Learn about a fascinating historic, cultural heritage site, its spiritual connection to First Nations, its central role in Indigenous and colonial activities between the Lower and Upper Great Lakes, and its critical role in the survival of a nation.
On the East Holland River in the Lake Simcoe watershed, it had many names, but today this place that shaped the province is known as the Lower Landing.
The Bradford Bypass threatens to obliterate it.
Find out the history hiding in plain sight and what we can do about it in a time of reconciliation.
Facilitated by Claire Malcolmson, Executive Director, Rescue Lake Simcoe Coalition
Intro by Bill Foster, Chair, Forbid Roads Over Greenspaces
With presentations by:
Roddy Assance, Great grandson of Chief Assance who led his people to Christian Island after the forced relocation away from Coldwater
Leland Porte, member Chippewas of Georgina Island, avid fisherman and family cook. Father of 4 including two new twin boys. Knows Lake Simcoe or Ahunyung like his forefathers did.
Cynthia Wesley Esquimaux, Georgina Island First Nations member
Becky Big Canoe, Georgina Island First Nations member, Chair, Water is Life Coalition for Water Justice
Bert Duclos, Cultural Heritage Consultant, local historian
*If you can’t come to the April 18th webinar about the Lower Landing but you may be interested in attending a Townhall about the Bradford Bypass please add your email here and we’ll be in touch when we have Townhall dates.
Rescue Lake Simcoe Coalition will update you about the health of Lake Simcoe, what governments are and are not doing about it, and our response. Learn how you can engage in supporting Lake Simcoe as a property owner, cottager, resident, tourist or activist. Q&A to follow presentations.
Register for this virtual discussion in advance using the link below:
Our educational program has been accepted by the Simcoe County District Schoolboard, and we have three days of educational programming planned at the Barrie Public Library for kids from grade 4 to 6!
The Rescue Lake Simcoe Coalition invites 9-12-year-olds with their caregiver to participate in a 3-day outdoor exploration of Lake Simcoe and its watershed. This program will be taking place at the Kiwannis Club Pavillion
Activities will include:
• investigating plants and animals along the shoreline and in the river
Alessia along with volunteers from Drawdown at the Aurora Farmers Market, Summer 2022.
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.
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.
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.
1993
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.
1997
EA finished. Did not consider cumulative effects, climate change, or detail impacts on natural heritage, migratory birds, fisheries, First Nations, or discuss air pollution.
2002
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.
2005
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.
2008
Lake Simcoe Protection Act passed. Allows for major infrastructure if there is no alternative.
2017
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.
2018
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.
Proposed map of the Bradford Bypass, from the Ministry of Transportation.
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.
October 31, 2021
The Narwhal’s Emma McIntosh and Toronto Star investigative journalist Sheila Wang release a damning story, including details of plans to toll the highway, that the Bypass route today received the worst score for environmental impact compared to other bypass options in the area, in contrast to government claims, and that it would need to be expanded to 6 lanes by 2041. Read the Toronto Star: What the Ford Government Hasn’t Told you Its Next Controversial Highway Project.
November 2021
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.
December 2021
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.
May 2022
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.
Fall 2022
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.)
Early 2023
Final Environmental Impact Assessment Report
Preliminary design complete
The Bradford Bypass’ consultant team’s schedule can be found here.
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. [28] 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. [29] 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, [30] 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. [31] They said, no thanks, and cc’d the Minister of Municipal Affairs and Housing on their reply to the Coalition.
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.
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 Label
Small legend text
Definition
Examples of permitted activities
1. BEST POLICY PROTECT- ION
These 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- ION
These 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 POLICY
These 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.
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:
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.
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.
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.
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.
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Both the municipal staff reports on the LSPP and the RLSC comments submitted to municipalities can be accessed here.
If you really want to do the province’s survey we have suggested answers for some of the questions, here:
Q. 2. What do you think about the current policies in the Lake Simcoe Protection Plan?
Choose OTHER and add: I think the policies of the Lake Simcoe Protection Plan need to be implemented and financially resourced.
Q. 5. Which of the following policy areas do you think need improvement to better protect the health of the Lake Simcoe watershed? Rank them in order of importance, with 1 being the most important to improve and 10 being the least important to improve.
