Getting To Know Us: The benefits of smarter planning

This is a part one of three posts outlining our “two sides of the coin” approach to advocacy, or our focus on achieving what is known as “co-benefits”.

In this post, we focus on the first side of the coin, which is planning our communities in a way that is more efficient and that enhances the quality of life for residents.

Introduction

Defining "Environment" in a Comprehensive Sense

Spend just a little while with us, and you’ll quickly understand that when we say “environment”, we mean it in the classical sense, which is, “the area in which something exists or lives”. In other words, it includes the areas of our homes, our neighbourhoods, and our cities, as well as those areas more commonly associated with “the environment”, such as the wilderness or the global commons.

Maximizing Co-Benefits for Communities

In this post, the first of three that are planned in this series, we cover why planning our communities in a way that maximizes what are known as co-benefits makes a lot of sense, including by reducing the burden on the taxpayer and increasing quality of life and enjoyment.

Part two, which focuses on environmental benefits, and part three, which ties parts one and two together, as well as provides more specific information on our efforts, are in the pipeline, so keep an eye out!

The Greenbelt and Municipal Planning

Understanding the Greenbelt's Role in Ontario's Planning Regime

As an organization that focuses primarily on issues surrounding the Greenbelt, you might be a bit surprised by our focus on municipal planning and urban areas. The Greenbelt is a crown jewel on Ontario’s planning regime, and it helps to both direct development toward areas where it’s most beneficial, by, in large part, restricting sprawl, this, in turn, helps protect the valuable natural assets, such as farmland, fresh water, and clean air, that enable our high quality of life.

We think it is important to view the Greenbelt in this context, as a policy that serves as the foundation stone of Ontario’s prosperous and sustainable future. The Greenbelt, in other words, is a valuable tool that our Province has to shape land-use in a way that improves our cities, towns, agricultural areas, and natural habitat.

It’s crucial to underline, accordingly, the fact that, as a tool, the Greenbelt can be further implemented – enhanced and expanded – for the benefit of all Ontarians.

Impact on Municipal Budgets

Land-use and climate action! What could be more exciting than that!?

But seriously, land-use is a pretty dry topic on the surface – zoning, development applications, approval processes and appeals… (although the right of citizens to appeal has been severely curtailed in Ontario of later by the Ford government).

For evidence of how dry this stuff is, one need look no further than council meetings, where the vast majority of attendees are suits, representatives of developers. The reason they are there is pretty obvious – they stand to make money if they are able to get a decision going their way.

The Approvals Process, and Citizen Engagement

For citizens, on the other hand, attending these meetings is taking time from family or other social obligations – and it’s time they aren’t paid for, or, for the most part, time that would result in financial benefit to them.

Thus, the decks tend to be stacked at these meetings.

Councils, elected by the public, generally do their best to ensure decisions aren’t outrageously at odds with the public’s interest. But, councillors are often overworked and under-resourced, and need to rely on information given to them by city staff (also often overworked and under-resourced). In this scenario, it isn’t difficult to see the opportunity for developers to step into the gap and provide information and resources that buttress their claims.

For us at SCGC, a lot of our focus is on these processes because they determine where houses get built, and conversely where houses don’t get built (which happens to be where farmland and natural habitat is preserved!).

To be clear, building houses in not the issue – it’s where they are built that is typically the problem.

Below we briefly sketch out the first of these components.

Challenges and Solutions

Infrastructure Problems, a Growing Threat

Our suburban style of living, while there are a lot of nice things about it, is putting a huge hole in municipal budgets.

The roads that we use to get to and from work, to drop our kids off at school, to purchase groceries and to visit the mall, all cost a lot to maintain.

In 2021 the Financial Accountability Office of Ontario (FAO) released a report that puts the municipal infrastructure deficit at more than $50 billion. This is how much it would cost to bring roads, bridges, and other municipal infrastructure to a state of good repair.

Spread out infrastructure is less efficient and more expensive to maintain. The cost is likely to only increase as climate change results in more extreme weather, placing additional stress on it. (The FAO did a report on this, too.)

Why Sprawl Is So Attractive

One of the biggest bang-for-buck transformations that a municipality can do is convert farmland into urban development. This goes for developers, too, which is why many of them love to build sprawl.

The purchase price of farmland is low, relative to a similar size of land with existing infrastructure and development. When this land is brought into the urban envelope, its value increases dramatically.

(Witness the recent Greenbelt scandal, where plots of land value at $240 million prior to being given permission to build skyrocketed to a value of $8.523 billion once lands were removed from protections.)

