The Globe and Mail publishes today a major investigation into Canada's Freedom of Information laws and how they are applied or, too often, ignored.  

"Secret Canada" tells us that members of the public are routinely told by public bodies that "no records exist" when in fact they do. Freedom of Information requests can cost thousands of dollars, deterring all but the most determined. 

Over the past eight months I have been trying to find out as much as I can about the sale of the Greenbelt land in King. It was never earmarked for development. Neither King's Official Plan nor the recently adopted York Region Official Plan even hint at this possibility. Nevertheless, the land was removed from the Greenbelt on 21 December 2022.

Some of that land was offered, for a nominal fee, to Southlake for a new acute hospital. The offer was made by the developer Michael Rice to Southlake's Chief Executive, Arden Krystal, at a meeting in King Municipal Centre on 1 November 2022, three days before the Government announced that parts of the Greenbelt - including the lands in King - would be opened up for development. 

No Records

To this day, Southlake insists it has no records of that meeting. 

King Township initially said it had no records of the meeting. But that was untrue. 

The Mayor of King, Steve Pellegrini, said he met Michael Rice for the first time on 1 November 2022. That too was untrue.

King's Director of Growth Management, Stephen Naylor, refuses to give his opinion as a professional planner on whether a new hospital could have been located on prime agricultural land in the Greenbelt - prior to the Government's announcement on 4 November 2022 that the rules on developing the Greenbelt were to be changed. Naylor stonewalls, referring me to the Province when I seek only his own views.

On 18 January 2023 Ontario's Integrity Commissioner lauched an inquiry into whether Municipal Affairs and Housing Minister Steve Clark contravened sections 2 and 3 of the Members’ Integrity Act 1994 in respect of the decision to allow development on lands in the Greenbelt and Duffins Rouge Agricultural Preserve. (Photo Right: Steve Clark)

TIMELINE

2019: Susan McGovern, sister of developer Michael Rice and husband of John McGovern, Senior Vice President of Planning and Policy at the Rice Group, is appointed by the Ford Government to the Board of the Greenbelt Foundation.

9 August 2019: Southlake's land use consultants meet King Township's Director of Growth Management, Stephen Naylor, about plans for a second Southlake.

08 October 2019 – 11 September 2020: Former MPP and PC Cabinet Minister and now consultant lobbyist, Frank Klees, works under contract for the Rice Group. He has previously lobbied for changes to the boundaries of the Greenbelt. The Lobbyist Register asks: 

“What are you attempting to influence or accomplish as a result of your communications with Ontario public office holders?”  

Klees replies:

“The objective of the communications is to brief certain Ontario public office holders on the economic development opportunities represented by a number of the client’s emerging projects.”

What were these emerging projects? The Globe and Mail says Mr Klees did not return an email seeking comment.

31 January 2020: Southlake presents its final Master Plan submission to the Ministry of Health. It sets out a "vision and blueprint" for the delivery of programs and services "through a well defined redevelopment plan..." The Master Plan is confidential and is exempt from the provisions of the Freedom of Information and Protection of Privacy Act under sections 17(1)(a) (Third Party Information) and 18(1)(c) (Economic and other Interests of Ontario).

February 2020: Greenbelt Foundation and Oak Ridges Moraine Foundation are now integrated with a new Committee established to oversee the work of preserving, protecting and restoring the environmental and agricultural integrity of the Oak Ridges Moraine. Susan McGovern is a member of this Committee.

February 2020: John Dunlap, Southlake Board member, King landowner and Land Agent who facilitated the sale of the Bathurst Greenbelt lands to Michael Rice, writes to King Mayor, Steve Pellegrini:

Hi Steve, Would you have some time in the next while to catch up on a few businesses trying to come to King? One is a large equestrian group who would be great to have in the Township. Thanks, John

20 July 2020: John Dunlap writes to King Mayor Steve Pellegrini saying he was interested in donating land "to create a new site for Southlake". (Source: Freedom of Information request. Details released 21 December 2023)

10 August 2021: Southlake hosts a virtual Town Hall highlighting its plans for a new hospital. Newmarket Today reports the hospital plans to expand to a nearby area but is yet to find a suitable location.

December 2021: Ontario Government establishes the Housing Affordability Task Force with a mandate to provide the Minister with recommendations ton accelerate progress in closing the housing supply gap to improve housing affordability. (From District Auditor Report August 2023)

January 2022: The developer Michael Rice begins talks with Southlake about its expansion plans. (Source: Globe and Mail 28 April 2023)  (Photo Right: Michael Rice)

Jordan Holt, the Rice Group’s manager of acquisitions and finance, asked for a meeting about the hospital’s expansion plans in early 2022, telling John Marshman, Southlake’s vice-president of capital, facilities and business development, in an e-mail that he would “prepare a preliminary overview of our company/land holdings that may be of interest to you.”

26 January 2022: John Marshman (Southlake Vice President Capital, Facilities and Business Development) has Microsoft Teams "follow-up" meeting with Jordan Holt (Rice Group). Organiser Marianne Greco.

March 2022: Greenbelt Council's terms of reference are changed to weaken its mandate to protect the environment, including to make its advice confidential (from Auditor General's Special Report on Changes to the Greenbelt)

28 March 2022: Bob Schickedanz’s 687 acre (2.78 sq km) property south of Miller’s Sideroad is advertised for sale by John Dunlap who is owner of adjacent property at Bathurst and Davis Drive West through numbered company 2201506. Dunlap is on the Board of Southlake. Dunlap says it is a prime land banking opportunity. He notes that:

“Surrounding municipalities are almost out of development land.”

April 2022: Luca Bucci resigns as Chief of Staff to Housing Minister Steve Clark to become Chief Executive of the Ontario Home Builders Association whose President is Bob Schickedanz who sells the Greenbelt land in King to Michael Rice on 15 September 2022. 

April 2022: The Integrity Commissioner writes: "Mr. Rice shared with me copies of agendas for his company’s acquisitions meetings from April through November 2022, indicating there was a “Greenbelt Strategy” item discussed regularly with a number of different areas and sites discussed, including the King Township property." 

8 April 2022: Province announces that Southlake is to receive $5M to help plan for a new hospital.

3 May 2022: Michael Rice enters into an agreement of purchase and sale to purchase the 687 acre property at Bathurst. (Source: Integrity Commissioner's Report. Paragraph 95)

22 June 2022: Lake Simcoe Region Conservation Authority annual dinner where King CAO, Daniel Kostopoulos talks to Michael Rice about the lands south of Miller Sideroad.

2 June 2022: Progressive Conservative Party of Ontario forms a second consecutive majority government. (from Auditor General's Special Report on Changes to the Greenbelt)

22 June 2022:  Southlake Board of Directors Report to Annual Meeting: Capital Development Update 

28 June 2022: 3.38pm (* response to FOI request see 6 April 2023 below) From John McGovern (Senior Vice President Policy and Planning, Rice Group) to Daniel Kostopoulos (Chief Administrative Officer, King Township) copied to Michael Rice: 

Subject: Lake Simcoe Region Conservation Authority Dinner last week

“It was great to see you at the LSRCA (Lake Simcoe Region Conservation Authority) dinner last week and glad to hear you are doing well. You spoke with Mike Rice about the lands we have under contract in King and we would like to meet with you in the near future to further that discussion. Please let me know when you have availability to meet and we can co-ordinate a convenient location.”

29 June 2022: 4.20pm* From Tania Sciotto (Executive Assistant to King’s CAO) to John McGovern:

“I am reaching out on behalf of Daniel to see if you and Mike Rice would be available for a meeting with our Mayor sometime in the next few weeks and, if so, perhaps a lunch or coffee would work well.”

Below, please find a few suggested dates and times. If you can kindly confirm availability for yourself and Mike that would be greatly appreciated. 

Tuesday July 12 – 1pm or later; Tuesday July 18 – 10am; Thursday July 21 – 10am; Monday August 8, 10am, 12pm noon or 2pm; Monday August 15 – any time after 10am.

29 June 2022: 4.24pm* John McGovern to Tania Sciotto: 

Subject: re Meeting with Daniel Kostopoulos

“Let me discuss this with Mike and get back to you tomorrow or Monday.”

29 June 2022: 4.24pm*: From John McGovern (Senior Vice President Policy and Planning, Rice Group) to Erin Lindsay (Vice President, Administration, Rice Group) copied to Michael Rice:

Subject: re meeting with Daniel Kostopoulos: 

“Please review (forwarded message below) with Mike and let me know what works best.”

29 June 2022: 4.51pm*: From Erin Lindsay to Tania Sciotto:

Subject: re meeting with Daniel Kostopoulos: 

“ Michael and John’s availability is Tuesday July 12^th at 1pm. If you need anything else oplease feel free to reach out directly to neither myself nor @Stephanie Sousa

29 June 2022: Minister of Municipal Affairs and Housing Steve Clark receives mandate letter from the Premier. The 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". (from Auditor General's Special Report on Changes to the Greenbelt)

29 June 2022: Steve Clark receives mandate letter from the Premier, Doug Ford

30 June 2022: 4.21pm*: Mayor Pellegrini to King CAO Daniel Kostopoulos, (meeting organiser) 

Subject: Accepted: Lunch meeting with John McGovern and Michael Rice (RICE Group)

When: July 12, 2022. 1pm – 3pm

Where: Terra Restaurant, 8199 Yonge Street, Thornhill L3T 2C6

4 July 2022: Housing Minister's Chief of Staff, Ryan Amato, is appointed by the Premier's Office Chief of Staff. (from Auditor General's Special Report on Changes to the Greenbelt)

11 July 2022: 9.13am*: From John McGovern (Senior Vice President Policy and Planning, Rice Group) to Tania Sciotto, Executive Assistant to King’s CAO, Daniel Kostopolous. Subject: Declined: Lunch meeting with John McGovern and Michael Rice (RICE Group):

“Hi Dan, Mike and I attended a family wedding on Saturday and we were just informed that someone in attendance has tested positive for Covid. Although we are not displaying any symptoms out of an abundance of caution we should reschedule our lunch meeting to a future date. Sorry for the short notice and if I test negative all week I will see you on Friday at the Chairman’s event. Thanks.”

