The Bradford Bypass - Clearing the Air

There are a lot of misconceptions, myths, and misunderstandings regarding the role that highways and cars play in our economy, and the impact they have on our environment and communities. Many of these are coming to the fore with the Bradford Bypass. Here we address some of them.

Municipalities in the Lake Simcoe region, including just recently Barrie, are being asked to weigh in on the Bradford Bypass, a proposed highway that would run just north of Bradford, through the Greenbelt and Holland Marsh, to connect the 404 and 400 highways.

There have been a number of statements and assertions made in support of the project. Environmental organizations, including ours, and community members argue, however, that these points either don’t hold water, or that they represent ways of planning that are outdated in an age of environmental crises.

Let’s look at some of the main arguments supporters make and why they are wrong.

Argument 1: It isn't our problem

This argument is tied in with jurisdictional concerns, but there’s an important distinction to be made between the political boundary, on the one hand, and the impact of the project on the environment, on the other.

Let’s start with the jurisdictional concerns and then move on to the environmental impact concerns.

It’s a well established political norm to work across political boundaries to address issues that may have an environmental impact. Perhaps the most prominent example of this is the Intergovernmental Panel on Climate Change (IPCC), which has members from 195 nations. A less well known, but much older, example is the International Joint Commission, which was established in 1909 and works to address issues affecting the quality of water along the border between Canada and the United States. Much of The Great Lakes are overseen by this body.

Environmental impacts, we now understand very well, are often difficult to contain, particularly when they occur in the fluid dynamics of air and water, and so work across jurisdictional boundaries is crucial to address them. 

Photo of Barrie's waterfront during sunrise.

A more local example of the importance of working across political boundaries to address environmental impacts is our Conservation Authorities, which are established according to the natural boundaries of watersheds, and so attempt to capture, in a sense, the environmental impact of our actions.

Now, to address the more localized impacts and whether a highway in Bradford will affect those of us living in Barrie.

Part of the rationale for building the highway is to accommodate the projected population growth in Simcoe County, not simply the growth that is expected in the Bradford area. The vehicle trips this project is intended to accommodate come, in large part, from surrounding municipalities, including Innisfil and Barrie, which sends commuters down the 400 highway toward Toronto and the GTA. 

(As an aside, there have also been a number of comments made, including by the mayor of Innisfil, that discount the voices of those who don’t live in the immediate area. These voices come from communities the Bypass is meant to serve. Accordingly, the decision of whether to continue to pour public funds into highways and car-centric development will impact how communities are shaped in these surrounding areas, determining, for example, whether there’s money available to ensure residents there have access to well-connected transit and/or safe cycling and walking routes.)

Argument 2: A new highway will reduce emissions and help combat climate change

The notion that a highway will reduce emissions seems to be based on the idea that vehicles stuck in traffic emit more greenhouse gases than those not stuck in traffic.

On the surface this seems like a reasonable argument, but the data, and experience, doesn’t back it up. Below, we cover two of the most glaring reasons why this doesn’t hold. 

Induced Demand

As more roads and highways are built, the consequence is more use of roads and highways – one begets the other. As roads and highways make land more accessible commercial centres are built at interchanges and residential areas are developed, and with this more vehicles flood into the extra capacity that has been created.

This phenomenon is known as “induced demand,” and it has been shown to happen over and over again when roads are expanded and highways built to “ease congestion.”

(Who doesn’t want congestion eased? The problem is that this just doesn’t accomplish that. Want to spend less time stuck in your car? Stop building roads as the primary way of getting everywhere.)

Evidence shows that the eventual result of these efforts to ease congestion is always more congestion. (Some of you may have also noticed that increased demand is exactly the business case proponents are making for the highway, so there’s that, too.)

The Free Burger Analogy

Here’s a great analogy of that helps explain induced demand.

Imagine that 10,000 free hamburgers are placed in the central square of a city, with a lead time of preparation and notice given to the public (as would happen with building a highway).

What would happen?

People would come and eat the hamburgers, and soon there would be none left.

There would soon be a problem, however.

More people would come to get the free meals than what’s available.

The solution?

Put out more free burgers. And so on and so forth.

Alternatives, such as the taco joint down the street, would be decimated.

This is exactly what happens to public transit and walkable communities every time we build more highways and car-centred sprawl.

See the original post here.

There’s also this explainer, but it doesn’t include hamburgers… you’ve been forewarned.

Idling cars produce more GHG emissions than moving cars

Studies show that this is a myth. Emissions are actually strongly correlated with the distance and rate or speed of travel, and weakly correlated with the level of congestion.1Congestion and emissions mitigation: A comparison of capacity, demand, and vehicle based strategies

Vehicles travelling at higher speeds emit more GHGs than those moving at lower speeds. Building more highways and inducing more people to travel at higher speeds leads to higher emissions. This is compounded by induced demand, which sees more vehicular traffic occur.

There are further reasons why this argument is no longer valid.

Vehicles sold today are increasingly equipped with kill switches that turn off the engine when the car is stationary. Accordingly, vehicles stopped in traffic are producing very little, if any, GHG emissions. Further, and this is linked to a lengthy explanation below, government policy is increasingly geared towards promotion of a modal shift from vehicles with internal combustion engines to those with electric drives. In both cases emissions from idling, even without the research noted above, is made moot.

