03 02 2009 PAC AgendaTOWNSHIP OF ORO-MEDONTE
PLANNING ADVISORY COMMITTEE MEETING AGENDA
COUNCIL CHAMBERS
Date: Monday, March 2, 2009 Time: 7:00 p.m.
3. DISCLOSURE OF PECUNIARY INTEREST AND THE GENERAL NATURE
THEREOF: - "IN ACCORDANCE WITH THE ACT"
5. PRESENTATIONS:
['4XF44thT,43
a) 7:00 p.m. Proposed Plan of Subdivision, 2008 -SUB -01; and Proposed
Amendment to the Zoning By -Law, 2008-ZBA- 13, Part of Lot 5,
Concession 14 (Medonte), Township of Oro-Medonte, South of
Warminster Sideroad, East Side of Highway 12, 9733 Highway 12
(Anderson).
7. PLANNING APPLICATIONS:
101
=0-
9. OTHER BUSINESS / EDUCATION:
a) Tom Kurtz, re: Source Water Protection Committee Update.
b) Glenn White, Manager of Planning Services re: Lake Simcoe Protection Plan
Workshop.
10. ADJOURNMENT
1 01 it,
(q
JAN
C]"JIN C 11L
C, orr
2006-2010 TERM
Present: Council Representatives
Mayor H.S. Hughes
Deputy Mayor Ralph Hough
Councillor Mel Coutanche
Councillor Sandy Agnew
Councillor John Crawford
Councillor Dwight Evans
Regrets: Councillor Terry Allison
Public Representatives
Roy Hastings
Tom Kurtz
Mary O'Farrell -Bowers
Larry Tupling
Staff Present: Glenn White, Manager of Planning Services; Steven Farquharson,
Intermediate Planner; Janette Teeter, Deputy Clerk
Also Present: Jerry Young; Kris Menzies, MHBC Planning
1. OPENING OF MEETING BY CHAIR.
Deputy Mayor Hough assumed the chair and called the meeting to order.
2. ADOPTION OF THE AGENDA.
Motion No. PAC090126-1
Moved by Tom Kurtz, Seconded by Mary O'Farrell -Bowers
It is recommended that the agenda for the Planning Advisory Committee meeting of
Monday, January 26, 2009 be received and adopted, as amended, to add as Item 9c),
Councillor Agnew, re: Proposed Future Development of Horseshoe Resort and as Item
9d), Councillor Agnew, re: Official Plan Review Update.
Carried.
3. DISCLOSURE OF PECUNIARY INTEREST AND THE GENERAL NATURE
THEREOF: - "IN ACCORDANCE WITH THE ACT".
None declared.
4. MINUTES OF PREVIOUS MEETING —November 24,2008.
`
�Motion No. PAC090126-2
Moved bvTom Kurtz, Seconded bxMary O'Farm*U-Bowens
Kis recommended that the minutes of the Planning Committee Meeting held on
November 24, 2008 be received and adopted.
5. PRESENTATIONS.
6. PUBLIC MEETINGS~
7' PLANNING APPLICATIONS.
o] Report No. []S 2000-OD2.Steve Farquharson, Intermediate Planner, re: Proposed
Official Plan and Zoning By-law Amendment, 2DO8-Z]3A-1O.2OOU-C}PA-O2.Lot 1.
Concession 5 ({}no). Township ofC]no-K8edonbe. South Side of Horseshoe Valley Road
and West of Line (1188077Ontario Ltd.).
Steve Farquharson, Intermediate Planner presented a PowerPoint presentation.
Kris Menzies, MHBC Planning, on behalf of the applicant, presented a PowerPoint
presentation.
Motion No. PAC090126-3
Moved bxRoy Hastings, Seconded bvLarry Tupling
|tisrecommended that
1. Report No. DS 2OU9-OD2.Steve Farquharson, Intermediate Planner, re: Proposed
Official Plan and Zoning By-law Amendment, 2008-ZBA'10.2008'OPA-02. Lod 1.
