Written by Claire Malcolmson- Executive Director of the Rescue Lake Simcoe Coalition and has a Masters Degree in Planning.
The Mayor of King Township, Steve Pellegrini, has been pushing publicly for a hospital to be built on Ontario’s Greenbelt. This is wrong for healthcare, wrong for King, wrong for the Greenbelt — and it’s illegal.
Someone needs to point out to Pellegrini, and the public, that provincial regulations do not allow a hospital to be built on Ontario’s Greenbelt. True, Premier Doug Ford has taken steps to destroy the Greenbelt by swapping land in and out — he’s on video actually lying before the last election promising he “won’t touch” the protected area.
But even after Ford’s lies, the rules still stand: provincial policy does not allow politicians to grab Greenbelt land for a hospital just because they feel like it’s a good idea. The only way it could happen would be for Ford’s Municipal Affairs Minister, Steve Clark to issue a Minister’s Zoning Order (MZO) and command that the rules be ignored.
Here’s where the law stands: Ontario’s Greenbelt Plan allows for the extension of some infrastructure, but a hospital is not listed as infrastructure in public policy. It falls under the definition of a public service facility or institution.
Ontario’s highest ranking planning policy, the 2020 Provincial Policy Statement (PPS), includes health and educational facilities among public service facilities. But it also says clearly that these facilities belong in community hubs, close to infrastructure, transit and transportation — not in green space that is now unserviced and would have to be paved.
Whoever is behind the push for this hospital in this green location needs to justify how its location is in conformity with provincial law. That’s hard to do, unless the plan is to build more subdivisions on the landowner’s property, and make the hospital part of a “settlement area” as the rules require for building hospitals.
Why not put a new hospital where people actually live and work already, instead of allowing a select group of developers to pave Ontario’s Greenbelt and add to sprawl?
There ought to be public conversations about the right place to put a hospital — not shadowy advocacy or edicts based on Premier Ford’s broken promise to protect the Greenbelt. King does need a hospital, but not on the Greenbelt where Ford, Clark and their developer friends think it should go. Mayor Pellegrini should know this and say so.
Salt levels in our freshwater is such a pervasive issue affecting so many lakes that it deserves attention. Canada uses five million tonnes of road salt every year. Once the snow and ice melt the chloride flows into streams, rivers and eventually into our lakes and groundwater. Unfortunately, that chloride will stick around all year, long after winter ends. Researchers have found that some freshwater bodies experience salinity levels that are 25% the concentration of seawater.
At the current rate of increasing salt use and concentration, Lake Simcoe could reach the long-term exposure threshold by 2058, which is 120 mg/L. This is approximately 11 years earlier than previously anticipated by scientists. Despite salt application training and best practices being used more widely than ever, salt levels are on the rise. There is a relationship between the growth of the road network and increases in chloride concentrations in Lake Simcoe.
We know that highways play a part in this nightmare scene. For instance, according to the Lake Simcoe Regional Conservation Authority, prior to the 404 extension being built in 2014, 12% of samples taken from the Maskinonge River (over which the 404 travels) exceeded the chronic (or long term) chloride level. Between 2014 and 2019 that number increased to 84% of samples!
This issue is of real interest to those concerned with the health of Lake Simcoe and the impacts of the Bradford Bypass. Ontario’s fast tracked Environmental Assessment process does not look at the operation of the highway, only its construction, and it does not look at the health of Lake Simcoe, at all. Their solution for dealing with salt contaminated soil is just to remove it. Out of sight out of mind? We should be doing more to reduce the use of salt, and we should seriously consider whether it makes sense to put this highway here, where the salt levels in the East Holland River already exceed the chronic long term exposure limit. (See the next chart!)
Chloride Concentrations in Lake Simcoe Tributaries (rivers that flow into the lake)
Some of the adverse effects of increased chloride concentrations in freshwater include:
Changes to the structure of the lake because salt water is denser than freshwater.
Helping invasive saltwater species to survive in our lakes.
Reducing the abundance and biodiversity of microscopic plants and animals. This has a cascading effect on the rest of the food web.
With less competition from species sensitive to chloride, we will see an increase in mosquitoes.
Exposure to high (acute) concentrations of salt is deadly to fish and amphibians but lower (chronic) concentrations affect how they reproduce, grow, and thrive.
How Salt Affects a Lake Ecosystem
Freshwater in Ontario, including Lake Simcoe, is not being prioritized and protected by our provincial or federal governments. The Province has refused to classify salt as a toxic substance under the Environmental Protection Act. The Federal Minister of Environment and Climate Change could use the Fisheries Act to fight the excessive use of salt because its application and movement into waterways can be toxic to fish if levels are high enough.