This, of course, is extremely profitable for developers, and municipalities can, for a period of time, also feel like they have come out ahead. The newly added tax base contributes much needed revenue, which can be used to address those infrastructure needs outlined above.

The Economic Drag that Sprawl Creates Over Time

But, over the course of several years, that spread-out infrastructure in the newly developed area, along with pre-existing spread-out infrastructure, starts to act as a drag on municipal coffers, and ultimately creates a net-negative revenue flow – more goes out to maintain it than comes in from the tax base it services. (By some estimates, municipalities receive just 10 – 20% of revenue vs liability over the lifetime of these developments. Any business run this way would have been bankrupted long ago, and yet that’s what we demand of our elected leaders.)

Factoring in the costs of pollution associated with needing a car to access amenities, like groceries, not to mention the contribution to climate change those cars make, and those costs only grow.

This is why experts in the area have taken to calling sprawl a “Ponzi scheme” and “Ontario’s tar sands“.

A recent study by the City of Ottawa found that, every year, it cost $465 per capita to service residents in low density areas, while it took in $606 more per capita than it spent from those living in high density areas.

Sprawl is an expensive, and inherently inequitable form of development. Those living in suburban sprawl areas don’t pay the full cost for the infrastructure servicing them, with those living in more dense parts of the jurisdiction, which often tend to be those who are also less well off, subsidizing their cost.

Click the image for a larger version.

Sustaining Sprawl at the Cost of Other Services

When our local governments are constantly needing to increase revenue simply to maintain what we’ve already got, it puts a huge amount of pressure on other services, including many that we place high value on.

These services include cultural activities, funding for public transportation, for affordable housing and mental health, parks, libraries, schools and emergency services all have to compete for a slice of the funding pie, and many are limited due to the pressure on budgets that municipalities face, in no small part thanks to unsustainable patterns of urban development.

Even more pressure is added to the mix when costs associated with a rapidly changing climate are factored in.

As severe and unpredictable weather events ramp up, investments need to be made to ensure infrastructure, such as storm water systems, are able to cope. What were considered “100-year storms” just a decade ago are now likely to happen on an almost yearly basis, and the rare events – those 100-year storms – will be even wilder.

Moving Forward

Promoting Walkability and Mixed-Use Development

Over the past few decades, there has been a growth in the number of planners interested in how the way that we build our communities can improve quality of life for residents, enhance economic vitality, as well as promote a healthy environment. Much of the impetus behind this emergent practice is in response to the negative impacts that car centred planning, such as sprawl, has had on the livability of the places we call home.

Practices like promoting walkability in neighbourhoods, ensuring there is a range of housing choices and a mix of building types, with proximity between residential and commercial areas, accessible schools and other services, such as transit, as well as green-spaces such as parks and playgrounds, are some of what advocates of this form of planning promote.

Well-known planners in this area include Brent Toderian, former Chief Planner for the City of Vancouver, Jennifer Keesmaat, former Chief Planner for the City of Toronto, as well as Charles Marohn, of Strong Towns, to name a few.

And, while more conventional approaches to urban planning remain dominant, these ideas have filtered through. Concepts like complete streets, transit oriented design, along with a growing awareness of the risks of and vulnerabilities to climate change impacts, are increasingly present in high-level policy and planning documents.

(Until it was effectively scrapped by the Ford government, the Growth Plan placed a premium on complete communities, reflecting many of the principles outlined above.)

Photo of John St., Toronto, showing a street with many people walking on it, as well as people sitting on chairs at tables on the street. The widewalk has been extended to enhance walkability. Credit City of Toronto.

This image, taken from the City of Toronto’s website outlining their efforts to create more complete streets, illustrates how many municipalities are trying to reinvigorate streetscapes and enhance the experiences of the residents who live around them.

Credit: City of Toronto

Conclusion

We can build our communities in a way that improves our quality of life, that supports a thriving economy, and that promotes a healthy environment. Cities like Toronto, Calgary, Vancouver, and Montreal are implementing projects in-line with many of the goals outlined above.

By enhancing the livability of our urban areas, including with increased public transit and active transportation like walking, we mitigate negative impacts like carbon emissions and health risks associated with sedentary lifestyles. These are some of the co-benefits of better planning.

In our next post in this series, we look more closely at how poor planning impacts the environment.

-/-

This work by Simcoe County Greenbelt Coalition is licensed under CC BY-NC 4.0

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Teedon Pit- Waverley

Residents are fighting to protect what tests have shown is some of the more pure water in the world. The threat? Aggregate mining.

What's Happening?

