro￾tecting Tenants Act, 2023, the Minister has the power 
to make an order requiring an owner of land to enter 
into an agreement with the Minister or a municipality 
in matters where the Provincial Land and Development 
Facilitator or the Deputy Facilitator has been directed 
by the Minister to advise, make recommendations or 
perform any other functions with respect to the land. 
Until an owner has entered into an agreement required 
by order, they cannot use the land for a new purpose, 
but existing uses can continue. 

Special Report on Changes to the Greenbelt 65
the staff of a ministry or the Ontario Provincial Police, 
must register with the Office of the Integrity Commis￾sioner of Ontario. The Integrity Commissioner has the 
power, through the Member’s Integrity Act (Integrity 
Act) to investigate potential non-compliance with the 
Lobbyists Registration Act, 1998. Notably, a lobbyist 
cannot knowingly place a public office holder in a pos￾ition of real or potential conflict of interest. 
The Office of the Integrity Commissioner issues 
annual reports. Those annual reports highlight many 
areas that could be considered to strengthen lobbyist 
registration and regulatory powers of the Office of the 
Integrity Commissioner.
4.12 Potential Contravention of the
Public Service of Ontario Act, 2006
by the Housing Minister’s Chief
of Staff
During our work, we noted extensive involvement of 
the Housing Minister’s Chief of Staff in what we would 
have expected to have been an operational process 
led by the Housing Minister’s public service staff. We 
were advised by the Secretary of the Cabinet that it 
is not unusual in the development of materials for 
the Cabinet decision-making process to involve both 
the non-political public service and Minister’s Office 
political staff, namely the Chief of Staff or Directors 
of Policy, to work iteratively in developing a Cabinet 
submission. Although the Housing Ministry highlighted 
the risks of considering only specific land sites for 
removal and the limitations of the criteria being used, 
senior public service staff in the Housing Ministry con￾tinued to work with the Housing Minister’s Chief of 
Staff. Their view was that certain land sites were to be 
removed from the Greenbelt; hence selection criteria 
were modified to achieve this end. 
As previously noted, almost all of the properties 
removed from the Greenbelt were identified and were 
provided to the Greenbelt Project Team directly by 
the Housing Minister’s Chief of Staff after he received 
material from or on behalf of certain developers. These 
developers who had direct access to the Chief of Staff 
Industry and Land Development Association’s (BILD’s) 
Chair’s Dinner on September 14, 2022. 
At this event, the Housing Minister’s Chief of Staff 
and Deputy Chief of Staff were seated at the same table 
as prominent housing developers and a registered 
lobbyist. The Chief of Staff told us two developers 
provided him with packages at this event containing 
information about two sites from the Greenbelt: the 
DRAP lands in Durham Region (Site #1 in Figure 4) 
and the Bathurst-King site in York Region (Site #9). 
We were told that, later, when the Greenbelt Project 
Team advised the Chief of Staff of the need for more 
detailed information about the initial eight sites pro￾posed for removal, and the Chief of Staff contacted the 
housing developer for the DRAP site, the developer 
provided the Chief of Staff with requests to remove 
additional sites: the Book Road site in Hamilton (Site 
#4), Leslie-Elgin (Site #12) and Block 41 Lands (Site 
#13) from the Greenbelt. These three sites were ultim￾ately removed from the Greenbelt. 
Lobbyists are paid to try to influence the decision￾making of those in positions of government authority 
and public office. They act on behalf of themselves, an 
employer or client who may seek such actions as the 
introduction or repeal of particular laws, regulations, 
policies, programs, funding and contracts. Developers 
are considered lobbyists when lobbying on behalf of 
their organizations.
Lobbying is a practice available to those who have 
the means to fund it and who know how to contact 
politicians or their political public service staff. The 
private interests that lobbyists are paid to advance 
can be at odds with the public’s interest. Thus, lobby￾ing has the potential to influence government to make 
decisions that do not represent the interests of the 
majority. Although it is a driver of political change and 
has always been part of Canadian politics, lobbying is 
closely related to patronage (the exchange of personal 
gifts or favours) and carries with it the potential for 
conflict of interest. Therefore, it is usually closely scru￾tinized and regulated. 
For example, those who lobby the Ontario govern￾ment, including its elected officials or their staff, or  

66
are not elected, yet they are politically partisan. They 
work on behalf of the elected politicians and the party 
that is in power, in paid public service positions such 
as Chiefs of Staff and Directors of Policy within a Min￾ister’s Office or Premier’s Office. Refer to Appendix 7
for an organizational chart distinguishing political staff 
from public service employees, and showing the rela￾tionships of those involved in decision-making about 
the Greenbelt boundary changes. 
The participation of political staff employed in 
Ministers’ Offices in operational and administrative 
decisions is not unprecedented; their participation is 
governed by the rules in the Public Service of Ontario 
Act, 2006 (political activity rules and conflict of inter￾est rules) that also apply to regular public servants, 
and the particular rules under Part IV (sections 66 to 
70) that have been established to provide specific oper￾ational guidance to them. Minister’s staff are appointed 
under section 47 of the Public Service of Ontario Act, 
2006 by the Premier’s designate. This is the Chief of 
Staff and the Director of Human Resources in the Pre￾mier’s Office. 
Staff in the Premier’s Office and Ministers’ Offices, 
and public servants, are bound by ethical standards 
for the performance of their jobs and are governed 
by the Public Service of Ontario Act, 2006 and O. Reg. 
382/07—Conflict of Interest Rules for Public Servants 
(Minister’s Offices) and Former Public Servants (Minis￾ters’ Offices)—under this act. 
The ethics executive for public servants employed 
in Ministers’ Offices is the Integrity Commissioner of 
Ontario. Public servants employed in Ministers’ Offices 
are required to comply with the conflict of interest 
regulation made under the Public Service Act of Ontario, 
2006. Section 6 of O.Reg.382/07 states:
6. (1) When performing his or her duties to the 
Crown, a public servant shall not give preferential 
treatment to any person or entity, including a person 
or entity in which the public servant or a member of 
his or her family or a friend has an interest.
(2) When performing his or her duties to the Crown 
a public servant shall endeavour to avoid creating the 
appearance that preferential treatment is being given 
to a person or entity that could benefit from it.
stood to significantly benefit financially by having 
received preferential treatment through the use of a 
biased process that was non-transparent to the public. 
Although the Housing Minister informed us that he 
was unaware of what his Chief of Staff was working on, 
and his Chief of Staff told us that he did not inform his 
Minister of what he was working on, the Minister ought 
to have known that the Chief of Staff was the primary 
recipient and provider of lands to the Greenbelt Project 
Team, especially given the high-profile, politically 
sensitive and controversial nature of the Greenbelt 
Project. 
We spoke with the Secretary of the Cabinet, who 
informed us that the general practice in Ontario is for 
the Premier, the Executive Council and its ministers to 
make policy decisions that are then operationalized 
by the public service and typically overseen by Deputy 
Ministers. However, we were told that in Ontario, there 
is no standard legislated divide between the policy and 
operational responsibilities of ministers and political 
staff working in their offices, and deputy ministers 
and staff working in the permanent public service. 
The Secretary of the Cabinet told us that the degree 
to which a publicly elected minister or that minister’s 
staff, or regular public servants, participate in the 
administration and implementation of policy decisions 
“can vary depending on the complexity of the matter 
and whether certain of the implementation decisions 
attract public policy considerations that may require 
the weighing of economic, social and political factors.” 
While there are some examples of statutory respon￾sibilities being assigned to specific individuals who 
then work independently of others in a ministry, 
Ontario contemplates a model where all work together 
to support the mandate of the ministry, with the min￾ister having overall responsibility and charge of that 
ministry.
In this leadership model, non-political public sector 
employees (permanent public sector employees) work 
to support the mandate of their ministry, and may do 
so under the direction of political public service staff. 
The minister, who is in charge of and responsible for a 
ministry, is an elected politician appointed to the port￾folio by the Premier. Political public service employees  