11 July 2022: 9.26am*: From Tania Sciotto to Steve Pellegrini and Daniel Kostopoulos 

Subject: lunch with John McGovern and Michael Rice – Rice Group.

“Just an FYI – Mike and John attended a family wedding on Saturday and were just informed that someone in attendance has tested positive for Covid. Although they are not displaying any symptoms, they’ve asked to reschedule tomorrow’s lunch meeting to a future date. If John tests negative all week he said he will be at the Chairman’s event on Friday.”

11 July 2022: 9.36am*: From Tania Sciotto to Erin Lindsay: 

“Daniel received John’s note this morning regarding cancelling tomorrow’s lunch meeting. In an effort to try and reschedule would you please sent me a few dates in August that would work well for both John and Mike. I will try and co-ordinate a suitable time that also works well for both Daniel and our Mayor as well.”

11 July 2022: 9.50am*: From Daniel Kostopoulos to Tania Sciotto and Steve Pellegrini.  

“Thank you for this update. The decision to reschedule is prudent and most appropriate.”

11 July 2022: 9.56am*: From Tania Sciotto to Erin Lindsay: 

Subject: re meeting with Daniel Kostopoulos: 

Daniel received John’s note this morning cancelling tomorrow’s lunch meeting. In an effort to try and reschedule would you please send me a few dates in August  that would work well for both John and Mike. I will try to co-ordinate a suitable time that also works well for both Daniel and our Mayor as well.

11 July 2022: 10.36am*: From Erin Lindsay to Tania Sciotto:

Subject: re meeting with Daniel Kostopoulos: 

“… the two dates that work for Michael and John are August 10^th 11^th. Let me know if these dates work for the Mayor and Daniel.”.

12 July 2022: 12.16pm*: From Tania Sciotto to Erin Lindsay (Rice Group)

Subject re meeting with Daniel Kostopoulos

Great. Thank you. Let’s aim for 1pm on Wednesday August 10 (Terra Restaurant, located at 8199 Yonge Street, Thornhill)

12 July 2022: 12.52pm*: From Mayor Pellegrini to Daniel Kostopoulos:

Subject: Accepted. Meeting with John McGovern and Mike Rice (Rice Group)

12 July 2022: 12.16pm*: From Tania Sciotto to Erin Lindsay (Vice President, administration, Rice Group)

Subject: re meeting with Daniel Kostopoulos: 

“Great, thank you. Let’s aim for 1pm on Wednesday, August 10^th at Terra Restaurant… I will send a meeting invite out shortly.”

12 July 2022: 1.28pm*: From Erin Lindsay to Tania Sciotto:

Subject: re “meeting with Daniel Kostopoulos

“Thank you. Received the invite. Have a great week.”

12 July 2022*: Calendar Entry by Robert Adshead:

Subject: Meeting with John McGovern and Mike Rice (RICE Group)

Location: Terra Restaurant 8199 Yonge Street, Vaughan, On L3T 2C6

Start: Wed 2022-07-12: 1.30pm

End:  Wed 2022-07-12: 3pm

Organiser: Daniel Kostopoulos

Required attendees: Steve Pellegrini, John McGovern, Michael Rice. 

Optional attendees: Erin Lindsay, Teresa Barresi

9 August 2022: The Building Industry and Land Development Association (BILD) and 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." (from Auditor General's Special Report on Changes to the Greenbelt)

10 August 2022*: Calendar Entry by Tania Sciotto:

Subject: Meeting with John McGovern and Mike Rice (RICE Group)

Location: Terra Restaurant 8199 Yonge Street, Vaughan, On L3T 2C6

Start: Wed 2022-08-10: 1.30pm

End:  Wed 2022-08-10: 3pm

Organiser: Daniel Kostopoulos

Required attendees: Steve Pellegrini, John McGovern, Michael Rice. 

Optional attendee: Erin Lindsay

14 September 2022: BILD holds its Chair's Dinner. Two prominent housing developers (one of whom is Michael Rice) approach the Housing Minister's Chief of Staff and provide him with packages that contain information on two sites in the Greenbelt (one of which is the land in Bathurst in King) (from Auditor General's Special Report on Changes to the Greenbelt). This version of events is contradicted by the Integrity Commissioner's report paragraphs 273 and 274. See entry below for 27 September 2022)

15 September 2022: King Greenbelt land south of Miller’s Side Road sold by Bob Schickedanz to Mike Rice’s private company, Green Lane Bathurst GO Inc, for $80M

16 September 2022: 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 including bathurst. (from Auditor General's Special Report on Changes to the Greenbelt)

22 September 2022: John Dunlap comes off the Southlake Board. 

22 September 2022: Southlake Board of Directors approves the formation of a Land Acquisition Sub Committee. (Unknown) Board Member declares a conflict of interest. FOI response from Southlake confirms that Dunlap was not present at this Board meeting. We now know this was incorrect. He was present and then left.

27 or 28 September 2022: Ryan Amato meets Michael Rice at Rice's office and collects additional information on the Bathurst property. (Source: Integrity Commissioner's Report. Paragraphs 276 and 277)

4 October 2022: 1.12pm*: From Tania Sciotto to Tania Sciottto. Subject: Meetings and Notes. Follow up Flag.

1. Pre-meeting in advance of Meeting with Southlake Oct 18? 9am

Rice Group – Mike Rice and John McGovern

Stephen, Mayor and Daniel, Mike Rice and John McGovern

2. Meeting in November with Rice Group and CEO of Southlake Arden, Rice Group and Mayor, Daniel and Stephen

Meeting: Hospital Expansion Discussion

(THIS IS REDACTED FOR THIS REASON: Personal information 14(1) and out of scope of the request)

6 October 2022*: Executive Assistant to King’s CAO, Tania Sciotto, emails Erin Lindsay at the Rice Group: 

“As per my voice mail message yesterday, Mayor Pellegrini and Daniel Kostopolous would like to meet with Michael and John sometime in October, if possible. Also in attendance will be our Director of Growth Management Services, Stephen Naylor. The purpose of the meeting is to have a pre-meeting in advance of a meeting with Southlake which will likely be scheduled sometime early November.”

Below please find a few available dates and times. If you could kindly let me know what works best for both Michael and John that would be greatly appreciated.

Monday, October 17 – 1.30pm; Tuesday October 18 – 9am or 11am; Thursday October 20 – 10.30am; Friday October 21 – 10am.

Thank you. I look forward to hearing back from you.”

6 October 2022: Housing Minister’s Chief of Staff Ryan Amato provides Greenbelt Project Team with the initial criteria for potential removal of lands from the Greenbelt. These draft 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. (Source: Auditor General's report)

11 October 2022: 3.57pm*: From Tania Sciotto to Erin Lindsay and Stephanie Sousa (Rice Group)

“Just following up my email below, please let me know if any of the proposed dates/times work.”

11 October 2022: 4.18pm*: From Stephanie Sousa (Rice Group) to Tania Sciotto. Copied to Erin Lindsay and John McGovern (Rice Group)

Subject: Re meeting with Mayor Pellegrini and Daniel Kostopoulos – Township of King. Importance High

“My apologies for the delayed response. Michael and John will be able to meet with Mayor Pellegrini, Daniel Kostopoulos and Stephen Naylor on Monday October 17 at 1.30pm. Will you be sending out calendar invite with the details?”

11 October 2022: 4.49pm*: From the Executive Assistant to King’s CAO, Tania Sciotto, to Stephanie Sousa, administrative assistant to the Senior Leadership Team at the Rice Group. Copied to Erin Lindsay and John McGovern (Rice Group)

“Thank you for your quick reply! A calendar invite has been sent for Monday October 17 at 1.30pm.”

11 October 2022: 5.04pm*: From Stephen Naylor (photo right) to Daniel Kostopoulos:  

“Subject: Accepted: Pre-meeting with Michael Rice and John McGovern (RICE Group) in advance of Southlake meeting

12 October 2022: 8.53am*: From John McGovern to Teresa Barresi and Tania Sciotto:

“Subject: Accepted: Pre-meeting with Michael Rice and John McGovern (RICE Group) in advance of Southlake meeting.”

17 October 2022*: Calendar entry by Robert Adshead:

Subject: Pre-Meeting with Michael Rice and John McGovern (RICE Group) in advance of Southlake meeting 

Location: King Municipal Centre from 1.30pm – 2.30pm. Meeting involves Steve Pellegrini, Stephen Naylor (King’s Director of Growth Management) Michael Rice and John McGovern. Organised by King’s Chief Administrative Officer, Daniel Kostopoulos.