On January 14, 2021, a permit to take water (PTTW) was granted allowing CRH Canada, and more specifically its subsidiary, Dufferin Aggregates, to take nearly 1.5 million litres of water per day to wash aggregate extracted from their mining operation.

On January 27th Tiny Township Council unanimously voted to appeal the PTTW to the Environmental Review Tribunal.

There has been a long fight to protect what some tests have shown to be some of the most pure water anywhere in the world. The primary threat to this water is aggregate mining.

An application to expand the pit was submitted in 2012. You can see the area proposed for expansion, outlined in yellow, on the image below.

A map of the proposed expansion of the Teedon Pit aggregate operation near Waverley, Ontario. Map shows County Greenlands, as well as evaluated and unevaluated wetlands. Credit: Simcoe County Greenbelt Coalition.
A map of the proposed expansion of the Teedon Pit aggregate operation near Waverley, Ontario. Map shows County Greenlands, as well as evaluated and unevaluated wetlands. Credit: Simcoe County Greenbelt Coalition.

Quick Facts

1.3 Million Litres Taken Per Day

Purest Water in
the World

Up To 40 Trucks
Per Hour

Why is it a concern?

Water Contamination

As gravel from aggregate mining is washed the runoff debris is meant to be captured. Residents in the area, however, have found an increasing amount of debris, or silt, in their water, and that the amount of this debris as correlated with the increased activity at the pit.
 
The quarry is located above the Alliston Aquifer and many residents in the area rely on groundwater wells as their primary source of water.
 
Further, water in the area that has been tested has been shown to be some of the most pure water in the world, with less trace contaminants than samples taken from ice cores in the remote arctic. The water in these ice core samples, by the way, pre-date human industrial activity.
 
It is thought that the unique geological features of the area, namely the Simcoe Uplands and Oro Moraine, with its glacial deposits, is key to the water’s purity. A quarry is effectively punching a hole in this filtration.

Traffic

Expansion of the quarry would cause an increase in traffic to and from the mine, with an estimated 40 trucks an hour passing through the area. This is nearly one large truck per minute.

Restoration

The aggregate industry has a terrible record of rehabilitation.

This is something they are required by law to do, but, for the most part, they don’t, and they get away with it.

In their 2006/2007 report, the Environmental Commissioner of Ontario noted that 100 out of 121 operations surveyed had not done the rehabilitation activities required under the Aggregate Resources Act.

Arial view of dirt dug up in a mining operation. Credit Ivan Bandura.
Arial view of dirt dug up in a mining operation. Credit Ivan Bandura.

How Can You Get Involved?

  1. Like, follow, and support Friends of the Waverley Uplands on Facebook.
  2. Send a message to elected representatives via the Wellington Water Watchers.
  3. Support residents in their fight by donating. Visit this page to learn how, and to find more ways to get involved.
  4. Finally, use the form below to receive alerts for issues happening in Tiny Township, including this one.

Sign Up to Receive Alerts for Tiny 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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Letter

The Year That Was: 2023

Our approach to our work has always been how we can make an impact in long-lasting and effective ways.  We hold ourselves to high standards — how can we create better rules, better systems and better communities? 

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Subscribe to Our Newsletter

We send out a once-monthly newsletter full of information on what’s happening in Simcoe County and beyond, including information on how you can take action to protect the health of your community.

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

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

Subscribe to Our Newsletter

We send out a once-monthly newsletter full of information on what’s happening in Simcoe County and beyond, including information on how you can take action to protect the health of your community.

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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Subscribe to our newsletter to make sure you don’t miss out!

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Letter

The Year That Was: 2023

Our approach to our work has always been how we can make an impact in long-lasting and effective ways.  We hold ourselves to high standards — how can we create better rules, better systems and better communities? 

Internally, that means we reflect to ensure that we’re putting our values into practice. This year, we decided to adopt a different way to assess our impact. 

Read More »

Subscribe to Our Newsletter

We send out a once-monthly newsletter full of information on what’s happening in Simcoe County and beyond, including information on how you can take action to protect the health of your community.

Submission on Proposed Changes to the Provincial Policy Statement, 2019

We have grave concerns about the policy direction under the PPS review. As outlined by the Ontario government, the PPS is “the primary provincial land use policy document guiding municipal decision-making.” So the tone, focus and direction given in this document greatly impacts our communities, our environment and our future.

