How the Greenbelt supports a cleaner Lake Simcoe

Claire Malcolmson

Until April 19th the Province of Ontario is listening to ideas about growing the Greenbelt, and I want to encourage people to share at least some basic thoughts about it with the government. Did you know that the campaign that resulted in getting the Lake Simcoe Protection Act started with an unsuccessful bid to have Simcoe County included in the Greenbelt? Way back in 2005 we were worried about the impacts of heavy development pressures on Simcoe County, and that has not changed. How can Greenbelt policy help alleviate some of those impacts?

The Greenbelt covers 58% of the Lake Simcoe watershed. 
Source: Lake Simcoe Protection Plan, 2009.

The Lake Simcoe Protection Act, 2008, and Plan apply to the watershed area, outlined in the map above. Within that area, where the Greenbelt applies today in York and Durham Regions, the “countryside” is protected. In Simcoe County, where there is no Greenbelt, not so much. These farm land areas are facing intense development pressure. 

Simcoe County must plan for a population of 555,000 and 198,000 jobs by 2051 up from a population of 307,050 today. Despite there being a projected oversupply of 75,000 homes permitted to be built in Simcoe County to 2031, planning and permitting will go on because that’s what the province has ordered. The problem is that both construction and development negatively affect Lake Simcoe’s phosphorus loads, which in turn worsens water quality. In it’s  2010 Phosphorus Reduction Strategy, the province analyzed the impacts of development on phosphorus loads, and concluded that there would be additional phosphorus loads, even with the development impact mitigation policies of the LSPP. This is a problem since we are supposed to be cutting phosphorus loads in half to protect Lake Simcoe and its ecosystem.

Municipalities may be welcoming policy alignment between provincial plans, as they have expressed in their comments to the province about the LSPP review. (See my blog on this topic here.) The Greenbelt expansion exercise and the LSPP review, which are happening simultaneously, are both good opportunities for the province to investigate and analyze the effect of some of possible policy choices. They will need to address the issue of having no plan to achieve the LSPP’s 40% “high quality natural cover” target. 

The ideal solution could be applying the Greenbelt to the whole watershed, maintaining the LSPP’s shoreline policies, and adding a new designation for the watershed’s “high quality natural cover”. For a more fulsome overview of the “high quality natural cover issue see our report here and the map below. 

The Rescue Lake Simcoe Coalition’s intern and planner Mallory Nievas analyzed the strength of policies of the Greenbelt, Growth Plan, Oak Ridges Moraine, Lake Simcoe Protection Plan, and found that the policies of the LSPP are the strongest of the bunch at protecting the shoreline. The policies of the LSPP, Greenbelt and ORMCP are similar when it comes to natural feature protection (forests, wetlands). 

Where the Greenbelt differs in a way that would help Simcoe County and Lake Simcoe, is its unique “Protected Countryside” designation, which is meant to protect agricultural land. Non-agricultural uses of land in the Greenbelt’s “Protected Countryside” are allowed “to support a range of recreation and tourism uses such as trails, parks, golf courses, bed and breakfasts and other tourism-based accommodation, serviced playing fields and campgrounds, ski hills and resorts.” Within the Protected Countryside, Town and City boundaries are firm, which reduces the tendency towards expensive to service, low-density, land gobbling, lake polluting, suburban urban form, and promotes denser community building. 

Based on analyses outlined above, it’s expected that the watershed’s population will more than double and likely add 20 tonnes of phosphorus to the lake by 2051. The Lake Simcoe Protection Plan target is to lower phosphorus loads from an average of 90 tonnes to 44 tonnes per year by 2045. We are concerned that the province is approving development without any public discussion or consideration of the long term damage it causes to Lake Simcoe. That should concern everyone.

The public has until April 19th to contact the province and encourage them to expand the Greenbelt to Simcoe County. 

Visit www.simcoecountygreenbelt.ca for tools and tips.

Ontario’s comment portal on Greenbelt expansion is at https://ero.ontario.ca/notice/019-3136 

The Rescue Lake Simcoe Coalition and Simcoe County Greenbelt Coalition’s full comments and submission to the province on Greenbelt expansion can be found here for people’s use in their own submissions.

Our two coalition’s new report, Lake Simcoe Under Pressure can be found at www.RescueLakeSimcoe.org 

Image 1: This map indicates the extent to which land features are protected by environmental policy in Simcoe County. There is plenty of potential to increase the size and the level of protection afforded to Simcoe County’s Natural Heritage System. The full report is available at https://rescuelakesimcoe.org/about-us/accomplishments/lake-simcoe-greenlands-project/
Legend below.
Legend LabelSmall legend textDefinitionExamples of permitted activities
1. BEST POLICY PROTECT- IONThese features are subject to policies that prevent or tightly restrict development or other land cover change on them. Permitted activities include aggregate extraction, infrastructure development, and stewardship related work.These features are subject to policies that prevent or tightly restrict development or other land cover change on them. An Environmental Impact Assessment (EIA) is required to demonstrate environmental impacts of permitted activities are minimal and can be mitigated. Level 1 includes mostly features protected by provincial policies: – significant woodlands; – significant valleylands; – Provincially Significant Wetlands (PSWs); – Areas of Natural Scientific Interest (ANSI’s); – Lake Simcoe shoreline; – natural areas abutting Lake Simcoe; – Significant Wildlife Habitat; – Provincial Parks – Natural Areas (Niagara Escarpment Plan); – Core Areas (Oak Ridges Moraine Conservation Plan).– new aggregate operations, with restoration and environmental impact requirements, low footprint infrastructure that has been proven to have no alternative, non-intrusive recreation, maintenance of existing infrastructure, fish, forest, wildlife management, stewardship and conservation activities, flood or erosion control, retrofits to stormwater facilities.
2. MODERATE POLICY PROTECT- IONThese features are subject to policies that allow some site alterations or land cover change, having met criteria and conditions. Permitted activities include aggregate extraction, infrastructure development, and stewardship related work. Development and site alteration may be allowed, having met criteria and conditions.These features are subject to policies that allow some site alterations or land cover change, having met criteria and conditions. An Environmental Impact Assessment (EIA) is required to demonstrate that environmental impacts are minimal and can be mitigated. Level 2 includes: Setbacks and vegetation protection zones around protected features such as ANSIs, PSWs, permanent and intermittent streams and lakes; – significant groundwater recharge areas and highly vulnerable aquifers; – linkage areas (Oak Ridges Moraine); – Simcoe County Greenlands linkage areas; – features adjacent to level 1 features.– new aggregate operations, with restoration and environmental impact requirements. – Having met criteria to demonstrate limited environmental impact: development and site alteration, wind power facilities. – No Environmental Impact Assessment required for: Low footprint infrastructure that has been proven to have no alternative, non-intrusive recreation, maintenance of existing infrastructure, fish, forest, wildlife management, stewardship and conservation activities, flood or erosion control, retrofits to stormwater facilities.
3. NOT PROTECT- ED BY ENVIRON- MENTAL POLICYThese areas are already developed and / or are not subject to environmental protections.These areas do not contain features that are protected. Level 3 includes: farmland; roads; settlement areas and built up areas. The Greenbelt Protected Countryside designation is included because it does not protect Natural Heritage Features. It does, however, restrict settlement boundary expansions.N/A