There are ways to mitigate and reduce toxic chloride concentrations. According to the Lake Simcoe Conservation Authority many times there is just too much salt being applied. They have noted a drastic reduction in salt used in parking lots following training and education. A common salt alternative is sand, which is widely used in colder climates where salt is ineffective. Additionally, beet juice and brine have been implemented with success in cities like Calgary and Winnipeg.
Recently, I’ve been wondering ‘what motivates people to go that extra mile to make a difference?’ And naturally, I’ve been wondering, how can people sit on their duff as the world burns and our water turns green? If you want to be inspired by a couple of outstanding people who really went that extra mile for the Rescue Lake Simcoe Coalition (RLSC), Bobby Eisenberg and Annabel Slaight, keep reading.
The Rescue Lake Simcoe Coalition was started almost 20 years ago now by some truly remarkable people who made a difference by providing a framework for positive change, and then surrounding themselves with people they respected, and wanted to work with. Two pioneers of our work, Robert (Bobby) Eisenberg, and Annabel Slaight both received one of the greatest acknowledgements of their selfless contributions to the world by being appointed to the Order of Canada, the Governor General’s award! In writing this I discovered that no less than three people who have been on the Board of the RLSC have received the Order of Canada. Wowza! What a legacy! I am really proud to know them and to share with you some of the talent we have had on our team.
What sets these people apart? Let me start with Bobby. This guy is simultaneously one of the friendliest and most tenacious people I know. For Bobby, friendship and loyalty are at the core of everything he does and the way he does it. For instance, we still get together for social visits and reminisce about all the amazing work we have done together: The Lake Simcoe Protection Act (2008), banning corporate contributions to Municipal Election campaigns (2016), and contributing to anti-SLAPP legislation in Ontario in Protection of Public Participation Act, (2015). Whenever we talk, Bob brings up the (dearly departed) gentlemen George Connel (also an Order of Canada recipient) and Jack MacDonald, and my distant relative (and alive) Bob Matthews, all of whom led the Board with dignity, calm, and such grace. The manners and the lack of ego, despite their massive accomplishments, that these men brought to the organization are something to really cherish. Bob always reflects his deep respect for these mens’ intellect, hard work, and friendship. In a word: teamwork.
What these guys had in common was a real clarity of purpose, and absolute reliability. At a time that almost pre-dates the wide use of email and lost links and the chaos that all of that brings, it makes me wonder if we weren’t better off meeting in a room together once a month to talk, be passionate, argue our points, then go away, do our work, and report back, rather than firing off dozens of emails a day.
Being a good friend of mine, Bob has continued to be a supporter of my work at the RLSC even though his focus has shifted to other work, supporting Sistema, a free after-school music and social development program for children living in underserved communities with the end goal of transformative social change. I am needless to say, grateful. It is in part thanks to Bobby that we are offering matching donations in the months of November and December 2022, up to $15,000!
The most astonishing thing to me about Bob is his incredible breadth of talent. Although writing fiction has become a recent focus, his main gig is being a partner at York Heritage Properties; they mostly redevelop urban heritage buildings, like the Carpet Factory in Southwest Toronto, pictured below. He told me a story about him and his then work partner at Intra Urban Properties, at an earlier point in his career, buying the building I later lived in (as a co-op) and deciding that they would not develop the property as had been their intention. Instead, they were moved by the residents’ wish to turn the building into a co-op. They didn’t renovict the tenants. They sold them the building and let the tenants be! These guys seriously have heart. In the context of today’s gong show provincial government, and the development industry’s clear influence on their policy development, it is good to know that there are in fact good developers out there.
Until this point, I haven’t described Bobby’s tenacity. Well. Anyone on the provincial Lake Simcoe Advisory Committee knows Bobby is like a dog with a bone. He was unrelenting in making key points that remain critical today:
1. Phosphorus load measurements in the main lake are not a reflection of the health of the lake; nearshore areas are a mess and show it! The details surrounding the presentation of information are critical.
2. That the actual sources of phosphorus pollution must be identified (ie. agricultural source vs. “tributaries of the lake”, which on their own are not a source of pollution!) You have no idea how hard we had to fight to get that information! But the province finally did it in the Phosphorus Reduction Strategy, 2011.
I believe more people are aware of Annabel Slaight because she has been the main spokesperson, and the driving force, of the Ladies of the Lake since it began in the mid- 2000’s. Annabel was on the Board of the RLSC, not the first, but an early BoD member. Selling a canoe as a fundraiser for the RLSC was considered, and then in typical Annabel style, the lid came off what was possible, and some women decided to do the famous “cheeky but not cheesy” nude calendars in 2006 and 2009. Their runaway success meant the group spun off and spent the $400,000 they earned not with the RLSC, but with their own organization. “The Ladies of the Lake” later merged with Slaight’s Ontario Water Centre, which is now focused on the Clearwater Farm. The lady just does. Not. Give. Up. And for that we thank her.
