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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This is a comment that was posted by SCGC board member Phil Brennan on Ontario’s Environmental Registry regarding the Forest Sector Strategy


In today’s world, more than ever, good forest management needs to reflect a balance between different uses and needs of the forest.  

You do not double industrial output without making provisions for education and research (we must have ecological reserves to study and compare growth with our silvicultural practices); make effective provisions for biodiversity; build into the planning process strong provisions for mitigating climate change (planting trees has limited potential and it is wiser to take care of what we have); including provisions that are supported by experts for the sustainable management of wildlife and fish; building in protections and future growth potential for tourism; effective protection of natural heritage; including strong provisions for species-at-risk (e.g. caribou habitat); and, incorporating the social needs of affected communities through transparent consultation.

Specifically, I have the following concerns:

  1. The commitment to sustainability must specifically address all the points above throughout the development of the final strategy.  Window dressing is not acceptable. 
  2. Any plan to reduce so-called red tape needs to specifically chart the pros and cons of the existing and proposed changes to legislation – if the Class EA for Forestry is to be replaced in whole or part – how will the new rules insure that the public has the same opportunities to affect change as in the current assessment approach. Transparency here is critical.  If there is an intention to change the ‘area of the undertaking’ this must be clearly articulated in any proposal and needs public scrutiny.
  3. The pros and cons of changing from the current FRI based inventory approach need to be documented in a scientific and professional document for the public,  including the provision of clear information on the new remote sensing technology that is proposed and the manner in which it is verified on the ground. 
  4. It is not at all clear how the proposal will provide for additional wood supply certainty.  That’s what the current forest planning manual and requirements has already been designed to do.  
  5. While I applaud any logical efforts to increase the sustainable harvest, the challenges around this need to be more specifically articulated.  The reality is that for economic reasons we have lost pulp mills, sawmills (quality is a factor here), and board mills.  Ontario has been looking for ways to use its surplus birch and poplar supplies for decades.   Even on the private lands, particularly in Southern Ontario, the challenge is utilizing poor quality trees, not saw logs due to a long history of high grading.
  6. Increasing growth potential in our forests suggests a more intensive forest management and greater utilization of lower value material on harvested sites.  This suggests spending more money on forest management and it is not at all clear where that money would come from.  On private land,  the Ontario government  walked away from more intensive forestry work under the Woodlands Improvement Act and the Forestry Act in the last two decades to save money – hard to imagine us going back to programs like that in the near future under our current budget challenges. 
  7. Forest fires and insect and disease attacks, particularly in older forest tracts can be expected to have a significant impact on all uses of the forest and harvesting  and this needs to be addressed in developing new targets for the harvest in Ontario.  We must learn from the Australian situation. With these things in mind, I support the development of a rigorous and professional ‘Provincial Climate Change Impact Assessment’ and having it factored into moving forward with forest management and wood supply solutions in Ontario. 
  8. The document notes that Ontario has developed its own provincial policy as an alternative to the federal output-based pricing system to reduce carbon emissions in the section on maximizing the use of mill by-products to fight climate change.  Everyone who knows anything about fighting climate change knows that the Ontario approach is very weak and expected to fail.    If Ontario wants to use climate change arguments as part of its strategy to increase industrial output, you now need to have credible experts document the proposal.  
  9. The proposed Forest Sector Advisory Committee must include NGO’s that represent the interests of the non-timber industry for any strategy to be implemented properly. 

Thank you for this opportunity to comment.

Phil Brennan

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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