What Municipal comments about the Lake Simcoe Protection Plan reveal

Early in 2021 the Ontario Ministry of Environment, Conservation and Parks (MECP) consulted on the review of the Lake Simcoe Protection Plan (LSPP) and made some presentations to municipal Councils. The Ministry will either make, or not make, amendments to the LSPP by this summer. 

The Rescue Lake Simcoe Coalition (RLSC) analysed the five staff reports on the LSPP from York Region, Durham Region, and the lower tier municipalities of Innisfil, Georgina, and King. In three cases, the RLSC wrote to the municipality and Council and made a delegation to request clarification and/or to suggest changes on some staff reports. Both the municipal staff reports on the LSPP and the RLSC comments submitted to municipalities can be accessed here

Some key themes emerge from our study of the publicly available municipal comments regarding the review of the LSPP:

  1. There is strong municipal support for protecting Lake Simcoe, and for strengthening policies of the LSPP by reflecting on what has been learned in the first 12 years implementation.
  2. The province did not provide adequate information and analysis of the effectiveness of LSPP policies for the policy review. Most municipalities emphasize that the province must continue monitoring and tracking the effectiveness of various remediation actions, and report on the lake’s health against the LSPP’s targets and objectives.
  3. Accommodating the watershed population ordered by the province’s Growth Plan (projected to at least double by 2051) while meeting the phosphorus (P) reduction target of the LSPP (which is to cut phosphorus loads in half by 2045) is a massive challenge.
  4. Municipal responses vary greatly when it comes to accommodating growth. At one end is the Town of Georgina standing strong with Georgina Island First Nation opposing the Upper York Sewage System, and at the other end, Innisfil’s staff report obliquely suggesting that some places be allowed to increase P loads to accommodate growth. 

While most municipal responses highlight the importance of reducing phosphorus loads to Lake Simcoe by revising the Phosphorus Reduction Strategy, they also discuss the merits of various ways to reduce P loads. Should we continue to focus on P reductions from sewage treatment plants, or from other remedial actions that reduce erosion and runoff? 

Sewage Treatment Plants and phosphorus offsets: 

Most municipalities recognize that reducing phosphorus from sewage treatment plants (STPs) is effective but expensive. They suggest how the province can reduce phosphorus loads from other more “cost-effective” sources. The question is, if STP’s P load caps are eased, will the other P reduction techniques adequately mitigate the harm caused by urban growth?

The RLSC has concerns about the feasibility and timing of the offset approaches suggested. First, the Precautionary Principle is a “guiding principle” of the LSPP, and it would be fitting therefore to not assume that agricultural and landowner remediation and Best Management Practices will be successful at the scale required to bring down P loads without substantive evidence. If the province wants to reduce P loads in a cost-effective way, more research and monitoring is needed to demonstrate that other offsets will work over time and not degrade, fail, and add more phosphorus to the lake than presumed. Until such real-world evidence is provided, other sectors should not be allowed to increase their P loads.

Durham Region supports a future focus “…on more significant sources of phosphorus such as, stormwater and agricultural/rural runoff and invasive species, and that the existing phosphorus loading caps for water pollution control plants be maintained.” The RLSC is in support of this kind of approach.

York Region recommends that P offsets should be used to accommodate new P loads from STPs, and recommends focusing on agricultural and stormwater infrastructure improvements. There is little evidence, however, that offsets from agricultural projects can be relied on as long-term P offsets. And the reduction in family farms, and the related increase in corporate owned farms (mainly land speculators) also means that there are fewer farmers who are land stewards, and fewer farmers willing to undertake remediation on their farms at the scale required to offset the Upper York Sewage System (UYSS), a new STP. If the UYSS discharges into Lake Simcoe, more reliable and enduring offsets will be needed, namely the proposed Government of Canada and York Region – funded stormwater treatment / phosphorus reclamation centre on the East Holland River, which could remove 7 tonnes of P per year.

Although their submissions do not mention the UYSS discharging into Lake Simcoe, York and Durham Regions are advocating for it. York Region supports the UYSS, while Georgina, their lower tier municipality on the lake, opposes it, in harmony with Georgina Island First Nation.

Managing Growth 

Almost all of the staff reports refer in some way to the challenges of accommodating the province’s growth plan population minimums while meeting the requirements of the LSPP. 

York Region asks point blank, “Clarify how municipalities can comply with both legislated growth targets and wastewater servicing restrictions under the Lake Simcoe Protection Plan.”

Georgina’s report says, “Increased pressure on the watershed ecosystem will materialize given the anticipated, significant future growth in the watershed planned in the next 30 years…. Despite the best of intentions and practices, phosphorus loading targets in the lake have not been met since the adoption of the LSPP in 2009. Clearly, better efforts and measures are required to address this condition in the face of increased population growth in the watershed.”

Innisfil advocates for the LSPP to accommodate growth: “phosphorus targets for Lake Simcoe may not be sufficiently in step with other recently updated Provincial policies. Changes to broader the provincial policy landscape, particularly changes to the growth forecasts and policies of A Place to Grow (“Growth Plan”) to be implemented through the County of Simcoe Municipal Comprehensive Review (“MCR”) process, need to be viewed and considered comprehensively with the LSPP…. The MECP’s 10-year review provides an opportunity to examine the growth pressures in the Lake Simcoe watershed and ensure that provincial plans offer a parallel consideration for sufficient servicing capacity to support growth forecasts.”