October 21, 2019

Municipal Affairs and Housing
Provincial Planning Policy Branch
777 Bay Street
13th floor
Toronto, ON M5G 2E5
planningconsultation@ontario.ca

RE: SCGC Comments on ERO 019-0279

Please accept our submission to the aforementioned review as it relates to the Provincial Policy Statement (PPS). We appreciate your consideration of our comments.
About Simcoe County Greenbelt Coalition
With our 35 member groups from urban, rural and semi-urban communities, we aim to promote community development that is financially, environmentally and socially sustainable, such that provides a net benefit to residents. A major part of this is to recognize the value that natural heritage, agriculture and water gives to our communities, including the numerous benefits and co-benefits of ecosystem services. Ensuring the people of Simcoe County, and Ontario broadly, continue to receive these benefits requires an approach to economic development that is evidence based, transparent and accountable to the public, and with full consideration of the long-term impacts that communities will either have to deal with or benefit from.

We have grave concerns about the policy direction under the PPS review. As outlined by the Ontario government, the PPS is “the primary provincial land use policy document guiding municipal decision-making.” So the tone, focus and direction given in this document greatly impacts our communities, our environment and our future.

Our general concerns include:

  • Softening of language from “shall” to “should”, such as in policies that relate to transit supportive development and protection of natural features;
  • Use of “market-based housing” when discussing appropriate mix of housing. This approach emphasizes methodology that only considers past and current housing trends. A housing shift is needed to encourage more affordable housing, transit-oriented and sustainable development. Clearly, this is not what the past few decades of development has provided us, and as such, should not be the foundation upon which we build communities of the future. This is particularly true when it comes to providing affordable housing, which largely addresses needs of those who cannot or have difficulty accessing appropriate housing in regular market conditions;
  • Excluding protections of natural heritage features, such as in policies dealing with what considerations municipalities should undertake when determining impacts regarding housing and infrastructure.
  • Lost opportunity for the PPS to clarify the Province’s stand on crucial issues, including the protection of prime farmland, the need to prioritize action to mitigate and adapt to the impacts of climate change, as well as, at a time when many municipalities are struggling financially, a comprehensive plan to foster communities that are both financially and environmentally sustainable.

We have more specific concerns as outlined below:

Aggregate Should Not Trump Environmental Protection

Proposed policy allows mineral aggregate extraction to occur in protected, provincially significant natural features, including wetlands, woodlands, valley lands, wildlife habitats, fish habitats, endangered and threatened species habitats and areas of natural and scientific interest outside of the Greenbelt.

We feel it necessary to remind you that this type of policy adjustment could have large ramifications for Simcoe County residents, our eco-systems, water sources and natural heritage as large aggregate supplies are situated in and around many of our communities, as well as in and around significant groundwater resources and natural heritage areas.

For eight years between 2003-2013 Simcoe County was the largest aggregate producer, by volume, in Ontario. During those years Simcoe County produced 11.64 million tonnes of aggregate, on average, annually. Five municipalities within the County, Clearview, Oro Medonte, Ramara, Springwater and Severn, consistently produce an excess of one million tonnes per year, as seen in Table 1 below.

There are over 100 licensed pits and quarries within Simcoe County, with a total licensed area of 3917.16 ha. It was estimated by the Ontario Geological Survey (2013) that Simcoe has a potential unlicensed resource area of 2404 hectares for sand and gravel with roughly 237.7 million tonnes of aggregate resources. Further, the bedrock-derived aggregate resources that are currently unlicensed is a potential resource area of 27,503 hectares, containing 10,928 million tonnes of aggregate resources. Together, that is roughly 30,000 hectares potentially being dedicated to aggregate extraction.

Although Simcoe County is large, we must keep in mind that 30,000 hectares is roughly half the size of Lake Simcoe. Add into that the associated roads and infrastructure which aggregate operations require and clearly large swaths of land could be dominated by aggregate activity.

Map showing aggregate resources in Simcoe County, Ontario

Most of these deposits and resources are located in the northern part of the county. Although it is less populated than the southern part of the county, it nevertheless has important infrastructure contained within it. The northern part of the county contains most of the connected forest cover, a high percentage of wetlands and many river and stream systems.

Moreover, the population in the northern part of the county is primarily serviced by groundwater wells and has a higher concentration of residents who are similarly serviced by individual private groundwater wells.

Layering the sand, gravel and bedrock resources against source water protection maps shows that most of these identified resources (licensed or unlicensed) are surrounded by or contained within highly vulnerable aquifers – the source of drinking water for most of the population in that region.