Concession 5 (Oro), Township of Oro-Medonte, South Side of Horseshoe Valley Road
and West ofLine 4(1188877Ontario Ltd.)bereceived and adopted.
2. That it is recommended to Council that Official Plan and Zoning By-law Amendment
Applications 20O8-[}PA-O2and 2OD8-ZBA-1O.Lot 1.Concession 4.(CJno).Township of
{]ro-k8gdontethat would serve toredesignate the subject lands from "Horseshoe
Valley — Medium Density" to "Horseshoe Valley- Low Density Residential" on
Schedule D of the Official Plan, and to rezone lands from Agricultural/Rural Exception
(A/RU*15) Zone to Residential One Exception Hold (Rl*H) Zone on Schedule A15 of
Zoning By-law 87-BG.baapproved.
Planning Advisory Committee meeting
A
2. CORRESPONDENCE AND COMMUNICATION.
None.
9. OTHER BUSINESS / EDUCATION.
a) Tom Kurtz, re: Source Water Protection Committee Update.
Tom Kurtz presented a PowerPoint Presentation.
Motion No. PAC090126-4
Moved by Larry Tupling, Seconded by Roy Hastings
It is recommended that the verbal information presented by Tom Kurtz re: Source Water
Protection Committee update be received.
Carried.
b) Andria Leigh, Director of Development Services, re: Draft Lake Simcoe Protection
Plan - Consultations.
Motion No. PAC090126-5
Moved by Tom Kurtz, Seconded by Mary O'Farrell -Bowers
It is recommended that the correspondence dated January 13, 2009 and verbal
information presented by Glenn White, Manager of Planning Services, re: Draft Lake
Simcoe Protection Plan -Consultations be received.
Carried.
c) Councillor Agnew, re: Proposed Future Development of Horseshoe Resort.
Kris Menzies, MHBC Planning, provided background information on Horseshoe Resort.
Motion No. PAC090126-6
Moved by Roy Hastings, Seconded by Mary O'Farrell -Bowers
It is recommended that the verbal information presented by Councillor Agnew re:
Proposed Future Development of Horseshoe Resort be received.
Carried.
Planning Advisory Committee Meeting
January 26. 2009. Pape 3
d) Councillor Agnew, re: Official Plan Review Update.
Motion No. PAC090126-7
Moved by Larry Tupling, Seconded by Roy Hastings
It is recommended that the verbal information presented by Glenn White, Manager of
Planning Services re: Official Plan Review Update be received.
Carried.
Moved by Tom Kurtz, Seconded by Mary O'Farrell -Bowers
It is recommended that we do now adjourn at 8:40 p.m.
Chair,
Deputy Mayor Ralph Hough
Deputy Clerk,
Janette Teeter
Carried.
Manager of Planning Services,
Glenn White
Planning Advisory Committee Meeting
I-- 1A WM P.— A
PRIMER: The Clean Water Act, 2006 and Proposed Lake Simcoe Protection Plan
Building on Existing Protections
2--
Clean Water Acte 2006 ( CWA
" _ PROPOSED Lake Simcoe Protection Plan
Key
"...to protect existing and future sources of drinking water."
