2021-04-19 Honorable Steve…

2021-04-19
Honorable Steve Clark, Minister of Municipal Affairs and Housing
Government of Ontario
17th Floor, 777 Bay St., Toronto, Ontario M5G 2E5
RE: Consultation on growing the size of the Greenbelt– ERO 019-3136
The Zephyr Society of Lake Simcoe
The Zephyr Society of Lake Simcoe is a unique non-profit organization dedicated to ecological research in the Lake Simcoe watershed, focusing on scientific field investigations and analysis of wildlife, geomorphology, riparian tributary systems and landscape ecology. Application of these scientific study findings to planning and policy initiatives at the municipal, provincial and federal government levels is the Zephyr Society’s mandate.
Activity in these areas of inquiry began in 2005 when the Society was formally established. In the past 15 years significant contributions have been made in the science of landscape ecology and application and applied to planning and related areas of our interest. This work has continued through the implementation of the original Ontario Greenbelt, the Oak Ridges Moraine Act north slope and the Lake Simcoe Act. Contributions have been made in support of other local community organizations, principally the South Lake Simcoe Naturalists (SLSN), and others who have been consistent partners in advocating for natural systems in the south Lake Simcoe area. Our work specifically on the Greenbelt Plan has included submissions and publications such as our submission to Ontario of “Grow the Greenbelt Review Comments – EBR 013-1661, The Zephyr Society of Lake Simcoe, in early 2018.
Our organization has been active in planning reviews of the current Greenbelt Plan, seeking to ensure its integrity and to grow additional conservation spaces and places for natural heritage and food lands. This in recognition of the greenbelt value in sustaining nature and humans for the future in Southern Ontario.
Participating in Provincial stakeholder and interest group meetings and workshops and preparing and submitting comprehensive and detailed reports (including journal articles and book chapters), we continue to be actively engaged with local stakeholders. We assisted in formal representations and submissions from natural heritage organizations in generating recommendations to the previous provincial Coordinated Greenbelt Review.
With the Provincial ERO 013-4504 process, in which we have participated in workshops and submissions and in early 2019 regarding the Proposed Amendment to the Growth Plan, stated interest in strengthening and growing the Ontario Greenbelt, we submitted follow-up recommendations.
In our meetings with politicians, planning staff and others we focused on issues of landscape ecology, existing natural habitat conservation and locally and provincially significant wetland, geomorphological features conservation in the South Lake Simcoe area. We have stressed the importance of ecological form and function of natural features inclusion and protection in the Greenbelt.
Consistent with our knowledge of work by conservation partners, in the larger geographic context, we strongly support the protection of headwaters across the Greater Golden Horseshoe area. These vital landscapes include some key “white belt lands” and municipal Secondary Plan Areas that are not currently included in the existing Greenbelt Plans but are important landscapes to be protected.
With regard to this, we highlight Question 4 of your consultation request document to make suggestions for other potential areas to grow the Greenbelt and draw attention to three key action areas of responsible, implementable and defensible in science, landscape level extensions to the Ontario Greenbelt in South Lake Simcoe.
A. Growing the Protected Area of the Greenbelt by Shrinking the Pefferlaw Secondary Plan Area in the Town of Georgina (approx 2,000 hectares).
B. Urban River Valley designations in the Town of Georgina (Black River, Beaver River, Pefferlaw River)
C. Glacial Lake Algonquin Shoreline lands, including in the Town of Georgina.
We have provided our comments on Consultation for ERO # 019-3136 – Growing the Greenbelt in the consultation Question format consistent with your government’s request.
Our organization is delighted to have the opportunity to contribute to this important consultation, helping realize appropriate growth of the Greenbelt in these challenging pandemic times. We congratulate your government for taking this broad and creative step in planning and hope our suggestions and recommendations will be helpful to you and your colleagues in the work ahead. We and our partners are open to follow-up scientific and planning contributions with you, to the extent that limited, resources and other commitments allow. We look forward to assisting you to develop plans, policy and operational arrangements for realization of your excellent objective: to grow the greenbelt.
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Growing the Greenbelt Consultation Questions: Response and Recommendations
As requested in your governments ERO # 010-3136 – Growing the Greenbelt posting, we provide below science-based and planning comment on the six consultation question areas. These comments are consistent with other community based natural heritage organizations, including Ontario Nature, Ontario Greenbelt Alliance and others. In addition to general macro landscape scale comment, we provide some key suggestions and recommendations, useful immediate planning and policy steps that can be taken in our south Lake Simcoe research area. These suggestions are contained in the question 4 response.
Paul Harpley BSc (Hons.) M.A., Director
c.c.
The Zephyr Society of Lake Simcoe, executive
Dr. Rob Milne, Wilfrid Laurier University
Ian Hilton, E.P.D.I.
South Lake Simcoe Naturalists
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The Honorable Caroline Mulroney, MPP York-Simcoe
Minister of Municipal Affairs and Housing – Ontario, Steve Clark
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Below we respond to the six consultation questions and offer our recommendations on how to proceed.
Question 1: What are your thoughts on the initial focus area of the Study Area of the Paris Galt Moraine?
While we support the inclusion of the Paris Galt Moraine we recommend that other moraines across the GGH be included as well. Moraines are very important natural features on the landscape. It is why research members of the Zephyr Society of Lake Simcoe were so involved with the original efforts of science to help establish the Oak Ridges Moraine as a protected area and eventually the Oak Ridges Moraine Act. Long-term, climate change impacts such as extreme, and more variable weather events, like warm and droughty periods and flood events, are buffered by the form and function of intact moraines on the landscape.
The Paris Galt Moraine is the headwaters for many rivers and streams protecting groundwater aquifers, for drinking water for communities, supporting regional ecosystems, sustainable development, and economic growth.
Consequently, the Zephyr Society of Lake Simcoe supports the inclusion of the entire geomorphic feature known as the Paris-Galt Moraine in the Greenbelt, including sections south and west of Brantford.
Question 2: What are the considerations in moving from a Study Area to a more defined boundary of the Paris Galt Moraine?
Key to the defining the boundary of the Paris Galt Moraine is the establishment of an interdisciplinary research team to engage in field, lab and detailed reconnaissance and mapping work, first at the broad landscape level, followed by detailed local edges work. Geomorphologic, groundwater hydrology and surficial hydrologic physical geography investigation including stream and river detailing must be done. This work will set the stage for further moraine boundary delineation, and lead to terrestrial and aquatic work that is dependent and intimately integral to the form and function of the moraine. Various modelling of the parameters noted above and others to test resilience water resources and other systems in an ecological and watersheds approach moving forward would confidently result in a confident defined boundary for the feature.
Some members of the Zephyr Society of Lake Simcoe were involved some of this work on the Oak Ridges Moraine early on, especially on the north slope of the moraine draining off the moraine into the Lake Simcoe lowlands through the important three rivers Pefferlaw, Black and Maskinonge Rivers, draining into Lake Simcoe. There were many engagements in the work with Ontario Ministries (MNR, MOE in those days etc.). Actual key our interest was involvement of the federal Geologic Survey of Canada (GSC) staff which we engaged with particularly on the north slope landscape of the ORM.
These investigations would include results like protection of all the headwaters and groundwater aquifers associated with the moraine. The protection of all local ecosystems, ensuring drinking water resources for communities and planning for climate change impacts must be central in this work.
Extensive consultations with local rural and urban communities including Indigenous communities in this process with a social science-based methodology is recommended. This has specific relevance in duty to consult with First Nations.