In recent weeks, with the provincial government attacking environmental protections in ways I have never experienced, we thankfully have some new volunteers stepping up to help the Rescue Lake Simcoe Coalition. It is important that people understand that that is the only way local advocacy efforts can be sustained. The RLSC being still “active” 20 years after it was conceived by Bobby Eisenberg and the other founders is testament to the power of people.
It is clear to me now that the powers of destruction are persistent and well-heeled. Within our network, we have these qualities too. Let’s use them, and live our lives to our highest purpose, to carry on the legacy that people like Bobby started. To remain a force for good, more people need to emulate the grit of the Bobbies and Annabels of the world, roll our sleeves up and get to work.
Are you interested in volunteering? We need the following roles to be filled in 2023 because we do not have the funds to pay someone to perform these roles. If you have experience in these areas put your skills to use while meeting like-minded citizens, dedicated to good deeds.
By Claire Malcolmson with contributions from Leslie Stevens
This month we are telling people stories, because as you likely understand, there is no advocacy for Lake Simcoe without people willing to do it. This is a sad story actually, but we absolutely wanted this man’s amazing story and spirit to be honoured.
Texas Joe Constantine was a RLSC Board member for about a year in 2020. He died on October 25 2022, in the arms of his loving wife, Leslie, who is my second cousin and who I know well through our connection to our family’s cottage property in Innisfil. He and Leslie own the old farmhouse I lived in with my young family in Innisfil for four years.
Texas was only 47 years old when he died of cancer. He did however live one of the fullest, freest and most meaningful lives I have encountered in my time.
As a RLSC Board member he simply offered to help and supported our very boring but necessary communications work. He offered the best help we can get, the “what do you most need help with?” kind of help. Little did I know what an incredible, inventive human Texas was when we started working together.
Soon, I understood the kind of guy he was: In 2020 Leslie and Texas built an ice sailboat and circumnavigated the lake over the course of a winter. The initiative was all theirs, in very typical Leslie and Texas style, and they raised $1000 for RLSC while doing it. Here is a news piece and YouTube link to their initiative.
First leg of the journey! Looking east from DeGrassi Point into Cooks Bay, winter 2020.
Texas lived life with enthusiasm and engagement, pursuing his dreams and supporting his beliefs. He was introduced to environmental activism in his teens, and spent much of his life supporting humanitarian and environmental action and activism. In particular, his long tenure at sea with Greenpeace, which he reports as many of the best times of his life. He dreamed of becoming a pilot, a dream that he made a reality over the past decade, culminating in his ultimate goal of being a pilot at Porter Airlines.
He loved to sail, to fly, to explore caves and mountains, back roads and bogs. He loved to learn new things, and was always working on a project that involved creating something, fixing something, playing at something, or tearing something apart. He was mechanically- and mathematically-minded, and practical in his approach to almost everything.
His friendships were essential to him, and he would make new friends everywhere he went; considering that the only place he says he hasn’t been is Thailand, that means he has friends across the entire globe. These connections to people, and working together for good things, or engaging in ridiculous escapades, or just being happy sharing space and a board game or a movie held immense value to him. Texas left a deep impression on people, and the interactions were always valuable to him.
Over the years, Texas said he had led a very fulfilling life; he didn’t have a long list of things he still wanted to experience or do, and that if he died, he would be satisfied with the life he had lived. When he received his terminal diagnosis, what he felt sad about was the “small stuff”: that he wouldn’t get to rebuild the porch on the Lodge and sit holding Leslie’s hand on the porch swing when they were old; that he wouldn’t get to go to the family gatherings; that he wouldn’t get to sail the trimaran one more time; that he wouldn’t be able to finish fixing the old Ford tractor (again). But he was right. He lived a good life; a fun life; a meaningful life; a life of adventure. Definitely gone too soon, but the time for which we all had him was amazing.
May each of us live lives so rich, meaningful,and fulfilling. Best wishes to all.
It was the end of 2020, an awful year of isolation and disaster all over the world. My contract job was coming to an end and I was having nightmares of not finding another gig. I decided to apply for a Master’s degree. I felt that I had so much more to learn about what sustainability means, and also thought going back to school might put a pause on the whole “becoming an adult” thing I was supposed to be doing.
So here I am, finishing my first year of a Master’s in Environmental Studies, lucky enough to have gotten a summer internship with the Rescue Lake Simcoe Coalition; a charity I never heard of before April of this year. I thought it would be an experience in skills I was already pretty “good” at: communication, outreach, social media. I was hit with a steep learning curve when faced with the challenges that came with working for a grassroots, activist organization.
RLSC is a small organization that runs on volunteer work which meant that I was left to problem solve, and was trusted with the solutions I proposed. Despite the challenges, it was extremely rewarding being responsible for the tasks I’d undertaken, coming up with creative solutions and given freedom to follow through with my ideas.