Protect, improve or restore the elements that contribute to the ecological
objective(s)
health of the Lake Simcoe watershed, including, water quality, hydrology,
key natural heritage features and their functions, and key hydrologic
features and their functions;
• Restore a self-sustaining coldwater fish community in Lake Simcoe;
• Reduce loadings of phosphorus and other nutrients of concern to Lake
Simcoe and its tributaries;
• Reduce the discharge of pollutants to Lake Simcoe and its tributaries;
• Respond to adverse effects related to invasive species and, where possible,
to prevent invasive species from entering the Lake Simcoe watershed;
• Improve the Lake Simcoe watershed's capacity to adapt to climate change;
• Provide for ongoing scientific research and monitoring related to the
ecological health of the Lake Simcoe watershed;
• Improve conditions for environmentally sustainable recreational activities
related to Lake Simcoe and to promote those activities;
• Promote environmentally sustainable land and water uses, activities and
development practices; and
• Build on the protections for the Lake Simcoe watershed that are
provided by provincial plans that apply in all or part of the Lake Simcoe
watershed, including the Oak Ridges Moraine Conservation Plan and the
Greenbelt Plan, and provincial legislation, including the Clean Water Act,
2006, the Conservation Authorities Act, the Ontario Water Resources Act
and the Planning Act
ornrriittees ..;,
Source Protection Committees (SPC) are local multi-
The Lake Simcoe Science Committee is composed of scientific experts in
stakeholder groups formed under the CWA that are tasked
watershed protection issues, would review the environmental conditions of
with preparing terms of reference, assessment reports and
the watershed and advise on the program.
source protection plans for each Source Protection Area.
• The Lake Simcoe Coordinating Committee coordinates Plan
implementation, resolves issues, and provides advice and assistance to the
Minister regarding actions and policies to deal with threats.
• Membership on the SPC and the two Lake Simcoe committees may overlap. Shared membership would facilitate the sharing of information
and coordination and integration of the two programs.
Cgnsultat�on, <
The Province has and will continue to consult broadly with
The Province intends to consult broadly with stakeholders throughout the
the public and key stakeholders on the development of the
implementation of the Lake Simcoe Protection Plan.
source protection program.
• The Ministry will consult with the SPC on the development and
• SPCs are required to consult with the public, municipalities,
implementation of the Lake Simcoe Protection Plan.
and First Nations at various stages during the source
protection planning process, most notably during the
preparation of the terms of reference, assessment reports
` =
and source protection plans.
2--
• Although it is not mandatory, the SPC could consider
interaction / consultation with the Lake Simcoe committees
as they develop their assessment report and source
protection plan.
tlfat `;
Conceptual and tier 1 water budgets being completed as
• Lake Simcoe Region Conservation Authority (LSRCA), in consultation with
Budgets
part of the assessment report for each source protection
municipalities, will complete Tier 2 water budgets (integrated three-
°,
area across the province.
dimensional groundwater models and continuous surface water simulation
r
Tier 2 water budgets required only for stressed
models) in all stressed subwatersheds (as identified in the Tier 1 water
subwatersheds containing a municipal residential
budget) that have not proceeded to Tier 2 under the CWA.
drinking water system identified in the Tier 1 water
• Water budgets may be used to inform:
budgets.
o Instream flow targets;
• If Tier 2 water budgets confirm subwatersheds are stressed,
o Municipal water conservation and efficiency plans, and municipal
a tier 3 local area water budget and water quantity risk
decisions concerning growth and development;
assessment is carried out for each system in the watershed.
o Water-taking strategies and decisions made by the Director concerning
Policies to be developed in local source protection plans for
Permits To Take Water; or
any significant drinking water threats to water quantity
o Policies that would be included in future amendments to the Plan.
identified in Tier 3 water budgets.
t9ttf�f�
All SGRAs that are linked to any type of drinking water
It is proposed that mapping of SGRAs from the source protection program
Grn�ate
z
systems are mapped in the assessment report.
Drinking
will be used under the Lake Simcoe Protection Plan, with potential
water threats and issues can be identified in these
modifications based on an ecological (rather than purely drinking water)
areas and policies can be written to address these in the
focus.
source protection plan.
• It is proposed that municipalities will be required to delineate SGRAs within
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their official plans and develop policies relating to these areas.