17 October 2022: 2.40pm*: From Steve Pellegrini to Daniel Kostopoulos:

“Subject: Accepted: Pre-meeting with Michael Rice and John McGovern (RICE Group) in advance of Southlake meeting.”

26 October 2022: The Housing Minister indicates he first became aware of the specific land sites proposed for removal. (Auditor General's Report) 

27 October 2022: Housing Ministry briefs staff in the Premier's Office and Cabinet Office on proposed removal of sites from the Greenbelt. (Premier is not present for the meeting.) (from Auditor General's Special Report on Changes to the Greenbelt)

November 2022: Susan McGovern's four year term on the Board of the Greenbelt Foundation ends.

1 November 2022: Housing Ministry briefs Housing Minister/ Associate Minister of Housing on the proposed removal of land sites from the Greenbelt. (from Auditor General's Special Report on Changes to the Greenbelt)

1 November 2022: Premier indicates he first became aware of the specific land sites proposed for removal on November 1, prior to a Cabinet meeting held on November 2. The Auditor General comments: "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. (from Auditor General's Special Report on Changes to the Greenbelt)

1 November 2022: Meeting at King Municipal Centre involving Southlake Chief Executive, Arden Krystal; John Marshman, Southlake’s Vice President, Capital Facilities and Business Development; King Mayor Steve Pellegrini; King Director of Growth Management, Stephen Naylor; John McGovern and Michael Rice. Rice makes a commitment to give Southlake land for a new hospital at a nominal fee. The Township of King and Southlake say they have no records of that meeting other than the invitations calling it. (King’s Township Clerk informs me later that Naylor was not present at this meeting.)

2 November 2022: Cabinet approves Housing Ministry's proposal to begin public consultation procesds to amend the Greenbelt. (Cabinet members receive proposal matereial shortly before Cabinet meeting.) (from Auditor General's Special Report on Changes to the Greenbelt)

3 November 2022: Property owners/developers are notified their land is being proposed for removal from the Greenbelt. (from Auditor General's Special Report on Changes to the Greenbelt)

4 November 2022: Mayors of affected municipalities are notified lands in their jurisdictions are being proposed for removal from the Greenbelt. (from Auditor General's Special Report on Changes to the Greenbelt)

4 November 2022: Minister Steve Clark makes public announcement that certain lands are to be removed from the Greenbelt, opening them up for development. 

6 November 2022: Blog: “Greenbelt up for grabs” 

7 November 2022: 12:09 pm: Steve Pellegrini emails Southlake’s Arden Krystal attaching a draft of the motion he proposes to put before King Councillors that evening:

“Call if you have any questions, thanks Steve”

7 November 2022: 2:24 pm: Arden Krystal emails Pellegrini with an amended version of his proposed motion:

“Hey Steve. Thanks so much for your support – this is truly exciting! I wondered if you would be agreeable to a few small edits to the motion that I think will have the same impact but perhaps be less controversial. Please let me know if these would be acceptable. Cheers and thanks again.”

7 November 2022: 3:48 pm: Pellegrini emails Krystal

“All good. Will make those changes”

7 November 2022: 3:49 pm Arden Krystal emails Pellegrini with copies to Township Clerk Denny Timm and Chief Administrative Officer Daniel Kostopoulos:

“Awesome. Many thanks!!”

7 November 2022: Mayor Steve Pellegrini moves a motion at King’s Committee of the Whole, adopted unanimously, saying land would be made available for a new hospital in King for a nominal fee. Arden Krystal tells Pellegrini the motion should be amended to make it less controversial. (Source: Globe and Mail 28 April 2023)

7 November 2022: 3.55 pm: Michael Rice emails King CAO, Daniel Kostopoulos re Bathurst Lands: 

"Attached is a the (sic) designations laid over the actual arial (sic) photo you can clearly see why the land outlined in yellow is designated protected countryside because it is the same at (sic) the lands in red also protected countryside. The lands are high and dry and included in operational; farming for cattle. We attached the designation Mapping from the province and the map issued by the Ministry last Friday.

Please give me a call if you can just need to pass some comments on."

7 November 2022: 11.03 am. John Marshman emails Michael Rice:

"It was a pleasure to meet you in person last week. I'm following up to see if we can find a time to meet with yourself and/or someone from your team to discuss further. Let me know what works for you and I will coordinate scheduling. Best. John"

7 November 2022: 11.06am Michael Rice emails john Marshman:

"Sure we can meet. We are ready to review concepts... what time works for you?"

8 November 2022:  Blog: New owner of Greenbelt land at Bathurst prepared to gift the site to Southlake for a nominal fee.   

8 November 2022: Blog: New Owners of Greenbelt land are sitting own a gold mine  

13 November 2022: Blog. Who bought the greenbelt lands west of Bathurst?

16 November 2022: 2.30pm - 3.30pm. John Marshman meets Michael Rice re Southlake Regional Hospital

24 November 2022: Southlake Board meeting. The Board receives a report and presentation on "Master Plan - Redevelopment Update". (FOI request for minutes, redacted where appropriate, is later refused.)

28 November 2022: Ontario 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. (from Auditor General's Special Report on Changes to the Greenbelt)

28 November 2022: Blog. Frank Klees and Selling the Greenbelt. 

5 December 2022: Southlake's Land Acquisition Sub Committee, chaired by John Marshman, has its first meeting. Marshman tells members there is one "known opportunity" for a new hospital. This was the "Bathurst and Davis Drive Opportunity".

6 December 2022: Blog. Consultant Lobbyist Frank Klees and the Greenbelt.  

11 December 2022: Blog. Lands will be returned to the Greenbelt in construction hasn’t started by 2025.  

19 December 2022: Blog. Ford to reward developers if they build affordable housing.

19 December 2022: Follow up meeting with Southlake at King Municipal Centre involving Steve Pellegrini and representatives from Souithlake. Louise Oram, PA to Arden Krystal, is listed as an attendee. (FoI request received from Southlake 21 December 2023). Meeting organised by Daniel Kostopoulos, Chief Administrative Officer of King.) Meeting rescheduled to 24 January 2023.

21 December 2022: The Rice lands are formally removed from the Greenbelt.

January 2023: John Marshman, Southlake’s Vice President Capital, Facilities and Business Development, contacts Jordan Holt, the Rice Group’s Manager of Acquisitions and Finance, sending a request for information required by Southlake’s architects. (Source: Globe and Mail 28 April 2023)

16 January 2023: Southlake Site Selection meeting to review of the "Bathurst and Davis Drive Opportunity".

18 January 2023: Integrity Commissioner David Wake says he will conduct an inquiry into whether Minister Steve Clark contravened sections 2 and 3 of the Members’ Integrity Act 1994 in respect of the decision to allow development on lands in the Greenbelt and Duffins Rouge Agricultural Preserve.

19 January 2023: King Mayor Pellegrini tells the ERA newspaper:

“The Township had worked with a previous owner looking to develop the land but couldn’t because it was in the Greenbelt.

The landowner died a few years ago and the family sold the land to the Rice Group. The sale closed a couple of weeks before it was pulled from the Greenbelt. 

When without warning the province pulled the King land out of the Greenbelt, council capitalised on it by saying “at least give us a hospital”.”

20 January 2022: Blog. Building in the Greenbelt: Developers were tipped off.

21 January 2022: Blog. Greenbelt land bought for $80M could now be worth over $600M.  (Photo right: Bob Schickedanz)

22 January 2023: I write to Integrity Commissioner David Wake: 

Re: the Government’s Decision to Amend the Greenbelt Plan to allow development on certain lands

I have read your report of 18 January 2023 and I welcome your decision to conduct an inquiry into whether Minister Steve Clark contravened sections 2 and 3 of the Members’ Integrity Act 1994 in respect of the decision to allow development on lands in the Greenbelt and Duffins Rouge Agricultural Preserve.

I write as a private individual and a former Member of the UK Parliament who has, for many years, followed planning and development issues here in York Region.

Prior knowledge

Michael Rice is President of Green Lane Bathurst GP Inc which bought a 687-acre block of Greenbelt land in the Municipality of King in September 2022 for $80M (the Rice lands).

I believe the Government’s intention to remove this land from the Greenbelt (south of Miller’s Side Road, east of Dufferin and west of Bathurst) was likely known to Michael Rice before he bought the lands but certainly before Mr Clark’s public announcement was made on Friday 4 November 2022 which flagged up the proposed removal of 15 parcels of land from the Greenbelt totalling 7,400 acres and allowing development on it. Three days after the Government’s Greenbelt announcement, on Monday 7 November 2022, the Municipality of King unanimously carried a motion moved by the Mayor, Steve Pellegrini.

The motion (attached) wanted to see a new hospital on the Rice lands. It stated unequivocally that: “the landowner is committed to providing the necessary lands for the Southlake Regional Health Centre site for a nominal fee.”

I was taken aback that the Council had been able move so quickly. Only days after the Government’s announcement, and with a weekend intervening, elected officials felt able to pass with confidence a resolution telling King residents that a new hospital could be coming their way with the landowner essentially gifting the necessary lands to Southlake.

Common knowledge

It was, of course, common knowledge that Southlake, located here in Newmarket, was looking for a second site for an acute care hospital. On 10 August 2021 the hospital’s Chief Executive, Arden Krystal, told a Town Hall that Southlake needed more space and there was no room to expand on site. She said the present Davis Drive site would be retained and re-purposed for walk-in or ambulatory patients and a new greenfield site would focus on acute and very technical medicine. She hoped some land could be gifted by benefactors. She said the second site would ideally be located within 5km – 10km of the existing site “and the closer the better”.