RLSC should be the first thing that comes up when you google search “small but mighty.” Despite limited funding and resources, RLSC seems to be the loudest in the room when speaking about environmental issues, especially those that impact the watershed.
The Lake Simcoe Protection Act, for those who don’t know, is the strongest watershed-based legislation in Canada! And little RLSC was involved in passing this act and developing its plan. The act was passed in 2008. The act was followed by the Lake Simcoe Protection Plan to implement the protection legislated in the act. The RLSC is still fighting for the Plan to be reviewed and improved. It is important for the health of the lake for communities throughout the watershed to understand the LSPP so that the legislation is upheld and collective pressure is put on the provincial government to review and strengthen the plan.
RLSC is working on expanding and sharing their mission with people who live around the watershed; that includes some of York Region, Durham Region, and Simcoe County. RLSC is improving their reach to new and existing audiences to strengthen their goals of improving Lake Simcoe. That’s where I’ve come in to research innovative ways to engage audiences in our work.
If you’re familiar with the Rescue Lake Simcoe Coalition at all, then you probably know Claire, the Executive Director of RLSC, a quick, dedicated woman who’s last breath will probably be “WE NEED TO RESCUE LAKE SIMCOE!!!” Claire has been running the coalition, going to council meetings, speaking to politicians, leading protests, and unapologetically calling out leaders for their lack of concern about the health of the lake. Claire has also mobilized a force of volunteers who similarly seem to eat, sleep and breathe all things Lake Simcoe.
During several community events, I worked with many volunteers who had a distinct energy to educate and inspire anyone who looked our way. I witnessed Wilma (a long-time volunteer), and Mary Jane, gracefully take on several residents who visited our booth at a community fair to share their “beef” with the coalition. I cowardly watched from the sidelines and listened to their encyclopedia of facts about irresponsible development and water pollution. Wilma and MJ were seriously fulfilling their roles as water defenders. They showed me the importance of knowing your facts and sources and not running away when someone disagrees with you.
It has become clear to me that if I want to pursue a career in environmental outreach, I need to get more comfortable with talking to people who don’t think of the environment the same way I do. This also opened my eyes to what it means to be an activist organization, being center stage at community events and having tough conversations with people who make decisions, whether through their position on council, boards, or through their vote for government.
As an environmental student, it is hard not to feel hopeless at times, constantly discussing the impending impacts of the climate emergency. However, being a part of an activist organization has allowed me to channel my fears and worries into manageable action that can be seen at the local level.
An example of this is helping to campaign against the Bradford Bypass project. Having conversations with community members, working with RLSC’s member groups or other organizations, and intentionally reviewing jargon-filled public reports of the project has actually given me some feeling of hope. I have felt a fulfilling sense of belonging, and being an important part of a large community fighting against this destructive project.
Being a steward to nature does not only mean changing your own behaviours and signing petitions. It also means having difficult, and sometimes scary conversations, to educate and defend the environment that in many ways cannot defend itself. Maybe my individual work has not put a stop to urban sprawl, or reduced phosphorus pollution in the lake, but the feeling that I might have educated a few people on these topics has encouraged me to keep fighting for change.
Congratulations to our friend and volunteer Anna Bourgeois, who has just won a 2022 Healthy Community Award. The Lake Simcoe Region Conservation Authority bestows this award upon individuals and groups whose volunteer work increases community connections, engagement and awareness of issues confronting the health of the Lake Simcoe watershed.
What has Anna done to merit this honour? The list of her ongoing actions is staggering, and is a testament to her refusal to leave the task of “saving the planet” to “someone else.”
Anna is the Director of Concerned Citizens of Ramara; she is both a board member and secretary with both AWARE Simcoe and the Simcoe County Greenbelt Coalition, and she is an extremely active volunteer with Rescue Lake Simcoe Coalition’s Laugh for Lake Simcoe fundraising team. Other organizations with whom she consistently shares his impressive skill set: Miller Quarry Public Engagement Committee; Orillia Water Watchers; Just Recovery Simcoe; Stop the Bradford Bypass; the Green Party of Ontario, and the Green Party of Canada.
Devoted to residents’ right to know whether the local environment and resources might be at risk, Anna scours Ramara Township council meeting agendas for items associated with illegal or questionable soil dumping, zoning bylaw alterations, noise bylaw and gun range infractions, municipal water supply system fragmentation and local quarry interactions such as bylaw compliance, exemptions and amendments–particularly where they might infringe on the health of water and soil.
When folks meet to protect the purest water of the Waverly Highlands and the Elmvale Flow, or to protest the Bradford Bypass and Highway 413, Anna is there.