Question 3: What are your thoughts on the initial focus area of adding, expanding and further protecting Urban River Valleys?
The protection of rivers is very important to our organization. We have been involved in riparian, fluvial and related geomorphological work for many years with the
We strongly concur with the inclusion of additional Urban River Valleys in the greenbelt, and further recommend that private lands also be included in this designation. As noted in the ERO posting, publicly owned lands “are often lands designated in municipal official plans as parks, open space, recreation, conservation and/or environmental protections.” The designation of public lands under the Greenbelt will do little to enhance the quality of the Greenbelt, as the government intends. It is private lands within the Urban River Valleys, more so than public lands, that are threatened with urbanization and development.
Additionally we recommend that MMAH designate entire river valley corridors rather than only sections flowing through urban areas in order to adequately protect the benefits provided by these important water bodies.
With respect to our physical geographic area of research in the South Lake Simcoe region we would strongly recommend the Black, Pefferlaw, and Maskinonge Rivers, and Zephyr Creek. Urbanization and intensive farming including sod, biosolid application, phosphorus and nitrogen loading, pesticide and related intensive agriculture has resulted in significant negative changes to these waterways. These rivers were disturbed and developed early on in settlement in early Ontario, including with early resource extraction (forest, gravels, water engineer works etc.) and have not recovered and now urbanization and intensive agriculture are degrading them.
We concur and also recommend that all river valley systems suggested by others that connect the Greenbelt’s protected countryside to the Great Lakes and inland lakes, especially Lake Simcoe be considered, including the Black, Pefferlaw, Maskinonge, Nith, Grand, Conestogo, Eramosa, Speed, Nottawasaga, East Holland, Talbot, Ganaraska, and Don Rivers, and Zephyr, Duffins and Carruthers, Twelve Mile, Gages and Cobourg Creeks.