On Thursday 22 December 2022, I submitted a Freedom of Information request to the Municipality of King (FOI-2022-070) asking for information on who received this “nominal fee” commitment from the landowner and the form it took – whether in writing or given verbally.

Commitment given on 1 November 2022

On 20 January 2023 the Township Clerk, Denny Timm, informed me: “The commitment of a nominal fee for the hospital lands was conveyed verbally to Mayor Pellegrini during an in-person meeting with Rice Group and Southlake Representatives on November 1, 2022.”

This in-person meeting was three days before Minister Clark’s public announcement on opening certain Greenbelt lands for development. I do not know who initiated the meeting, its agenda, where it was held nor how long it lasted. I do not know the names of those who represented the Rice Group or Southlake. I asked the Municipality for sight of all records held by it (including emails, phone calls and meeting records) but the Township Clerk, Mr Timm, tells me a search was conducted and “no responsive records were located”.

That said, we do know the landowner told Mayor Pellegrini that the necessary lands for the new hospital would be provided for a nominal fee.

Unanswered questions

The new owner of the Rice lands, Michael Rice, is not a novice when it comes to planning and development matters. It is his bread-and-butter work, his day-to-day business. It seems inconceivable to me that he would have made an offer to provide the lands needed by Southlake for a nominal fee if he was not certain his lands could be developed.

In the light of this, I very much hope your inquiry will establish:

1. When did Michael Rice first learn that the lands purchased in September 2022 could be developed? And from whom did this information come?

2. When did he, or an agent acting on his behalf, first approach Southlake with the offer of lands? Or did Southlake approach him?

3. Did Southlake know the lands being offered were in the Greenbelt? If not, what steps if any were taken to verify the lands were developable?

4. What was on the agenda of the meeting between Mayor Pellegrini, Rice and Southlake on 1 November? Who called the meeting and for what purpose?

5. Did Mayor Pellegrini ask the landowner what evidence he had that the Rice lands were developable?

I very much hope your inquiry will answer these questions and I look forward to reading your report. 

24 January 2023: Follow-up meeting to the one on 1 November 2022 when Rice made his offer of free land to Southlake. The meeting involves Arden Krystal and John Marshman from Southlake and Mayor Steve Pellegrini and King CAO Dabniel Kostopoulos. King will tells me they have no records of this meeting other than the invitation list.

25 January 2023: Blog. Selling the Greenbelt.  

26 January 2023: Southlake Board meeting. (FOI request for minutes, redacted where necessary, is refused.)

26 Januaary 2023: Housing Minister Steve Clark asks the Provincial Land and Development Facilitator, Paula Gill, to:

"facilitate discussions and negotiations with landowners of fifteen parcels of land that were removed from the Greenbelt Plan Area in December 2022 to achieve development agreements and build a shared vision for concrete actions and timelines to achieve government objectives for development on these sites."

"The objective of this assignment is to develop clear agreements between landowners and the province to support downstream development and achieve shared goals such as enhanced community amenities, public services and greenspace. I am seeking your advice on the approach to prioritize and sequence this work."

The Provincial Land and Development Facilitator post has since been abolished by the Ford Government.

I filed a Freedom of Information request concerning the Bathurst lands. The Ministry found two responsive records but access was denied in part under these Freedom of Information and Protection of Privacy (FIPPA or the Act) exemptions:

• 17 – Third party information
• 18 – Economic and other interests of Ontario
• 19 - Solicitor-client privilege

27 January 2023: Blog. Bob Schickedanz, President of the Ontario Home Builders Association, was landowner who sold Greenbelt land in King to Michael Rice  

1 February 2023: Blog. The Sale of the Greenbelt: the Southlake connection.

1 February 2023: Blog. Steve Pellegrini and the removal of land from the Greenbelt. 

1 February 2023: Newmarket Today reports:

“When Rice bought the King Greenbelt lands in the summer, Pellegrini said they met to talk about it. He said there was no indication at that time the Greenbelt land would be opened for housing development and Rice did not indicate anything like that.”

Pellegrini said they have been looking for a new site for a Southlake Regional Health Centre since 2019, and had explored the area for that reason. He said a different landowner had offered land in that vicinity.
When Rice bought the King Greenbelt lands in the summer, Pellegrini said they met to talk about it. He said there was no indication at that time the Greenbelt land would be opened for housing development, and Rice did not indicate anything like that.


“We met with them, we said, ‘Wow, you’re buying Greenbelt, you plan on farming?” Pellegrini recounted. “They came out and upfront and said ‘we have land holdings all over Ontario and Canada.’”
“Quite frankly, I just assumed they were doing what many others do, and land bank,” Pellegrini added.
But at that point, Pellegrini said he did ask Rice if some of his land could be made available for a Southlake site, and Rice said yes.


Even though the land was still Greenbelt, Pellegrini said the province would have the authority to put a hospital there and keep it Greenbelt.
“A hospital is a provincial institution. It is permitted in the Greenbelt. We’re not asking for it (the lands) to be removed (from the Greenbelt),” he said. “We’re asking for a hospital. It’s no different than a highway or a transit.”
Asked about that going against the spirit of the Greenbelt as untouched greenspace and farmland, Pellegrini said the province would have to factor that against other community needs.
“You would have to weigh the health and wellness of the community, as well,” he said, adding that Southlake is “bursting at the seams.” 
With Rice agreeing to provide some land, Pellegrini said they held a meeting Nov. 1 to talk about it with Southlake representatives. 

He said the timing of the provincial Greenbelt announcement Nov. 4 was coincidental, and they had no idea it was coming.

Pellegrini said King is not in favour of lands being taken out of the Greenbelt. The township passed another resolution Dec. 12, stating it is not in favour of changing the Greenbelt boundaries and asking the province to ensure natural heritage areas remain protected and the development will have high environmental standards. It also asks for 25 per cent of the units to come there be dedicated as affordable housing. 


The township’s resolution on the Southlake site also specifies that it opposes provincial plans to redesignate a portion of King's Oak Ridges Moraine as a settlement area. That area is situated right next to the Greenbelt lands in King.
“I’m just advocating, like any other mayor in the region, to have a hospital in their community,” he said.

1 February 2023: CTV News Toronto reports:  

“Pellegrini said he met with representatives of the Rice Group at their request and discussed the possibility of them donating the land for a hospital… At no time did they discuss further development of the Greenbelt land, Pellegrini added.”

1 February 2023: Global News reports:

“In an interview, Pellegrini said members of the Rice Group, who made an $80M land purchase, wanted to introduced themselves and that meetings with developers who own Greenbelt land were common practice.

Pellegrini said he used the opportunity, unprompted, to push for land to develop new hospital infrastructure which, he said, could be allowed under provincial regulations.”

1 February 2023: the Globe and Mail reports:

“The mayor says it (the meeting on 1 November 2022) was a routine meeting with a developer who had recently purchased land in his municipality, adding that he understood Mr Rice had made the deal months before it closed. Mr Pellegrini also says it was him, not Mr Rice, who suggested the site as a possible location for a new branch of Southlake Regional Health Centre…

“I asked Mike Rice, this is the whole thing, I asked him, would you donate land if we could get a hospital? And he said yes… That’s the only time I talked to him.”  (My underlining for emphasis)

Pellegrini tells the G&M he wasn’t aware of Greenbelt plans in advance.­­

The Globe and Mail reports that at the meeting on 1 November 2022 Mayor Pellegrini asked Mike Rice if he would donate land to the hospital:

“That’s the only time I talked to him.”

2 February 2023: Mayor Pellegrini issues a statement:

“I was disappointed to read yesterday of the false information being disseminated by Marit Stiles, the incoming leader of the Provincial NDP, regarding the Township of King and the Greenbelt. I was equally disappointed that Ms. Stiles did not reach out to King to check the facts…

The incoming NDP leader mentions a meeting with the Rice Group and the Township. The Township did meet with the Rice Group just prior to the Province’s announcement of redistribution of land identified as Greenbelt. It is common to meet with new landowners in the municipality.  

Ms. Stiles mentions the discussion of a hospital on Greenbelt land in King. The idea of a hospital in King is not a new one. I have been moving this idea forward since 2019—on different lands, with different landowners. At the time of our meeting, I brought the idea of a hospital forward to the Rice Group and they were open to discussion.” 

2 February 2023: Blog. Greenbelt land broker, John Dunlap, owns land next to Michael Rice’s $80M purchase. 

3 February 2023: The ERA newspaper reports on 3 February 2023: 

"When the Rice Group closed on the sale of the land in August, Pellegrini approached them about his idea.”

“When Rice bought the King Greenbelt lands in the summer, Pellegrini said they met to talk about it. He said there was no indication at that time the Greenbelt land would be opened for housing development, and Rice did not indicate anything like that.”

4 February 2023: Blog: Steve Pellegrini in his own words. 

7 February 2023: Paul Freeman, Chief Planner of York Region tells me:

“a hospital would be considered institutional and would be directed to settlement areas given the agricultural designation of the subject lands.”