Argument 3: We need highways to prepare for growth

It is true that we need to plan and prepare to meet increased growth. The question that needs to be answered, however, is how can we do this in a way that is efficient? In other words, how do we make the best use of the resources available to us? (More people means more pressure on resources. If we plan prudently we can ensure that that pressure is lessened, so that our communities can continue to rely on clean water, vibrant green spaces, and fertile farmland.)

Here again highways fail to make the grade.

Highways, most often used to transport a single person per car, are possibly the least efficient option for transportation.

This lack of efficiency – the cost that cars have – has real impacts on our society, including on municipal budgets.

There is currently a multi-billion dollar infrastructure deficit in Ontario, much of it related to roads. This is a cost borne by the taxpayer.2Canadian Infrastructure Report Card

(Roads and highways, if you think about it, are basically subsidies to developers, since they cost more for the public to maintain than they return to the economy when compared with alternatives such as complete communities linked by rail. See the graphic below for more on this.)

Click for a larger version. Learn more about these costs at thediscourse.ca/scarborough/full-cost-commute.

If we are serious about preparing to accommodate the projected growth in population that our region will see in the coming decades, we need to be looking at options that are efficient, that give the best return to the taxpayer, that protect the crucial resources our communities rely on, such as wetlands that filter water, forests that provide habitat for wildlife and filter air of pollutants, and farmland that provides us with healthy, local food.

This last point, the value of supporting a local food ecosystem, is particularly important given the price shocks we have been exposed to with a stretched out global supply chain. It’s also particularly salient given the area this highway will impact, the Holland Marsh or the “Salad belt”, which has some of Ontario’s most valuable, productive farmland. 

The increasing cost of food is something we’ve all experienced over the course of the pandemic, and it’s a factor that will only increase in volatility as climate change increasingly impacts agricultural areas in closer to the equator. The US breadbasket, for example, and the aquifer it relies upon, the Ogallala Aquifer, the country’s largest, is facing serious risks due to increased temperatures from climate change.

Congestion is a drag

This argument is pretty straight forward – the more time people and goods spend stuck in traffic, the more money and potential productivity our economy loses.

Even if you’ve entirely bought into the notion that the best economy is the most productive economy (there is a growing chorus from economists and activists taking issue with this notion, pointing out that the goal of our economy should be to promote the health and well-being of citizens, rather than the simplistic, never-ending pursuit of GDP growth, and the corollary impacts it has on the health of the environment, as well on our social and mental health) the straight forward solution to this would be to plan for strongly connected, complete communities.

These are communities in which efficient transportation is prioritized, enabling people to get to and from work easily and without relying on cars. (Cars and their operation, after all, suck up a lot of financial resources that could otherwise be circulating within the local economy.)

Argument 4: We will all be driving electric vehicles soon, so we don't need to worry about emissions

There are other ways in which our car-centric planning, which highways perpetuate, is creating problems. Many jurisdictions will be hard-pressed to meet GHG emissions targets due to the over-reliance on cars that our communities have – a long history of building for cars rather than for people.

A key method for achieving a large portion of reductions, though even with this their targets, for the most part, are still badly missed, is encouraging a modal shift in transportation from internal combustion engines to electric vehicles. 

A reliance on EVs for emission reductions raises several red flags, however. EVs are an important tool in transitioning to an economy that is in line with what’s needed to ensure a safe planet for our children and grandchildren, but they are just that, a tool to transition.

The more that we rely on EVs the greater the risk we build into our strategies for reducing GHG emissions, and, importantly, our environmental and social impact.

Again, this is one of those issues that on the surface appears to be a no-brainer, but it’s exactly for this reason that it’s problematic.

Phantom reductions

EVs, on their own, represent a stark contrast with the heavy impact we now know is associated with cars using internal combustion engines. Run an EV in a garage with the door closed and you don’t have any problems.

Where things start to get tricky, however, is when you consider the complete cost of the EV, including the source of the power an EV is using and the materials required for its components.

The electricity used to power an EV may not be from a renewable source. Ontario currently generates part of its power with natural gas. Natural gas is a source of methane, which, gram for gram, is one of the most potent GHGs. 

Most of the natural gas that we use in Ontario, and this goes for home heating and cooking as well, comes from Alberta and BC, where fracking is used to extract it from the ground. Methane is released in the process of fracking as well, along with a number of other highly damaging environmental impacts. There is also an increasingly large liability of abandoned wells, which the public is likely on the hook for.

Picture of an oil drill with a red sunset behind it. Credit Zbynek Burival.

“Most of the natural gas that we use in Ontario, and this goes for home heating and cooking as well, comes from Alberta and BC, where fracking is used to extract it from the ground.”

The important point here, however, isn’t necessarily the type of power that is being used, but rather the ability of governments to effectively control the type of power. Relying on EVs for emissions reductions may be an effective political win locally, but without an ability to determine where the power is coming from, governments are taking a risk that emissions will simply be displaced from one jurisdiction to another.

The control, or lack thereof, that local governments have over the power generation mix pales in comparison to their control over where the materials used in EVs come from.

This is where risk starts to increase exponentially. Emissions reductions can be claimed locally, but what in fact has happened is they have been displaced elsewhere. This opens the door to a race-to-the-bottom scenario where some jurisdictions are forced to compete for emissions, becoming a dumping ground for the reductions gained in wealthier areas. This dynamic is already occurring, with certain parts of the world, largely in the global south, competing to attract economic investment by slashing environmental regulations. (And here in Ontario, the provincial government’s COVID economic recovery strategy has been largely based on skirting environmental regulation in order to push forward with developments.)