Innisfil went on to suggest sub-regional targets, presumably to accommodate local growth impacts. It is no secret that Innisfil and landowners and developers operating there have massive growth ambitions. They suggest that the province consider the following: “Could a sub-regionalized approach to the LSPP better achieve Provincial planning goals? …. The Town welcomes the opportunity to discuss with the MECP the introduction of sub-regionally focused amendments following the MECP’s 10-year review, where they are supported by data and provide specific controls related to the environmental threats, growth pressures, and presence of natural heritage resources within each sub-watershed area. The approach may resemble sub-regional policy variations introduced to the Growth Plan and could be informed by the MCR process.” This approach suggests that one part of the lake can pollute more than others. This is not going to work. Clean streams in Oro-Medonte will not make Innisfil’s frequently closed beaches any cleaner. 

Ultimately, the province will have to decide if their growth agenda is more important than Lake Simcoe. We do not have the systems in place to accommodate a doubling of the watershed’s population by 2051. We may never have it all figured out. Until we do, the rate of growth is simply unsustainable, and it seems that Lake Simcoe municipalities are saying that, without saying that exactly.

Harmonizing provincial plans

Three of the five staff reports recommend policy harmonization with other provincial plans, referring to an opportunity to use the Greenbelt (GB) or Oak Ridges Moraine Plan’s (ORMCP) natural heritage feature definitions in the LSPP as one example. This suggestion is appealing for a number of reasons. One, planners and developers would find it easier to implement and to understand the applicable policies if they were the same across the ORMCP, GB and LSPP. Two, if this change could go some way towards achieving the LSPP’s “40% high quality natural cover” target, which so far has been a target without implementing policy. 

But staff comments on policy harmonization also point out some of the gaps and mistakes made by the province in their haste to dismantle environmental policy. Municipalities question whether water, wastewater and stormwater policies are meant to accommodate growth, or to protect the quality and quantity of affected waters. Indeed, the Growth Plan says one thing on this topic and the Provincial Policy Statement says another. One assumes that the province will clarify the intent. We sure hope they come down on the side of water protection. If not, their Made in Ontario Environment Plan promises will have been as empty as Dear Henry’s bucket. 

The province’s public consultation on the LSPP review has ended, but there are still many concerns and questions they will need to address before landing on solutions that will keep Lake Simcoe healthy. For this to happen, the province must accept that their Covid recovery plan (build build build) will have negative impacts on the places that Ontarians love, and change course. 

—- 

Both the municipal staff reports on the LSPP and the RLSC comments submitted to municipalities can be accessed here

Watershed protection this amazing needs to stand

Ontario’s Lake Simcoe Protection Act and Plan represents the best watershed policy in Canada. It’s a model so good it’s been replicated in Ontario’s Great Lakes Protection Act. The Lake Simcoe experience is leading the way for reducing stormwater impacts in a high urban growth context, using low impact development techniques, and adaptive watershed management. As global climate change impacts grow, algae blooms and flooding will get worse in many waterbodies; Lake Simcoe’s Protection Plan offers a model for reducing nutrients and contaminants and protecting and restoring the watershed’s flood-absorbing wetlands and forests. It’s a hard-fought model worthy of protection.

But the Rescue Lake Simcoe Coalition is concerned that the Lake Simcoe Protection Plan (LSPP) could be weakened in 2021, and that’s why we are asking water protectors across Ontario and Canada to help us Protect Our Plan.

The Lake Simcoe Protection Plan is up for statutory review by the Province of Ontario; the public consultation period ends March 3rd, 2021, and the province says that by the summer, amendments to the Plan will be made.

The Coalition and its 26 member groups are campaigning to Protect Our Plan, urging the Province to leave the Plan’s targets and objectives alone, and focus on the Plan’s implementation.

Protect Our Plan Priorities in brief:

  1. Improve water quality by reducing Phosphorus loads to the lake, to 44 tonnes per year, as soon as possible, from urban and agricultural areas, and from aggregate and construction sites;
  2. Support a healthy environment around the lake and reduce flooding impacts by protecting 40% of the watershed area’s forests and wetlands;

If enough people support excellent watershed protection, it will be possible to raise the bar for watershed health in Ontario. Groups and organisations can support strong watershed protection by signing onto our Lake Simcoe Protection Plan review priorities, and individuals can sign our petition and / or use our template to send a letter to their MPP here: https://rescuelakesimcoe.org/take-action-2/

Lake Simcoe is an hour’s drive north of Toronto, and its watershed population of nearly 500,000 includes Barrie, Orillia, Bradford, Newmarket, Orillia, Sutton and Beaverton. The watershed / drainage basin is 3,400 square kilometres, about five times the size of the lake itself, and is between the GTA’s Oak Ridges Moraine and Greenbelt, and “cottage country” to the north. The watershed is under intense development pressure, with its population is projected to double by 2051. See maps here.

It’s practically impossible to imagine today that the Lake Simcoe Protection Act received UNANIMOUS ALL PARTY SUPPORT a short thirteen years ago at Queen’s Park. The largely Conservative voter base around the lake cares about protecting our water and a quality natural environment. Protecting the environment is not a partisan issue at the local level. That’s why we are reaching out to people of all stripes to join us in Protecting Our Plan.

Ice fishermen and women love Lake Simcoe too. They need it to stay healthy and clean to support the watershed’s $420 million sustainable recreation sector.
Conservative MPP Garfield Dunlop, Simcoe North, at Queen’s Park in 2006, introducing Lake Simcoe Protection Act as a Private Members Bill, with heads of Environmental Defence, Ontario Nature, and Rescue Lake Simcoe Coalition.

The Lake Simcoe Protection Act was the brainchild of the Rescue Lake Simcoe Coalition’s founding Chair (and Environmental Defence and Ontario Nature Board member), progressive developer Bobby Eisenberg; and environmental lawyer David Donnelly, who was working for citizens protecting the environment in Oro-Medonte (Simcoe County) at the time. Supporting his constituents, Conservative MPP Garfield Dunlop (Simcoe North) introduced what became the Lake Simcoe Protection Act as a private member’s bill as a member of the opposition at Queen’s Park. Two years later, Premier Dalton McGuinty’s government introduced and passed the legislation, but Dunlop’s lead made protecting Lake Simcoe a non-partisan issue. Will it remain so?