7 February 2023: Blog: Selling the Greenbelt: Can hospitals be built in the Greenbelt?   (Photo right: Paul Freeman)

7 February 2023: I write to the Integrity Commissioner, David Wake, for the second time:

Re: the Government’s Decision to Amend the Greenbelt Plan to allow development on certain lands

I wrote to you on 22 January 2023 welcoming your decision to conduct an inquiry into whether Minister of Municipal Affairs and Housing, Steve Clark, contravened sections 2 and 3 of the Members’ Integrity Act 1994 in respect of the decision to allow development on lands in the Greenbelt and Duffins Rouge Agricultural Preserve. I also posed a series of questions which I hoped your Inquiry would answer.

Michael Rice, who bought the (former) Greenbelt lands in King south of Miller’s Side Road, east of Dufferin and west of Bathurst on 15 September 2022, told the Mayor of King, Steve Pellegrini, at an in-person meeting on 1 November 2022 that he would make land available for a new hospital. It seems to me the participants at that meeting had an inkling that the planning rules governing development in the Greenbelt were about to change.

Mayor Pellegrini has stated on many occasions that Provincial regulations would allow a hospital to be built in the Greenbelt. I doubted things were quite so straightforward.

Paul Freeman, the Chief Planner of York Region, explained the position in an email to me on 6 February 2023:

“The planning system in Ontario is based on a conformity hierarchy, meaning to be permitted in a zoning by-law a land use must conform to the local official plan, which must conform to the Regional official plan (in this case prime agricultural designation), which must conform to Provincial Plans (Greenbelt Plan or Oak Ridges Moraine Conservation Plan (ORMCP), and Growth Plan). Only the Province can change Provincial Plans.

In our interpretation, a hospital would be considered institutional and directed to settlement areas given the agricultural designation on the subject lands. As I’ve indicated above, only after the use is permitted in the Greenbelt Plan or ORMCP can official plans and zoning bylaws be amended to be consistent with and permit the use at the local level. Now that the lands have been removed from the Greenbelt, presumably natural heritage features will still be protected and the official plan and zoning by-law will be amended to reflect the Province’s direction. This is necessary to enable development applications and building permits. I would anticipate the Province will be issuing a Minister’s Zoning Order to further define how development on these lands is to proceed.”

It follows from this that prior to Minister Clark’s announcement on 4 November 2022 to open certain parts of the Greenbelt to development, a hospital would not have been permitted on the Rice lands as these did not include a settlement area.

The Government’s formal decision on 21 December 2022 to remove the Rice lands from the Greenbelt and to redesignate a portion of the Oak Ridges Moraine as a settlement area has, of course, changed the picture entirely.

On 1 November 2022 Michael Rice offered lands for a new hospital for a nominal fee. But, if we are to rely on Mr Freeman’s understanding of the position, a hospital on the Rice lands was impossible given the regulations applying on that date.

8 February 2023: Mayor Pellegrini tells the King Sentinel:

“Notably, the Province does not require the removal of lands from the Greenbelt to build a hospital. They may build Provincial infrastructure on any lands they deem suitable.”

“When Rice bought the King Greenbelt lands in the summer, Pellegrini said they met to talk about it. He said there was no indication at that time the Greenbelt land would be opened for housing development, and Rice did not indicate anything like that. “We met with them, we said, ‘Wow, you’re buying Greenbelt, you plan on farming?” Pellegrini recounted. “They came out and upfront and said ‘we have land holdings all over Ontario and Canada.’”

“Quite frankly, I just assumed they were doing what many others do, and land bank,” Pellegrini added.

But at that point, Pellegrini said he did ask Rice if some of his land could be made available for a Southlake site, and Rice said yes.

8 February 2023: Blog. Greenbelt Developer helped finance Dawn Gallagher Murphy’s 2022 election campaign for the Provincial Parliament. 

9 February 2023: Mayor Pellegrini tells the King Sentinel:  

“… the Province does not require the removal of lands from the Greenbelt to build a hospital. They may build Provincial infrastructure on any lands that they deem suitable.”

10 February 2023: Blog: Selling the Greenbelt: King's Mayor, Steve Pellegrini, insists a hospital can be built anywhere the Province chooses.  

22 February 2023: Blog:  Selling the Greenbelt: Southlake holds back details on key meeting where Greenbelt land was offered for a nominal fee. 

28 February 2023: Blog: Selling the Greenbelt: Rice asked for meeting with Southlake. 

3 March 2023: Southlake say they have no records of the meeting on 1 November 2022 other than an invitation from King’s CAO, Daniel Kostopoulos, which is undated and shows no recipients. My request was in these terms:

 “I request sight of all records held by Southlake (including emails, phone call and meeting records) relating to the in-person meeting on November 1, 2022, involving Mayor Pellegrini of King, the Rice Group and representatives from Southlake in which a commitment was given that lands in King would be provided to Southlake for a nominal fee.”

8 March 2023: I email the Clerk of King Township, Denny Timm:

You wrote to me on 20 January 2023 in reply to my Freedom of Information request (FOI-2022-070). (Your letter was dated 20/01/2022 but this was clearly an error.)

 As you know, I had asked for sight of all records held by the Township relating to the commitment given by a landowner in King to make land available for a new Southlake hospital campus for a “nominal fee”.

 You told me the commitment was conveyed verbally to Mayor Pellegrini during an in-person meeting with the Rice Group and Southlake representatives on 1 November 2022. You said a search had been conducted and no responsive records were located.

 I also submitted a Freedom of Information request to Southlake requesting sight of all records held by them – including emails, phone call and meeting records – relating to that 1 November 2022 meeting.

 On 3 March 2023 Southlake released one responsive record to me which is described in their Index of Records as a “meeting invite dated November 1, 2022”. 

The invitation to Southlake comes from the municipality’s Chief Administrative Officer, Daniel Kostopoulos, and concerns “hospital expansion”. This communication from Mr Kostopoulos to Southlake is clearly a record and I imagine there would be a similar invitation to the Rice Group. In the light of this, I wonder if I could ask you to conduct another, perhaps more focussed, search of the files held by Mr Kostopoulos relating to the meeting on 1 November 2022?

I note that Stephen Naylor, the Township’s Director of Growth Management, was present at the meeting and I am requesting that his files too are examined for records relating to that I November 2022 meeting.

To recap: I am requesting sight of any record of information – whether printed on paper or held electronically - concerning that 1 November 2022 meeting where the “nominal fee” commitment was given. My request for records includes meeting notes, emails and internal memos to King staff and elected officials. 

 I am familiar with the guidance issued by the Information and Privacy Commissioner of Ontario which requires public institutions to conduct a reasonable search for responsive records. The IPC says:

“A reasonable search occurs when an experienced employee who is knowledgeable in the subject matter of the request makes a reasonable effort to locate records related to the request.”

“A reasonable effort is the level of effort you would expect of any fair, sensible person searching areas where records are likely to be stored. What is reasonable depends on the request and related circumstances.”

 I believe my request is reasonable given your earlier statement that there were no responsive records.

I have also consulted the municipality’s Records Classification and Retention Schedule By-law 2019-089. However, the 1 November 2022 meeting was so recent – and the issue remains so current – that I believe the responsive records are most likely to be with Mr  Kostopoulos and Mr Naylor and their respective offices.

Separately, your decision letter of 2 March 2023 in respect of FOI-2023-009 tells me a search was conducted and no responsive records were located concerning my request for information on the process or mechanism the Township put in place from 2019 onwards to identify lands in King which might be suitable for a new Southlake hospital.

Given Mr Naylor’s responsibilities as Director of Growth Management I would formally request that his files are examined (if they have not been already) to see if there are any responsive records.

Please let me know if there is anything further I need to do to progress these requests or if I can leave the matter with you.

 I look forward to hearing from you in due course. 

8 March 2023: I write to the Integrity Commissioner David Wake for the third time:  

Re: the Government’s Decision to Amend the Greenbelt Plan to allow development on certain lands 

I wrote to you on 22 January 2023 and again on 7 February 2023 about your Inquiry into Minister Steve Clark’s decision, announced to the public on 4 November 2022, to allow development in certain lands in the Greenbelt. 

Over the last month I have received replies to a number of Freedom of Information requests I filed with the Township of King and with Southlake Regional Health Centre. These are attached. I believe these may be relevant to your inquiry. 

As you know, the Greenbelt lands were bought by Green Lane Bathurst GP Inc for $80M on 15 September 2022 from Bob Schickedanz, then President of the Ontario Home Builders Association. The new owner, Green Lane Bathurst GP Inc, was incorporated on 19 July 2022 and its President is Michael Rice. In December 2022 the Government removed these lands from the Greenbelt. 

The Mayor of King, Steve Pellegrini, and senior staff met with representatives of the Rice Group on 10 August 2022, 17 October 2022 and, of course, on 1 November 2022 when the commitment was given by Michael Rice to make Greenbelt land available to Southlake Regional Health Centre for a nominal fee. 

Did Michael Rice know his lands were going to be removed from the Greenbelt? 

The question at issue is whether, on 1 November 2022, Michael Rice gave his “nominal fee” commitment in the certain knowledge that his lands were going to become developable with the removal of their Greenbelt designation. Did he have inside information that the rules were about to change? 

Or was he gambling $80M on a hunch that, maybe, at some point in the future, his lands might become developable? And, despite this uncertainty, would he gift to Southlake 60-80 acres out of the 687 acres he had just purchased? 