Perpetuating colonialism

The components used in batteries come, in large part, from countries in the global south.

Lithium is largely found in arid regions of Bolivia and Chile. Mining lithium requires huge amounts of water, as well as sulphuric acid, and the use of these resources is wreaking havoc on local environments.

A copper mine in Chile.

Cobalt is mostly mined in the Democratic Republic of Congo, where child labour is often implicated and a near complete lack of environmental regulation and protections exists.

While we don’t use power generated in these areas, we are nevertheless displacing a huge environmental burden onto them with our efforts to reduce our emissions through our reliance on EVs.

This is not only an environmental issue, it is also, and perhaps more importantly, a social justice issue.

Those of us who are able to afford an EV are far more responsible for climate change than those who live in these areas of the world.

Placing the burden of our emissions reductions on those who are not responsible for climate change represents a profound injustice. This is a continuance of colonialism, whereby the externalities of our economic and social activity are dumped, effectively, onto regions and people who don’t have the means to defend themselves, people and communities who are already at a disadvantage due to centuries of the very same colonialism, the extraction of value, that has so greatly benefited the global north. Such a dynamic is a taking over of their environment, of their communities and their farmland and their rivers and streams and aquifers, for our purposes. To the extent that we rely on solutions with a long tail, whereby the impacts are felt in ways that we do not have to directly grapple with, we assume an increased risk of wrong and error associated with that activity. 

Additional costs

Recycling of the materials associated with EVs represents another challenge that municipalities will have to face.

While current lithium-ion batteries are difficult to fully recycling, new solid state batteries anticipated to come online soon should be easier. This is a double-edged sword, however, meaning that while the impact to the global south may be somewhat reduced (see induced demand for why this won’t solve the problems here), it will make it more likely that this is a service that local governments are expected to support.

There are also factors that many governments don’t seem to be including yet in their future estimation of infrastructure costs, namely the added weight associated with EVs and the impact that will have on roads.3Vehicle Weight vs Road Damage Levels 

This means that as more EVs use our roads, we will need to increase road weight tolerances, which means we’ll be increasing the amount of aggregate that we need to mine or recycle. All of this increases the amount of money that we need to spend on car infrastructure.

Conclusion

We really need to be planning now for the communities that we want in twenty, thirty, fifty years from now. We need to do this in a way that preserves and enhances the natural resources that we have, so that our economy can continue to flourish for our children and grandchildren, and not be depleted in the short-term here and now.

Build within the urban boundary for density so that people can access groceries and workplaces and schools and parks by walking and cycling. This has benefits for our health and wellbeing as well as for our pocketbooks freeing up money in the household budget, otherwise spent on cars, that can instead be spent on quality time with family and friends.

Freeing us up from the expense of owning and operating a car – the second-biggest expense in Canadian households – also makes it possible to transition to a four-day work week, further supporting the health and wellbeing of citizens and helping to reduce the impact that our economy has on the environment.

Build high-speed rail between urban hubs so that we don’t need highways, and situate neighbourhood car-sharing nodes, so residents can access efficient and affordable personal transportation options if required.

All of this, compared to the costs associated with building highways and pouring money into mitigation the costs that will follow them, is in fact easy. All it requires is vision and leadership.

Young girl with a bubble. Credit Leo Rivas.

How Can You Get Involved?

  1. Links and resources are available here: linktr.ee/stopthebradfordbypass
  2. Visit our Bradford Bypass issues page to learn more about the project.
  3. Donate to help us fight this highway! See how some of our efforts have paid off in a Toronto Star/National Observer investigation into the highway.
Photo of a highway bridge. Credit Ajai Arif.
Planning

The Bradford Bypass – Clearing the Air

There are a lot of misconceptions, myths, and misunderstandings regarding the role that highways and cars play in our economy, and the impact they have on our environment and communities. Many of these are coming to the fore with the Bradford Bypass. Here we address some of them.

Read More
Arial photo of the Holland Marsh, with Lake Simcoe in the distance. Credit Jeff Laidlaw.
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Bradford Bypass

The provincial government is proposing a highway that would connect the 404 with the 400. The proposed route passes along the northern edge of Bradford, and through portions of the Holland Marsh.

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Sprawl and Ontario's Greenbelt

Sprawl is one of the most wasteful forms of development, leading Ontario’s former Environmental Commissioner to call it “Ontario’s oil sands.” A strong Growth Plan, together with an expanded Greenbelt, can help ensure growth in a way that is sustainable and more cost effective.

Sprawl is the Dominant Growth Style in Simcoe County

We’ve been dealing with losing our natural spaces and farmland to sprawl in this region for a long time. It’s been the main way we’ve grown our communities for decades, and we continue to do so, even though it’s outdated and extremely wasteful, today.

Consider:

  • Between 2006 and 2014, Simcoe County released more greenfield lands for development (sprawl)  than any other region in southern Ontario. This, despite the fact that the amount of growth they were anticipated to receive was much less than many places;1Neptis (2013) Implementing the Growth Plan for the Greater Golden Horseshoe
  • The IGAP report in 2006 outlined that due to urbanization pressure of sprawl and without intervening action, “the available potable water and aquaculture of these watersheds are threatened” within Simcoe County;2Intergovernmental Action Plan for Simcoe County. (2006)
  • The Lake Simcoe watershed is calculated to lose 12,000 hectares of natural and semi-natural space by 2031.  That’s equivalent to 1000 Vaughan Mills Malls;3Ministry of the Environment and Climate Change. (2014).  Minister’s Report on Lake Simcoe
  • Over the past 40 years, Barrie’s footprint grew by 550% losing over 150km2 of natural and semi-natural space.4Statistics Canada

What Can Be Done?