But while both the Province of Ontario and the Government of Canada pledge to protect Lake Simcoe, the threats keep coming. Changes to growth planning rules in Ontario, a proposed highway across a sensitive wetland and wildlife area of the Holland Marsh, and the Minister’s Zoning Order, (MZO) requested for the gigantic Orbit development in Innisfil all highlight the challenges of accommodating growth while protecting the environment.

What happens at Lake Simcoe is a bellweather for our ability to protect water quality in urbanizing areas. Let’s keep the protections at Lake Simcoe strong so other areas can catch up. Take action before April 2021 to defend best-in-class environmental watershed policy.

Lake Simcoe seen from the site of the proposed Bradford Bypass / Holland Marsh Highway, looking north east towards Cooks Bay and Georgina. Photo Credit Jeff Laidlaw.

Explainer video: What is the Lake Simcoe Protection Plan? https://rescuelakesimcoe.org/

More on the history of the LSPP https://rescuelakesimcoe.org/2018/12/08/history-of-the-lake-simcoe-protection-plan-vision-leadership-and-listening/

In Praise of Wild Places

An essay by Nari Hwang, Grade 8 student from Shanty Bay Public School.

 The author

A map of Lake Simcoe made from pictures taken on a trip around the Lake

“To many a city person there comes a time when the great town wearies them. They hate its sights and smells and clangor. Every duty is a task, and every caller is a bore. There come visions of green fields and far rolling hills, of tall forests and cool, swift flowing streams.”

This excerpt from “Camping and Woodcraft” by Horace Kephart,  a book first published in 1917 and given by my grandfather to his father, still speaks to me over the years. It is still true for many of us.  It explains that sometimes we need to go out into the wild places and do whatever we wish; to be free and to breathe in the clear wilderness air. 

Wild places have the power to make us feel alive and free, they are vital to the health of the environment, and they have been a source of inspiration over the centuries for countless artists, scientists, free spirits and even office bound bankers like my great grandpa. 

Feeling a little pull to the outdoors? Let’s go on a little journey and explore the importance of wild places…

Like so many adventures, ours starts… on the couch! Boredom rules! Someone suggests a walk and everyone sluggishly puts on their boots, squints into the sun and heads off to countless possibilities.

The cool air tingles our cheeks and our hearts start beating a little faster. In a moment, I am climbing a tree with my brother and sister. We are pirates! Hey, you grab a stick sword too and join in! With no laundry to do, or calls to make, the grown-ups loosen up too and we run and laugh and seek and look at teeny tiny inch worms, and feel the soft poofiness of mossy fairy places. Other times, we can just sit quietly and soak in the green earthiness. Experts in mental health even recommend that kids have the chance to get bored, get outside, and get creative.  Whether to try new things, bond with those you love or enjoy some solitude and time to think, wild places, big or small are just the place to do it.

Let’s turn onto a new path, because wild places aren’t only good for encouraging that feeling of awesomeness! They are also a source of creative inspiration. Without the wild places, where would the wild things be? This is a question answered in Maurice Sendak’s children’s story, Where the Wild Things Are. Here, a boy travels to a fantasy land full of weird beasts, becomes king and then heads home in time for dinner. Wild places have been the source of creative inspiration in many books for young people — The Call of the Wild, Lost in the Barrens, and The Jungle Book are a few that I have read with my family. You can probably think of others too.

Think also of the music, dance, theatre and poetry that was inspired by singing birds, rolling hills or dancing leaves. Canadian visual artists like Tom Thomson, Emily Carr, the Group of Seven, Bill Reid and Kenojuak Ashevak have shown us the rough beauty of our landscape and have inspired many to pack lightly, put on some good hiking shoes, or slide into a tippy canoe to go see more of Canada. Each of these creative works asks us, to hear the call, to come along, to join in the adventure and experience a little wild — even if only in our imaginations.

However, we need wild places, not just because they are inspiring, but also for environmental reasons. Forests are good for filtering ground and surface water as it moves through toward bodies of water. They also absorb unwanted carbon dioxide and provide safe habitats and food for native animals and plants. Wetlands and marshes also provide important biodiverse ecosystems and form the main filtration systems in nature! Other places like wild fields or meadows are good for native pollinators, and a whole different ecosystem of creatures and native weeds that are vital to our earth.

Each wild place is a unique ecosystem that produces its own unique cycle and flow of nutrients. Plants and animals live, and serve a special purpose, then once they die and decompose, they turn once again into soil. New plants use that soil to grow, and whatever eats that plant will have new energy and the cycle will continue. It is miraculous and inspiring! 

According to the Canadian Wildlife Federation, Canada is home to more than 70 000 wild species and 43 national parks and reserves that cover nearly a quarter million square kilometres. It’s also home to 30 percent of the world’s boreal forests and 25 percent of the world’s wetlands. 

But, our wild places are in danger because of us. We need to take action against things like climate change and pollution. 

David Attenborough’s new film  called “David Attenborough: A life on our Planet” talks about how our earth is changing because we take more than the earth can afford to give. He says, “The true tragedy of our time is still unfolding across the globe, barely noticeable from day to day. I’m talking about the loss of our planet’s wild places, its biodiversity… We cut down over 15 billion trees each year. We reduced freshwater populations by over 80% replacing the wild, with the tame… We must restore the biodiversity; the very thing that we’ve removed, it’s the only way out of this crisis we have created. We must re-wild the world.”

So, how do we do that? Most of us don’t own a big area of untouched land so how can we create our own little backyard wild place? Think about leaving an area in your yard un-mowed and plant some native wildflowers there. Leave the ditch near your home alone and let the native weeds grow for pollinators. Live near water? Consider a natural shoreline. If you need to remove an old tree, leave about ten feet of it behind and you will be supporting an insect and fungi high-rise condominium!

Wild places have the power to encourage adventure and fun, to improve mental health, to inspire great works of creativity and to sustain and strengthen biodiverse environments.

Remember I began with talking about my great grandpa’s book that has been passed down to my family? It also says that “this instinct for a free life in the open is as natural and wholesome as the gratification of hunger and thirst and love.”  I can imagine him reading these words that also make me excited about wild places and thankful that we still have so many to enjoy. But with that comes a responsibility to protect those places and the species that live there. Let’s leave the wild places wild and ensure that generations to come can know their glory and wonder!