King’s Mayor Steve Pellegrini says the 1 November 2022 meeting was entirely innocent. He takes the simple and uncomplicated view that hospitals can be built anywhere in the Greenbelt if the Province so decides. My earlier letter to you of 7 February 2023 set out the views of the Chief Planner of York region, Paul Freeman, who says 

“a hospital would be considered institutional and directed to settlement areas given the agricultural designation on the subject lands.” 

A Minister’s Zoning Order can, of course, over-ride official plans but, even so, things are not absolutely cut-and-dried. Even though the Rice lands have now been taken out of the Greenbelt, Mr Freeman tells us we can expect an MZO defining how development will proceed. Mr Freeman presumes that natural heritage features will continue to be protected. 

Are the Rice lands developable in their entirety? 

In the light of this, the views of King’s Director of Growth Management, Stephen Naylor, who was present at the meeting on 1 November 2022, are relevant. Mr Naylor, who describes himself as an experienced Director of Planning and Development, would be able to express an opinion on whether all or any part of the Rice lands could be developed for a hospital or if there were any constraints of the kind identified by Mr Freeman. If so, which areas of the Rice lands were offered to Southlake and with what rationale? 

According to the Township’s records, the last time Mayor Pellegrini met with the previous owners of the Rice Lands was in 2015. On 19 January 2023 he told the ERA newspaper: 

“The Township had worked with a previous owner looking to develop the land but couldn’t because it was in the Greenbelt.” 

Different Landowner offered land 

But by 2019 the prospect of a new hospital was on the horizon and the Mayor wanted to see the new Southlake located in King. It could be anywhere in the Greenbelt. Mayor Pellegrini was scouring the municipality looking for a suitable site: 

“I have been moving this idea forward since 2019 – on different lands, with different landowners.” 

He told the press a “different landowner” had offered land in the vicinity. 

Who was this “different landowner”? We do not know his or her identity. However, we know that John Dunlap, the land agent who sold the Schickedanz land to Michael Rice, owns land immediately adjacent and to the south of the Rice lands. Dunlap was a member of the Southlake Board until September 2022. His lands remain in the Greenbelt. 

Despite these statements from the Mayor, the municipality has been unable to show me any records relating to the process or mechanism in place to identify lands in King which might be suitable for a new hospital. 

“The lands we have under contract” 

The first contact between the Rice Group and King in 2022 (according to the Township’s records) came on 28 June 2022 when John McGovern, the Rice Group’s Senior Vice President, Policy and Planning, emailed King’s Chief Administrative Officer, Daniel Kostopoulos:

“Hi Dan, it was great to see you at the Lake Simcoe Region Conservation Authority dinner last week… (held on 22 June 2022) You spoke with Mike Rice about the lands we have under contract in King and we would like to meet with you in the near future to further that discussion…” 

Over the summer and autumn there followed a series of email exchanges and meetings between the Rice Group and the Township leading up to the one on 1 November 2022 when the “nominal fee” commitment was made. 

Those present at this meeting on “hospital expansion” at King Municipal Centre included Mayor Steve Pellegrini, Stephen Naylor, the Director of Growth Management at King, Arden Krystal, Southlake’s Chief Executive, and John Marshman, Southlake’s Vice President Capital Facilities and Business Development.  (Note to reader: I was subsequently told by the Township Clerk that Mr Naylor was not present at the 1 November 2022 meeting.)

No Records Exist 

When I asked for sight of records of this key meeting I was told none existed. The Town Clerk, Denny Timm, told me on 20 January 2023 that a search had been conducted and no responsive records were located. 

On 2 February 2023 I lodged a further Freedom of Information request with King asking for the dates in 2022 on which (a) Mayor Pellegrini and/or (b) Township staff met Michael Rice. 

Mayor Pellegrini had told the Globe and Mail on 1 February 2023 (and other media outlets) that he met Michael Rice for the first time on 1 November 2022: 

“That’s the only time I’ve talked to him.” 

You will see from the attached response from King that Mayor Pellegrini and Township staff met Michael Rice twice before this - on 10 August 2022 and on 17 October 2022. 

It is for these reasons that I have today asked the Town Clerk at King, Denny Timm, to undertake a second search for records of the 1 November 2022 meeting focussing on the 2022 files of Stephen Naylor and Daniel Kostopoulos. 

I have also submitted two further Freedom of Information requests to King asking for sight of records of the meetings held on 10 August and 17 October 2022 – the latter being described as a 

“pre-meeting with Michael Rice and John McGovern (Rice Group) in advance of Southlake meeting”.

I have also asked Southlake to conduct a search of the files of Arden Krystal and John Marshman for records – including emails and meeting notes - of the meeting on 1 November 2022. 

I shall forward the responses to these Freedom of Information requests as soon as I receive them. 

10 March 2023: Blog: Selling the Greenbelt: Southlake has no records of meeting where Michael Rice made land gift. 

15 March 2023: I file the following FOI with Southlake:

“In Southlake’s Directory of records (see attached) I request sight of the Index of Records held in the category “capital projects” described as records relating to the “planning, construction and commissioning of new and renovated hospital facilities”.”

16 March 2023: Integrity Commissioner David Wake says he and his staff have reviewed extensive material gathered so far and have done independent research on the matter. He says he is preparing summonses for numerous witnesses to be interviewed.

16 March 2023: Blog: Selling the Greenbelt: Southlake Chief Executive, Arden Krystal, should be questioned under oath about gift of Greenbelt land for new hospital.  

19 March 2023: Blog: The Greenbelt Inquiry: "Just tell me what you remember." 

21 March 2023: I file the following FOIs with Southlake:

“I request sight of the sections of the Board Policy Manual that deals with (a) “Board Meetings Policy” and (b) the duties of the Secretary.

and

“I request sight of the background materials submitted to the Board in relation to the formation of the Land Acquisition Sub Committee which is referred to in the summary of the 22 September 2022 Board Meeting, redacted as you think fit.”

and

“I request sight of the minutes of the Board Meetings on 22 September 2022, 24 November 2022 and 26 January 2023, redacted as you see fit.”

21 March 2023: Blog: Southlake and the public interest. 

25 March 2023: Blog: Why did Doug Ford give John Taylor a public dressing down?  

27 March 2023: From Denny Timm, Town Clerk of King Township to me:

Subject: RE: Freedom of Information requests re land for Southlake Hospital:

Thank you for allowing me time to review your email.

In your access request FOI-2022-070, you asked the following:

At the 7 November 2022 Committee of the Whole, elected officials approved a motion moved by the Mayor and seconded by Councillor Cober concerning land in King which could be used as a site for Southlake Regional Health Centre. The motion asserts that "the landowner is committed to providing the necessary lands for the Southlake Regional Health Centre site for a nominal fee". I request sight of all records held by the Township (including emails, phone call and meeting records) relating to this commitment. I am specifically requesting information on who received this commitment and the form it took - whether it was in writing or given verbally. I also request information on what is the "nominal fee".

My understanding of the access request was that you were requesting information regarding the commitment of the nominal fee and specifically, who received the commitment of the nominal fee and what form it took – in writing or verbal, and the amount of the nominal fee. I responded that a search had been conducted and no responsive records were located. Given this, the letter added that the commitment of the nominal fee was conveyed verbally to Mayor Pellegrini during an in-person meeting with Rice Group and Southlake Representatives on November 1, 2022.

The decision letter was issued to you on Friday, January 20, 2023. I do acknowledge the typo in the date of the letter which should have stated 2023, not 2022.

I understand that your request is now seeking “any record of information – whether printed on paper or held electronically - concerning that 1 November 2022 meeting where the “nominal fee” commitment was given.” 

As FOI-2022-070 has been responded to, the appeal period has closed, and the file is closed, I would request that you submit a new FOI request. We will process this request as a new access request, issue a new decision letter with any applicable responsive records and have a new 30-day appeal period, should you wish to appeal to the Information and Privacy Commissioner’s Office after the issuance of the decision letter. 

Regarding your follow-up on FOI-2023-009, I intend to respond to this part of your email by the end of this week (being by Friday, March 31, 2023).

28 March 2023: Access request to King Township (FOI-2023-014 – meeting on Hospital Expansion, November 1, 2022): 

“I request sight of any record of information – whether printed on paper or held electronically – concerning the meeting on “Hospital Expansion” held at King Municipal Centre on 1 November 2022 in which the following participated: Arden Krystal, John Marshman, Steve Pellegrini, Stephen Naylor and Michael Rice. The search for responsive records should include files held by Daniel Kostopoulos and Stephen Naylor.” (Date range: 2022-06-01 to 2023-03-27)

31 March 2023: King Town Clerk, Denny Timm, emails me:

As communicated to you on Monday, March 27, 2023, I committed to following-up with you today regarding your follow-up question on FOI-2023-009:

Separately, your decision letter of 2 March 2023 in respect of FOI-2023-009 tells me a search was conducted and no responsive records were located concerning my request for information on the process or mechanism the Township put in place from 2019 onwards to identify lands in King which might be suitable for a new Southlake hospital.

Given Mr Naylor’s responsibilities as Director of Growth Management I would formally request that his files are examined (if they have not been already) to see if there are any responsive records.

I can confirm that Mr. Naylor did not undertake any active scans or site location searches for a new hospital site in, or around 2019, and as such, there are no additional records to disclose.

Should you not be satisfied with the search conducted, you may appeal the decision to the Information and Privacy Commissioner of Ontario…

I will consider FOI-2023-009 closed. 