Special Report on Changes to the Greenbelt 67
Information and Information Technology (I&IT) 
resource guidelines, forwarding government informa￾tion to personal accounts is not appropriate because of 
cybersecurity concerns. It also outlines that using non￾government resources to conduct government business 
is unacceptable.
Under the OPS Acceptable Use I&IT Guidelines: 
“only the work email account (e.g., @Ontario.ca) 
should be used for government work.” The use of 
non-OPS managed platforms and services including 
Zoom for government work also requires prior approval 
from an OPS manager.
Communication between lobbyists and political 
staff using their personal email accounts also creates 
the perception of preferential access and treatment, 
and thereby an unfair advantage to those receiving 
unauthorized confidential information from political 
staff. 
It is important to note that any communication 
between lobbyists and political staff about government 
business is still subject to the Freedom of Information
and Protection of Privacy Act, and is not excluded from 
this act even if the communication occurred on a per￾sonal email account.
4.15 Record-Retention Policies
for Political Staff Communications
Needs Reinforcing
During the course of our audit, we observed that 
emails were regularly being deleted by political staff. 
However, email correspondence relating to the under￾taking to make changes to the Greenbelt was not 
exempt from the Archives and Recordkeeping Act, 2006, 
(Recordkeeping Act) and should not have been deleted. 
We also noted that descriptions of meetings on political 
public service employees’ calendars were not fulsome 
and clear so as to be able to ascertain the purpose of 
various meetings.
The Recordkeeping Act governs the manage￾ment, destruction and preservation of the electronic 
and paper records of public bodies. This ensures that 
records related to the activities of all public bodies are 
available and fosters government accountability and 
(3) A public servant shall not offer assistance to a 
person or entity in dealing with the Crown other than 
assistance given in the ordinary course of the public 
servant’s employment.
4.13 Risk of Additional Non￾Compliance by Political Public Service
Staff with Public Service of Ontario 
Act, 2006
During the course of our audit, we found several exam￾ples where it appears that political public service staff 
gave preferential treatment to lobbyists, potentially in 
violation of the Public Service of Ontario Act, 2006 (see 
Section 4.12). This included providing information 
about the ownership and purchasing of lands, setting 
up investment-opportunity meetings with Minister’s 
Office staff, and the consideration of draft legislative 
and regulatory changes. 
As well, during the course of our audit, we found 
situations where lobbyists working for developers 
emailed political staff to suggest amendments to legis￾lation. In these cases, political staff copied and pasted 
the wording of the lobbyists’ proposed amendments 
into a new document, which they then forwarded on 
to Deputy Ministers for inclusion in legislative pack￾ages. Senior non-political public servants, who were 
directed by political staff to carry the proposal forward, 
appeared unaware that the proposed amendments had 
originated from a lobbyist.
4.14 Use of Personal Email
Accounts Contrary to Public Service
Cybersecurity Guidelines
During the course of our audit, we noted that political 
staff received emails from lobbyists and other external 
parties on their personal email accounts that they then 
forwarded to their government email. Conversely, 
there were occasions when government emails were 
forwarded by political staff from their government 
accounts to their personal email accounts.
According to the Ontario Public Service (OPS) 
Securing Your Workplace Guidebook and the  

68
transparency. The records schedule outlined in the 
Recordkeeping Act dictates how and when relevant 
public records are to be maintained, transferred, 
altered or destroyed.
The obligations around retaining and destroying 
public records apply to ministers, their political and 
office staff as well as ministry program area staff. 
Excluded records include ministers’ personal, political 
caucus and constituency records. Exemptions to the 
records schedule are possible for: an access request 
made under the Freedom of Information and Protection 
of Privacy Act; requests by the Legislative Assembly; 
legal discovery or other proceedings; or public inquir￾ies through the Public Inquiries Act, 2009 (Inquiries 
Act).
Any information used to document, support or 
direct government decision-making, policy develop￾ment, activities or operations is captured by the 
retention and final disposition schedule outlined in the 
Inquiries Act. Relevant records must not be transferred, 
altered, destroyed or otherwise disposed of until such 
time that one has been notified that the matter is 
concluded.
Files that relate to the development and delivery of 
the government’s policy and legislative agenda, includ￾ing issues under consideration by the minister that may 
form part of the government’s policy agenda, must also 
be retained. This includes submissions from the public. 
With regard to stakeholder relations, any correspond￾ence, notes, meeting agendas or minutes, and messages 
including phone calls must also be retained. Ministers’ 
correspondence and communications records need to 
be retained while the minister is in office and four years 
after the file closes, at which point the records transfer 
to the Archives of Ontario. 