What’s wrong with Innisfil’s Orbit Ministers Zoning Order request?

Innisfil Council has approved a draft Minister’s Zoning Order (MZO) for the Orbit, a massive development planned for the location of a GO train stop, the 6th line, between the 20th sideroad and Lake Simcoe.

 

It’s off to Simcoe County Council to approve on November 24th.

 

County Council is made up of the Mayors from all around the County. For the sake of sane regional planning, we are asking Simcoe County residents to tell their Mayor and Minister of Municipal Affairs and Housing not to approve the Orbit MZO proposal. 

 

We hear there are some chinks in the armor and that some Simcoe County Mayors / Deputy Mayors are opposed.

Proposed site of the Orbit: See Lake Simcoe in the background!?
Proposed site of the Orbit: See Lake Simcoe in the background!?

An explanation and points to make are below.

 

But first of all, in the context of an alarming loss of farmland and natural areas in Southern Ontario, this does not represent environmental planning. This is a new city in greenfields, which is the opposite of Smart Growth. The Orbit plan looks like this:

Orbit proposal and natural features: Image by Adam Ballah, Simcoe County Greenbelt Coalition.
Orbit proposal and natural features: Image by Adam Ballah, Simcoe County Greenbelt Coalition.

The proposed site now looks like this:

Why oppose the Orbit MZO proposal?

  1. Using an MZO is totally inappropriate for a proposal that would facilitate the development of a new city of 150,000 people way outside Innisfil’s current settlement boundaries. Innisfil’s population is 36,000. A proposal of this scale must go through democratic planning channels like an Official Plan Amendment.

 

  1. Innisfil Council and staff are lying about public support for the proposed use of an MZO. While there is some community support for the Orbit, based on the claims that it would get a GO station in place by 2022, preserve other farmlands (ironic to the 9th degree) and protect the environment by putting what would have to be all future growth around the Orbit, Innisfil Council has not addressed the public’s concerns about using an MZO and has mischaracterized a frenzy of interest (actually alarm) as public support. There are worrying irregularities in the introduction of the motion that Council approved (just 7 days after the first MZO draft was made public), to use an MZO. Cynically, Council voted to use an MZO immediately after they had voted to extend the public input period, ignoring the fact that most public comments were objecting to the use of an MZO.

 

  1. This proposal sets in motion developers’ dreams of developing Innisfil 6th line all the way to Hwy 400, where they want to build up new employment areas (like what we see on the 400 north of the 8th line where employers / businesses can locate ) for which there is no market research.

 

  1. An MZO is a blunt planning tool that leaves no opportunity for public input or public or Town appeal. If the Minister approves this concept, the Zoning Order will be written by the Minister. Based on how MZOs have been used so far by the Ford Government, it does not have to include conditions requested by the Town or County Council.

 

  1. Nothing in the draft MZO guarantees that the Orbit would be built as pitched. Because there is no market research supporting the viability of people buying condos in a farm field, we have grave concerns that this is greenwash, and that the ultimate build out will not be dense or environmentally friendly. Despite reassurances from Town staff we remain concerned that provincial policies like the Lake Simcoe Protection Plan could be ignored. For instance, MZOs have already been issued in the past few months to destroy at least 6 Provincially Significant Wetlands in favour of development in other parts of Southern Ontario, overriding provincial policy.

 

  1. Typically, Simcoe County must share new population allocations with all of their 18 municipalities. Innisfil’s MZO request for 20,000 people for the first phase of the Orbit dilutes the marketability of what other municipalities can build. It also means that developers who went through the proper channels and own land within Innisfil’s settlement area boundaries could not see their plans realized for many years; this is totally unfair, rewards cheaters, and punishes those who followed the Planning Act.

 

Frankly, the province is showing their true colours now, and are using COVID-19 as cover for giving gifts to developers (many of whom are PC party donors) all over Southern Ontario. They have done nothing to protect Lake Simcoe except fund a couple of studies.

 

It’s time to get angry and use your democratic rights. Make a call! Looks like it’s up to us to try to protect Ontario’s environment.

 

  1. Find your Mayor here and please call or send them a personalized email. https://www.simcoe.ca/Clerks/Pages/councilmembers.aspx
  2. If you’re emailing, please cc the ultimate decision-maker, Minister of Municipal Affairs and Housing, Steve Clark. minister.mah@ontario.ca
  3. There’s not much point asking Innisfil Mayor Lynn Dollin or Deputy Mayor Dan Davidson as they are in support. If you’re from Innisfil, call / email the Warden, top of the list in the link above.


For more information please see the Rescue Lake Simcoe Coalition’s submission to Innisfil Council on the MZO proposal here: https://rescuelakesimcoe.org/wp-content/uploads/2020/10/RLSC-Submission-on-MZO-Innisfil-Oct-2020.pdf

 

www.rescuelakesimcoe.org

If municipalities truly want a clean Lake Simcoe they need more than hope

Municipal Response to Protect Our Plan delegations to Council

As the Rescue Lake Simcoe Coalition prepares for the Lake Simcoe Protection Plan’s statutory review to begin this fall, we’ve been making delegations to Councils around the watershed, with about half complete so far. Along with Coalition member group leaders, we are ensuring that Councils know what the Lake Simcoe Protection Plan does, and about the lake’s stressors. 

We also asked for Council support for a resolution [https://rescuelakesimcoe.org/wp-content/uploads/2020/04/Rescue_Lake_Simcoe_Coalition_Proposed_Resolution.pdf] that calls on the province to implement and resource the Lake Simcoe Protection Plan. This blog summarizes Council responses so far, and what that might tell us about municipal priorities. 

Only two of eight municipalities that we approached so far have strongly supported our motion requesting that the province do its job on Lake Simcoe. Why? The most generous possibility is that they want to provide feedback to the province one time when the LSPP review is taking place and the province’s proposals are clear. At the same time, if these Councils were serious about Lake Simcoe’s health they would preemptively ask the province to not touch the LSPP’s targets, as our model resolution outlines.

The conflict is this: municipalities are, to varying degrees, addicted to growth. Limited in their powers of taxation, they seek to cover the costs of building a bigger and better community on the back of new development and the associated Development Cost Charges collected by the municipality. 

