Prepared For

Ministry of Municipal Affairs

Government of Ontario


Prepared By

The Ontario Property and Environmental

Rights Alliance


May 30, 2004

Ontario Property and Environmental Rights Alliance


Established in 1994, the Ontario Property and Environmental Rights Alliance (OPERA) is a provincial coalition of trade associations and advocacy groups with a common mandate to “protect and entrench in law, the rights and responsibilities of private landowners against arbitrary restrictions and decisions of government”.


Opera member organizations include:


Association of Rural Property Owners                                            Georgian Triangle Development Institute

Grey Association For Democracy and Growth                               Halton Regional Federation of Agriculture

Lanark Landowners Association                                                      Ontario Ski Resorts Association

Renfrew County Private Landowners Association                        West Carleton Rural Association

York Durham Farmers Assessment Association                            Wood Producers of Ontario Association


A number of concerned landowners also hold individual membership.


Correspondence may be directed to:  R.A. (Bob) Fowler at (519) 369-2195 or





The Ontario Property and Environmental Rights Alliance (OPERA) wishes to submit the following concerns with Bill 27 to the Minister, the Honourable J. Gerretson.


We identify the major shortcomings of the Bill then direct your attention to two attachments which relate primarily to the findings of the Golden Horseshoe Greenbelt Task Force report.


One is a presentation made during the public session at Caledon East on May 31 and the other written by one of the members and published in the Ontario Farmer.  Both refer to concerns regarding the legislation.  We direct your attention specifically to the issue of how the plan will be implemented, that is development control vs administration by local municipalities. 


We will gladly answer any questions.  Please call Bob Fowler (519) 369-2195 or e-mail


Bill 27 – Concerns


1.      The exact boundaries of the proposed Greenbelt have not been delineated.  The outside boundary is relatively clear but many regional landowners will not be sure whether they are in or out of the urban boundaries.  Explicit maps are needed immediately.


2.      We are strongly opposed to legislation which prevents woodlot owners from cutting trees.  We accept the need for management plans and marking by private forest professionals but believe trees are a very important crop.  Woodlot management is to be encouraged but we do not support Ministry of Natural Resources Conservation Lands programs because they prevent woodlot owners from selling either sawlogs or firewood.


We note your interview published in the Ontario Farmer regarding compensation when a business is terminated by legislation.  A ban on the cutting of trees represents a cessation of woodlot businesses.  We shall investigate the feasibility of a Class Action Suit in cooperation with the sawmill and lumber industry should tree cutting be proscribed.


3.      We are very concerned that the issue of compensation of landowners has been ignored.  The Ottawa Greenbelt owners were paid compensation.  We anticipate your legal staff will claim no compensation is necessary based on the lack of any Property Rights legislation in Ontario.  This issue is discussed in detail in our Presentation to the Task Force.  Common law appears to suggest compensation is appropriate.


4.      We encourage your Ministry to conduct appropriate background studies prior to implementing the Task Force recommendations.  The Report is based on opinions which we do not believe are consistent with reality.


5.      We request that an information campaign directed at residents of the Golden Horseshoe.  We do not believe most landowners are aware of this Act, the Task Force Report or their implications.


6.      We strongly support implementation of the Greenbelt by municipalities.  Our experiences with the Niagara Escarpment Commission have been entirely negative.  Comments by independent, experienced hearing officers are presented in detail in the attached presentation made at Caledon East.