**Updated November 25, 2021**
Please provide your feedback to Simcoe County by December 3rd about the changes proposed to the province’s Natural Heritage System (NHS). We’ve created this guide to help you.
WHY? In 2008 all parties unanimously supported the passage of the Lake Simcoe Protection Plan. It is now in effect but more needs to be done to achieve its objectives. For instance, the Lake Simcoe Protection Plan identifies that 40% “high quality natural cover” (HQNC) is needed to protect and restore the watershed’s ecological health. A low estimate is that hundreds of thousands of dollars have been spent identifying and mapping these areas. We want them protected, not just studied!
Putting these features in the province’s new Natural Heritage System will give some green spaces MORE policy protection than they now receive. But Simcoe County has recommended more areas get removed from the province’s Natural Heritage System map than we think the province’s criteria and laws recommend. For example, they have taken out registered plans of subdivision from the NHS. But some of those won’t get developed for 30+ years, if ever. We think those should remain as the province mapped them, IN the Natural Heritage System.
CLICK ON A HOTSPOT BELOW TO SEE DETAILED MAPS AND BRIEF CONCERNS.
Green indicates the province mapped it as part of the Natural Heritage System. Red means it is proposed to be taken out. Blue means additions to the NHS.
Right-click on the small maps that pop up above to zoom in, or download this map and find the tile for your location.
WRITING YOUR SUBMISSION: WHAT TO SAY & HOW TO SAY IT
Use the County’s form, and don’t give up! Despite appearances, it is not just for developers to use. Tips for specific questions are below.
**Please only submit one form.
Or email email@example.com.
***Comments must be received by 4:30 pm on December 03, 2021
Question 3. Subject Lands (ARN) Area Roll Number (optional). Find them here.
If you don’t have the roll number or locates exactly, provide an address for the property you are referring to, or many addresses, or road intersection, or the tile number from the 87-page map below. Tile numbers are listed below for each area of concern.
Question 9. Which criteria for refinement applies to your property? Check all that apply.
Do not be deterred – this is not just about your property. None of the options really apply. Instead, fill out the field – Other – and say “Mapped areas of high quality natural cover should be included in the NHS” or something similar.
Question 10. Describe the area or natural feature on your property which you would like refined and provide the reason(s) for the refinement.
Insert all or part of the following text depending on your area of concern.
Big Bay Point: Tiles 28 & 29
Most of Big Bay Point was mapped and identified as “High Quality Natural Cover” by the province of Ontario in 2011; the province found that the BBP area was worthy of inclusion in the NHS. Any components of the Point that are not approved plans of subdivision must be included in the Natural Heritage System. There is no guidance in the province’s NHS Technical Criteria that suggests that registered plans of subdivision should be removed from the NHS.
Additional details on BBP locations of concern:
- Two areas north shore of BBP, on the edge of Barrie: Both areas are mapped as Significant Woodlands in Innisfil Natural Heritage Discussion paper Final, pg. 14. North South Environmental. These are in the High Quality Natural Cover map from the province. Indicated as “shoreline residential” with Natural Heritage overlay on Innisfil OP 2017 Land Use Schedule. Not in a settlement area.
- Area 1 – west side – 3655 20 Sideroad, Innisfil; 3699 20 Sideroad, Innisfil, 3718 Fairway Road, Innisfil, 1344 Robinson Place, Innisfil, over to roll # 431601005411070, All of Longwood road, down to Big Bay Point rd. 3710 Strathallan Woods Lane South, Innisfil, lands southwest of Longwood, to Stathallen woods. As a whole these are all large enough to keep in the NHS.
- Area 2 – east side – the area between the Silverbirch and Whitecap Dr subdivision, and the next NHS area. Roughly from 1215 Shoreview Drive, Innisfil on the west end of this section, to along Shoreview Dr., to Guest Rd – hard to believe these are less than 50% forested. These should remain in the NHS.
- Friday Harbour Golf Course – put it back IN the NHS since it is large, not a subdivision, has some natural cover and could have more, and is part of a “high quality natural cover” area
- Church compound – 3857 30 Sideroad, Innisfil. Currently a collection of cabins, but is not a subdivision. Would like as much as possible to remain in the NHS.
- Crescent Harbour, South corner – landowner starting to alter landscape, may be looking to build. Crescent Harbour Rd (titled Block Plan-area and shoreline highlighted) and also Plans 675 from 1923 and Plan 1016 from 1951 that confirm the designation as a subdivision. It has not been developed.