Saving Lake Simcoe runs afoul of the growth agenda that drives many municipalities. It requires maintaining today’s tough caps on sewage treatment plants’ phosphorus pollution, building with a lower environmental impact, and offsetting phosphorus pollution generated by construction or the land use change, or both. None of these choices thrill developers or municipalities responsible for paying for sewage treatment. 

But the reality is that the watershed’s population is projected to double by 2041 while the current provincial government is leading an unabashed pro-growth agenda, going so far as to re-brand our license plates for consistency. Development certainly contributes to phosphorus loads, and the change in land use and hardening of surfaces is usually not good for water quality or flow. As it all flows downstream, these impacts will negatively affect Lake Simcoe’s health. 

Knowing what we know, and limited by the technology we have today, doubling down on development impacts is necessary to save Lake Simcoe. It is a “polluter pay” approach, which is being applied already in the Lake Simcoe watershed, and which Ontario’s Conservative government theoretically supports. Ultimately the choice for elected officials and their administrations amounts to admitting that development hurts the lake and recouping costs for remediation and hope it works; or sticking one’s head in the sand while saying that you love Lake Simcoe and hoping that future generations can undo the mess we are making.

We thought it would be pretty easy to get municipal support for this motion, since we are really just asking the province to just do its job. The Rescue Lake Simcoe Coalition’s model resolution can be read in full here [https://rescuelakesimcoe.org/wp-content/uploads/2020/04/Rescue_Lake_Simcoe_Coalition_Proposed_Resolution.pdf] , but the substantial parts are these: 

THEREFORE BE IT RESOLVED, THAT the Town of XXXX calls on the Ontario Government to demonstrate its commitment to clean water and protecting what matters most in the provincial statutory review of the Lake Simcoe Protection Plan, by ensuring that provisions in the Lake Simcoe Protection Plan that protect water quality are not weakened and that policies protecting natural heritage be strengthened, in order to meet the targets of the Lake Simcoe Protection Plan; and
THAT the Ontario Government be requested to work collaboratively with affected Provincial Ministries and all levels of government, including First Nations and Métis, to achieve the goals and targets of the Lake Simcoe Protection Plan and to resource the programs that improve Lake Simcoe’s water quality during the provincial statutory review of the Lake Simcoe Protection Plan;

So far, only two of the eight Councils we’ve approached have fully endorsed our resolution. Unsurprisingly, the places that aren’t desperate to attract new growth have responded most positively to the Rescue Lake Simcoe Coalition’s pro-environment position. Those are the Barrie City Council and Georgina Island First Nation Band Council.

Orillia’s Environmental Advisory Committee supported our resolution and we are hoping for some action now at the Council level. 

Oro-Medonte’s Council resolution committed the municipality to continue to support the LSPP in its review year.

Whitchurch Stouffville Council’s resolution said the same, and they directed staff to continue to work with the Lake Simcoe Region Conservation Authority to implement best practices in order to minimize the impacts on Lake Simcoe and the surrounding watershed. 

In East Gwillimbury, following a presentation by a well known local naturalist, a staff planner prepared a thoughtful summary for Council, but ultimately the conclusion was: “Staff will report back to Council when the Province issues updates regarding the LSPP, as well as opportunities to provide comment.” This characterizes the responses from Innisfil and BWG too. 

Innisfil: nothing

Bradford West Gwillimbury: nothing 

Looking forward, the Rescue Lake Simcoe Coalition and allies are going to make another eight  delegations to Council this fall about the upcoming review of the Lake Simcoe Protection Plan, in Simcoe County, Durham Region, Newmarket, Aurora, King, Brock, Uxbridge, and Georgina. Residents can support our campaign by calling their Councillor and asking them to support our resolution and protect Lake Simcoe.

We hope it is now clearer to Councils that the environment is a low priority for the province, and that any municipal politician making promises about protecting the environment should take some time to both push the province to implement the Lake Simcoe Protection Plan, and do the same with their own municipal plans and processes. While the Rescue Lake Simcoe Coalition is doing what it can to push the province to implement the Lake Simcoe Protection Plan, and not weaken it, the lake needs all the municipal help it can get.

Minister’s Ten Year Report on Lake Simcoe Obscures Progress by Mixing Science and Politics

August 7, 2020

On July 17th Barrie-Innisfil MPP Andrea Khanjin released the Minister of the Environment’s Ten Year report on Lake Simcoe and made a $581,000 funding announcement for Lake Simcoe research. The Minister was nowhere to be seen. Also missing were a credible science monitoring report and the 2018 and 2019 Ministers reports on Lake Simcoe.

We should take this investment to mean that the province is very aware that there are people like you and me who are going to make them wear the impacts of their decisions and actions on Lake Simcoe. We are a strong constituency, and we need to keep it that way. Public pressure is the Lake’s best defence.

I will focus my questions and comments on Lake Simcoe, but the Lake does not exist in a geographical or policy vacuum. Recent and proposed changes to the Growth Plan are going to perpetuate suburban sprawl until 2051 and beyond. The changes virtually guarantee that the scarce remaining farmland in southern Ontario will be bought by land speculators, threatening the viability of local food production. Recent policy changes and proposals also threaten the protection of more natural areas as aggregate extraction will soon be permitted in habitats of endangered species and other natural features outside the Greenbelt and possibly the Lake Simcoe watershed. The Environmental Assessment process is a shell of what it used to be. I could go on. The point is that the environmental policy regime in Ontario has been shattered. This will naturally affect Lake Simcoe.

Now, to the substance of the Minister’s Ten Year Report on Lake Simcoe. The Ten Year Report is far rosier than it should be. There are more unknowns, strange changes, and looming disasters than the report lets on. While I agree that the remedial actions have been helping the lake, there is an obvious editorial slant towards the bright side. I find this problematic because this report forms the backdrop to the review of the Lake Simcoe Protection Plan. I worry that it will lead readers to think that the Lake is doing well and needs less protection.

Indeed, fishing and swimming is the way most people use the lake, and the Ten Year Report underreports downward trends and / or existing poor conditions at beaches and regarding fish health. People who use Lake Simcoe have a right to know the truth, warts and all.