Always eager to share knowledge and inspire engagement, Anna regularly posts to the Concerned Citizens of Ramara, Simcoe North Green Party and Team Ramara Facebook pages, as well as Twitter.
An acclaimed professional graphic designer, Anna has created—pro bono—graphics for several campaigns and organizations, including Laugh for Lake Simcoe, Stop Sprawl Orillia, AWARE Simcoe, Orillia Water Watchers, Ramara Legacy Alliance, Sustainable Orillia–which included the Orillia Food Map, which helps vulnerable community members access food—and others.
As a farmer, Anna collaborates on decisions related to the Ontario Farmland Trust Conservation Easement Agreement on her and her husband Mike’s farm.
For Anna, environmental stewardship isn’t a sideline; it is a way of life. John F. Kennedy said: “Every person can make a difference, and every person should try.” Anna is the embodiment of that statement, and an amazing role model for all of us who are concerned about the health of the Lake Simcoe watershed and the state of our planet’s ecosystems as a whole.
Summary: The Bradford Bypass is a proposed 16.2 km, 4 – 8 lane highway that would connect Highways 400 and 404 just below Lake Simcoe’s Cooks Bay. The proposed route is just north of Bradford, approximately 100 – 200 m from existing neighbourhoods and parks. It bisects the Holland Marsh Provincially Significant Wetland, proposing to use piers to hold up the bridge across this area. As of September 2022, there is no budget, no technical design drawings, and the studies are incomplete. But the province of Ontario changed its Environmental Assessment regulations and then exempted the Bradford Bypass from the Environmental Assessment process, substituting a streamlined process that identifies the route and allows construction to begin this fall regardless of the outcomes of environmental and traffic studies in progress. Minor changes to the route could occur depending on archaeological studies.
Bradford Bypass highway Draft Environmental Assessment (EA) Proposal was written. Substantially rewritten in 1994 and became legal terms of reference for the current EA Study to this day.
EA finished. Did not consider cumulative effects, climate change, or detail impacts on natural heritage, migratory birds, fisheries, First Nations, or discuss air pollution.
EA approved with conditions including requirements for upgraded studies on archaeological resources, stormwater management, groundwater protection plan, noise, and compliance monitoring.
This EA anticipated severe stormwater and groundwater impacts and adverse effects on fish habitat.
The project didn’t go ahead after the completion of the EA. Reasons include a change in provincial government that enacted major planning and environmental protection legislation: Greenbelt Act & Places to Grow Act. Together they laid the foundation for planning that was aimed at building more compact communities and transit over highways and sprawl.
Lake Simcoe Protection Act passed. Allows for major infrastructure if there is no alternative.
Ontario Liberals decided not to pursue the Bradford Bypass and then did an about-face and included it in the Growth Plan. Still, nothing happened.
Project was revived by the new Progressive Conservative government of Ontario, after nearly 20 years of inactivity on the file, with conditions of the 2002 EA approval not met. Updates to the understanding of the site conditions were supposed to be made every 5 years, and were not.
July 8, 2020
The Government of Ontario proposes to exempt the Bradford Bypass from the conditions of the original EA. The Ministry of Transportation (MTO) and the project consultant team, AECOM, present information about the Bypass to municipalities throughout this time, not mentioning the proposed exemptions or changes to the EA Act. They do not produce side-by-side comparisons of the old and the new process for an EA, so municipalities are led to believe that the studies that will be undertaken will mean something. They don’t. Read the exemption here – Environmental Registry of Ontario posting.
February 3, 2021
First attempt at a Federal Impact Assessment. Rescue Lake Simcoe Coalition and Simcoe County Greenbelt Coalition, being represented by Ecojustice, request a Federal Impact Assessment of the project. The request raises the Project’s potential to cause adverse effects on areas of federal jurisdiction and public concerns related to those effects. It also raises concerns that the adequacy of the provincial environmental assessment process to address those issues, particularly in light of Ontario’s proposed exemption to the Environmental Assessment Act. This request is supported by a coalition of 21 environmental groups, including Ontario Nature, Wilderness Committee, Environmental Defence and many local groups.
May 3, 2021
Minister of Environment and Climate Change, Hon. Jonathan Wilkinson decides not to designate the Project for a Federal Impact Assessment. Minister’s response available here.
It also means they exempted this project from completing the conditions in the conditional approval from 2002. They will proceed without evaluating health impacts, climate change, and the impact on Lake Simcoe. Nothing in the studies they are doing will affect the route location, except for some minor adjustments in the route to avoid archaeological sites and a golf course.