1. Protecting natural areas or features such as wetlands and forest cover
2. Improving development practices (such as site alteration or resource extraction)
3. Improving municipal infrastructure (such as stormwater ponds and sewage plants)
4. Encouraging agricultural stewardship of the environment
Choose Other and add: Reduce Phosphorus loading.
Q. 6. Please share any details on the policy areas you identified as most important.
Reach Phosphorus reduction target: Consult widely then revise the Lake Simcoe Phosphorus Reduction Strategy to make it actionable, with interim targets and funding solutions for each sector. Maintain the prohibition on new Sewage Treatment Plants discharging to Lake Simcoe.
Strengthen Natural Heritage policy: The LSPP has a target of 40% high quality natural cover (HQNC) but there are no policies to achieve the target. 28% of the watershed is “high quality natural cover” but only half of that is well protected by provincial policies. Achieving natural heritage targets can be improved by focusing research and analysis on the land around the areas that qualify as high quality natural cover but are not well protected by policy.
Increase policy protections, prohibiting site alteration and development, for these unprotected or somewhat protected areas, to protect all of the High Quality Natural Cover that we have.
Focus Traditional Ecological Knowledge study, restoration, and land trust property acquisition efforts around those areas that are HQNC but not protected and areas that are almost big enough to qualify as HQNC (25 hectares plus).
The Province must review Official Plans for conformity to the Lake Simcoe Protection Plan, and specifically to the technical Natural Heritage guidelines for the Lake Simcoe watershed.
Development practices: The results of the Phosphorus Offset Program must be analyzed to determine how well the remediation actions (AKA Best Management Practices) are working, and to determine how long the offsets last. Consider strengthening development offsets to achieve Phosphorus reduction targets.
Improving municipal infrastructure: Financially support the improvement of ineffective or absent municipal stormwater facilities.
Give the LSRCA all the powers it had before December 2020. Deny the use of Minister’s Zoning Orders in the Lake Simcoe watershed, particularly if Natural Heritage is affected. Disable the ability of the Minister to override science based decisions of the Conservation Authority in the Lake Simcoe watershed.
Agriculture: Pay farmers for agricultural riparian / shoreline areas planting and rehabilitation. Maintain / fund programs that assist in reducing fertilizer application, and no-till practices.
Q. 7. Are there new policy areas that we should consider?
Choose Yes. Please provide details:
Determine cost of achieving the phosphorus reduction target, and allow development cost charges for new developments in the Lake Simcoe watershed to pay for the remediation of the lake. Amend the Development Charges Act to allow municipalities to recover 100% of their additional infrastructure costs to service new residential and commercial projects from their developers.
Q. 8. Do you have any ideas to share with us about how the province along with its partners can implement the Lake Simcoe Protection Plan more consistently and effectively?
Review all OPs for conformity to LSPP, and make the results and recommendations public.
Develop subwatershed targets and aggressive timelines for achieving Natural Heritage targets. Work with municipalities, Conservation Authorities and land trusts to achieve them.
Protect wetlands and wetland complexes of all sizes in all situations.
Have the Lake Simcoe Region Conservation Authority (LSRCA) review all development permit applications, as per their pre-December 2020 powers. Make Ramara a member of the LSRCA.
Only permit new development where municipal water and sewer servicing allocation exists, where an assessment of cumulative impacts determines that there will be a net benefit to water quality, and where the development will reduce phosphorus loads to the lake, from both sewage and stormwater.
Do a 360 review of Innisfil’s Our Shore policy (with affected members of the public); Develop a shoreline policy for all municipalities.
Determine cost of achieving the phosphorus reduction target, and assign an increased development cost charge for new developments in the Lake Simcoe watershed to pay for the remediation of the lake.
Communicate with the public about action taken, costs, rationale.
Q. 10. How can the government improve the way we report on the health of Lake Simcoe?
Systematically track and report progress against the targets of the Lake Simcoe Protection Plan.
Identify costs per Kg of phosphorus reduced of all actions taken, and the source of revenue for that action or Best Management Practice (BMP).
Take the next step with subwatershed plans by developing targets and action plans and report on the achievement of those in that subwatershed.
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!