Special Report on Changes to the Greenbelt 69
Appendix 1: Timeline of Key Events
Prepared by the Office of the Auditor General of Ontario 
1971 Progressive Conservative Party of Ontario forms majority government.
1972 Land that would later become the Duffins Rouge Agricultural Preserve (DRAP) is expropriated by the Province from private 
owners for the purpose of supporting a proposed federal airport.
1973 Niagara Escarpment Planning and Development Act passes, with the purpose “to provide for the maintenance of the 
Niagara Escarpment and land in its vicinity substantially as a continuous natural environment, and to ensure only such 
development occurs as is compatible with that natural environment.” 
1985 Province approves the Niagara Escarpment Plan to guide land-use planning within the Niagara Escarpment Plan Area. 
1999 Regional Municipality of Durham, the City of Pickering and the Province begin to sell back previously expropriated 
preserve land to the original landowners or tenant farmers after the airport was never built.
Purchasers are required to agree to a conservation easement under the Conservation Land Act to protect the land for 
agricultural uses in perpetuity. The easements are held by the City of Pickering, and the prices are based on the value 
of lands used for agricultural purposes.
2001 Oak Ridges Moraine Conservation Act, 2001 passes, providing authority for the creation of the Oak Ridges Moraine 
Conservation Plan for the Oak Ridges Moraine Area (an environmentally sensitive, geological landform in southcentral 
Ontario that stretches 160 kilometres from the Trent River in the east to the Niagara Escarpment in the west, covering 
approximately 470,000 acres). 
2002 Oak Ridges Moraine Conservation Plan is established, providing direction on land use and resource management for the 
land and water located within the moraine. 
2000 
 to 
2004
Approximately 3,000 acres of the 4,700 acres of land in the Duffins Rouge Agricultural Preserve is purchased, 
mainly by developers. 
2003 Liberal Party of Ontario forms majority government.
2004 Greenbelt Protection Act, 2004 passes and the Ontario government creates the Greenbelt Task Force to assess and 
provide recommendations on the potential Greenbelt boundary. 
2005 • Without consulting the Province, the City of Pickering removes the conservation easements on two-thirds of the 
properties sold by the Province in the Duffins Rouge Agricultural Preserve.
• Greenbelt Act, 2005 passes, defining and approving the Greenbelt boundary, and establishing the Greenbelt Plan. 
The Greenbelt Area includes areas covered by the Niagara Escarpment Plan and the Oak Ridges Moraine Conservation Plan. 
• Duffins Rouge Agricultural Preserve Act, 2005 passes, reinstating the easements on the Duffins Rouge Agricultural 
Preserve.
2005 
 to 
2007
Large housing developer seeks to develop lands in the DRAP and takes the Province to court. The court rules against 
the developer. 
2013 Housing Ministry creates a new Urban River Valley (URV) designation in the Greenbelt Plan and adds 630 acres in the 
Glenorchy Lands to the Greenbelt as URVs. 
Continued on page 70 

70
2015 
 to 
2017
As part of the Province’s Co-ordinated Land Use Planning Review of Ontario’s four provincial land-use plans in the 
Greater Golden Horseshoe, the Housing Ministry undertakes the required 10-year review of the Greenbelt Plan, with 
the participation of municipalities, staff within the Ministry of Municipal Affairs and Housing and the Ministry of the 
Environment and Climate Change, developers, Indigenous communities, environmentalists and other stakeholders. 
The review includes three rounds of public consultation on the Environmental Registry of Ontario (Environmental 
Registry) for 90 days, 174 days and 47 days respectively, resulting in: 
• the addition of 24,958 acres to the Greenbelt (including 21 URVs); and 
• the removal of 371 acres across 17 areas from the Greenbelt (minor boundary refinements). 
2018 • June: Progressive Conservative Party of Ontario forms a majority government. 
2020 • December: More than half of the members of the Greenbelt Council resign over the Province’s decision to fast￾track development on the Lower Duffins Creek wetland east of Toronto and the intent to disempower conservation 
authorities. (Chair resigns December 7.)
2021 • February: Housing Ministry posts a proposal notice on the Environmental Registry for a 61-day consultation period to 
expand the Greenbelt by adding 13 URVs and lands from the Paris Galt Moraine. 
• March: New rules are implemented to make the Greenbelt Council’s advice confidential and restrict its members, 
ability to talk to journalists as per a new media protocol. The Chair becomes restricted to only answering questions 
about the Council’s mandate and processes, while other members can answer questions about their roles and 
professional backgrounds—but are bound to keep Council deliberations confidential.
• December: Ontario government establishes the Housing Affordability Task Force, with a mandate to provide the 
Minister with recommendations to accelerate progress in closing the housing supply gap to improve housing 
affordability.
2022 • February 8: Housing Affordability Task Force concludes in its report that Ontario needs to build 1.5 million new 
homes over the next 10 years to fill the housing gap. 
• March: Greenbelt Council’s terms of reference are changed to weaken its mandate to protect the environment, 
including to make its advice confidential.
• March 24: Housing Ministry decides not to proceed with expanding the Greenbelt into the Paris Galt Moraine area 
and posts its decision on the Environmental Registry. The Ministry’s rationale is that it needs to understand how the 
proposed addition may impact growth in housing and employment areas. The Ministry moves forward with the next 
phase of consultation to add 13 URV areas to the Greenbelt, and Ministry staff prepared maps for the new URVs and 
boundary amendments for the Greenbelt Regulation. 
• March 24: Housing Ministry posts a proposal notice on the Environmental Registry for a 30-day consultation period 
to expand the Greenbelt by adding or expanding the 13 URVs consulted on in the first phase of consultation. 
• April 27: On the day they are scheduled to submit the proposal to government for final approval, Ministry staff receive 
direction that the Province is no longer proceeding with the proposal to expand the Greenbelt by adding or expanding 
the 13 URVs. 
• June 2: Progressive Conservative Party of Ontario forms a second consecutive majority government. 
Continued on page 71
Appendix 1: Timeline of Key Events (continued)
Prepared by the Office of the Auditor General of Ontario  