One of the main concerns about aggregate extraction is its effect on surface and groundwater. Extraction changes the slope of the land and water drainage patterns. This is a change that is effectively impossible to revert back to an original state, making any claim of full rehabilitation highly unlikely

Further, aggregate resources within an aquifer store the water. If you remove the aggregate the water storage capacity of that aquifer is significantly damaged and reduced. A case study conducted in Minnesota found that while impacts on water were not found in every quarry and pit, declines in aquifer levels were a common occurrence.

Map showing aggregate resources in Simcoe County, overlaid with Highly Vulnerable Aquifers.
Map showing aggregate resources in Simcoe County, overlaid with Highly Vulnerable Aquifers (shown in red).

Farmland is also impacted by aggregate operations. The quarries and pits and their related infrastructure fragment farmland and the rural economy.

As seen below, the aggregate resources identified in Simcoe County also tend to be surrounded by high class farmland.

Ontario is already losing over 150 acres of farmland per day. Deregulating aggregate to get into areas that jeopardize our local food systems is short-sighted and only further stunts the sustainable economic development of rural communities. Aggregate can provide jobs, but only for a period of time. Agriculture, properly conducted, can provide jobs, as well as food security, climate change mitigation, and cultural benefit year after year after year.

County of Simcoe Aggregate Resources Layered Against Soil Classes
County of Simcoe Aggregate Resources Layered Against Soil Classes.

Allowing aggregate to expand and initiate operations in highly sensitive areas such as significant forests, wetlands, valleylands and ANSIs is unconscionable considering that there is no evidence to support a need for increased access to supply.

OSSGA contends that less regulation, such as what is proposed in the PPS and Growth Plan, is needed to increase supply due to a large, expected population growth. We believe that this is an intentionally misleading premise.

First, the demand that OSSGA insists is there is not much more than what they already produce. OSSGA estimates 3.84 billion tonnes of aggregate will be needed by 2041. Per year that works out to 174 million tonnes of aggregate annually, which is only 10 million tonnes more than their average annual production. In some recent years, the industry has produced over 200 million tonnes of aggregate – obviously the capacity to produce more already exists.

This needed increase also assumes that demand for aggregate will not decrease or stabilize. Over 50% of aggregate in Ontario goes towards the building of roads. As we continue to build our communities up, as opposed to sprawling out, the construction of new roads and highways (which, as noted, is where the majority of the aggregate goes) will mean less demand for aggregate. It is quite possible that these changes alone could mean that aggregate demand may only stabilize and hence an increase in production may not be needed at all.

The rationale for the proposed amendment within the PPS rests on the assumption that natural areas destroyed by pits or quarries will eventually be rehabilitated, as required by law. However, it fails to acknowledge that aggregate operations are often open for decades, or that legal requirements to rehabilitate sites are often poorly enforced and routinely ignored. It also fails to account for the loss of significant and/or at-risk animals and plant species and their habitats in the meantime. This loss is likely permanent, too, as sites are rarely returned to their original state.

The poor record of rehabilitation of aggregates operations has been thoroughly covered in past reports of the Environmental Commissioner of Ontario, which have revealed that:

Recommendations

  • Remove new policies that would allow aggregate extraction in sensitive areas (2.5.2.2) and those that would allow extraction in prime agricultural areas (2.4.4.1).
  • Include policies that require aggregate to provide evidence of net need for new pits/quarries or expansions.

Protections for Wetlands Must be Retained or Enhanced

Wetlands are vital to maintaining water supply and water quality, and to enhance landscape and community resilience in an era of climate change as they play a critical role in flood attenuation and act as carbon sinks. They also provide habitat for many of the province’s most imperiled plants and animals. A 2009 study commissioned by the Ministry of Natural Resources estimated that the ecosystem services provided by wetlands in southern Ontario alone were over $51,614,795,000 per year. According to the authors, ecosystem services such as these “are the foundation of human well-being and they also represent a significant part of the total economic value of our landscape and economy.”

South and east of the Canadian Shield (Ecoregions 6E and 7E) at least 72% of wetlands have been lost to development, with losses exceeding 90% in some areas. We are therefore very concerned about the proposed policy 2.1.10:

2.1.10: Municipalities may choose to manage wetlands not subject to policy 2.1.4 and 2.1.5, in accordance with guidelines developed by the Province.

The policy is permissively and vaguely worded and invites an ad hoc approach to wetland management across the province

Further, policies 2.1.4 and 2.1.5 stipulate that site alteration should not occur in wetlands that are deemed significant. The implication of placing management of wetlands not subject to these policies with municipalities is that they are not considered “significant”. This effectively paints all wetlands outside of the significant classification with an extremely broad brush. Since many wetlands have not been evaluated, this generalization is highly likely to cause irreparable damage to wetlands that if evaluated would likely meet the standard required to be classified as significant.