First and foremost, we have to intentionally choose different development patterns.  Sprawl must be stopped and settlement boundaries must be held firm. 

Unfortunately, this doesn’t make developers and those wanting to cash out very rich. 

As a result, extreme lobbying efforts within our municipal councils promote sprawling patterns as a supposed answer to economic woes – which simply isn’t true. 

In fact, sprawling developments have been shown time and time again to cost the municipality more than what it brings in with new tax revenue and growth.5Report: The High Cost of Sprawl

Infographic on the high cost of sprawl. Credit: Smart Prosperity Institute.
Infographic on the high cost of sprawl. Credit: Smart Prosperity Institute. (Click image for larger version.)

We can also address this through provincial policy, specifically, the Greenbelt. 

The Greenbelt Plan was created to direct growth to existing communities to prevent sprawl from paving over farmland and our most precious, sensitive landscapes. 

Ontario’s Greenbelt policies have been recognized internationally as one of the most legally effective and clear policies when compared against other greenbelt across the globe. 

Although far from perfect, the Greenbelt has been shown to stop the loss of farmland to sprawl, support water systems and act as a natural solution to climate change.

The only thing that is required is political will to prioritize protection of our water, wetlands, greenspaces and farmland over outdated economic policies that are based on infrastructure such as sprawl, highways and pipelines.

We Have an Opportunity to Shift Our Decisions

The province is asking for feedback about how and where to grow the Greenbelt in Ontario. 

Frankly, we think we should protect as much of our land and water as possible – our economy, food security and water security depend on it. 

However, we also recognize that the political will isn’t as bold as the vision that Ontarians may have, so that’s where citizens need to push the needle. 

We need to have conversations about how we create healthy, sustainable, thriving communities. 

Science is showing us that our patterns and choices are problematic for our own survival. 

Let’s start by doing one meaningful thing – grow the Greenbelt to the rest of the Lake Simcoe basin, to areas within Simcoe County that are important to providing clean water, air and food for residents. 

Better is always possible even if it isn’t politically expedient.

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The New Growth Plan Puts Sprawl Over All

We can no longer treat land use as its own issue, nor can we always assume that growth is always a net benefit to our communities. This is simply not true. We can grow our communities in ways that provide affordable housing, protect our natural spaces and water and aspire to create healthy, vibrant centres where people can live and work.

The Ford government is rolling back progress on building healthier communities.

How Did We Get Here?

The transition from 1950s sprawl development to smart growth policies as a provincial concern was really solidified by Premier Mike Harris. 

Yes, that Mike Harris. 

Despite his first term, which gave municipalities more freedom to grow as they wish, by the second term key grassroots movements to protect the Oak Ridges Moraine demonstrated to the public how sprawling growth patterns were hurting our water, our land and our health. 

In response, the Harris government decided to get sprawling growth patterns under control and set up a series of Smart Growth Panels across Ontario. 

That was in 2002.

Central Zone Smart Growth Area map.
Central Zone Smart Growth Area map.

The Central Zone panel, which included Simcoe County region, concluded early on in its mandate that the status quo sprawl and growth at all costs mentality would lead to dire consequences for the region by 2035 including: commuting trips that would take 45 percent longer, mostly due to congestion; a marked deterioration in air quality; worsening delays in the movement of goods; and higher taxes.1Neptis: Smart Growth and Places to Grow

Complete Communities Connected by Public Transit

The panel sketched out a concept of how growth in this area should go to avoid those outcomes – its vision relied heavily on compact, complete communities connected by public transit: TTC rail, GO rail, bus rapid transit, and inter-city and inter-regional rapid transit. There were also delineated areas for protected natural zones and an awareness of agricultural lands that were under increasing pressure from growth. 

When the Liberals came into power in 2003, they used a lot of the concepts from the Smart Growth Panels to form Ontario’s first Growth Plan. The award-winning Growth Plan directed growth to form complete communities and stop sprawl.

Ontario's Growth Plans, through the years.

Cover of Ontario's Growth Plan 2020

Growth Plan (2020)

This is the most recent version of the Growth Plan, revised by Doug Ford’s government, which contains many of the problems pointed out in this post.

Cover of Ontario's Growth Plan (2017)

Growth Plan (2017)

The plan as it was under the previous Liberal government.

Cover of Ontario's Growth Plan (2006)

Ontario's Growth Plan (2006)

The original the Growth Plan, titled “Better Choices, Better Future.”

Unfortunately, these efforts were short lived.

A series of amendments and regulations watered down the objectives over the years, but at its core it still aspired to keep sprawl in check through limiting growth in rural areas, ensuring large developments were on municipal services, promotion of public transit, climate change considerations and rigorous criteria in order to expand settlement areas.

So why the history lesson on planning? 

Well it’s important to note that governments, over previous decades, have been trying to avoid the situation the province is now promoting, which is sprawling subdivisions, and with a very little strategy to deal with climate impacts, water impacts, and loss of farmland and biodiversity that come with it.

