I am writing to object to…

I am writing to object to the proposal to expand the boundary and permitted use framework for the Innisfil Heights Strategic Settlement Employment Area (IHSSEA). The basis for this is as follows:

1. The proposed expansion appears to almost double the size of the current IHSSEA and yet there was no map provided identifying the spatial extent of the proposed expansion, description of the lands or size of the expansion area. It is impossible for anyone to make informed input based on the extremely cursory proposal description. The EBR Notice is therefore flawed.
2. The proposal on the EBR provides absolutely no justification for this expansion and thus again it is impossible to make informed input on the proposal. The EBR Notice is therefore flawed.
3. The Proposal makes no mention of the provisions of the Places to Grow Act under which this proposed action is to be made. The EBR Notice is therefore flawed.
4. It does not appear there is express authority in the Places to Grow Act for the Minister to issue details on the boundaries or permitted uses of a strategic settlement employment area. The Act allows for amendments to the Growth Plan and the issuance of regulations. While the Growth Plan refers to such, the Plan cannot permit what the legislation does not.
5. There is no documentation that the Town of Innisfil or County of Simcoe engaged in any public notice regarding the proposed expansion. Converting upwards of 1,000 acres of prime agricultural land for development warrants full public notice at the municipal level.
6. The expansion flies in the face of the Growth Plan policies/requirements for a land needs assessment and municipal comprehensive review (MCR) prior to the expansion of any settlement area. The MCR is required to be first undertaken at the County level. All municipalities in the GGH are in the midst of preparing new MCR’s to plan for the 2041 planning horizon now contained in the Growth Plan. Any expansion prior to the County’s MCR is premature and prejudicial to other lower tier municipalities and land owners who may also be seeking urban expansion for employment uses.
7. Section 2.2.8.3 of the Growth Plan then requires that any settlement expansion demonstrate there are existing or planned infrastructure and community facilities; that such infrastructure and community facilities are financially viable over the full life cycle of these assets; that the proposed expansion would align with a water and wastewater master plan etc. There is no demonstration that any of this analysis/justification has been undertaken as well as for any of the other policies governing settlement expansions. Indeed, part of the Town’s rationale for the expansion is the inability to extend full water and sewer services to the IHSSEA in a financially viable manner and yet there is no documentation that sewer and water can be provided in a financially viable manner.
8. The Growth Plan also requires that watershed planning has demonstrated that the expansion, including the associated servicing, would not negatively impact the water resources system. The majority of lands are within the Lake Simcoe watershed and governed by the Lake Simcoe Protection Plan – although all of the IHSSEA is proposed to use Lake Simcoe as a receiving body for sewage effluent. There are hard limits on sewage treatment plant discharges into Lake Simcoe. Further, the Lake Simcoe Region Conservation Authority has concluded that already approved development will exceed the capacity of the lake. There is no demonstration that any work has been done to address the requirements of the Lake Simcoe Protection Plan.
9. There is no documentation regarding the ability for Highway 400 to accommodate additional growth of this scale or for what is likely the need for a new interchange at the 6th Line.
10. There is no discussion about the Town/County request in relation to the types of permitted uses and more liberal policies regarding uses.