We question why such a policy would even exist based on the substantial amount of science that underscores the importance of wetlands to water quality and quantity, climate and flood resiliency, and habitat for wildlife.

We have come to understand that proposed policy 2.1.10 is intended facilitate wetland offsetting in unevaluated wetlands.

SCGC strongly believes that the precautionary approach – the prudent approach – should govern serve as a formative principle in determining land-use policy. Accordingly, we would argue that all wetlands should be deemed significant until an objective, science based evaluation has occurred that shows a high degree of certainty otherwise.

Furthermore, allowing municipalities to “manage” wetlands as they see fit establishes a scenario in which the treatment of wetlands will be disjointed and inconsistent. Wetland management is key to watershed planning and flood resiliency – both should be declared areas of provincial interest and thus not left in the hands of municipalities with vague wording and non-existant outcomes or targets.

While we strongly disagree with wetland offsetting, if such a policy were to exist it must clearly state the purpose and parameters, including requirements to:

  • Achieve a net gain in wetland area, quality and function;
  • Set clear limits to offsetting, taking into account the type, location, vulnerability and irreplaceability of wetlands, as well as their cultural significance to Indigenous peoples;
  • Implement the mitigation sequence, which positions offsetting as a last resort after first avoiding, then minimizing negative impacts.

To fully appreciate the scope and potential outfall that such a policy could have, we need look no further than Simcoe County. As demonstrated in Figure 4, the amount of unevaluated wetlands, also known as locally significant, in Simcoe County is large and spread throughout the county, with a notable concentration in the northern region.

Unevaluated Wetland Systems in Simcoe County (green)
Unevaluated Wetland Systems in Simcoe County (green).

As mentioned previously, Simcoe County groundwater systems are pervasive throughout the county and supply the large majority of residents and businesses with their water for daily use. Wetlands are a key element of the water recharge and purification system within a groundwater system. Thus, limiting or destroying a wetland’s function impacts local water systems as well as increases flooding risk.

In Figure 5, it is clear that many of these unevaluated wetlands are enveloped by Highly Vulnerable Aquifers and/or Significant Groundwater Recharge Areas.

Layering of wetlands over key water systems Highly Vulnerable Aquifers (red) and Significant Groundwater Recharge Areas (yellow/bright green)
Layering of wetlands over key water systems Highly Vulnerable Aquifers (red) and Significant Groundwater Recharge Areas (yellow/bright green).

No one knows for sure how much change and destruction a groundwater system will tolerate before its function is impaired and therefore unable to provide adequate amounts of potable water. How much risk is the province willing to undertake in the name of aggregate extraction and housing?

Recommendations

  • Remove policy 2.1.10.
  • Declare all wetlands as a matter of provincial interest.
  • Ensure that if wetland offsetting is to be a consideration, it is absolutely as a last resort with no net loss and clear limits.
  • Provide adequate funding to MNRF and/or municipalities so that they can evaluate their wetlands appropriately.

Housing Policies Open Up a Pandora’s Box for Rural and Semi-Rural Communities

New policies allow for greater flexibility for communities to select individual on-site sewage services and individual on-site water when municipal services are not available, planned or feasible in rural settlement areas at the time of Official Plan review or update.

It means that communities can build out in rural areas that, generally, are unable to support complete communities. In Simcoe County in particular, there is a net surplus of development approvals, especially in the more rural areas.

We firmly believe that a change in the servicing hierarchy to include communal and private servicing would proliferate a sprawling built form. As a result, this sprawling built form spreads municipal and provincial resources thin as there are more roads to maintain, operate, etc. with a small tax base to cover costs of upkeep. Costs related to infrastructure, it should be noted, will almost certainly increase with the impacts of climate change, and so planning should proceed accordingly. Further, sprawl locks in high emission lifestyles for decades, increasing the challenge, already considerable, of meeting the needed, science-based targets of net-zero carbon emissions by 2050.

Another concerning component to this proposal is that communal wells and private wells are not covered under Source Water Protection Plans. Therefore, encouraging growth that knowingly builds water systems not properly protected is a huge risk to public health and abdicates the caretaker role of government.

Including terms such as “market based” housing and extending the planning horizons are also troubling, as noted above. Both of these items only encourage the maintenance of the current housing mix and provide more opportunities for land banking for future greenfield development. Land banking is now thought to be one of the primary drivers of the housing affordability crisis.