What is Happening Now?

It’s not hyperbole to say that the changes  made recently by the province with respect to growth and planning take us back to the 1990s. Some of the problematic changes include:

  • Density targets for our region have been scaled back tremendously.

This calculation outlines how efficiently we use land to house people and places of employment.   

  • The limits that were put on growth, previously known as population allocations, are now set as a minimum target, not as a maximum as they were before.
  • Formerly, settlement areas could only be expanded during the Official Plan (OP) process, so long as evidence is presented to demonstrate need. Now  they can be expanded up to 40 hectares outside of the OP period.
  • New developments no longer need to prioritize being serviced by municipal water or wastewater – septics and communal septics are now allowed more easily.

This enables development to get into more natural, rural areas, and puts water quality at risk.

  • Calculations to determine how much land must be set aside for new growth outside of built upon land have changed too.

The municipality must now plan for growth to 2051. This means that in the middle of a pandemic with no knowledge of how work/commute/travel patterns will change, municipalities must decide by June, 2022, how much new land to give up to development.

It also means that due to COVID restrictions this Municipal Comprehensive (MCR) process, that requires public consultations, is limited to online interactions. That’s why many communities are asking their local government to delay these decisions until people can properly consult with staff and neighbours.

  • Municipalities are now forced to calculate how much land based on market needs.

Simply put, there are two ways to calculate this – looking to see what you will need in the future based on changing demographics, what you already have planned, and anticipated need (e.g. more rentals/apartments/seniors residences etc.)…

OR

…you can look back to what has historically been provided by the market (e.g. detached homes, McMansions) and then just extrapolate that forward. 

The current government chose the second option.

This means that in places like Simcoe County where large homes dominate housing stock, we can expect more of that despite more people requiring smaller units and apartments (seniors downsizing, youth, low income).

This also means that more of our green spaces and farmland will be sacrificed to provide for McMansions and sprawl, while people who need housing types that are more affordable (laneway homes, stacked townhomes, apartments) will be mostly ignored.

Photo of "McMansions". Credit: Brett VA - CC BY 2.0.
Photo of "McMansions". Credit: Brett VA - CC BY 2.0.

Why Is It A Concern?

In all of this we need to understand one simple truth – how we grow and where we grow has a massive impact on climate change, water health, biodiversity and our health consequently. 

Growth patterns lock in centuries of impacts and GHG emissions. We can no longer treat land use as its own issue, nor can we always assume that growth is always a net benefit to our communities.

This is simply not true. We can grow our communities in ways that provide affordable housing, protect our natural spaces and water and aspire to create healthy, vibrant centres where people can live and work.

Or, we can grow our communities in ways that use 1950s thinking to deal with 21st century challenges – which will lead to more sprawl, more highways and less public oversight.

One path chooses the needs of the people and our natural communities, the other helps line the pockets of speculative developers at the community’s expense. 

Unfortunately, the province’s policies are 60 years behind the evidence and science, and our communities, now and in the future, will be worse for it.

How Can You Get Involved?

  1. Push back against mega-projects, such as the Bradford ByPass, The Orbit, and the Upper York Sewage Solution.
  2. Share your concerns on social media.
  3. Sign up to our newsletter to stay informed on developments with growing the Greenbelt and limiting sprawl.

Links to Further Reading

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Open Letter - Ramara Must Officially Rescind Request for MZO

Ramara has requested a MZO for developments in the Rama Road Corridor. Without an official letter from the municipality rescinding that request it remains in play.

Dear Mayor and Council.

As you are aware, we have grave concerns about the power of Minister’s Zoning Orders (MZO) – how they cut out public consultation and undermine the role that environmental studies play in ensuring developments don’t result in a net loss of value to the public, being two key issues.

The use of a tool that is as blunt and powerful as a MZO is especially concerning in places where landscapes and watersheds are shared, with their ecosystems or flows extending beyond a single jurisdiction.

Image showing the watersheds in and surrounding Lake Simcoe and Simcoe County.
Image showing the watersheds in and surrounding Lake Simcoe and Simcoe County.

Return to the Planning Process

To ensure development provides a benefit to the community, by which we mean both our human communities and the natural communities that we are a part of and rely upon, it is crucial that they meet a high level of rigour in determining their ‘fitness’ in a given location. Projects such as what is proposed for the Rama Road Corridor must, at minimum, meet the requirements set out under the Planning Act process.

MZOs Cause Inconsistency and Confusion

Confusion remains, however, regarding whether a MZO has been requested by Ramara for projects in the Rama Road Corridor. Our coalition was relieved to hear, during the Orillia special meeting this week, that Ramara does not want to proceed with a MZO request.

It is important to be very clear that the Township of Ramara has initiated a MZO request, and that until and unless Council officially rescinds this request with a letter to the Minister, this request stands.

Ramara Has Requested a MZO

The fact that Ramara has initiated a MZO request, which is all that is required since there is no formal application process outlined under Section 47 of the Planning Act for MZOs, is evidenced by the following:

First, a motion was passed by the Township of Ramara on November 2, 2020. In item 6.1 of the agenda council passed a motion to allow Mayor Clarke to sign a letter to accompany the Rama Road Economic Employment District package. Although the letter does not mention a MZO application in its body, within the package the request for a MZO for this project was bluntly stated:

“The municipality is requesting that the Minister ​enact​ a Minister’s Zoning Order for the three proposed developments in order to commence the growth and development within the Rama Road Corridor.”1Township of Ramara. Minutes of the Committee of the Whole Meeting Dated: Monday, November 2, 2020.​ ​(Emphasis added.)