6 April 2023: King replies to my FOI 2023-012 filed on 8 March 2023. (Shown in timeline above as *)

17 April 2023: FOI filed with the Township of King:

“I request sight of any record of information – whether printed on paper or held electronically – concerning the pre-meeting held at 1.30pm on 17 October 2022 at the King Municipal Centre, in advance of the Southlake meeting on Hospital Expansion on 1 November 2022, in which Mayor Pellegrini, Stephen Naylor, John McGovern and Michael Rice participated. The search for responsive records should include files held by the Mayor’s Office, Daniel  and Stephen Naylor.” (Date range: 2022-10-12 to 2022-11-01)

!7 April 2023: Ontario Auditor General, Bonnie Lysyk, requests Michael Rice to attend an interview at her office in connection with an 

"audit looking at the recent changes to the Greenbvelt and their economic implications including their effect on Ontario's housing goals."

19 April 2023: Blog: Selling the Greenbelt: Why did Steve Pellegrini mislead the public about his meetings with the developer, Michael Rice?  

23 April 2023: I write to King’s Director of Growth Management, Stephen Naylor:  

I write as a resident of Newmarket who is interested in planning and development issues in York Region.

For some months now I have been trying to understand the sequence of events which gave rise to the Council resolution of 7 November 2022 on the Southlake Regional Health Centre, moved by Mayor Pellegrini, which stated that the 

“landowner (of the lands south of Miller’s Side Road and west of Bathurst) is committed to providing the necessary lands for the Southlake Regional Health Centre site for a nominal fee.” 

You would of course have been present at the pre-meeting on hospital expansion which was held on 17 October 2022 and at the meeting on 1 November 2022 when Mr Rice made the commitment referred to in the Mayor’s motion above so you will be familiar with all the issues.

Would it be possible for you to explain the planning justification or rationale for permitting an institutional use such as a hospital on agricultural land in the Greenbelt given the planning regime in force before 4 November 2022 when the Government announced that certain areas of the Greenbelt were to be opened up for development?

I can see nothing in King’s Official Plan nor in the Zoning By-law for the Countryside which was approved by your Council on 24 September 2022 that would permit such a development. Nor can I see anything in the commentary from York Region as the approval authority that would suggest such a development would be permitted.

On 10 September 2020, York Region approved King’s Official Plan which had been adopted by the Municipality on 23 September 2019. At the time the Plan was described as a comprehensive and long-term vision which addressed the Township’s long term planning requirements to the year 2031. The documentation said the Plan conformed with Provincial and York Region land use policy direction.

Attachment 4 in the bundle of documentation presented to the Regional Council makes it clear that the Township’s Official Plan conformed with the Greenbelt Plan 2017 and with the Oak Ridges Moraine Conservation Plan 2017. In the light of this I do not understand how a major institutional use such as an acute hospital could be sited on prime agricultural land in the Greenbelt or in the Oak Ridges Moraine outside a settlement area.

I have been in correspondence with Mayor Pellegrini and Mr Timm about the 7 November 2022 resolution and matters that flow from it and as a courtesy I am copying this letter to them.

I am grateful and I look forward to hearing from you.

26 April 2023: Blog: A second Southlake in King? We need to hear from Stephen Naylor.  

27 April 2023: Mr Naylor replies:

In response to your email below I would note that the decision to remove these lands from the Greenbelt was made by the Province of Ontario. I believe that your question should be directed to that body. 

27 April 2023: I reply to Mr Naylor:

Thank you for your email in response to my earlier one of 23 April 2023.  It is very much appreciated.

You ask me to put my question to the Province of Ontario. But my question seeks your professional opinion:

Do you believe a hospital was a permitted use for the Rice Lands under the Greenbelt Plan, prior to their removal from the Greenbelt last December?

The Rice Lands appear to be mostly “Protected Countryside” in the Greenbelt Plan with a small part being “Countryside” under the Oak Ridges Moraine Plan. The Provincial Policy Statement puts hospitals and other health facilities within the definition of “public service facilities” which are allowed in settlement areas within the Greenbelt but not on Protected Countryside lands. It follows that a hospital would not be permitted on the Rice Lands under the Greenbelt Plan or the Oak Ridges Moraine Conservation Plan.

Do you disagree with this conclusion?

As before I am copying this to Mayor Pellegrini and Mr Timm. I look forward to hearing from you.

27 April 2023: Blog: Selling the Greenbelt: The New Southlake was planned to be built on Greenbelt land in King owned by developer Michael Rice and former hospital Board member John Dunlap.   

28 April 2023: I write to the Ontario Integrity Commissioner, David Wake, for the fouth time: 

I wrote to you on 22 January 2023, 7 February 2023 and 8 March 2023 about your Inquiry into Minister Steve Clark’s decision, announced on 4 November 2022, to allow development on certain lands in the Greenbelt. 

I have new information which I believe may be relevant to your inquiry. What follows should be read in conjuction with my earlier letters. 

No records 

Until yesterday, the Township of King insisted it held no records relating to the consequential meeting at King Municipal Centre on 1 November 2022 when Michael Rice offered Southlake Regional Health Centre land in the Greenbelt for a new hospital for a nominal fee. This was the subject of a Council motion on 7 November 2022 moved by King’s Mayor, Steve Pellegrini, which was carried unanimously. 

Southlake too insists they have no records of the 1 November 2022 meeting other than one invitation sent by King’s Chief Administrative Officer to an unidentified recipient on a date unspecified. (This is the subject of an appeal to the Information and Privacy Commissioner.) I told King’s Town Clerk, Mr Denny Timm, that, in my view, this was clearly a record and if one existed there could well be others. He advised me to file a new Freedom of Information request which I did on 28 March 2023. 

The Decision Letter arrived yesterday, 27 April 2023. It is attached together with the supporting documents. The documents are significant for these reasons: 

They show the Rice Group’s plans for the proposed siting of a new hospital on Greenbelt land in King were well advanced prior to the 1 November 2022 meeting. The draft presentation “Southlake Hospital – Site Proposal” was emailed by the Rice Group’s Erin Lindsay to King’s Chief Administrative Officer, Daniel Kostopoulos, “for review” on 26 October 2022. 

Concept Site Plan 

The draft presentation – partially redacted - relates to a draft concept site plan. This is not something that can be put together overnight on the back of an envelope. There would have to be an awareness of all the many factors which could shape the final design. After all, this presentation was designed with a specific audience in mind – the hospital’s Chief Executive, Arden Krystal, and Southlake’s Vice President Capital Facilities, John Marshman. The proposal to site a hospital on the Rice lands was clearly something that had been maturing for months. 

A pre-meeting on “Southlake Expansion” between King’s Mayor, Steve Pellegrini, and King’s Director of Growth Management, Stephen Naylor, and Michael Rice and John McGovern (Senior Vice President policy and Planning, Rice Group) took place on 17 October 2022. That followed an earlier meeting on 10 August 2022. Michael Rice spoke to Mr Kostopolous as early as 22 June 2022 when the Greenbelt lands were already under contract to him though the $80M purchase was not completed until 15 September 2022. 

Permitted Land Uses 

It is impossible to believe that these meetings occurred without someone raising the issue of permitted land uses on prime agricultural land in the Greenbelt. The documentary evidence clearly suggests the Rice Group believed it would be possible to build a hospital on the Rice Lands. 

The triangular Southlake logo in the presentation’s graphic appears to show the proposed location of the new Southlake. If this is a rough approximation of the location, it straddles land owned by Rice and John Dunlap – a former member of the Southlake Board (until September 2022) and the land agent who facilitated the sale of the Greenbelt from Bob Schickedanz, the former president of the Ontario Home Builders Association, to Michael Rice. 

John Dunlap’s land was not removed from the Greenbelt on 21 December 2022. It is unclear to me why the Rice Group’s presentation appears to show part of the hospital’s footprint on Dunlap’s land which remains in the Greenbelt. 

Incomplete

The picture I paint is, unfortunately, incomplete. I am still waiting for a number of Freedom of Information requests to come through from King Township and from Southlake. I have asked King for sight of all records relating to the Southlake pre-meeting on 17 October 2022. And I have asked Southlake for sight of records relating to their plans for a second site for a new acute hospital. It is difficult to believe there are no records relating to the offer of lands for a nominal fee. 

I am sorry to write to you yet again about these matters but I could not anticipate how difficult it would be to get timely, complete and accurate responses to Freedom of Information requests which appeared to me to be simple and straightforward. 

29 April 2023: Blog: Documents reveal hospital proposal on Greenbelt.  

16 May 2023: I write again to Stephen Naylor:

I am sorry to trouble you again.

I wrote to you on 23 April 2023 asking if you could explain the planning justification or rationale for permitting an institutional use such as a hospital on agricultural land in the Greenbelt given the planning regime in force before 4 November 2022 when the Government announced that certain areas of the Greenbelt - including lands in King - were to be opened up for development.

On 27 April 2023 you replied, advising me that I should direct my question to the Province of Ontario. In the belief that you may have misunderstood the thrust of my question I emailed you later that day asking if you agreed with my view that a hospital would fall within the definition of “public service facilities” and would be allowed within settlement areas in the Greenbelt but not on Protected Countryside.  Would it be possible for you to address this straightforward point?

As I say, I am asking for your views as a distinguished professional planner. Plainly, your opinion is not a matter for the Province.

As before, I am copying this to the Mayor, Steve Pellegrini, and to the Town Clerk, Danny Timm for their information.