It is unclear why this would be considered at a time when we need to fully confront how damaging our built form is to the climate and environment at large.Ontario’s main emission source is from individual transportation and Ontarians are driving more than ever, as noted below.

Ontario population measured against passenger kilometers. Source: Natural Resources Canada
Ontario population measured against passenger kilometers. Source: Natural Resources Canada

The main reason behind our increasing driving trends is how and where we build our communities. Roughly 75% of Ontarians live in car dependent neighbourhoods – places where the distance between daily needs, such as grocery stores, work places, schools, and medical care, is beyond that easily walked, and/or transit is not established well enough to entice people out of their cars.

Unfortunately, that trend is continuing to rise in Ontario as well as across Canada. Consider that between 2006 and 2016, car dependent growth (rural and suburban) accounted for 85% of the population growth in Canada. In the GTA specifically, 83% of growth occurred in car dependent neighbourhoods rather than active cores where walkability and transit are well established.

This has a huge impact on our environment, health, community design, transportation and climate change. Our building patterns set our carbon footprint and climate risk for decades to come. If anything, considering the financial, social and environmental costs of this type of building pattern, the province should be using this opportunity to move Ontario’s growth even more towards more compact development.

Further, changing demographics also need to be considered before proposing policies that promote sprawling growth patterns. Car dependent, rural communities are generally only accessible for people of a certain age, stage and income – namely, middle class and middle age. By 2031, it is estimated that 42% of people in car dependent suburbs around Toronto will no longer have a driver’s license. This means that to effectively “age in place” and to make our communities accessible for all, residents either will have to have options for transit or live in walkable communities.

In Simcoe County, specifically, our communities will need to be better designed for seniors – especially if the province is serious about “aging in place” to deal with long-term care bed backlogs. By 2041, the population of seniors 65 years and older in Simcoe Muskoka is projected to surpass 218,800, which is more than double the number of seniors from 2011.

Figure 7 indicates that all senior age groups will increase in population. The largest increase will occur among the 90+ age group, which will increase by 346% from 4,345 in 2015 to 19,380 in 2041. How will these people be encouraged to “age in place” if we keep building remote, car dependent neighbourhoods? Becoming an age friendly community means ensuring accessibility. Policies such as what is proposed in the PPS encourage low density, car dependent neighbourhoods which will not be sufficient to support our aging population. This only puts more of a strain on our public health system and other supports for seniors.

Senior Population Projections by Age Group 2015-2041
Senior Population Projections by Age Group 2015-2041

Recommendations

  • Maintain policies that encourage development to be on municipal services over communal or private servicing.
  • Include policies that promote age friendly communities such as intensification, access to transit and walkable communities.

Summary

The members of SCGC want to see a fair balance between growth and the environment. Further, there needs to be more consideration for our natural environment and water when considering aggregate and growth policies. As a mainly rural/suburban region, we are highly dependent on our groundwater resources, and our economy is inextricably linked to our lakes, farmland and natural environment. Changes to policy, such as what is proposed in the PPS, impact our way of life and our economy.

In times of dwindling water resources, a changing climate and mass biodiversity loss, we want the province to have the will to put forth policies that address these losses – policies that correct our course and move us towards solutions. Unfortunately, we do not see any measurable steps outlined in these policy proposals that will correct our course, only make matters worse. We strongly implore the province to reconsider the direction and vision that it is now offering within the proposed PPS.

Sincerely,

Margaret Prophet
Executive Director, Simcoe County Greenbelt Coalition

Report: How well protected are Greenlands in Simcoe County?

This report, led by the Rescue Lake Simcoe Coalition, looks at the levels of protection provided to lands in Simcoe County.

It concludes that more needs to be done to ensure high quality water, wildlife habitat, and food production.

Overview

In 2019 the Rescue Lake Simcoe Coalition undertook a study to determine how much land in Simcoe County had some level of protection.

Land-use policies, or regulations made by provincial and local governments that determine where cities and towns are built and how natural resources are used, have struggled to keep up with the demands of a changing climate.

Pressure on water, farmland, and natural areas for habitat and carbon sequestration are increasing, yet we see only incremental change in policies governing them.

This report set out to look at the state of lands protected in Simcoe County, and to determine whether more needs to be done.

Categories of Protection

The report identifies three levels of protection based on different polices they are covered by, and notes current and likely vulnerabilities or threats to natural areas, water, and farmland under existing policies.

Protected Lands Map

A map was produced that shows where the different levels of protected lands, as well as the proportion of lands under the different categories of protection.

As you can see a good portion of Best Protected greenland is covered by the Minesing Wetlands, located in the centre of the County just to the west of Kempenfelt Bay in Lake Simcoe.