Special Report on Changes to the Greenbelt 71
2022 • June 29: Minister of Municipal Affairs and Housing (Housing Minister) receives a mandate letter from the 
Premier outlining the government’s priorities and policy directions for the Housing Ministry. The stated goals 
include: “In Fall 2022, complete work to codify processes for swaps, expansions, contractions and policy updates 
for the Greenbelt,” and “This should include a comprehensive plan to expand and protect the Greenbelt.” 
• July 4: Housing Minister’s Chief of Staff is appointed by the Premier’s Office Chief of Staff. 
• August 9: The Building Industry and Land Development Association (BILD) and the Ontario Home Builders’ 
Association (OHBA) release a five-point plan to address the housing crisis in Ontario. Number three on the plan is 
to “make new land available to build housing.”
• August 11: Premier’s daughter’s stag and doe party. News media report that developers attend the party.
• August 30: Upon request, Housing Ministry briefs the Housing Minister's Chief of Staff on potential tools available 
to amend the Greenbelt boundary, comparing system-wide and site-specific approaches.
• September 14: BILD holds its Chair’s Dinner. Two prominent housing developers approach the Housing Minister’s 
Chief of Staff and provide him with packages that contain information on two sites in the Greenbelt (Sites #1 and 
#9 in Appendix 4). Shortly thereafter, one of the developers provides the Chief of Staff with additional information 
plus information related to Sites #4, #12 and #13. These five sites ultimately make up 92% of all land removed 
from the Greenbelt in 2022. 
• September 15: Sale of Site #9 in King Township (next to the Newmarket boundary) is finalized and the title is 
transferred to the housing developer. The final sale price is $80 million.
• September 16: Housing Minister’s Chief of Staff informs the Housing Ministry that the government wants to 
consult on removing lands from the Greenbelt using a site-specific approach. Housing Ministry indicates that the 
Housing Minister’s Chief of Staff communicates three priority sites for removal from the Greenbelt: Sites #1, #4 
and #9 as listed in Appendix 4.
• September 25: Premier’s daughter’s wedding. News media report that developers attend the wedding. Photographs 
of the seating arrangements for the wedding include the developer for Sites #10 and #14 in Appendix 4.
• September 27: Law firm sends requests directly to the Housing Minister’s Chief of Staff, by email, to have Site 
#15 removed from the Greenbelt.
• September 29: Same law firm sends letter to Housing Minister in an email to the Housing Minister's Chief of Staff 
requesting that Site #10 be rezoned through the Official Plan review of York Region. 
• September 29: Same law firm sends another request directly to the Housing Minister’s Chief of Staff, by email, to 
have Site #14 removed from the Greenbelt.
• October 3-5: Greenbelt Project Team is formed. Its six members are non-political public service staff in the 
Housing Ministry. 
• October 6: Housing Minister’s Chief of Staff provides Greenbelt Project Team with hardcopy information from 
packages he received on eight proposed land sites (Sites #1, #3, #4, #9, #12, #14, #15 and one not chosen for 
removal) as well as the initial criteria for removal.
• October 6-13: Greenbelt Project Team members are required to sign confidentiality agreements. Site #11 is 
identified by the Greenbelt Project Team as a proposed property for removal. 
Continued on page 72
Continued
Appendix 1: Timeline of Key Events (continued)
Prepared by the Office of the Auditor General of Ontario  

72
2022 • October 7: Housing Minister's Chief of Staff receives correspondence addressed to him from same law firm that 
corresponded on September 29, regarding the same property (Site #10). This letter requests Site #10 be removed 
from the Greenbelt and does not mention the Official Plan review. 
• October 13-31: Five USB keys are provided to Greenbelt Project Team by the Housing Minister's Chief of Staff 
containing information on proposed sites for removal (includes Sites #2, #5 and #13) and additional information 
on previously identified sites. 
• October 19: Sites #6, #7 and #8 and two sites that were not removed are provided by Housing Deputy Chief of Staff 
to the Housing Minister's Chief of Staff. These properties had been assessed through the Official Plan review and 
were proposed for removal because they are in the Greenbelt.
• October 24: Municipal elections are held, 11 days before notices related to the changes to the Greenbelt’s boundary 
are posted on the Environmental Registry on November 4, 2022. Some municipal councils are sworn in weeks 
after the election, limiting their ability to provide comments related to these notices by December 4, 2022, when 
the consultation period ended.
• October 25: Housing Ministry posts a proposal notice on the Environmental Registry to revoke the Central 
Pickering Development Plan, a provincial land-use plan that established policies for development in a designated 
area in Central Pickering as well as protecting the Duffins Rouge Agricultural Preserve from development. 
• October 26: Chair of Greenbelt Council resigns, replaced by Hazel McCallion as new Chair. 
• October 26: Housing Minister is briefed in person by Housing Ministry and Minister’s Chief of Staff on proposed 
removal of land sites from the Greenbelt. 
• October 27: Housing Ministry briefs staff in the Premier’s Office and Cabinet Office on proposed removal of land 
sites from the Greenbelt. (Premier is not present for briefing.) 
• October 31: Housing Ministry provides second briefing to the Premier’s Office and Cabinet Office on Greenbelt 
Project. (Premier is not present for briefing.) 
• November 1: Housing Ministry briefs Housing Minister/Associate Minister of Housing on the proposed removal of 
land sites from the Greenbelt. 
• November 1: Premier is briefed by political staff on the proposed removal of land sites from the Greenbelt.
• November 2: Cabinet approves Housing Ministry's proposal to begin public consultation process to amend the 
Greenbelt. (Cabinet members receive proposal material shortly before Cabinet meeting.)
• November 3: Property owners/developers are notified their land is being proposed for removal from the Greenbelt.
• November 4: Housing Ministry’s Deputy Minister and staff provide a briefing on Greenbelt land removal to Caucus. 
• November 4: Housing Ministry posts four proposal notices on the Environmental Registry and initiates a 30-day 
public consultation period to amend the Greenbelt by removing or re-designating 15 sites (including the Duffins 
Rouge Agricultural Preserve in Pickering), adding or expanding 13 Urban River Valleys and adding a portion of the 
Paris Galt Moraine.
• November 4: Mayors of affected municipalities are notified lands in their jurisdictions are being proposed for 
removal from the Greenbelt.
• November 7: Briefing on the Greenbelt Project is provided to the recently appointed Greenbelt Council.
Continued
Continued on page 73
Appendix 1: Timeline of Key Events (continued)
Prepared by the Office of the Auditor General of Ontario  