Public opinion poll regarding the Bradford Bypass highway reveals reversal of earlier apparent public support for the Bypass from a poll conducted by Bradford West Gwillimbury. The 2021 OraclePoll, commissioned by Lake Simcoe Watch, says: Opposition to the highway is 48%; 29% it and 23% are unsure. This after the following truthful statement was presented to those polled: “The government of Ontario is planning to build a 16 km, four lane Holland Marsh Highway to link Highways 400 and 404. The proposed highway would increase phosphorous and road salt pollution to Lake Simcoe, endanger fish spawning habitat, eliminate 23 acres of provincially significant wetland, and eliminate 81 acres of wildlife habitat. Do you support construction of this highway?”
November 9, 2021
East Gwillimbury-based Forbid Roads Over Green Spaces (FROGS) makes a second Impact Assessment designation request to the Federal Minister of Environment, now Hon. Steven Guilbeault, with two other community groups, Concerned Citizens of King Township and Stop the Bradford Bypass. The second request provided information about the way in which the exemption regulation changed the regulatory environment for the Project, and detailed increases in public concerns. It also provided additional information about the Project’s potential adverse effects within federal jurisdiction, including on fish habitat and greenhouse gas emissions.
Nov 13, 2021
Day of Action protest against the Bypass in front of Minister of Transportation and York Simcoe MPP Hon. Caroline Mulroney’s office.
May – December 2021
Seven Lake Simcoe watershed municipalities pass resolutions asking for better oversight of Bradford Bypass highway, an Impact Assessment, or impacts to Lake Simcoe studied. Read details in the December 9, 2021 update letter to Minister Guilbeault.
December 8, 2021
63 environmental groups representing tens of thousands of Ontarians write to the Minister to support the Second Request.
AECOM (consultant for MTO on this project) identifies that over 80 square metres of fish habitat would have to be permanently removed as a result of “early works” near Yonge street and Bradford’s 8th Line that would impact an un-named tributary containing direct warmwater fish habitat to the east of Yonge street. They suggest that MTO ask the Department of Fisheries and Oceans Canada (DFO) if authorizations were required for the Bradford Bypass “early works” under the Fisheries Act.
Coalition of environmental groups write to the Minister of Fisheries and Oceans Canada to request that they do their job of protecting fish, and provide or deny, as appropriate, the permits needed for the work. Earlier, DFO staff said they needed to evaluate the impact of the entire project, but in the case of the Bradford Bypass, the provincial exemption regulation allows the project to be carved into smaller pieces, therefore allowing the project to proceed piecemeal, without an evaluation of the entire project. Ontario Federation of Anglers and Hunters also wrote to the MTO / AECOM team to suggest that DFO oversight of this was appropriate.
March 14, 2022
Lawsuit launched against Minister of Environment and Climate Change Hon. Steven Guilbeault, questioning whether he followed the Impact Assessment Act in his decision to not reconsider the request for a Federal Impact Assessment. Appellants are Rescue Lake Simcoe Coalition, Forbid Roads Over Green Spaces (FROGS), Ontario Nature, Wildlands League, Western Canada Wilderness Committee, Environmental Defence, and Earthtroots. “There are errors of fact in the Minister’s decision that cannot be allowed to go unchallenged” says Tim Gray of Environmental Defence. “For the sake of Canada’s environment and the communities dependent on it, we must make sure that destructive projects, such as bulldozing a super-highway through one of Ontario’s largest wetlands, receive a proper and thorough review.” National Observer article: Environmental groups file lawsuit against federal minister over Bradford Bypass.
March 23, 2022
DFO provides a “letter of advice” to the MTO Bypass team allowing for the removal of 80 square metres of fish habitat for the “early works” portion of the Bradford Bypass without a permit. It says effectively, (paraphrasing) ‘Go ahead. Use the following techniques to avoid harming or destroying fish habitat. It’s a self assessment system. Notify the DFO if you are in violation of the rules and if you are destroying fish habitat.’ (The request from the Bypass team clearly indicated that they were removing 80 sq meters of fish habitat.) This is a real head-scratcher.
April 23, 2022
Yours To Protect Earth Day protest against the Bradford Bypass.
DFO responds to a formal petition, sent by a member of the Stop the Bradford Bypass team, which asked many specific questions. The response indicated that there were never any instances between 2001 and 2022 where a Fisheries Act authorization or Species At Risk Act (SARA) permit was formally denied, or where a letter of advice was refused. The response also confirms that MTO never applied to DFO for any authorizations for any of the water crossings associated with the 404 extension from Green Lane to Ravenshoe road and had been permitted to self-assess any impacts on fish and fish habitat under a memorandum of understanding.
August 16, 2022
Environmental Conditions Report released and public comments are due one month later. Some studies that one would expect to be in an environmental conditions report are missing. Some still have not been updated in the field. There is no discussion of climate change or induced demand. The report only references greenhouse gas emissions in the context of an upcoming air quality assessment. There is no assessment of chloride (salt) or phosphorus impacts, or impacts to Lake Simcoe. The province requires the project proponents to complete a stormwater management plan, but there appears to be no requirement to follow it.