- Leonard’s beach wetland- make sure this remains IN the NHS
Gilford: Tile 22
- 1284 Shore Acres Drive, Innisfil. Roll # 431601000400200 Large “unevaluated” wetland proposed to be removed – this must be protected in the NHS. It borders a large privately held conservation area at DeGrassi Point, and abuts the historic Walker Farm, a heritage site, and helps to reduce flooding in Gilford which is already a problem. It “…has been a draft plan of subdivision for executive estates since around 1986” according to the local Councillor. It is included as “estate residential” in Innisfil OP 2005 Land Use Schedule. In the 2017 OP it is not in the Gilford settlement area boundary.
Oro-Medonte: Tiles 36, 37 & 48
Almost the entire Oro Medonte shoreline is identified by the province as High Quality Natural Cover. 8 Mile Point has a conservation area that should be included in the NHS. Only remove the built-up areas that are approved plans of subdivision. There is no guidance in the province’s NHS Technical Criteria that suggests that registered plans of subdivision should be removed from the NHS.
Additional details on Oro-Medonte locations of concern:
- 8 Mile Point
- Has a conservation area that should be included in the NHS. They did not request that this conservation area be removed from the NHS.
- Just north of 2880 Lakeshore Rd E is the Carthew Bay Wetland. Roll #434603 001 206 500. Take care not to remove this from the NHS, and only take out the housing on Lakeshore.
- 2553, 2501, 2461 Lakeshore Rd E – these are large woodlands and should not be removed from the NHS.
- 820 Memorial Ave. Subdivision between Woodland Dr and Memorial Ace on outskirts of Orillia. Shoreline wetland must be protected.
- Roll # 434603001213860 – shoreline habitat with no road access. Keep in NHS. Just west of Line 15 S.
- Just north of 538 Line 12 South, Oro-Medonte, NHS wooded area should remain in NHS. Roll # 434 60106 1044300
- 16 Taras Boulevard. Held by “Ukrainian Park”. Appear to be looking for Zoning change, from EP2 to EP1 for seasonal trailer and or cabins. ZBA 10 – but no application – This is currently forested, should remain so, is in the HQNC area mapped by the province. Does not appear to be “community area” in the Simcoe County GIS.
UCCI / Greenwood Forest Road – Registered Plan 51M-187, Block 43
– Residents are opposing the development; it’s a significant woodland connected to the NHS; it is mapped by the province as an area of High Quality Natural Cover; it should not be removed from the NHS
– Not proposed as a subdivision, but it meets the criteria of a subdivision. Therefore there is no registered plan of subdivision.
– The proposed 10 proposed UCCI development lots would have these approximate addresses:
– proposed lot 9 lots on Greenwood Forest Road attached would be approximately 30 Greenwood Forest Rd (lot 9 attached) thru to lot 2 attached would be approximately 60 Greenwood Forest Road
– the one lot on Windfields (lot 1) that are situated directly beside the cold water creek would be approximately 23 or 25 Windfield Dr West
– the developer UCCI has submitted to Township of Oro Medonte in June 2020 this request:
– Applications 2020-B-04 to 2020-B-12 and Notice of Public Meeting Zoning By-law Amendment (“ZBA”) Application 2020-ZBA-05, for the lands described as Registered Plan 51M-187, Block 43, in the Township of Oro-Medonte, County of Simcoe.
– it is under consideration and not yet approved.
– 691 LINE 9 SOUTH, should remain in NHS, not developed. May be part of the same proposal.
– Assessment # 434601000830000, just east of line 5, also unsubdivided, forested, should remain in NHS. 21 Windfields Dr.
- Near Lakeshore E and Orillia St, West of Line 7, just east of where line 8 would be. Roll # 434601000955002, 434601000955001, 434601000955000, 434601000954904, 434601000954911, 434601000954912 undeveloped subdivision contiguous with NHS, keep in NHS.
- Red removal outline on water – is this to remove water rights? Close to Line 7, 131 Lakeshore Rd. E.
- Roll # 434601000935500 and 118 Lakeshore Road West, Oro-Medonte – super rare undeveloped shoreline lots – this must not be removed from the NHS. This is a common Beach property for community park! This is connected to the north to the NHS and HQNC.
- Line 2 area – Roll # 434601000711100 “Shanty Bay Church Woods”. Seriously people. This was saved BY THE COMMUNITY, BY RESCUE LAKE SIMCOE COALITION DIRECTOR TIM CROOKS. RIP. This must stay. It is protected by a covenant with the Couchiching Conservancy.
Ramara: Tile 50
There should be a buffer on the north side of the Canal Lake along the Trent-Severn Waterway abutting the Greenbelt. Ensure that all of the province’s High Quality Natural Cover is included in the province’s NHS. Only remove the built-up areas that are approved plans of subdivision. There is no guidance in the province’s NHS Technical Criteria that suggests that registered plans of subdivision should be removed from the NHS.