Special Report on Changes to the Greenbelt 73
2022 • November 16: Duffins Rouge Agricultural Preserve Repeal Act, 2022 is introduced in the Legislature. The 
proposed act removes additional protection from development for the majority of the area affected by the 
proposed Greenbelt amendments. 
• November 22: Ministry of Natural Resources and Forestry posts an exception notice on the Environmental 
Registry exempting the Duffins Rouge Agricultural Preserve Repeal Act, 2022 from the public consultation process, 
citing reliance on the ongoing public consultation for proposed Greenbelt amendments. 
• November 28: Legislature passes Bill 23, the More Homes Built Faster Act, 2022, which makes significant 
changes to the Planning Act, the Conservation Authorities Act, the Ontario Heritage Act and the Ontario Land 
Tribunal Act to support the implementation of the government’s housing strategy. 
• November 28: Member of Provincial Parliament requests Integrity Commissioner of Ontario investigate as to 
whether the Housing Minister and the Premier have contravened the Members’ Integrity Act, 1994. 
• December 4: During the 30-day public consultation period from November 4 to December 4, 2022, the Ministry 
receives over 35,000 responses, overwhelmingly in opposition to any removals or land swaps in the Greenbelt. 
• December 8: Legislature passes the Duffins Rouge Agricultural Preserve Repeal Act, 2022. 
• December 12: Housing Minister is briefed by the Housing Ministry on Greenbelt Project and the Premier’s Office 
political staff is briefed by the Housing Ministry. 
• December 14: Housing Ministry files O. Reg. 567/22 under the Greenbelt Act, 2005 and O. Reg. 568/22 under 
the Oak Ridges Moraine Conservation Act, 2001, implementing the Ministry’s proposed Greenbelt boundary 
changes, and O. Reg. 566/22, revoking Minister’s Zoning Order 154/03, which had protected the Duffins 
Rouge Agricultural Preserve from development, all of which were approved by the Cabinet earlier that day. The 
amendments remove approximately 7,400 acres from 15 areas of land, while adding approximately 9,400 acres 
of land elsewhere. No changes are made to the proposal to address the public’s concerns.
• December 14: On the recommendation of the Housing Minister, Cabinet revokes the Central Pickering Development 
Plan. 
• December 15: Lieutenant Governor proclaims the Duffins Rouge Agricultural Preserve Repeal Act, 2022 in force, 
repealing the Duffins Rouge Agricultural Preserve Act, 2005. 
• December 21: Housing Ministry posts decision notices on the Environmental Registry to notify the public of its 
decision to approve the 2022 Greenbelt changes, with no revisions, following the consultation period.
2023 • January 11: Auditor General of Ontario receives a joint letter from all three Ontario opposition party leaders 
requesting a value-for-money audit and an assessment of the financial and environmental impacts of the 
government’s decision to remove lands from the Greenbelt.
• January 18: Auditor General of Ontario announces her Office will conduct a value-for-money audit into the 
financial and environmental impacts of the recent Greenbelt changes.
• January 18: In submissions to the Integrity Commissioner of Ontario (as noted in the Office of the Integrity 
Commissioner’s January 18, 2023, report), the Housing Minister and Premier “advised that the selection of the 
affected lands was made by public servants who were subject to an enhanced confidentiality protocol and that 
the minister was briefed and accepted their proposal only a few days before he presented it to Cabinet and the 
government made its announcement shortly thereafter.”
• January 18: Integrity Commissioner of Ontario initiates an investigation based on the November 28 MPP complaint. 
Continued
Continued on page 74
Appendix 1: Timeline of Key Events (continued)
Prepared by the Office of the Auditor General of Ontario  

74
2023 • March 9: Regional Planning Commissioners of Ontario (RPCO) releases a report indicating Ontario’s municipalities 
already have 85% of the 1.5 million housing units in their approval pipelines. The report states that “RPCO continues 
to not support in principle the removal of lands from the Greenbelt as a necessary step to address Ontario’s 
housing needs.” 
• March 16: Office of the Integrity Commissioner launches an investigation as to whether the Minister of Municipal 
Affairs and Housing contravened sections 2 and 3 of the Members’ Integrity Act, 1994 with respect to the decision to 
allow development on lands in the Greenbelt and Duffins Rouge Agricultural Preserve.
• April 6: Government's new housing Bill 97, Helping Homebuyers, Protecting Tenants Act, 2023 is tabled to make 
amendments to several acts. 
• April 6: Government’s new housing bill has its first reading in the Legislature and receives royal assent on 
June 8. The Housing Ministry’s Market Housing Division, which generally oversees the implementation of the 
Ministry’s housing bills, tells our Office the government intends to release housing bills at least annually.
• June 8: Bill 97 receives royal assent. It amends the Planning Act, giving the Housing Minister the power to require 
a landowner to enter into an agreement with the Minister or a municipality in matters where the Provincial Land 
and Development Facilitator has been directed by the Minister to advise, make recommendations or perform any 
other functions with respect to the land. It also amends the Planning Act to give the Housing Minister the power to 
exempt lands subject to Minister's Zoning Orders from complying with provincial policies and Official Plans where 
other planning approvals are applied for, such as subdivision plans. 
Appendix 1: Timeline of Key Events (continued)
Prepared by the Office of the Auditor General of Ontario 
Continued 

Special Report on Changes to the Greenbelt 75
1. Pre-application consultation
Developer provides basic proposal information to municipal staff. Consultation helps identify key issues.
2. Application submission
Developer submits development application and pays corresponding fees.
3. Application deemed complete/incomplete
Within 30 days of receiving an application, municipal staff advise the developer if the application meets the 
requirements.
4. Circulation to internal departments, external agencies and councillors
The application is circulated to relevant internal departments, external agencies and councillors.
5. Public notice
A sign with details of proposed development is put in place and must remain on the site until a decision is rendered
on the application.
6. Public informal open house
Depending on the response to the public notice, an informal open house may be held in order to hear comments
and concerns from the public.
7. Public meeting
Municipal staff hold public meeting (notice must be given at least 12 days prior to the date of the meeting).
8. Planning and Development Committee issues report
The report summarizes all comments received from the public, the Committee’s position on the application
(approve or refuse) and conditions that must be satisfied if application is approved.
9. Decision on Official Plan Amendment and/or Zoning Bylaw Amendment
If an application receives approval by City Council, all of the conditions required in the previous step must be satisfied.
If an application is refused, an applicant has the opportunity to appeal if Council refuses or neglects to decide within
the required time frame.
10. Notice of decision by Planning and Development Committee or Council
People who have requested to be notified of the adoption will be notified within 15 days of the Council passage of
the Official Plan Amendment/Zoning Bylaw Amendment/Plan of Subdivision.
11. Post application
• If no appeals are received after notification of decision, the Official Plan or Zoning Bylaw Amendment comes into effect.
• If no appeals are received after the Notice of Decision of Draft Approval of the Plan of Subdivision has been sent, 
the owner must satisfy all of the conditions of the draft approval.
Appendix 2: Typical Application Process for a Proposed Development
Prepared by the Office of the Auditor General of Ontario 

76
Appendix 3: Select Amendments Enacted by Bill 23, the More Homes Built Faster 
Act, 2022
Prepared by the Office of the Auditor General of Ontario
Act Affected Description of Amendments 
Planning Act • Expands the Housing Minister’s power to amend an Official Plan if it is likely to adversely 
affect a matter of provincial interest.
• Expands private landowners’ ability to build additional units on existing residential lots in 
urban areas and prohibits the appeal of related official plan policies.
• Removes the planning role of seven upper-tier governments (e.g., Regions) in the Greater 
Golden Horseshoe.
• Prohibits conservation authorities from appealing planning decisions.
• Prohibits public appeals of consents and minor variances.
• Changes parkland dedication provisions (except for certain types of projects, and reduces 
the amount of parkland to be dedicated) and requires municipalities to spend/allocate 
60% of funds each year that can only be used for the purchase or upgrade of parks.
• Narrows application of site plan control for residential buildings.
• Removes the restriction on applying for an Official Plan or zoning bylaw amendment 
within two years of municipal adoption.
Conservation Authorities Act • Removes the requirement for the Minister of Natural Resources and Forestry to approve 
the sale, lease or disposition of certain lands. (Under amendments to the regulations, 
conservation authorities will have to identify which lands in their land inventory could 
support housing development by December 31, 2024.) 
• Prohibits conservation authorities from reviewing or commenting on proposals or 
applications under prescribed acts (including the Planning Act; Aggregate Resources Act; 
Condominium Act, 1998; Drainage Act; Endangered Species Act, 2007; Environmental 
Assessment Act; Environmental Protection Act; Niagara Escarpment Planning and 
Development Act; Ontario Heritage Act; and the Ontario Water Resources Act), unless 
related to natural hazards where protecting sources of drinking water. 
• Changes the factors that conservation authorities may consider in their decisions on 
development permits, by removing consideration of the effects of the development on 
“pollution” or the "conservation of land,” and adding the effects on “unstable soil or 
bedrock”, while maintaining consideration of the effects on “flooding”, “erosion” and 
“dynamic beaches."
• Extends the requirement for mandatory issuance of development permits when Minister’s 
Zoning Orders are issued by the Housing Minister under s. 47 of the Planning Act to the 
new type of Minister’s Zoning Order in s. 34.1 of the Planning Act.
• Expands Cabinet’s/Natural Resources Minister’s powers to exempt lands, activities, types 
of development and types of authorizations from the need for a conservation authority 
development permit. 

