After reviewing the…

ERO number

019-6813

Comment ID

92281

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Individual

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Comment

After reviewing the Provincial Policy Statement, The Planning Act, and the Growth Plan for Northern Ontario it appears that the issues around unorganized townships in Northern Ontario have not been adequately addressed. The PPS does not adequately address the unorganized townships particularly in Northern Ontario.

Recently Parcels in unorganized townships have been purchased for the express purpose of selling shares in the property. The use of an ‘unorganized township’ for these communes/communities/ medieval villages or land lease communities is used as a selling point to shareholders. Unorganized townships are portrayed as having few regulations. Every shareholder will own one unregistered land lease lot on the said Parcel which is owned by a corporation. These communities are mostly ‘off grid’ and some are called medieval villages instead of land lease communities. These Parcels of land in unorganized townships are divided into ‘lease lots’ without ever having gone through the rigors, requirements and approvals for subdivision under The Planning Act. There is little to no properly planned infrastructure such as waste management, fire protection, road development, sewage, gray water solution and drinking water availability in these ‘off grid’ land lease communities. Safety of residents when roads are not maintained nor easily accessible on land lease lots that are not marked with numbers is a concern for both fire and ambulance services. Indeed fire services may not be available at all.

This shareholder structure appears to be seen as a way of going around The Planning Act and proper approvals for subdivision. Suitability of the land for the proposed purpose does not take into account the size, shape, or suitability of the land for housing or recreation. The number of land lease lots allowable seems to follow the pattern of as many as can be crammed into the Parcel. Vehicular access is questionable. Adequate water supply and sewage disposal are items of concern. As waterfront is an attraction for these land lease communities they are currently being built on water front parcels calling into question environmental degradation and the future protection of the watershed. Protecting the watershed is of utmost importance to the residents already present on historical properly subdivided and approved lots who may have their water supply threatened by inadequate handling of sewage and gray water.

This practice of creating land lease communities is in contravention of Section 47(2.1) of the Planning Act which states that only one land lease community home per parcel is allowed. It also appears to contravene sections of the PPS such as section 2.7 which states that town sites shall not be permitted. The PPS or the Planning Act does not state how these villages, or communes, or land lease communities, are to be prevented or regulated while more proliferate in the unorganized townships of Northern Ontario.

The PPS does not address the economic concerns with respect to patented mining claims in Northern Ontario in unorganized townships. Many historical mining patents have had Mining Rights and Surface Rights split and thus any Parcel with Surface Rights Only or with Surface and Mining Rights can theoretically become a target for a land lease community in an unorganized township. Surely there are hundreds of these parcels in unorganized townships in Northeastern and Northwestern Ontario. There is a real estate trade in these parcels for recreational or permanent residential use. Allowing one residence and one land lease lot per parcel adhering to regulations regarding water and sewage is not a problem and can contribute to a slow and controlled growth for Northern Ontario. Encouraging development and expansion of existing communities however should be a priority in order to ensure infrastructure develops simultaneously with population growth. The proliferation of land lease communities on old patent surface rights could present a difficulty and ‘a headache’ in dealing with multi lease lot owners in a land lease community for a mining or exploration company. Should a mining or exploration company ever need to acquire surface rights for development multi lease lot owners presents multi problems. Negotiation with a single land owner to carry out exploration is relatively simple while having to approach eighty or more ‘lease lot’ holders on one old patent could present a deterrent to proceeding with an exploration program. Future development in the mining industry by local, national, and international companies could be hampered.
Consultation with Indigenous people has not been addressed in the preceding documents, particularly with respect to hunting and fishing. The land lease communities are already promoted to as havens for living off grid, hunting , fishing, and living off the land.

The PPS, The Planning Act, and the growth for Northern Ontario document should reflect the situation that exists. By not addressing the growing issue of lease lot communities in unorganized townships in Northern Ontario, proliferation of land lease communities is guaranteed. The PPS needs to address the unorganized townships more diligently taking into account existing residents and Indigenous rights.