GENERAL COMMENTS ABOUT SIMCOE COUNTY’S NATURAL HERITAGE SYSTEM MAPPING
- There is a challenge acknowledged, and identified in the province’s NHS technical guidance, around the protection of NH in a highly fragmented landscape. That defines the Lake Simcoe watershed and Innisfil in particular. This guidance recommends the protection of smaller patches in fragmented landscapes. Thus I am asking that North South Environmental, then Simcoe County and finally the Ministry of Environment, Conservation and Parks ensure that no small patches of natural cover that are close to areas of “high quality natural cover” are removed from the NHS.
- Refinements of NHS mapping must aim for a net increase in protected NHS lands and must capture the entirety of all local PSWs and locally significant wetlands as this natural infrastructure is integral to climate adaptation and mitigation. These are also goals of the Lake Simcoe Protection Plan. More specifically I recommend these targets:
- Forest cover: 50% forest cover or more of the watershed is likely to support most potential species,and healthy aquatic systems. Simcoe County has 22%, but is losing forest cover.
- Wetlands: The greater of (a) 10% of each major watershed and 6% of each subwatershed, or (b) 40% of the historic watershed wetland coverage, should be protected and restored, and no net loss of wetlands. Simcoe County has 14% wetland cover based on our analysis, and approximately half of its historic wetland cover. Simcoe County is losing wetlands.
- Achieve the LSPP’s 40% High Quality Natural Cover target: The NHS refinement opportunity must result in the protection of all mapped High Quality Natural Cover in the Simcoe County portion of Lake Simcoe watershed. The maps have been available on LIO since 2011, and can also be found here along with the technical guidance for identifying these features.
- I support the inclusion of the LSRCA’s Natural Heritage System Restoration Strategy recommended areas for an NHS, and the inclusion of the LSRCA’s recommended areas for restoration in the SC NHS.
- Registered plans of subdivision that were not brought into the settlement area boundary by July 1, 2017 or that are not going to be developed with the 2022 MCR updates to 2051 should remain in the provincial NHS. As per the Growth Plan policies, if they are not contiguous with existing settlement area boundaries there is no justification at this time for their removal from the NHS as they should not be approved for development. See Growth Plan policy 18.104.22.168. and 22.214.171.124
- The MNRF has mapped all Lake Simcoe watershed wetlands. It is up to the County to now apply appropriate protection through this process. SC mapping does not include all mapped wetlands.
WHAT HAPPENS NEXT?
Consultants and County planners review public comments, and propose a final NHS map.
Municipalities have until January 12, 2022 to provide comments and feedback to the County. A report will go to County Council for approval likely in Jan or Feb. Then to the Province for approval. We have been told that public comments will all in be included in the public report. We have also been told that questions will be answered at one time, and that time is not now.
WATCH FOR THIS
Here are some recommendations or statements from North South Environmental’s Review and Refinements to the Growth Plan’s NHS that we will expect to see in Simcoe County’s OP, as they support the County’s decision to remove registered plans of subdivision from the NHS:
“It is anticipated that the County Official Plan will require that all draft approvals have lapsing dates and will include policies that indicate that when determining whether a draft approval should be extended for lapsing draft plans of subdivision, the policies of the Growth Plan must be considered in the development review process.” (p 12)
“…municipalities may refine the NHS for the Growth plan at the time of initial implementation in their official plans.” (p 8) so there could be opportunities for improvements and removals later on in your municipality.
“In some cases, portions of registered Plans of Subdivision remain undeveloped and there are portions of key natural heritage features and key hydrologic features located within these subdivisions; these key natural heritage features and key hydrologic features are currently protected by in-effect zoning and Official Plan designations and relevant policies. It is anticipated that the County Official Plan will include policies that direct the local municipalities to establish appropriate policies in their Official Plans that control how development and redevelopment occurs in these subdivisions.” (p 11)
Simcoe County is recommending removing 7000 sites from the NHS where there are “minor discrepancies” in mapping of areas less than 1 hectare. Rationale is ease of administration. We need to respond to this approach. I think we should use the province’s Lake Simcoe High Quality Natural Cover map as the rationale for keeping some in the NHS mapping. (p. 21)
- Refined detailed Simcoe County draft NHS map – 87 pages
- Simcoe County Natural Heritage System page for the Municipal Comprehensive Review
- Provincial criteria for the addition and removal of NHS
A Place to Grow Act 2020
“Other implementation” policy 126.96.36.199
If a plan of subdivision or part thereof has been registered for eight years or more and does not meet the growth management objectives of this Plan, municipalities are encouraged to use their authority under subsection 50(4) of the Planning Act to deem it not to be a registered plan of subdivision and, where appropriate, amend site-specific designations and zoning accordingly.