If I authored the report it would highlight:

  • Phosphorus loads have skyrocketed in recent years; new development and its impacts are increasing pressure on the lake, and the remedial actions are not keeping up with the need to drive down phosphorus loads;
  • The nearshore area is a mess of invasive species, and the nearshore ecology has undergone massive changes in the past ten years; impacts are yet inadequately studied;
  • We don’t know why dissolved oxygen levels have gone up (good) while phosphorus loads have gone up (bad). This result is the opposite of what lake modelling told us to expect. The most likely explanations involve positive changes brought on by invasive species absorbing, consuming and / or moving phosphorus from one part of the lake to another. The long-term consequences of this are unknown;
  • We are not achieving the Lake Simcoe Protection Plan’s natural heritage targets for forests, wetlands and shorelines, which are, essentially, to protect what we have and increase the size and quality of natural heritage features. Instead, we have lost wetland and forest cover across the watershed. The legal mechanisms in place will not achieve the Lake Simcoe Protection Plan’s natural heritage targets;
  • Remedial actions are working but they are not compensating for the impacts of development and climate change. The Lake’s health will not improve without limits to growth, a strong emphasis on restoration, natural heritage protection, and invasive species control.

The most important point, however, is one of transparency. One should not blend science and politics in such an impenetrable way. The Minister of Environment, Conservation and Parks is a politician, not a scientist. Yet the Minister’s report says, “This consolidated report, which addresses both five-year and annual reporting requirements under the Lake Simcoe Protection Act, 2008, describes the collaborative efforts taken to implement the Lake Simcoe Protection Plan, as well as results of monitoring programs and progress towards the plan’s objectives.” It reports on the results of monitoring and progress towards objectives inconsistently and inadequately. If the province intended to produce more scientific reports to support the review of the Lake Simcoe Protection Plan, which we now understand they will do, they should have been clear about that when the Minister’s report was released.

Here’s what is expected: The Lake Simcoe Protection Act, 2008, which has legal effect, lays out some reporting requirements requiring “the Minister of the Environment to prepare a report that, describes the results of any monitoring programs; and describes the extent to which the objectives of the Lake Simcoe Protection Plan are being achieved at least once every five years.” 1 The Lake Simcoe Protection Plan says, less forcefully, that the “Ministry of the Environment in partnership with other ministries will produce a report that describes the results of monitoring programs as well as the extent to which the objectives of the Plan are being achieved.”

The Minister’s combo Science and Politics report of 2020 simply does not provide the analysis needed to evaluate the extent to which the objectives of the Plan are being achieved, and does not meet the reporting requirements of the Lake Simcoe Protection Act.

It is not appropriate to put all of this information into one report with little to no citations, and with no editorial input from the Lake Simcoe Science Committee. There is a totally unscientific catch-all reassuring the reader that, “Each priority area is supported by data and trends collected from several provincial monitoring programs, and supplemented with data from partners such as the Lake Simcoe Region Conservation Authority.” I do not mean to diminish the work of these conservation professionals. But the Minister’s report is not a science report without citations. In the absence of any other public explanation, the reader concludes that the province is trying to take the shortest route possible to meet the reporting requirements of the Lake Simcoe Protection Act and Plan by jamming it all into one inadequately sourced document.

The last comprehensive monitoring report on Lake Simcoe was released in 2014. It had been discussed and developed by the Ministry of the Environment and Climate Change in collaboration with the Lake Simcoe Science Committee over many months. The Minister’s 2014 Five Year Report on Lake Simcoe appropriately followed the Five Year Comprehensive Monitoring Report. It highlighted the good news, like the Minister of the Environment, Conservation and Parks in 2020, but at least it referenced an independent science report. The 2014 Comprehensive Monitoring Report has authors, citations, and references listed. It includes standard “science stuff” like clearly identifying progress against targets, which is inconsistent at best and deliberately misleading at worst in the 2020 report.

For instance, although the overall watershed trend is a LOSS of forests and wetlands (1% loss each over a ten year time period) what is highlighted in the press release of July 17 is, “The 10-year report on Lake Simcoe shows the restoration of more than 15 kilometres of degraded shorelines, the planting of more than 55,000 trees and shrubs, and the creation and restoration of 120 hectares of wetlands…” 2. Highlighting successes without context is misleading, and is the reason why blending politics and science in one report is problematic.

Related to the loss of natural heritage is development, the only growing source of phosphorus loading at Lake Simcoe. Ten years ago the province acknowledged that approved development to 2031 in the watershed would ADD up to 15.3 Tonnes per year Phosphorus to the lake. 3 The provincial Lake Simcoe Science and Coordinating Committees’ formal advice to the Minister cautioned that development threatens the Lake’s health, advising, “Ensure that the assimilative capacity and ecosystem health of the watershed are considered prior to any amendments to future growth projections.” 4 In contrast, the province has recently inflated growth projections using market demand and land needs assessment methodologies that have been called speculative and flawed by critics. The province has allowed municipalities to expand their settlement boundaries more easily and more often, and has allowed developers to build fewer homes per acre. This new growth will double the watershed’s population by 2041 and add stress to the lake via phosphorus loads from construction in the watershed, and from land converted to urban uses. Therefore we absolutely need to maintain the development and construction policies, practices and offsets programs that reduce the pollution from development at Lake Simcoe.

This is a relatively minor point but I am truly puzzled by this one. The Minister’s 2020 remarks end with: “I want to thank the local conservation authorities, Indigenous communities, municipalities, agricultural and commercial sectors and residents who have worked tirelessly on implementing actions to protect and restore the ecological health of Lake Simcoe. I also want to thank the Lake Simcoe Coordinating Committee and the Lake Simcoe Science Committee for their advice on where our efforts need to be focused. This ongoing work requires collaboration and I look forward to continuing this important partnership with you.”

I just do not believe this. It’s polite to thank everyone, it’s true, but this is disingenuous considering what has happened under this administration. To date, the Conservation Authorities budgets’ have been slashed and their powers are expected to be severely curtailed in yet unreleased regulations; there is no Indigenous representation on the Lake Simcoe Science and Coordinating committees, and local Indigenous communities are poised to oppose the new Upper York Sewage System going into Lake Simcoe; the Lake Simcoe Science and Coordinating committees have not met since the current provincial government came to power; municipalities have less ability now to collect development cost charges from developers on some growth-related costs; farmers are furious with the province for basically putting housing development ahead of farmland protection; and frankly, to date commercial and residents have not been publicly engaged by the province.