I am grateful. 

18 May 2023: Counsel for Michael Rice advise Ontario's Auditor General that he would not be able to contribute anything that would be relevant to her audit. (see 17 April 2023 above)

30 May 2023: Blog: Selling the Greenbelt: Southlake and Transparency. 

31 May 2023: Auditor General advises Michael Rice that she believes he could offer "insight that is material to our audit". (see 18 May 2023 above)

4 June 2023: Blog: Doug Ford and Land Use Planning: Making it up as he goes along.  

6 June 2023: I file FOIs with King asking for sight of emails, maps and other records sent by Michael Rice to King’s CAO, Daniel Kostopoulos, on 7 November 2022 which relate to the proposed new Southlake hospital campus and the response from Mr Kostopoulos. I also ask for sight of the email exchanges and their attachments between Mayor Pellegrini and Southlake Chief Executive, Arden Krystal, concerning the motion moved by Mayor Pellegrini at the November 7, 2022 Committee off the Whole on the offer of land in King for a new hospital.

7 June 2023: I file FOIs with Southlake requesting sight of all records relating to information requested from the Rice Group by Southlake’s architects. I also ask for sight of email exchanges between Mayor Pellegrini and Arden Krystal on 7 November 2022. And I ask for all records relating to meetings between John Marshman (Southlake) and Jordan Holt (Rice Group) from 1 January 2022 onwards. I ask for sight of all records showing the dates in 2022 when Michael Rice or his representatives met named representatives of Southlake together with the agendas for these meetings. I ask for a list of Southlake Board members present at the Board meeting on 22 September 2022.

27 June 2023: Auditor General issues a summons to Michael Rice requiring him to attend her offices and be examined under oath. (see 31 May 2023 above)

5 July 2023: Southlake Chief Executive announces she is to retire in 2024.

5 July 2023: Second developer, Michael Rice, goes to court to avoid questions from Ontario auditor general in Greenbelt probe. (Source Toronto Star and CBC)

10 July 2023: Blog: John Dunlap meets Steve Pellegrini to discuss possible location for a new acute hospital in King

1 August 2023: Former Steve Clark aide, Luca Bucci, leaves his Chief Executive position at the Ontario Home Builders Association - without explanation.

 9 August 2023:  Auditor General releases her report on changes to the Greenbelt.

30 August 2023: Integrity Commissioner publishes his report.

8 September 2023: The Globe and Mail reveals that Susan McGovern, appointed by Doug Ford to the Board of the Greenbelt Foundation, is the sister of Michael Rice who bought the Greenbelt lands at Bathurst in King for $80M and is the spouse of John McGovern, the Rice Group’s Senior Vice President of Policy and Planning. 

19 September 2023: Blog: York region shgould challenge in the Courts Ford's decision to open-up the Greenbelt for development

20 September 2023: Blog: What is to be done with Steve Clark?

21 September 2023: Ford announces that lands removed from the Greenbelt in December 2022 are to be returned to it. He pledges never to build on the Greenbelt again.  Blog: Doug Ford admits it was a mistake to open the Greenbelt for development and, astonishingly, reverses course

24 September 2023: Blog: The Case for a Public Inquiry

25 September 2023: Blog: Hung out to dry: The disgraced Steve Clark will be reprimanded in the Legislature

29 September 2023: Blog: My deputation to King Township to ask Mayor Steve Pellegrini what he knows

2 October 2023: Blog: Did Ryan Amato know that Michael Rice had gifted for a new Southlake on the Greenbelt at Bathurst? And, if so, what did he do about it?

3 October 2023: Blog: From the Globe and Mail: Proposal to build hospital on protected Greenbelt land cancelled

10 October 2023: The RCMP announces it is launching a criminal investigation into “allegations associated to the decision from the Province of Ontario to open parts of the Greenbelt for development.”

12 October 2023: Blog: Why the RCMP should interview Steve pellegrini under caution

15 October 2023: I write to Mayor Pellegrini, copied to all members of King Council, asking about the "other lands".

Dear Mayor Pellegrini

We have been in correspondence before about your role in the proposed development of a second Southlake on prime agricultural land in the protected countryside in the Greenbelt in King.

I am writing to ask if you would now identify the location of the “other lands” in King that were discussed as a possible site for the second Southlake.

I had intended to put this question directly to you at tomorrow’s Council meeting but the Township Clerk informed me this would not be possible as King does not have an Open Forum component to its meetings.

In February 2023 you told the King Sentinel that you had been searching for a suitable site for a second Southlake for years:

“I have been moving this idea forward since 2019 - on different lands, with different landowners. At the time of our meeting, I brought the idea of a hospital forward to the Rice Group and they were open to discussion.”

You told me in your email of 19 April 2023 that at the meeting in question - your lunch with Michael Rice at the Terra Restaurant on 10 August 2022 - you asked him if he would be interested in donating land for a second Southlake.

“I brought the idea of a hospital forward to the Rice Group and they were open to discussion.”

The Integrity Commissioner, David Wake, interviewed you in connection with his inquiry into the former Municipal Affairs and Housing Minister, Steve Clark. In paragraph 288 of his report, Mr Wake writes:

“… the Mayor explained that other lands in the vicinity (of the Bathurst site) had already been discussed as a possible hospital site and that if Mr Rice contributed land from his recently purchased property, he believed it would be a viable option for the hospital and a significant benefit for King Township.”

I have been filing Freedom of Information requests with your municipality since December 2022 and I am told there are no records of discussions involving these “other lands”. No search was conducted by the Township to identify lands that might be suitable for a second Southlake. The Director of Growth Management has not been able to shed any light on these “other lands” and advises me to contact the Province.

Given this, I should be grateful if you would let me know where these “other lands” are located and who was involved in the discussions concerning their suitability as a possible site for a second Southlake.

I am copying this to your councillor colleagues and, as a courtesy, to the Chief Administrative Officer, Mr Kostopoulos, the Township Clerk, Mr Timm, and the Director of Growth Management, Mr Naylor.

I look forward to hearing from you.

16 October 2023: Blog: Greenbelt U-turn Bill tabled at Queen's Park

20 October 2023: Mayor Pellegrini replies to my email of 15 October (above).

I had a discussion years ago with a landowner that brought forward the idea of donating lands for a new hospital site.

I have provided records arising from this discussion to the Township Clerk. Any additional details regarding their disclosure should be directed to the Township Clerk.

24 October 2023: Blog: When is the disgraced ex-Minister Steve Clark going to be reprimanded?

26 October 2023: Blog: Ford and Calandra rule out debate on Integrity Commissioner's report censuring Steve Clark for his role in the Greenbelt scandal

28 October 2023: Blog: Decision on naming mystery landowner who "brought forward idea of donating lands" for a new Southlake will be made by King Township on 6 November 2023

30 October 2023: Environmental Defence and Ecojustice release a huge treasure trove of material from Freedom of Information requests. Blog: Chief Executive explains why Southlake has no records of the meeting when developer Michael rice gifted land for a new hospital

30 October 2023: Blog: Developer Michael Rice makes no mention of a second Southlake when asking for Bathurst lands to be removed from the Greenbelt

31 October 2023: Blog: Senior officials in the dark about second Southlake in King

31 October 2023: Blog: Servicing the Bathurst lands

15 November 2023: Former Housing Minister, Steve Clark, is "deeply remorseful".

19 November 2023: Blog: A Second Southlake in King: the "Bathurst and Davis Drive Opportunity"

27 November 2023: In a letter to the hospital's Privacy Office Arden Krystal explains that she has shared all records related to the November 1 2022 meeting. She says she has exhausted all disclosure and have no further details.

30 November 2023: Blog: The Greenbelt Scandal in King: Understanding what really happened and why

21 December 2023: King Township answers my Freedom of Information request of 2 February 2023 and reveals the Southlake Board member, John Dunlap, was prepared to offer his own land at Bathurst and Davis as the site of a new hospital. He told King Mayor, Steve Pellegrini, this on 20 July 2020.

23 December 2023: Blog: Former Southlake Board Member and Land Agent, John Dunlap, offered Greenbelt land for new hospital

29 December 2023: Blog: The Greenbelt Scandal: Michael Rice, John Dunlap, Steve Pellegrini and the new Southlake

14 January 2024: Blog: Southlake and the Greenbelt: John Dunlap declared a Conflict of Interest

25 February 2024: Blog: The Greenbelt Scandal and Southlake's search for a new acute hospital site

3 March 2024: Blog: The Greenbelt Scandal, a new hospital and Southlake's "known opportunities"

27 March 2024: Blog: Southlake struggling to find new site for its acute hospital complex.

5 April 2024: Blog: Building on the Greenbelt: What happened on 24 January 2023?

8 May 2024: Blog: Greenbelt Scandal Update: Another Case of No Records

19 May 2024: Blog: Dissembling Mayor Pellegrini still pushing for a new hospital on the Protected Greenbelt in King

2 June 2024: Blog: IPC to report on record keeping in relation to Greenbelt controversy

9 June 2024: Blog: Steve Clark still waiting to be reprimanded

17 June 2024: Blog: Southlake says it has no record of John Dunlap ever offering land for a new hospital

19 September 2024: Blog: Southlake refuses to relase Preliminary Concept Plan

4 November 2024: Blog: Southlake appeals go to Information and Privacy Commission Adjudicator

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Updated on 5 November 2024