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.
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.
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.
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.
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.
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.
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
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.
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.
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.
…learning about how planning works is important because it helps us get climate justice happening on the local level. It helps us understand how these changes can actually play out through local government.
But there’s a lot to learn and not a lot of clear information, so how can we learn more?
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.
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.
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.
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.
…if this government is truly committed to these initiatives, by which we mean that they are not being used as cheap politics to deflect from the criticism, fully deserved, that they are receiving with regard to the policy changes noted above, then we expect the following
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.
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.
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:
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.
Figure 4.
This application is problematic for the City of Orillia for several reasons.
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.
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.
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.
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.
…if this government is truly committed to these initiatives, by which we mean that they are not being used as cheap politics to deflect from the criticism, fully deserved, that they are receiving with regard to the policy changes noted above, then we expect the following…
This letter was written after the Province passed Bill 229, which came after a huge outcry from the public, from environmentalists, from Conservation Authorities, and from municipalities, among others, and which prompted the resignation of seven members of the Province’s Greenbelt Council.
There has been much attention paid lately to the future of our Conservation Authorities – one of the last regulatory bodies designed to protect our environment. In a response to the public outcry regarding the neutering of Conservation Authorities’ ability to protect water, wetlands and public health, Minister Clark made a series of statements and announcements:
First, was the promise of $30 million dollars to “create, restore and enhance wetlands” across Ontario;
Second, was a promise to improve the “quality and quantity of the Greenbelt”.
The timing of these announcements is troubling and does not add to our confidence in the government’s commitment to protecting the environment coming, as it has, on the heels of eight members of the Greenbelt Council quitting in protest over provincial policy changes. Changes that former Toronto Mayor and, until he resigned this past week, Chair of the Greenbelt Council, David Crombie outlined as “high-level bombing”.
But we are willing to accept these announcements in good faith, and we look forward to hearing more about these initiatives. To be very clear, however, if this government is truly committed to these initiatives, by which we mean that they are not being used as cheap politics to deflect from the criticism, fully deserved, that they are receiving with regard to the policy changes noted above, then we expect the following:
That no more MZOs will be issued that allow development in provincially significant or locally significant wetlands. It makes no sense to commit to restoring wetlands and putting taxpayer money towards that, while simultaneously destroying or impairing other wetlands. Refusing to do this would be creating a boondoggle for developers, using public money to offset wetland destruction.
Any MZO that is issued in the Lake Simcoe watershed will clearly outline how the Lake Simcoe Protection Plan policies will be adhered to, in order to ensure conformity with said policies as MZO conditions.
The Lake Simcoe Protection Plan, which will be reviewed in the new year, will be strengthened by building on proven existing policies (e.g. phosphorus loading targets and WWTP moratoriums), demonstrating the government’s commitment to protect the environment with policies that protect more high quality natural cover, including wetlands and forests. This should be a zero loss target and policy structure, meaning that there should be no reduction in the quantity and quality of natural cover going forward. Currently, the target in the LSPP is 40% high quality natural cover – a target that we are failing to meet.
The $30 million Wetland Restoration Fund will be money invested by the Government of Ontario and not “blood money” that comes from developers paying a fee to permit the destruction of wetlands. If it is based on offsetting, this is a “pay to pave” mentality that has been proven disastrous for watershed health in other jurisdictions. Funding wetland restoration through the destruction of other wetlands would be disingenuous to the government’s commitment and breaks faith with Ontarians who rely on wetlands for flood mitigation, drinking water purification and recreation.
Growing the Greenbelt includes keeping the existing Greenbelt strong. We don’t want to see a bait and switch where more Greenbelt is added in exchange for current Greenbelt lands being removed from protection. The Greenbelt, its farms and communities, contribute $9.6 billion of economic impact and $3.2 billion of environmental services to Ontario every year. As a region that is growing we will be relying on the services it provides far into the future. Dismantling it through land swaps threatens its ecological functions, and, consequently, its contributions to our collective prosperity and wellbeing.