Special Report on Changes to the Greenbelt 77
Ontario Heritage Act • Authorizes Cabinet to exempt a ministry or public body from having to comply with the 
heritage standards and guidelines in respect of a particular property, if in the Cabinet’s 
opinion such an exemption could advance a provincial priority, such as transit or housing.
• Authorizes the Minister of Citizenship and Multiculturalism to review the determination of 
heritage value of a provincial heritage property and confirm or revise the determination.
• Prohibits a municipality from designating a heritage property unless it is listed in the 
municipality’s heritage register.
• Limits properties that can be listed in a municipality’s heritage register to those that meet 
two or more of the prescribed criteria (as outlined in the regulations).
• Requires a municipality to remove a property from its heritage register if notice of 
intention to designate is not given within two years of listing.
Ontario Land Tribunal Act, 
2021
• Expands the Ontario Land Tribunal’s authority to dismiss a proceeding without holding a 
hearing.
• Gives authority to Cabinet to make regulations requiring the Tribunal to prioritize the 
resolution of specified classes of proceedings.
• Gives authority to the Attorney General to make regulations prescribing timelines for 
Tribunal decision-making.
Development Charges Act, 
1997
• Exempts “affordable”/“attainable” residential units, non-profit housing and inclusionary 
zoning units from development charges.
• Discounts development charges for rental housing.
• Makes changes to the method for determining the amount of development charges.
• Requires a municipality to spend or allocate 60% of its reserve fund each year for water 
supply, wastewater and highway services. 

78
SITE 1 | DUFFINS ROUGE AGRICULTURAL PRESERVE 
4,288.78 acres (57.86% of the 7,413 acres removed)
Appendix 4: Maps of Land Sites Removed from or Re-designated within 
the Greenbelt
Source of data: Ministry of Municipal Affairs and Housing
Duffins Rouge Agricultural Preserve 
South of Highway 407, west of West Duffins Creek, north of the CP Belleville rail line, in Pickering.  

Special Report on Changes to the Greenbelt 79
SITE 2 | KINGSTON ROAD AND HIGHWAY 401
133.01 acres (1.79%)
SITE 3 | NASH ROAD
85.78 acres (1.16%)
Northeast corner of Nash Road and Hancock Road, Clarington
765 and 775 Kingston Road E, Ajax 

80
SITE 4 | BOOK ROAD
1,809.37 acres (24.41%)
SITE 5 | HAMILTON MOUNT HOPE
162.77 acres (2.20%)
South of Garner Road W, west of Fiddlers Green Road, east of Shaver Road in the vicinity of Book Road, Hamilton
South of White Church Road E, west of Miles Road, north of Chippewa Road E, east of Upper James Street, Hamilton 

Special Report on Changes to the Greenbelt 81
SITE 7 | 502 WINSTON ROAD
14.94 acres (0.20%)
SITE 6 | CLINE ROAD
73.45 acres (0.99%)
South of the GO rail line, west of Oakes Road N, north of Main Street W, east of Kelson Avenue N, Grimsby
502 Winston Road, Grimsby 

82
SITE 8 | BARTON
9.82 acres (0.13%)
SITE 9 | BATHURST-KING
655.26 acres (8.84%)
331 and 339 Fifty Road, Hamilton
East of Dufferin Street, south of Miller’s Sideroad, west of Bathurst Street, King Township 

Special Report on Changes to the Greenbelt 83
SITE 10 | HIGHWAY 48
 88.34 acres (1.19%)
SITE 11 | 10379 KENNEDY ROAD
 36.99 acres (0.50%)
10379 Kennedy Road, Markham
10235, 10378 and 10541 Highway 48, Markham 

84
SITE 13 | BLOCK 41 LANDS
 15.60 acres (0.21%)
SITE 12 | LESLIE-ELGIN
 15.14 acres (0.20%)
North and west of Teston Road and Pine Valley Drive, Vaughan
East of Leslie Street, north of Elgin Mills Road E, west of Highway 404, Richmond Hill 

Special Report on Changes to the Greenbelt 85
SITE 14 | 11861 AND 12046 McCOWAN ROAD
 12.81 acres (0.17%)
SITE 15 | 19TH AVENUE AND McCOWAN ROAD
 10.58 acres (0.14%)
5474 19th Avenue, at the northeast corner of 19th Avenue and McCowan Road, Markham
11861 and 12045 McCowan Road, Whitchurch-Stouffville 

86
Appendix 5: Audit Criteria
Prepared by the Office of the Auditor General of Ontario
1. A complete and objective analysis of Greenbelt boundary changes was undertaken based on provincial needs, goals and 
priorities, and with regard to the potential impacts on the province, municipalities and Ontarians across relevant factors such as 
environmental, agricultural and economic.
2. Greenbelt boundary changes were executed in accordance with applicable provincial legislation, regulations, land-use plans, 
agreements and policies.
3. Accurate, timely and complete information (including financial, environmental and demographic data) was collected, analyzed and 
used to prepare proposals to amend the Greenbelt’s boundary and to support informed decision-making.
4. The criteria used to support decisions to change the Greenbelt’s boundary were transparent to Ontarians and unbiased.
5. Measurable performance indicators and targets were established for the implementation of the Greenbelt boundary changes 
and were reported publicly. Appropriate mechanisms were developed for monitoring and comparing results against targets, so 
that timely corrective action can be taken when issues are identified. 