With a motion of council to endorse this package, it most certainly can be considered an official municipal request for a MZO. Further, it doesn’t state it wants to explore a MZO discussion or open up the feasibility of a MZO, but enact one.

Simcoe County Has Backed This Request

Second, a request was made by the Township of Ramara to the County of Simcoe Council to endorse Ramara’s MZO request.

It first went to the Committee of the Whole on November 10, 2020. Mayor Clarke moved a motion “that the County of Simcoe supports the letter dated November 3, 2020, titled Rama Road Economic Employment District.”2County of Simcoe. Minutes of Committee of the Whole Meeting Dated: Tuesday, November 10, 2020.​ As a reminder, this letter accompanies the ​Rama Road Economic Employment District package which explicitly requests a MZO to be enacted.

Screenshot of the section of the Rama Road Corridor Package that requests a MZO.
Screenshot of the section of the Rama Road Corridor Package that requests a MZO.

Next, this recommendation was brought forward to County Council at a Joint Committee of the Whole and Council Meeting on November 24, 2020. From there, Resolution 2020-705 was passed by County Council which resulted in a letter dated December 7, 2020 to MMAH Minister Steve Clark from the County of Simcoe. The body of this letter further outlines that, in fact, a request to enact a MZO was made by Ramara Township AND that County Council supports their request:

Recommendation CCW-132-20

“That the County of Simcoe supports the letter dated November 3, 2020, titled Rama Road Economic Employment District.”

The County of Simcoe is pleased to inform you [Minister Steve Clark] that County Council supports the above proposal within the Rama Road Corridor, in the Township of Ramara, and their request for a Minister’s Zoning Order.”3County of Simcoe. Letter to Minister Clark – Subject: Township of Ramara – Rama Road Economic Employment District: Request for Ministerial Zoning Order (MZO

Only Approval Left Is By Province

Ramara’s MZO request now has two – township and upper tier – of the three approvals it needs to proceed. ​The only approval authority remaining is the province.

Evidently, if Ramara is reconsidering its MZO request for the Rama Road Corridor, then it is clear that the procedural motions that have been put in place need to be rectified.

Officially, regardless of intent, two levels of government have endorsed this MZO request. Saying otherwise is disingenuous to the process both councils have undertaken since November 2, 2020.

Ramara Must Rescind Its MZO Request

Public platitudes about intention do not rectify the official acts of council that have been completed thus far. Therefore, we are requesting that the Township of Ramara rectify this situation officially to align with its comments publicly that a MZO was not applied for. Specifically, the Township of Ramara should reopen the issue before council and pass another motion to send written correspondence to the province directing it to disregard its Rama Road Economic Employment District package and that Council will proceed with these lands through the standard process outlined in the Planning Act, not through a MZO.

Further, since the County of Simcoe is the recognized planning authority in the region, its endorsement of the MZO must also be rescinded. We suggest that a recommendation be made within the Committee of Whole for County Council to notify MMAH that County Council is revoking its support of the Rama Road Corridor MZO letter it sent to Steve Clark dated December 7, 2020. From there, County Council must adopt this recommendation and send formal written correspondence to Minister Clark.

In Conclusion

We hope that the Township of Ramara does not break faith with its public comments in the media and in front of a neighbouring council about not wanting a MZO for these properties. By not officially undoing councils’ actions, this MZO request will still be considered by the province. Further, the developers of this project will still have two levels of endorsement for their projects under a MZO and therefore the province could proceed with the MZO request without further input from either the County or Ramara.

Finally, we must go on record that regardless of the MZO application for the Rama Road Corridor, this project, as it stands, is incompatible with a net benefit for Lake Couchiching, Ontario’s significant wetlands, climate, residents of the Lake Couchiching area or the long-term fiscal health of Ramara Township.

We appreciate your attention to this matter and look forward to council actions that ensure this MZO application does not proceed.

How Can You Get Involved?

  1. Send a message to Council using our form.
  2. Share your concerns on social media.
  3. Sign up for alerts to stay up to date.

Sign Up to Receive Alerts for Ramara Township

Links to Further Reading

Help us fight MZO requests.
Send a message to your council and MPP, and report MZOs in your community.
Click Here

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In Innisfil, the proponent of a controversial development, The Orbit, has successfully sought backing from council to seek a Minister’s Zoning Order, or MZO, from the province.

If the province grants this request the developer gets a short cut through rules meant to ensure the public is consulted, environmental impacts are studied, and financial consequences understood.

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Rama Road Corridor - Ramara

Ramara is pushing large developments in what’s known as the Rama Road Corridor,  which was designated an employment district by the previous Liberal government. The township has requested a MZO for the developments, but has denied this is the case, claiming the request was simply meant to open dialogue with the province regarding the proposal.

What's Happening?

Ramara Township is pushing for developments along the Rama Road Corridor, and has requested a MZO from the province.

The developments – three are currently included in the proposal – would impact Lake Couchiching, including both on-land and shoreline/shallow water wetlands categorized as provincially significant.

A map showing where development is proposed, and showing how it will impact wetlands. Map by SCGC using layers from Simcoe County, the MNRF, and features drawn from the proposal.
A map showing where development is proposed, and showing how it will impact wetlands. Map by SCGC using layers from Simcoe County, the MNRF, and features drawn from the proposal. Click for a larger version.