The province, if it is genuine in its commitment to growing the Greenbelt, will base new included areas on science and public health, not just land ownership. Following such a process means that all source water areas (highly vulnerable aquifers, significant recharge areas, moraines and locally significant wetlands) in Simcoe County should be added to a bigger Greenbelt, at minimum. Simcoe County residents are highly reliant on groundwater for their daily needs. If we don’t protect these areas soon, the public’s health is at risk.
We hope that your government is genuine in its commitment to these ends. We are sure you would agree that using environmental policy as a ploy is dangerous to our public health and erodes faith in our democratic institutions and your governments’ commitment to acting in the best interest of all Ontarians.
Ultimately, it is in no one’s interest that a government fails – such an event has real life consequences for the people of Ontario, including to their health and wellbeing. We are committed to helping where we can to find success in the above noted expectations, but we will not betray our knowledge and understanding, born by evidence, of the actions required to create a more just, prosperous, and sustainable Ontario. We will be watching closely to ensure that you stick to the commitments you have made and do so in a genuine manner.
Governments have failed to act to protect our communities and the futures of our children and grandchildren, and they continue to treat our environment as if it’s incidental to life, rather than a foundation for it.
We need strong community organizations to fight for our future, now more than ever.
Please consider donating to support our work. It’s people like you who make us possible.
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.
Community led planning to ensure Innisfil’s natural heritage systems remain strong far into the future.
With the support of the Greenbelt Foundation, the Rescue Lake Simcoe Coalition analyzed and mapped environmental policies across Simcoe County and the Lake Simcoe watershed landscape.
Following this research, in February 2020 the Rescue Lake Simcoe Coalition hosted an event at Innisfil’s incredible IdeaLab and Library. This was attended by Innisfil residents, including some members of Council, the MPP for the area, Andrea Khanjin, and members of the Rescue Lake Simcoe Coalition’s Innisfil member groups, including the Innisfil District Association and Innisfree Ltd.
Participants discussed how to keep Innisfil’s natural heritage strong and connected into the future.
Only 14% of Simcoe County’s landscape fell into our “best protected by environmental policy” category; in the Lake Simcoe watershed, that percentage rose to twenty one. More of the areas’ natural heritage needs strong policy protection in order to create a robust and connected Natural Heritage System. The full reports can be accessed via the “Our Work” page, or by searching for “Reports”.
We need an intact ecosystem complete with forests and wetlands in order to protect biodiversity and good water quality. But a healthy environment also supports healthy people and local economies.
In the Lake Simcoe watershed a quality ecosystem supports the $420 million / year sustainable recreation sector, and delivers millions in ecosystem services like clean water, flood control, climate regulation and water filtration.
The Lake Simcoe Protection Plan includes a target of 40% high quality natural cover (HQNC) in the Lake Simcoe watershed, but no policies specifically support this target. Today, 28% of the Lake Simcoe watershed qualifies as HQNC but only half of that area is well protected by strong natural heritage policies that do not permit land use changes.
Greater efforts at the municipal level can increase the size and protections given to areas of High Quality Natural Cover, and improve on the identification and protection of other natural features that protect our environment and way of life. The 2020 provincial review of the Lake Simcoe Protection Plan is an opportunity to express the need for better protection of High Quality Natural Cover.
In February 2020 the Rescue Lake Simcoe Coalition hosted an event at Innisfil’s incredible IdeaLab and Library attended by Innisfil residents including some members of Council and the MPP for the area, and members of the Rescue Lake Simcoe Coalition’s Innisfil member groups the Innisfil District Association and Innisfree Ltd., for a lively discussion about how to keep Innisfil’s natural heritage strong and connected into the future.
This maps shows the result of the participatory mapping exercise noted above.
Summary of Aims
Due to the significance of patch size, it is of utmost importance to protect and maintain the 25 hectare patches mapped by the province as “High Quality Natural Cover” (HQNC) using the following steps:
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.
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:
We have more specific concerns as outlined below:
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.
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.
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.
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:
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:
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.
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.
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?
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.
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.
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
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.
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.
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.
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.
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, 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.
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.
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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