Special Report on Changes to the Greenbelt 87
Appendix 6: Ownership of Land Sites Removed from or Re-designated within 
the Greenbelt
Prepared by the Office of the Auditor General of Ontario
Site # Site Name
Primary 
Developer/Landowner
Size of Land 
(Acres)1 Owner
Date of Last
Purchase
1 Duffins Rouge 
Agricultural Preserve
TACC Development Inc. 47.73 Whittan Acres Inc. 31-Jul-20
19.15 Samir, Shafiq and Noor-Mohammed 
Adam Patel
22-Apr-20
9.09 Pydel Properties Inc. 2-Aug-22
5.02 Akkina Developers Inc. 30-Nov-21
2.77 Ashburton Asset Group Inc. 9-Dec-21
2.50 Pedram Maghsoudi Ghjlou 29-Oct-19
2.15 Syed Rabi Alam, Sabrina Sabah 9-May-19
2.15 Tom Burt 14-Oct-21
2.02 Rajani and Rathai Rajendran 31-Oct-19
2.01 Salvatore and Rosanna Modica 19-Feb-20
2.01 Jaswinder and Amarjit Jaswal 5-Oct-20
2.01 Sathiyaseelan Muthulingam, 
Nagula Rajarathnam
5-Oct-20
2 Kingston Road and 
Highway 401
Buena Vista 
Development Corp.
104.15 2615898 Ontario Inc. 18-Jun-18
20.25 Not available2 Not available2
3.96 Not available2 Not available2
3 Nash Road Streamliner Properties 86.00 1000366391 Ontario Inc. (bought 
from Nash Road Developments Inc.)
8-Dec-22
4 Book Road Fieldgate Homes 49.95 256 Book Road Developments Ltd. 28-Feb-23
29.37 Knollwood Real Estate Holdings 
Inc., David and Jessica Finn
9-Feb-23
12.40 Barbara Ann Smith, Wendy Ann 
Height
27-Aug-20
12.22 Book Shaver Developments Ltd. 6-Oct-22
10.16 Ralph, David Allen and Erin Leigh 
Vyn
7-Dec-18
5.63 Tibor and Anna Anghi 23-Feb-21
4.40 563 Shaver Holdings Inc. 28-Sep-21
Note: The table shows the most recent transaction for each registered parcel of land since 2018 (for the 15 land sites removed from the 
Greenbelt in 2022). In a case where there were no transactions since 2018, the earliest recorded transaction is noted. 

88
Site # Site Name
Primary 
Developer/Landowner
Size of Land 
(Acres)1 Owner
Date of Last
Purchase
3.00 Norma Gladys and Paul Rowe 
Chapman
21-Apr-21
1.01 2363823 Ontario Inc. 27-Aug-21
1.00 Anna and Marek Szeliga 14-May-19
1.00 Darren Joseph and Michelle Maxine 
Julian
14-Jun-19
5 Hamilton Mount 
Hope
Penta Properties, 
Melrose Investments, 
Valery Homes
6.90 Sarbjit Singh, Kuldip Dosanjh 22-Dec-20
6.15 Shelley Christine Moscardini 19-Dec-18
3.85 Michael and Dianne Bernacci 20-Sep-19
2.01 Michael Leblanc, Kaitlyn Walsh 27-Jul-18
6 Cline Road DeSantis Homes, 
Melrose Investments, 
Valery Homes
11.24 Sukhminder Singh, Kashmir Kahlon, 
Yasmeem Kahlon
1-Oct-20
0.86 Not available3 Not available3
0.85 Not available3 Not available3
0.65 Not available3 Not available3
7 502 Winston Road New Horizon 
Development Group
14.43 The Trustees of St. Vladimir’s 
Congregation at Hamilton Ukrainian 
Greek Orthodox Church of Canada
15-May-19
8 Barton 155090933 Ontario Inc. 9.28 5000933 Ontario Inc. 8-Nov-06
0.44 Not available3 Not available3
9 Bathurst-King Green Lane Bathurst 
Limited Partnership
596.21 Green Lane Bathurst GP Inc. 15-Sep-22
88.14 Green Lane Bathurst GP Inc. 15-Sep-22
10 Highway 48 Wyview Group 123.39 2724265 Ontario Ltd. 19-Oct-21
107.20 2724270 Ontario Ltd. 12-Mar-21
104.39 2714791 Ontario Ltd. 20-Dec-21
19.84 2594231 Ontario Inc. 15-Mar-18
11 10379 Kennedy Road Minotar Holdings Inc., 
Beechgrove Estates Inc., 
Halvan 5.5 Investments 
Inc.
109.43 Beechgrove Estates Inc. 3-Jul-13
12 Leslie-Elgin TACC Development Inc. 4.86 Leslie Elgin Developments Inc. Not available
1.88 The Regional Municipality of York 24-May-18
13 Block 41 Lands TACC Development Inc. 107.37 TACC Developments Inc. 7-May-21 

Special Report on Changes to the Greenbelt 89
Site # Site Name
Primary 
Developer/Landowner
Size of Land 
(Acres)1 Owner
Date of Last
Purchase
14 11861 and 12046 
McCowan Road
Torca Inc., 
Flato Developments
73.27 Torca II Inc 3-Sep-21
47.64 2743903 Ontario Inc. 8-Apr-22
15 19th Avenue and 
McCowan Road
Flato Upper Markham 
Village Inc.
102.02 Flato Upper Markham Village Inc. 26-Oct-17
1. Certain parcels of land had a percentage of their total area removed from the Greenbelt, while other parcels were entirely removed. For example, a property may 
be 102 acres in size but only some of that acreage included a Greenbelt removal.
2. This area was a road, so our Office did not purchase a land registration to review this property.
3. Our Office did not purchase a land registration to review this property due to the property’s small size. 

90
Appendix 7: Reporting Relationships of Political and Non-Political Staff 
Prepared by the Office of the Auditor General of Ontario
Assistant 
Deputy Minister
Deputy Minister
Greenbelt Project Team
Premier’s 
Chief of Staff
Secretary
of the Cabinet
Director of Policy 
(Housing)
Deputy
Chief of Staff
Chief of Staff
Minister
Political Staff
Premier
OFFICE OF THE PREMIER
CABINET
CABINET OFFICE
MINISTRY OF MUNICIPAL 
AFFAIRS AND HOUSING
Non-Political Staff 

