• Just 22 sites were reviewed for removal from the Greenbelt by a team known as the “Greenbelt Project Team” despite the fact that 630 requests had been made for removal since 2005. All but one of these sites were provided to the team directly by the Housing Ministry's Chief of Staff. The remaining site was added for consideration by the Greenbelt Project Team, however due to limited time constraints they were unable to research other candidate sites. Of the 15 sites ultimately selected, 14 were brought into the project by the Housing Minister’s Chief of Staff.
• 92% of the acreage removed belonged to two prominent developers, who had access to and requested removals directly from the same Housing Minister’s Chief of Staff at a September 2022 dinner function held by the Building Industry and Land Development Association.
• The developers who own these 15 sites could ultimately see a collective $8.3bn increase to the value of their properties from removal from the Greenbelt.
• A lack of transparency further percolated the entire process with respect to communication with non-political staff, with what was communicated to the public, and more.

• A decision to drop the only criteria that considered environmental and agricultural factors was made when most of the proposed sites did not meet the criteria. Ultimately, of the 15 sites removed, 13 involve the removal of Specialty Crop and/or Natural Heritage System lands.
• The land selected for offset is largely viewed as insufficient and unsuitable. The portion of the Paris Galt Moraine added represents only a fraction of the entire system. The URVs are already protected and are unsuitable for future development due to their steep slopes. Further, they do not contribute to agricultural land protection - a key objection of the Greenbelt.

• Despite the fact that the Greenbelt land opened up is intended by the Government to add “more homes faster”, the impacted municipalities indicate that the time required to run necessary infrastructure to these homes could take a very long time. The Durham region quoted up to 25 years, for example.
• The government has indicated that construction must begin by 2025 and that developers are responsible for footing the infrastructure bill, which is estimated by the Durham Region, for example, to cost up to $2bn dollars. However, no formal framework to assess this exists, nor are there any agreements in place.

• Due to the short time frame, sites could not be properly assessed with respect to infrastructure services, like running roads, sanitation or water treatment to the sites. A largely unsuitable proxy - proximity to developed urban areas - was used instead.
• The time period provided for public consultation, as is required, was set to the minimum possible time frame of 30 days. It coincided with a timeframe that was particularly challenging for municipalities given the proximity to municipal elections, which limited their ability to provide commentary within the already short period of time. Despite the short and poorly selected time frame, 35,000 overwhelmingly negative comments were received but no changes were made and the amendments to the Greenbelt Plan were made exactly as proposed.

Indigenous communities were not sufficiently and effectively consulted. With respect to consultation with Indigenous communities, the lack of consultation was insufficient to meet the Province’s Duty to Consult with regards to treaty rights and other rights.