Question 4: Do you have suggestions for other potential areas to grow the Greenbelt?
Areas to consider expansion of the Greenbelt should be places where priority can be on protecting areas of high ecological and hydrological value as well as agricultural areas that are under threat from urban development.
All moraines in the GGH to the Greenbelt, wetlands, cold water streams, headwater regions, and also locations including remnant Pleistocene features like the former Glacial Lake Algonquin and Iroquois Shorelines and Plains. This is good geography and planning practice and are important physiographic features known through form and function to be priority conservation lands candidates.
In South Lake Simcoe the Zephyr Society of Lake Simcoe has undertaken research on many of these features over two decades publishing on their geomorphology, form and function and conservation.
In relation to the sensitive areas of the Lake Simcoe basin, such as the glacial Lake Algonquin shorelines in the South Lake Simcoe area and the related sand plains are vital source-water protection areas. They define important Natural Heritage habitats. While water is important, we also recognize that natural heritage habitat, not just at headwaters, but also throughout watersheds draining to Lake Simcoe, such as at Pefferlaw are vital parts of our ecological environment.
Our Municipal Council Submissions to the Town of Georgina, Reports and meetings with local Council members succeeded in securing Municipal support from the Town of Georgina for our proposals. Motions were passed regarding proposed amendments for the Province to implement regarding two key in conservation opportunities to grow the existing Greenbelt focused on specific geographically identified locations. These two key issues define our needed and recommended improvements in an actual existing landscape site.

A. Growing the Protected Area of the Greenbelt by Shrinking the Pefferlaw Secondary Plan Area in the Town of Georgina.
It has been a central mandate and motivation for our organization and partners over 25 years in South Lake Simcoe to ensure implementation of planning actions that affect conservation of natural heritage lands and that strengthen core and corridor lands for wildlife, consistent with Landscape Ecology scientific guidelines. Consequently, we are extremely supportive of the current Provincial governments’ priority of “Growing the Greenbelt” especially where important natural areas lands are included in Secondary Plan areas as potentially developable. Realistically, these natural areas have minimal or no potential for development but are not included in protected Greenbelt areas.
This action will grow the Protected Area of the Greenbelt in the Town of Georgina. One of the primary issues of focus for our conservation and research work in the Town of Georgina is the current Pefferlaw Secondary Plan area. We have had concerns about its current extent and have argued since the 2005 establishment of the Provincial Greenbelt that the Secondary Plan area be” shrunk”. In 2014/2015 and later to 2015, we provided extensive written comment to the Province regarding the Greenbelt Review and Town of Georgina Official Plan Review (SLSN Reports Attachment 1, and Attachment 2).
At the Town of Georgina Council Meeting (May 13, 2015) regarding the proposed report “2015 Provincial Coordinated Land Use Review – Town of Georgina Report No. PB-2015-0026” (Attachment 3) these proposals were supported and later submitted by the Town of Georgina to York Region recommending that the Pefferlaw Secondary Plan area be “Shrunk”. It is particularly distressing that these recommended actions have not been implemented to date. The Growing the Greenbelt consultation of your Government is now “the opportunity at Pefferlaw”. Three key Maps attachments to the Town of Georgina Report No. PB-2015-0026, are attached for visual documentation of shrinking the Pefferlaw Secondary Plan (Attachments 4,5,6) also attached at end of Question 6 narrative).
A selection of key narrative of the impact of shrinking the Pefferlaw fron Town of Georgina Report No. PB-2015-0026 is,
The contraction of the existing 2,518 hectare Pefferlaw Settlement Area boundary to a more logical limit would transfer the balance of the Settlement Area to the Greenbelt lands, thereby growing the Greenbelt.
Town staff have completed an additional mapping review which includes an examination of the underlying land use designations and are recommending a boundary that delineates a 1,022 hectare area; an approximate 59% reduction from the current 2,518 hectare boundary. This final recommended boundary of the area to remain within the "Towns/Villages" designation for Pefferlaw within the Greenbelt Plan is shown on Attachments'3'and '4'. This would result in an area of 1,496 hectares to the Greenbelt
As part of the Official Plan Review, the Town's Planning consultant, MHBC Planning, prepared a report entitled "Review of Pefferlaw Hamlet Boundary", which provides a detailed examination of the above planning rationale for contracting the Pefferlaw Settlement Area boundary
The relatively small level of growth forecasted for Pefferlaw does not warrant having of 2,518 hectares of "Towns and Villages" designation in the Greenbelt Plan. The contraction of this Settlement Area boundary would more accurately reflect growth forecasts, more effectively implement the Town's official Plan growth management policies, better protect natural heritage/hydrologic features and Prime Agricultural Lands, address an optics issue regarding the physical size of the Pefferlaw Settlement Area and assist the Province in their desire to grow the Greenbelt.
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*Note: This would would be a contraction of 1,496 hectares of land (forest, meadow and farm food land primarily, that would become part of the Greenbelt.