The Township has said that it hasn’t requested a MZO, but they have, evidenced by two motions in council, at Ramara and at Simcoe County, as well as by a staff report recommendation.

The public deserves to participate in decisions that will affect their communities.

Ramara Council must uphold its duty to the public it serves by acknowledging the  MZO request, by rectifying it with a motion that would send a letter to the Minister revoking the MZO request, and re-committing to a planning process done  in good faith, with full public participation and due diligence paid to environmental and other necessary studies to ensure no negative impacts.

Status

The Township officially revoked the MZO request. The town may continue to pursue the development via normal planning processes.

The MZO request stands, after approval for the request letter to the Minister from both the Township and the County.

Until the Township officially revokes its request the MZO can be granted by the Minister.

The Township has not officially revoked its request.

Proponents

Parataxis Design And Development Corporation. 280 High Park Avenue, Toronto, Ontario. M6P 2S7

Timeline

February 8, 2021:

Orillia Council special meeting on the Rama Road Corridor, with Ramara Mayor, CAO, and staff participating.

This is the meeting at which the Ramara mayor and CAO state that Ramara is not seeking a MZO.

December 7, 2020:

November 24, 2020:

November 10, 2020:

November 2, 2020:

Learn More

A map showing where development is proposed, and showing how it will impact wetlands. Map by SCGC using layers from Simcoe County, the MNRF, and features drawn from the proposal.
Planning

Rama Road Corridor

Ramara Council must uphold its duty to the public it serves by acknowledging the MZO request, by rectifying it with a motion that would send a letter to the Minister revoking the MZO request, and re-committing to a planning process done in good faith, with full public participation and due diligence paid to environmental and other necessary studies to ensure no negative impacts.

Read More »

How Can You Get Involved?

  1. Send a message to local Councils.
  2. Sign up for alerts and updates on the issue.

Send a Message to Council

Message to Ramara Council

Dear Mayor Clarke and Ramara Council.

Please end the confusion regarding use of a MZO in the Rama Road Corridor and send a letter, passed by Council, to the Minister that officially rescinds any possible outstanding request.

The proper route to proceed with development is through the planning process, ensuring that it includes full and transparent public participation done in good faith.

Sincerely.

Message to Orillia Council

Dear Mayor Clark and Orillia Council.

Please take a stand to protect the health of Lake Couchiching and the water that we rely on for drinking as well as for recreation.

I ask that you send a letter to the Minister of Municipal Affairs and Housing stating that Orillia opposes the use of a MZO in the Rama Road Corridor.

Sincerely.

Sign up for Ramara Alerts and Updates

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Send a message to your council and MPP, and report MZOs in your community.
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The Orbit - Innisfil

A giant development proposed along the GO Train line in Innisfil. This mega-project is slated to pave over farmland and radically change how Innisfil grows for decades to come. It will also place a great burden on nearby Lake Simcoe.

What's Happening?

Update August 9, 2021: MZO order issued by province; Development proceeding.

In Innisfil, the proponent of a controversial development, The Orbit, has successfully sought backing from council to seek a Minister’s Zoning Order, or MZO, from the province.

If the province grants this request the developer gets a short cut through rules meant to ensure the public is consulted, environmental impacts are studied, and financial consequences understood.

Issuing a MZO effectively eliminates public input and reduces oversight into the net benefit of a development.

Innisfil council should affirm the principle that the voice of residents – your voice – matters when its comes to how their community develops, and require developers to follow the rules in place without any shortcuts.

Quick Facts

150,000 People

Paving Over Farmland

≠ Urban Growth Centre

Why is it a concern?

The Orbit is a concern, and should be given due process and careful consideration, given its size, scale, and location.
A map view of where The Orbit is proposed to be built. Natural features are overlaid.
A map view of where The Orbit, outlined in white, is proposed to be built. Natural features are overlaid. Click for a larger version.
On paper it seems great — a development focused on high density living, where people are close to amenities, including public transportation to major urban centres.
 
The glaring question, however, is why here — why should a development for 150,000 additional people be located in what is currently a largely rural area?
 
It seems the only reason this location is being pushed is the developer owns the land and wants to turn a profit, otherwise it makes absolutely no sense.
 
Given these concerns, this request for a MZO can be seen as an attempt to avoid uncomfortable questions that might be raised by going through due process and engaging in public consultation.
 
If a development is a net benefit to the community then developers can easily demonstrate that by engaging with those who it will most impact, namely the public and residents of the community.
 
We need more public engagement and participation in determining how our communities develop, not less.

How Can You Get Involved?

  1. Use our MZO action page to tell elected representatives of your concerns regarding their use.
  2. Write a letter to local papers outlining your concern with the development.
  3. Use our sign up form, below, to get updates on environmental issues, including The Orbit, happening in Innisfil.

Links to Further Reading

Help us fight MZO requests.
Send a message to your council and MPP, and report MZOs in your community.
Click Here

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Ramara’s MZO application
on Lake Couchiching

We hope that the City of Orillia will take a stand for the interests of its residents and the lake and officially oppose the MZO application request.

This letter was sent to the Mayor and Council of Orillia on January 12, 2021.

Grave Concerns

The undersigned is writing to you today with grave concerns about a MZO application recently submitted to the province by the Township of Ramara and supported the County of Simcoe. We strongly believe that this development is not in the best interest of Lake Couchiching, the environment writ large or the City of Orillia and its residents.