Lake Simcoe is not a political pawn. It’s a living thing that heals when the right conditions are in place. We need to engage experts in determining what the Ten Year monitoring results mean before contemplating any changes to the Lake Simcoe Protection Plan.

TAKE ACTION: If you share my concern that the government’s LSPP Ten Year Review this fall will leave the lake more vulnerable, you can take action now through this 1-click letter campaign.

Claire Malcolmson is the Executive Director of the Rescue Lake Simcoe Coalition. She has worked and volunteered on Lake Simcoe issues since 2001. Claire sat on provincial committees established to develop and then implement the Lake Simcoe Protection Act and Plan from 2008 – 2018.

The Rescue Lake Simcoe Coalition represents 26 groups around the Lake Simcoe watershed, and spearheaded the campaign to get the Lake Simcoe Protection Act in 2008. www.rescuelakesimcoe.org

  1. S. 12. 2. Lake Simcoe Protection Act
  2. Ontario newsroom. July 17, 2020. Ontario Taking Action to Further Protect Lake Simcoe. https://news.ontario.ca/ene/en/2020/07/ontario-taking-action-to-further-protect-lake-simcoe.html
  3. Ontario, 2010. Lake Simcoe Phosphorus Reduction Strategy. https://www.ontario.ca/page/lake- simcoe-phosphorus-reduction-strategy
  4. Minister’s Ten Year Report on Lake Simcoe, 2020 https://www.ontario.ca/page/ministers-10-year-report- lake-simcoe

Aggregate extraction in the home of endangered species? What this means for Lake Simcoe

There are over 27,000ha of potential aggregate resources (sand, stone and gravel) in Simcoe County.[i] Last year the Rescue Lake Simcoe Coalition analysed how well protected from development our natural features are, and found that only 14% of Simcoe County’s landscape is well protected, and of this, 11% sits atop aggregate resources.[ii]

As the province continues to push for more aggregate development, the health of communities and ecosystems are at risk. Increased atmospheric phosphorous, changes to water regimes, complaints of noise and dust due to blasting, traffic related to haulage, and impacts to the watershed’s forests and wetlands (and their wild inhabitants) are just a few concerns relevant to the Simcoe watershed.


The Provincial Policy Statement (2020) (PPS) sets out the ways in which natural features, such as aggregates, are to be managed. Under the PPS aggregate resources are afforded long-term protection in ways that other natural features are not. Particularly concerning is section 2.5.2.1, which states that “[a]s much of the mineral aggregate resources as is realistically possible shall be made available as close to markets as possible” and that demonstration of need or demand/supply analyses are not required. This directive is almost verbatim included in the County of Simcoe Official Plan.[iii] There is clear danger in assuming constant demand for which constant supply must be made available, as it leaves much of the province, especially the GTA, at risk of unfettered extraction.

Working in tandem with the PPS, the Growth Plan for the Greater Golden Horseshoe[iv] guides where and how development activities should take place. The Growth Plan is currently under review. Through Amendment 1 of the Growth Plan, the province is seeking to “make it easier to establish mineral aggregate operations closer to market.” To do so, changes would permit new aggregate operations in Natural Heritage Systems (except the Greenbelt), while removing prohibitions on aggregate operations from the habitat of endangered and threatened species within the Natural Heritage System.[v] Amendment 1 is currently open for comment on the Environmental Registry (ERO-019-1680) until July 31, 2020.

What stands in the way of rampant extraction? The Lake Simcoe Protection Plan (LSPP)[vi], is a bold policy that limits the impacts of development activities, including aggregate extraction on the Lake Simcoe watershed. What makes the LSPP particularly powerful is that in case of conflict between it and other provincial policies, “the provision that gives the greatest protection to the ecological health of the Lake Simcoe watershed prevails.” In fact, the LSPP is very strict against permitting new aggregate operations in specific key heritage and key hydrologic features.[vii]

The provincial government announced that they would begin a statutory review of the LSPP this fall. We need to ensure that the Plan is strengthened and implemented in ways that will protect the health of Lake Simcoe and its watershed for the long term. 

Dena Farsad, PhD (ABD)

July 24, 2020


[i] In 2013, the Ontario Geological Survey produced the Aggregate Resources Inventory Paper 188 which outlines potential quantity and quality of aggregate resources in the County of Simcoe. AIRP 188 identifies 2404 ha of primary resources (totalling 283.7 million tonnes) and 27,503 ha of possible bedrock-derived aggregates (totalling 10,928 million tonnes) within the boundary of Simcoe County.

[ii] See the Ministry of Natural Resources and Forestry’s Pits and Quarries online GIS mapping application to get a sense of the number and location of pits and quarries currently within the Lake Simcoe watershed.

[iii] See for example, section 3.3.1.5 and section 4.4.2 of the Simcoe County OP.

[iv] In Ontario, land-use planning happens under the guidance of the Planning Act, which establishes planning goals and processes, and sets out roles and responsibilities of municipal and regional governments. Section 3 of the Actmandates the establishment of the PPS. All regions and municipalities in Ontario must adhere to the policies set out in the PPS while developing regional and municipal official plans.

[v] In many ways, this is the nail in the coffin for endangered and threatened species as the Endangered Species Act, 2007 has already been significantly weakened under Schedule 5 of Bill 108 (More Homes, More Choice Act, 2019).

[vi] The Plan is given legislative authority via the Lake Simcoe Protection Act, 2008.

[vii] Including significant wetlands, significant habitat of endangered species and threatened species, and significant woodlands.

Take action!

Take action until July 31st, 2020 at https://act.environmentaldefence.ca/page/62895/action/1?ea.tracking.id=action and / or make comments on the province’s Environmental Registry of Ontario site here https://ero.ontario.ca/notice/019-1680Or email growthplanning@ontario.ca directly. 

Please include something like this in your comments:  Ontario’s proposed changes to growth, planning, and allowing aggregates in habitats of endangered species would be bad for Lake Simcoe’s water quality if enacted. I am very concerned about these and other proposed changes, allowing unfettered, and unneeded greenfield development across southern Ontario at the cost of farmland and natural heritage. 

Re. ERO 019-1679, the proposed changes to the Growth Plan for the Greater Golden Horseshoe and ERO 019-1680, the Lands Needs Assessment Methodology.