In our view, in light of the direct relationship between the Pefferlaw Secondary Plan and the Provincial Greenbelt, the Georgina Official Plan specifically be amended to increase the Greenbelt area and reduce the Pefferlaw Secondary Plan area as it exists now. Therefore, it is our recommendation that the province shrink of the Pefferlaw Secondary Plan area in the new Georgina Official Plan. This makes excellent planning logic and sense, and is
1. Consistent with the Province of Ontario focus on Growing the Greenbelt and managing growth in a controlled, planned and consistent manner.
2. Good Planning, and in the public interest
3. In the best Public Interest and supports conservation of natural habitat and wildlife
4. In the interest of the community of the Town of Georgina as per Report No. PB-2015-0026).
5. Is a geographically defined and identified area that can be represented in an Official Plan.
6. In the Lake Simcoe Act and Plan there is no provision for future large municipal sewage plant service to the hamlet of Pefferlaw, so development will be limited over many years.
7. In Ontario Growth Plan consultations and Plans, and the Grow the Greenbelt consultation Map etc. minimal infill etc. development is projected for 20-30 year horizon.
8. The required planning operational arrangements are primarily zoning change and administrative. Compared to other areas in the existing Greenbelt this Growing of the Greenbelt at Pefferlaw opportunity could be achieved Now.
9. There are existing York Region Forests in and adjacent to the proposed contracted area of the shrinking of the Secondary Plan area. Also, the significant Duclous Point Provincial Nature Reserve (Adjunct to Sibbald Point Provincial Park) in in the area and provides an incredible link of a Greenbelt area to Lake Simcoe (protected). This is a primary natural area linkage in landscape ecology, and a major goal of the Lake Simcoe Act, and Plan.

There are other advantages to this idea of “Growing the Greenbelt at Pefferlaw” – It should happen with you Provincial Government as soon as possible.

Maps for “Shrinking the Pefferlaw Secondary Plan area, and Growing the Greenbelt MAPS; Attachments 2,3,4 from 2015 Provincial Coordinated Land Use Review – Town of Georgina Report No. PB-2015-0026”

Attachment 4 – Existing Pefferlaw Secondary Plan Area. Source: Georgina Report No. PB-2015-0026, Attachment 2.

Attachment 5: Town of Georgina Recommended New Secondary Plan Boundary reduction, opening up lands for Growing the Greenbelt. Map of Aerial photo. Source: Georgina Report No. PB-2015-0026, Attachment 3.