Traffic impacts: The MTO itself identifies the “Adequacy of facility to accommodate future travel demand” as an issue. The response is: “No commitments are identified by the proponent; however, traffic studies involving traffic modeling and analysis is being undertaken through Preliminary Design.” The modeling is not publicly available. Claims that the highway will improve local traffic are unsubstantiated because the highway will fill up with traffic quickly. This is “induced demand”. The ECR indicates that the project is being planned for 2 lanes each way but anticipates it expanding to 4 lanes each way (p. 315).
Human health impacts: The ECR identifies twenty “sensitive receptors” already in the Air Quality study area: 5 retirement homes, 6 daycares, 9 schools.
There are also nine planned “possible” sensitive receptors in Bradford West Gwillimbury within the Air Quality study area, including a new Simcoe County District School Board school. Henderson municipal park with soccer fields is also in the study area. (P. 195)
November 2, 2022
Hearing regarding the lawsuit / Judicial Review of the Minister of Environment and Climate Change Canada not addressing the second request for a Federal Impact Assessment for this case.
Anticipated next steps:
Final Environmental Conditions Report (ECR) for Bradford Bypass Project will be released on the project website. No date given.
The Preliminary Design refinements, alternatives, and the evaluation, will be presented at Public Information Centre #2 in the fall of 2022.
Plan to start construction on bridge at Yonge St. (County Road 4) just north of Bradford. There are no detailed engineered drawings, no budget and the route details are not complete. While the timing is meant to coordinate construction with the widening of Yonge St at this location, critics argue that building the ‘early works’ bridge at this stage in the process is premature and establishes the route, regardless of the outcomes of studies underway.
End of 2022, early 2023
Draft Environmental Impact Assessment Report (EIAR)will be available for review.
Selection of Preferred Alternative for the Bradford Bypass Project (minor route changes.)
Final Environmental Impact Assessment Report
Preliminary design complete
The Bradford Bypass’ consultant team’s schedule can be found here.
58% of the Lake Simcoe watershed’s land is protected by the Greenbelt and its policies, and for this we are grateful.However, Lake Simcoe’s western shorelines in Simcoe County are not in the Greenbelt, nor is the rest of the County. This has contributed to leapfrog development over the Greenbelt and Oak Ridges Moraine and into Simcoe County, particularly in Barrie, Bradford West Gwillimbury, Innisfil, and New Tecumseth.
For example, sprawl removed 37,000 acres of natural and semi-natural space in Barrie between 1971 and 2011.  Between 2006 and 2012, Simcoe County zoned over 32,000 acres of farmland and natural space to sprawl.  Without protective policies like the Greenbelt to keep farmland in production and greenspace preserved, our natural spaces will be under constant threat to urbanization. Case in point, during Simcoe County’s Municipal Comprehensive Review consultation, the County received 79 developer requests to sprawl outside existing boundaries for a potential loss of almost 16,000 acres. 
Moreover, Simcoe County is highly reliant on groundwater for both private and municipal wells. This abundance of water is made possible by our recharge areas, wetlands and aquifers that pepper the region. Unfortunately, these places are also prime areas for new development, aggregate activity, and infrastructure such as highways. In 2006, the Intergovernmental Action Report for Simcoe County saw the threat that rampant urbanization was going to have on Simcoe’s water supply stating, “A number of the municipalities in the study area rely on inland water systems which have been demonstrated to be under strain (for example, the Lake Simcoe watershed has known issues as a result of Phosphorus loadings). Without intervening action, these watersheds’ available potable water and aquaculture are threatened.” 
Despite 15 years of requests to add Simcoe County to the Greenbelt, this has not happened. Meanwhile, we lose and destroy land that purifies and stores our drinking water and prevents flooding.
Public support for the Greenbelt translated into a provincial promise to protect it, which the province has upheld so far. But it’s tenuous. There have been motions from the York Region Councils of Markham  and Vaughan  to either downgrade protections of Greenbelt land next to existing communities or to develop in the Greenbelt.
The province has put the 830-acre North Gwillimbury Forest into the hands of the Lake Simcoe Region Conservation Authority, in the Greenbelt within the lake-side municipality of Georgina.  This is a welcome move, but it did not add any land to Southern Ontario’s protected areas. The forest was protected through a legal battle fought by resident and activist Jack Gibbons, who created the North Gwillimbury Forest Alliance, and fundraised more than $500,000 to fight the Town of Georgina, the Region of York and the LSRCA until it was ultimately protected. The credit goes to Jack, generous donors, and the citizens who insisted that a Provincially Significant Wetland should be protected.
