Join The Rescue Lake Simcoe Coalition Today!

Rescue Lake Simcoe Coalition

Rescue, Restore and Rehabilitate Lake Simcoe — Imagine the Future

Home » take action

Tag: take action

Take Action To Protect Our Forests and Natural Spaces!

by

**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 kristin.pechkovsky@simcoe.ca.

***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: 

Tile 48

  • 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. 

Tile 47

  • 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. 

Tile 36 

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 5.2.8.4. and 4.2.2.5
  • 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)

LEARN MORE 

A Place to Grow Act 2020

“Other implementation” policy 5.2.8.4

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.

Watershed protection this amazing needs to stand

by

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

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

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

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

Protect Our Plan Priorities in brief:

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

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

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

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

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

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

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

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

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

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

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

Most Shoreline Municipalities Support Strong Protections for Lake Simcoe

by

January 19, 2021

Responding to a pre-election survey conducted by our friends at Lake Simcoe Watch, the Mayors of Aurora, Barrie, Bradford-West Gwillimbury, Brock, Georgina and Oro-Medonte have all called for the development and implementation of a plan to achieve the Lake Simcoe Protection Plan’s phosphorus eduction target by 2026. The Lake Simcoe Protection Plan’s phosphorus reduction target is reducing current phosphorus loading from 90 tonnes per year (10-year average) down to 44 tonnes per year, so these Mayors’ responses are heartening. We are hopeful these political statements will help tip the scales towards a responsible, serious approach to bringing down phosphorus loads through a revised Lake Simcoe Phosphorus Reduction Strategy.

But it’s not all about phosphorus. Watershed health relies on a broader healthy ecosystem including flourishing natural areas and wetlands. The Rescue Lake Simcoe Coalition’s Executive Director, along with Coalition member group leaders, made delegations to Council across the watershed requesting Councils to pass a resolution like this:

WHEREAS a healthy environment provides the foundation for healthy communities, healthy people, and a healthy economy; and WHEREAS the passage of the Lake Simcoe Protection Act received unanimous, all party support in the Ontario legislature in 2008; THEREFORE BE IT RESOLVED, THAT the Town of X calls on the Ontario Government to demonstrate its commitment to clean water and protecting what matters most in the provincial statutory review of the Lake Simcoe Protection Plan, by ensuring that provisions in the Lake Simcoe Protection Plan that protect water quality are not weakened and that policies protecting natural heritage be strengthened, in order to meet the targets of the Lake Simcoe Protection Plan; and THAT the Ontario Government be requested to work collaboratively with affected Provincial Ministries and all levels of government, including First Nations and Métis, to achieve the goals and targets of the Lake Simcoe Protection Plan and to resource the programs that improve Lake Simcoe’s water quality during the provincial statutory review of the Lake Simcoe Protection Plan; and THAT copies of this resolution be provided to …

Almost all shoreline municipalities, including: Aurora, Barrie, Brock, Georgina, Georgina Island First Nation Band Council, and Orillia Councils passed this resolution. Municipal Council resolutions can be viewed in detail here. Additionally, Newmarket, Oro-Medonte, and Whitchurch Stouffville passed supportive resolutions. The Rescue Lake Simcoe Coalition is pleased with this result, and hopes that these municipalities will remember this as they make their comments on the Lake Simcoe Protection Plan for the province.

I speculate that one of the reasons for the show of support for our resolution is that municipalities have a lot of work to implement the Lake Simcoe Protection Plan and need the province to come to the table if collectively, we are to succeed in protecting the health of Lake Simcoe and its watershed.

At first, I was concerned that municipalities would not pass our resolution, and instead capitalize on the province’s pro-growth agenda. It would appear that some already are. For example, Innisfil, which did not pass our resolution, is currently asking the Province to issue a Minister’s Zoning Order (MZO) for the inconceivably large Orbit development which would accommodate 150,000 residents. This is a Town of 36,000 today. Despite Town officials’ reassurances, there is no guarantee that Lake Simcoe Protection Plan policies would apply through an MZO.

Additionally, the rapidly growing Towns of Bradford West Gwillimbury and East Gwillimbury, who also received our delegation, deferred taking a stand until the province started the Lake Simcoe Protection Plan review, which is now on until March 3 rd, 2021.

The Lake Simcoe Protection Plan (LSPP) is the best watershed-based legislation in Canada, and its policies are up for review. The Ontario Ministry of the Environment, Conservation and Parks has released a public survey, while offering presentations, townhalls, and a science forum to municipalities in advance of the March 3rd deadline. However, we are now almost one month into the review process and no further details have been provided by the Province.

Municipalities are being asked to provide comments on potential changes to the Lake Simcoe Protection Plan, so it’s a good time to ensure that they remember their public commitments.

In the absence of data that supports changes, the Rescue Lake Simcoe Coalition and its member groups have asked the province to “Protect Our Plan”; not change it, but rather focus on its effective implementation. To date, 2,800 people have signed petitions in support of the Rescue Lake Simcoe Coalition and Lake Simcoe Watch’s position and priorities.

For more information and for Rescue Lake Simcoe Coalition priorities for the review of the Lake Simcoe Protection Plan see https://rescuelakesimcoe.org/

With thanks to intern Shannon Pittock and Board member Kira Cooper for their help.

Rescue Lake Simcoe Coalition guidance on the province’s Lake Simcoe Protection Plan Review survey

by

Hello Lake Lovers,

The Province released a public survey about the Lake Simcoe Protection Plan on Friday December 18th:

Public survey: Lake Simcoe Protection Plan 10-year review

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.   

  1. 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. 
  2. 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.

  1. 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.
  2. Improving municipal infrastructure: Financially support the improvement of ineffective or absent municipal stormwater facilities. 
  3. 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. 
  4. 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.

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

by

August 7, 2020

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

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

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

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

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

If I authored the report it would highlight:

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

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

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

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

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

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

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

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

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

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

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

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

—

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

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

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

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

by

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

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

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

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

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

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

Dena Farsad, PhD (ABD)

July 24, 2020

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

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

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

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

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

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

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

Take action!

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

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

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

2023 Rescue Lake Simcoe Coalition