The Minesing Wetlands are a designated under the Ramsar Convention as a wetland of international importance.

Click the image for a high resolution version.

Conclusion and Recommendations

Wetland Cover

Environment Canada recommends a minimum of 10% wetland cover in Southern Ontario.

Simcoe County has 14% wetland cover based on this analysis, approximately half of which is historic or pre-settlement cover.

Despite the relatively good looking numbers, Simcoe County is losing wetlands.

Many subwatersheds are below the LSRCA’s watershed-wide targets. (Subwatersheds are areas that drain into a river that itself drains into the main receiving body of water, such as Lake Simcoe and Lake Huron.)

To achieve “no net loss”, all wetlands should be formally evaluated, identified and protected in the County’s Natural Heritage System.

Forest Cover

Having at least 50% forest cover equates to a “low-risk” approach, meaning that wildlife and ecosystems are highly likely to remain healthy and viable.

Simcoe County has only 22% forest cover based on this analysis.

Simcoe County is nowhere near the 50% forest cover target, and forest coverage continues to decline.

Forest cover is not evenly distributed across Simcoe County, with most cover in the north.

Ecologically based forest cover targets should be set for the subwatersheds

Impervious Land Cover

Impervious land, or land that does not allow for rainwater or other water to be easily absorbed, should be less than 10% of an urbanizing watershed. Impervious land cover increases costs of water management and risks of flooding.

Simcoe County is 8% urbanized. (Note that while not all land within an urban envelope is impervious, it is used as a rough proxy here in the absence of more detailed accounting.)

As new lands are zoned residential and developed the urbanized and impervious portion of the County will increase.

Efforts should be made to increase residential density within existing settlement boundaries to limit the need to convert more agricultural and natural lands to residential.

Initiatives like Barrie’s new Stormwater Climate Action Fund can be helpful in more accurately capturing the extra costs associated with impervious land cover.

Recommendations

We can achieve these ecological targets in Simcoe County, since we currently have 14% of the County in the Best Protected, and 58% in the Somewhat Protected categories.

But both of these categories allow for a death by a thousand cuts; many changes to land use are permitted even in the Best Protected category.

Provincial Actions

  • Maintain or strengthen the provincial policies that protect wetlands, forests and shorelines in provincial planning documents;
  • Make efforts to engage Indigenous people and ensure their perspectives and Traditional Ecological Knowledge are incorporated into provincial policies that protect wetlands, forests, shorelines and other significant natural features they may identify;
  • Work with municipalities and the County to implement the Growth Plan’s Natural Heritage System for the Greater Golden Horseshoe and related policies as soon as possible to protect linkages in particular;
  • Prohibit the removal of greenlands and linkages from the Growth Plan’s Provincial Natural Heritage System;
  • Preliminary maps of “high quality natural cover” have been developed by the province in the Lake Simcoe watershed. Take the next steps and ensure the mapping is completed, and that these features are protected in the Lake Simcoe Protection Plan;
  • Expand the Greenbelt into Simcoe County.

Municipal Actions

  • Municipalities in the Lake Simcoe watershed that have not already done so, should adopt the Lake Simcoe Region Conservation Authority’s Natural Heritage Strategy in their municipal Official Plans;
  • Municipalities in the Nottawasaga Valley watershed should implement the Natural Heritage recommendations in the NVCA’s Integrated Watershed Management Plan;
  • Set targets, implementation mechanisms, and timelines to meet or exceed the federal habitat protection guidelines above, on a subwatershed basis, and put biodiversity objectives in municipal planning documents;
  • Ensure that the “high quality natural cover” features in the Lake Simcoe watershed are protected in Simcoe County’s Official Plan;
  • Refuse requests to expand settlement boundaries, and instead develop “complete communities”;
  • Increase environmental restoration activity, focusing on linkages, shorelines and riverbanks;
  • Develop strong regional and municipal tree cutting bylaws and enforcement regimes using the Ontario Woodlot Tree Conservation By-law Template;
  • Explore and invest in green infrastructure.

Landowners

Landowners wanting to protect environmental or farm features on their lands forever can do so in a number of ways through a Land Trust.

Land Trusts are charitable organizations committed to permanent protection of lands with ecological, scenic, historical, agricultural and recreational values.

These Land Trusts operate in Simcoe County: Oak Ridges Moraine Land Trust, Couchiching Conservancy, Nature Conservancy of Canada, and Huronia Land Conservancy. See the Ontario Land Trust Alliance website for information about local land trusts.

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