Attachment 6: Map Show the land use Plan of Pefferlaw Secondary Plan Map with Growing Greenbelt around. Source: Georgina Report No. PB-2015-0026, Attachment 4.
B. Urban River Valley designations in the Town of Georgina
It is our contention that the inclusion of the urban river areas of Keswick, Sutton/Jackson’s Point and Pefferlaw in the Greenbelt is essential in the same way it is for rivers draining south from the Oak Ridges Moraine through communities on the watersheds surrounding Toronto including the Rouge River, Humber River and Don River. We originally in 2005 proposed in reports and workshops that these three rivers urban areas be included in the Greenbelt, and they were shown as dooted lines on Greenbelt maps but in later years they were administratively removed. We were never able to find out how they disappeared off maps.
In the Lake Simcoe drainage areas: important watersheds and rivers draining north off the Oak Ridges Moraine into sensitive Lake Simcoe are not designated. River Valley Connections at urban locations for the Maskinonge, Black and Pefferlaw Rivers remain unprotected In the Greenbelt Plan at this point. This must change. The public/private property dilemma we have raised in a previous question that this consultation process needs to resolve.
We contend that the formal inclusion of the urban river areas of Keswick, Sutton/Jackson’s Point and Pefferlaw into the Greenbelt into the must be a part of the Greenbelt expansion proposals. They should be included in the same way that rivers draining south off the Oak Ridges Moraine into communities in the south in Toronto and area are suggested for inclusion (eg. Rouge, Humber and - some 50 other rivers in the rest of the Greenbelt – (Draft Greenbelt June 6, 2016 Mapped).
We note that at the Town of Georgina Council Meeting Wednesday September 28, 2016 Council voted to make the formal inclusion of the Greenbelt into the urban river areas in order to implement the Urban River Valley Designations in the Town of Georgina. We strongly agree with Council, believe that the Official Plan of the Town of Georgina reflect this land use designation, and that the Region of York should support this.
We also requested the Region of York include a specific recommendations in their final Greenbelt Review Comments to the Province of Ontario of the previous government to the effect that they also support this recommendation.
These municipally supported priorities and recommendations were communicated in writing to the Province in 2016 and 2018 (Zephyr Society of Lake Simcoe, Grow the Greenbelt Review Comments – EBR 0123-1661, 2021-03-05).
C. Glacial Lake Algonquin Shorelands lands, including in the Town of Georgina.
Remnant Pleistocene features like the former Glacial Lake Algonquin and Lake Iroquois Shorelines and Plains are unique and well represented features with important functions in the South Lake Simcoe landscape. Our organization has done research on these important physiographic features, over two decades documenting their geomorphology long known to be priority conservation lands candidates.
In South Lake Simcoe the Zephyr Society of Lake Simcoe has undertaken research on many of these features over two decades publishing on their geomorphology, form and function and conservation.
In relation to the sensitive areas of the Lake Simcoe basin, such as the glacial Lake Algonquin shorelines in the South Lake Simcoe area and the related sand plains are vital source-water protection areas. They define important Natural Heritage habitats. While water is important, we also recognize that natural heritage habitat, not just at headwaters, but also throughout watersheds draining to Lake Simcoe, such as at Pefferlaw are vital parts of our ecological environment. We are aware of some local features in the Town of Georgina that could be immediate candidates for early locations to ‘Grow the Greenbelt’ through these physical geographic features’ conservation. We welcome opportunity to contribute further.

Question 5: How should we balance or prioritize any potential Greenbelt expansion with the other provincial priorities mentioned above?
Natural and water resource systems and farmland operations must take priority always and particularly in the Greenbelt. In terms of community and ecosystem health these systems are foundational to the Greenbelt and beyond. Expanding the Greenbelt and protecting important physiographic features natural ecosystems, water resources and sources, farmland, and wildlife habitat from development must be the highest priority action. Our changing climate and impacts we are seeing here and around the world are demonstrating this on a daily basis.
Consultation with municipalities should allow them to establish policies that go beyond the minimum standard set by the Greenbelt Plan. Policies and operational arrangements at the local landscape level must provide the highest level of protection priority for natural and hydrological features and farmland. Municipalities within the Greenbelt are not able to establish policies that are more restrictive for mineral aggregate extraction, and turf and sod operations and the application of biosolid, that often in our experience in South Lake Simcoe have great negative impact on river water quatilty, even those in the existing Greenbelt Plan.

The interrelatedness of transportation, conservation and economics and environmental impact must be front and centre and inform decisions, and actions. Many organizations like ours and have already done that calculation. It has led to calling to cancel plans to build Highway 413 (GTA West) and the Bradford Bypass (Holland Marsh Highway) as the above planning methodology is not in evidence. Similarly, refrain from using Minister’s Zoning Orders (MZOs) to fast-track development on natural areas and farmland.
Greenbelt expansion definitely presents opportunities to advance the achievement of objectives of the Lake Simcoe Protection Plan, The Oak Ridges Moraine Plan objectives, Ontario Biodiversity Strategy, Species at Risk objectives, Ontario’s Wetland Conservation Strategy, and Ontario’s Great Lakes Strategy.

Question 6: Are there other priorities that should be considered?
As systems approach planning process, beginning with research, analysis and implementation should lead this review and growth in the Greenbelt. Key areas of expansion should be identified, and full consultation ensue as previously detailed in this submission.

The siting new developments on sensitive farmland and natural areas, the government should prioritize building complete communities (gentle density, people friendly, walkable, jobs close by climate resilient) inside the boundaries of our existing hamlets, towns and cities. Best practices for development planning around these areas in the Greenbelt should be a priority moving forward.