Special Report on Changes to the Greenbelt 91
Appendix 8: Recommendations for the Secretary of the Cabinet and Chief of Staff 
in the Office of the Premier
Prepared by the Office of the Auditor General of Ontario
 Clarification of Roles and Responsibilities 
1. Given the extensive influence and direct involvement of non-elected political public service staff in the oper￾ational decision-making of the Ministry of Municipal Affairs and Housing, and the demonstrated impact this 
has had on what should have been an objective and unbiased decision-making process, the Secretary of the 
Cabinet and the Chief of Staff to the Premier:
• clarify and document the role of Chiefs of Staff and the role of Deputy Ministers in policy development 
and operational decision-making;
• clarify and document the distinction between policy development and operational decision-making 
aligned with normal business processes;
• establish a formal process whereby Deputy Ministers seek the advice and direction of the Secretary of 
the Cabinet when Chiefs of Staff or other political staff limit or affect the operational decision-making 
of a ministry;
• establish a formal process whereby a letter from the Deputy Minister can be provided to government, 
agreed to by the Secretary of the Cabinet, that distinctly highlights that the ministry was not able to 
provide a recommendation informed by sufficient supporting documentation and analysis.
 Limiting the Use of Confidentiality Agreements 
2. In view of the oath of secrecy all public servants take, the use of confidentiality agreements should be 
limited to only those circumstances requiring a high degree of confidentiality. The agreements should not 
be a barrier to the ability of public servants to consult and collaborate with other staff and experts as may be 
necessary, including public servants employed in other ministries and offices. Given public service employees 
are expected to maintain confidentiality in the conduct of their work, the use of confidentiality agreements 
by ministries:
• be limited and not serve as a barrier to the effective conduct of work by public service employees; 
• procedures be put in place that are transparent as to when it would be appropriate to ask a public 
service employee to sign a confidentiality agreement.
 Compliance with the Public Service of Ontario Act, 2006 
3. A request be made to the Integrity Commissioner of Ontario to determine whether the Chief of Staff to the 
Minister of Municipal Affairs and Housing acted contrary to the requirements of the Public Service of Ontario 
Act, 2006 with respect to his liaisons with land developers and their representatives.
We recommend that: 

92
 Controls over the Receipt of Third-Party and Lobbyist Material 
4. In order to reduce the risk of actual and the appearance of conflict of interest, and so that both the non-political 
public service staff and non-elected political staff in ministers’ offices are aware of materials provided by third 
parties, the government develop a procedure to ensure that any materials received from third parties, and 
that have been considered in the process of decision-making in a ministry or minister’s office, are centrally 
recorded and shared with the relevant senior leadership in both a ministry and minister’s office.
 Conflict of Interest and the Appearance of Conflict of Interest 
5. To reduce the risk of the appearance of conflict of interest, and consistent with the authority of Deputy 
Ministers under the Public Service of Ontario Act, 2006, to refer conflict of interest matters to the Integrity 
Commissioner of Ontario and seek his advice, processes be put in place for Deputy Ministers to proactively 
raise matters with the Secretary of the Cabinet, as their ethics executive, and that the Secretary of the 
Cabinet and the Deputy Ministers consult with the Integrity Commissioner on matters that may lead to 
reputational harm or public distrust of the Ontario Public Service.
 Records Retention (with a Focus on Emails) 
6. Non-elected political public service staff receive formal training on records retention policy as per the Archives 
and Recordkeeping Act, 2006, clarifying which types of emails and other documents are required to be retained 
and what information needs to be included on meeting calendars.
 Restriction on the Use of Personal Email Accounts for Government Business 
7. Non-elected political public service staff receive reinforced communications on the inappropriate use of 
personal email accounts for government business with annual, formal documented attestation that this 
policy is being followed.
8. Non-political public service staff receive reinforced training from the Integrity Commissioner of Ontario on 
the requirements of the Public Service of Ontario Act, 2006, providing situational examples on how they should 
appropriately liaise with parties external to the government who have self-serving interests (e.g., developers, 
lobbyists and other representatives of developers), also ensuring that the information received is handled 
appropriately by decision-makers.
 Consultation under the Environmental Bill of Rights, 1993 
9. In conjunction with the Deputy Minister of the Environment, Conservation and Parks, review and clarify the 
purpose of the public consultation period required under the Environmental Bill of Rights, 1993 so that the 
consultation process respects public input within a time frame that supports and enables meaningful consul￾tation about significant decisions impacting the environment.
 Consultation with Indigenous Leadership 
10. That Deputy Ministers be required to follow established protocols for appropriate and effective consultation 
with Indigenous leadership when proposing any initiatives that have the potential to affect their communities. 

Special Report on Changes to the Greenbelt 93
 Consultation with Stakeholders 
11. To assist ministries in their consultation with stakeholders that may be impacted by government decisions, 
Deputy Ministers establish and follow consistent protocols for engagement and consultation with affected 
groups. 
 Cabinet Submission Material 
12. For good governance that enables fully informed decision-making on significant issues, that:
• procedures be put in place so that Deputy Ministers raise to the Secretary of the Cabinet’s attention 
submissions for which they have not been able to fully conduct unfettered work;
• the Deputy Minister, with a copy to the Secretary of the Cabinet, sign off on the submissions indicat￾ing where work has not been able to be fully performed by public service employees in a comprehensive 
and effective manner as expected by the people of Ontario, which as such could tarnish trust in the 
public service and trust in government; and
• sufficient time be given to Cabinet members to fully read and review any material provided around 
significant and higher-risk decisions.
13. That Deputy Ministers:
• sign a notification to Cabinet, with a copy to the Secretary of the Cabinet, that the public service has 
not been able to fully perform work and analysis supporting the submission consistent with public 
expectations of the role of the public service and which could result in diminished trust in the public 
service and the government; and
• the notification outline any concerns with the process, information and evidence or time provided to 
prepare the submission.
 Re-evaluation of 2022 Decision to Change the Greenbelt Boundaries 
14. Given that the Premier and the Minister of Housing have communicated to us that they were unaware that 
the pre-selection of lands for removal from the Greenbelt was biased, controlled and directed by the Housing 
Minister’s Chief of Staff (a political public servant) rather than informed by environmental, agricultural and 
infrastructure considerations, we recommend that the government request that the Housing Ministry, in con￾junction with the Ministry of Natural Resources and Forestry, the Ministry of the Environment, Conservation 
and Parks and the Ministry of Agriculture, Food and Rural Affairs, Indigenous communities and relevant stake￾holders, such as impacted municipalities, re-evaluate the 2022 decision to change the Greenbelt boundaries.
 Strengthening Oversight by the Office of the Integrity Commissioner of Ontario 
15. Based on our work during this audit, an independent and comprehensive overall review be conducted of 
the Lobbyists Registration Act, 1998, Members’ Integrity Act, 1994 and Public Service of Ontario Act, 2006 to 
strengthen lobbyist registration and regulatory oversight powers of the Office of the Integrity Commissioner. 

Office of the Auditor General of Ontario
20 Dundas Street West, Suite 1530
Toronto, Ontario
M5G 2C2
www.auditor.on.ca
Cover photograph credits:
top: Claire Foran
middle: North Country Media House
bottom: © iStockphoto.com/jimfeng
ISBN 978-1-4868-7251-0 (Print, 2023 edition) 
ISBN 978-1-4868-7252-7 (PDF, 2023 edition) 