As you can see from the graphic below, a large portion of this development resides within a provincially significant wetland (PSW) and infringes on others. Currently, development within a PSW is prohibited under Ontario’s planning laws. A MZO would remove these prohibitions.

Figure 1.

In Figure 2, it is clear to see how the developments will also infringe on water intake protection zones as well as significant forests.

Figure 2.

For clarity, the development proposal would include 3 separate developments. The MZO is asking for all three of the development applications to be approved including:

Harbour Village at the Narrows (listed as “Resort Residential” on Fig. 1&2)

    • 258 room hotel, an additional 1,678 mixed units proposed

    • Creating 6,414 additional feet of frontage (through harbours and canals) mostly in the midst of a provincially significant wetland which is also one of the last, large intact wetlands on Lake Couchiching

Figure 3.

Rendering of aerial view of Harbour Village at the Narrows. Source: Rama Road Corridor MZO package, Ramara Township
Rendering of aerial view of Harbour Village at the Narrows.
Source: Rama Road Corridor MZO package, Ramara Township

Ramara Waterpark Resort (listed as “Waterpark” on Figures 1&2)

    • Includes a 58,500 sq ft water park, 7 hotels ranging from 6-10 storeys in height (totalling 700 hotel rooms), 8 restaurants, 152 condominium units (6-10 storeys), 252 stacked townhouse units; 8 storey, 34,000 sq ft retirement residence (40 units), commercial and retail space

Figure 4.

Site plan of Ramara Waterpark Resort. Source: Rama Road Corridor MZO package, Ramara Township.
Site plan of Ramara Waterpark Resort.
Source: Rama Road Corridor MZO package, Ramara Township.

Ramara Landing (listed as “Senior Living Homes” on Figures 1&2)

    • 172 townhouse units, 300 resident independent living building, 300 resident long term care home, Two 6 storey condominium towers (150 units total), community centre, water and wastewater treatment plant
Ramara Landing Site Plans overlayed on existing mapping. Source: Rama Road Corridor MZO package, Ramara Township
Ramara Landing Site Plans overlayed on existing mapping.
Source: Rama Road Corridor MZO package, Ramara Township

This application is problematic for the City of Orillia for several reasons.

The health of Lake Couchiching is vital to the health of the City of Orillia

Whether it be for drinking water for residents, recreation or supporting Orillia’s economy via its downtown and tourism, Orillia is highly dependent upon the wellbeing of Lake Couchiching.

A MZO application does not currently require environmental assessments to be completed, as per Section 47 of the Planning Act.

Although Ramara Township references a 1,400 page Environmental Assessment that has been done, it is our understanding that this EA only applies to a portion of the development that is proposed, and that this EA was completed in the early 2000s.

A lot has changed since then.

What we know about the necessity of shoreline wetlands to the health of a lake has also increased.

There is a reason why there aren’t policies within Ontario’s planning regime that guide how development should be done within a provincially significant wetland – because it isn’t allowed.

Since there are no statutory requirements within the Planning Act to complete environmental assessments as part of a MZO and there aren’t policies to guide how building on top of a PSW should be done, it is hard to understand how these wetlands will be protected through a MZO or through this development application at all.

And in the case of these particular shoreline wetlands, they play a significant role in flood mitigation and water filtration of Lake Couchiching.

Impairing these wetlands by building in the heart of them and directly infringing on other parts, squarely puts the health of the lake at risk.

A MZO application is not an appropriate tool for a large development such as this

MZOs cut out several key pieces of the Planning Act process, but most importantly, it removes the statutory consultation and appeal process.

Not only is this process for the public, but also for other stakeholders, such as neighbouring municipalities, to weigh in on shared assets and key issues.

Considering the significant impact this development could have on Orillia’s shoreline, water quality and recreation opportunities, the City of Orillia should be able to have meaningful opportunities to engage in the process and protect its interests.

With a MZO, the approvals are already given and Ramara Township would only be able to handle issues via site plan controls and permitting.

What meaningful process will the City of Orillia have under that system?

If issues do arise, what mechanisms will the City of Orillia have to outline its interests if approvals have already been given?

A large development such as this should have sober second thought, especially within a changing climate and biodiversity loss, but the idea of truncating the process by cutting out consultation through a MZO is unacceptable.

In conclusion

Of course, there are other issues that may be meaningful to members of council such as climate action.

Removal of forests and wetlands is directly incompatible with these goals.1Protecting wetlands and forests can reduce climate adaptation costs2Fighting climate change with conservation3The Role of Wetlands for Climate Change Mitigation and Biodiversity Conservation

The increased boat traffic could also impact shoreline residents on the west side of the lake and historical sites such as the Mnjikaning fish weirs, which are one of the oldest remaining human developments in Canada and a national historic site.

Again, there are many impacts that need to be fully considered, which underscores why a truncated MZO process, which removes meaningful community consultation, is not in the best interest of area residents or other stakeholders.

The City of Orillia has prided itself on its port and Couchiching shorelines. Consequently, council should consider itself a steward of the Lake and deem applications such as this as problematic – especially when utilizing a MZO.

We hope that the City of Orillia will take a stand for the interests of its residents and the lake and officially oppose the MZO application request.

Additional Resources

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Send a message to your council and MPP, and report MZOs in your community.
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