Finally, the province had some great ideas for Greenbelt expansion, which would have protected the Paris-Galt Moraine, a vulnerable aquifer in the Waterloo area, among other things. Unfortunately, the only idea they acted on was to extend the Greenbelt into already protected urban river valleys. Critics said in a media statement: “Proposed Provincial Greenbelt “expansion” does nothing for farmland and natural areas that need protection while new highways threaten the existing Greenbelt.”  It could be described as more of a re-branding of protected greenspace than meaningful policy change.
Thanks to the Lake Simcoe Protection Act (2008) and Plan (2009) the Lake Simcoe watershed is subject to some of Ontario’s strongest environmental policies, meant to protect its water for all its inhabitants, human and non, and the sensitive cold-water fishery, an economic driver in the area. All of the province’s 2018 – 2022 communications about Lake Simcoe have been rather rosy.  This is not unique to this government, but it is greenwashing, and it worries us.
Lake Simcoe Protection Plan review
The Lake Simcoe Protection Act requires the Minister of Environment, Conservation and Parks to review the Lake Simcoe Protection Plan every ten years to determine if its targets are being met, and whether its policies need to change.
Although it should have started in 2019, the province launched the Lake Simcoe Protection Plan review in late December 2020 and had finished consultation by mid-2021.  Despite the Lake Simcoe Protection Plan review being complete, the province has been silent on the results of the Lake Simcoe Protection Plan review for more than a year while it “sits on the Minister’s desk” for a decision.
Why not release its findings? We worry it is because the province plans to weaken protection in favour of development. In effect, by being silent on the coordination of sewage treatment plant allocations that would flow from the watershed’s population explosion outlined in A Place to Grow, 2020, that is what the province is already doing.
The Rescue Lake Simcoe Coalition has been sounding the alarm about the Lake Simcoe Protection Plan’s 40% “High Quality Natural Cover” target, which is a target without any implementation policies.
In addition to years of letters, research, mapping, reporting, policy analysis and briefs,  the we suggested that the province could use the Municipal Comprehensive Review’s provincial Natural Heritage System mapping process to bring us closer to this target.  They said, no thanks, and cc’d the Minister of Municipal Affairs and Housing on their reply to the Coalition.
With the Upper York Sewage Solution (UYSS), York Region Council is poised—dangerously—to encourage the development of a new sewage treatment plant (STP) in Northern York Region. The UYSS will add Phosphorus (P), a fertilizer and pollutant that will harm fisheries, to Lake Simcoe.
York Region recommends that the STP’s Phosphorus pollution be offset by projects that remove Phosphorus from the water, specifically agricultural and stormwater infrastructure improvements. However, there is little evidence that offsets from agricultural projects can be relied on as long-term P offsets. The reduction in family farms and the related increase in corporate-owned farms (mainly land speculators) also means 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 UYSS.
The problem started in the 1990’s, when development was approved in Northern York Region without water and wastewater servicing. The original plan to send it south to Lake Ontario at Durham region’s Duffins Creek wastewater plant was thwarted in 2010 when the provincial government of the day supported an examination of a Lake Simcoe “solution.” This was odd, given that the same government introduced the Lake Simcoe Protection Act in 2008, with a prohibition on new sewage treatment plants as a way to control the extent and impact of new development in the watershed.
It is possible that both Lake Simcoe and the Lake Ontario Duffins outlets are being considered to accommodate all the growth planned. It is impossible to know exactly what is happening since the province had the affected regions sign Non-Disclosure Agreements (never a good sign) regarding their conversations about the UYSS.
It has been speculated that the province passed legislation to prohibit the approval of the UYSS to shield themselves from legal liability stemming from development hold-ups due to the lack of servicing.
Affected municipalities and developers are understandably tired of this game. We are concerned that the province will approve this at some point.
The one positive piece that came from this is that in response to public and municipalpressure,  the province agreed to pay the balance of the cost of a Phosphorus Recycling Facility on the Holland River, which could remove 2.5 tonnes of P per year from that river as it flows into Lake Simcoe.  This would be the single largest P reduction project completed at Lake Simcoe!
This Phosphorus Recycling Facility was first proposed as a P offset for the UYSS. The federal government promised $16 million toward the facility’s construction in 2020.  York Region wants the UYSS, and they want the Phosphorus Recycling Facility to be one of its offsets. Other Lake Simcoe municipalities want P reduction to come at this scale, regardless of the outcome of the UYSS. Indeed, their municipal motions requested that:
… York Region, the Government of Canada and the Province of Ontario work collaboratively to move the Holland Marsh Polder Phosphorous Recycling Facility forward notwithstanding the “paused” status of the broader Upper York Sewage Solutions Project, including proceeding to an Environmental Assessment for the Facility commencing in 2021…
The provincial funding announcement did not include any reference to this facility’s connection to the UYSS. We hope that they will decide against the UYSS; but if they do approve it, the province and York Region must develop more enduring and measurable offsets like the Phosphorus Recycling Facility.