L�Ied
The term threat under the CWA is used very specifically and
It is proposed under the Lake Simcoe Protection Plan that a process will be
a�eerti
means an activity or condition that adversely affects or has
developed to undertake subwatershed evaluations that build upon and
d b e is
the potential to adversely affect the quality or quantity of any
integrate with source protection plans under the Clean Water Act, 2006, as
eyalgtt,i
water that is or may be used as a source of drinking water.
well as relevant work of the LSRCA and watershed municipalities.
k x
The assessment report will identify and categorize water
Subwatershed evaluations will be completed to determine threats and set
quality and quantity drinking water threats. Threats are
out targets and actions. The resultant targets and actions will relate to
identified only if they occur within vulnerable areas
phosphorus reduction, stormwater management, instream flow targets,
(intake protection zones, wellhead protection areas,
natural heritage restoration / enhancement, and more.
significant groundwater recharge areas, and highly
Within 5 years, the LSRCA will develop and complete subwatershed
vulnerable aquifers).
evaluations for priority subwatersheds.
• A specific and systematic water quality and quantity risk
Key findings and recommendations will be implemented by incorporation
assessment is used to identify and categorize drinking water
into relevant municipal official plans, through potential amendments to the
threats.
Plan, or through action by appropriate agencies under existing Plan policy,
• Drinking water quality and quantity threats are categorized
as appropriate.
as significant, moderate or low based on the vulnerability
:�.
scores and hazard ratings.
,�
Policies must be developed in source protection plans that
The proposed Plan contains many different policies addressing aquatic life,
address'
address significant drinking water threats to water quality
water quality, water quantity, shorelines and natural heritage, invasive
threats
and water quantity that have been identified in the
species, climate change and recreational activities.
assessment report. Policies may also be developed that
Policies in the proposed plan have differing dates for implementation.
address moderate and low drinking water threats.
• The Source Protection Committee will decide on
'
implementation dates for the policies in the plan.
• Source Protection Plans are due to the Minister on August
20, 2012.
Septic ..
The CWA amended the Ontario Building Code Act, 1992 to
Under the proposed Plan, the MMAH and the MOE will develop a proposal
Inspections
provide regulation making authority for mandatory on site
for a regulation under the Ontario Building Code Act, 1992 to designate the
sewage maintenance inspections. The amendment included
lands within 100 metres of the Lake Simcoe shoreline and any permanent
regulation making authority for mandatory re-inspection in
stream of Lake Simcoe as a prescribed area for required on-site sewage
prescribed areas. It is anticipated that these will include a
maintenance re-inspections.
subset of the "vulnerable areas" identified in an assessment
This initiative is only applicable to areas within the Lake Simcoe watershed.
report included in a source protection plan. It is anticipated
However, a small percentage of the systems captured under this policy may
that these will include septic systems within 100 meters of a
also be addressed under the source protection programs; the two
wellhead, within the 2 year time-of-travel and those located
inspection programs would be integrated.
�-
within the intake protection zone 1 or 200 meters of a
surface water intake, whichever is less.
�. Moniiorng ,'
Once assessment reports have been approved by the
• The Lake Simcoe Protection Plan requires ongoing monitoring and
Director, Source Protection Authorities are required to
reporting on progress.
submit interim progress reports in accordance with the
• The Lake Simcoe Protection Act requires that the Minister a) annually
CWA.
prepare a report on the implementation of the Plan and b) at least once
• Source protection plans will include monitoring and reporting
every five years prepare a report that describes the results of monitoring
to measure the effectiveness of the actions taken to protect
programs and describes the extent to which the objectives of the Lake
drinking water sources and ensure they are protected in the
Simcoe Protection Plan are being achieved.
future.
• The proposed Plan includes a comprehensive watershed-wide monitoring
• After the source protection plan is approved, annual reports
strategy addressing the magnitude of threats / stressors, key indicators of
submitted to the Ministry of the Environment will track
ecological health, and key processes that maintain ecological integrity.
implementation and compliance.
The proposed Plan also incorporates an iterative, adaptive approach that
• Once source protection plans are approved by the Minister,
employs social and science-based planning, monitoring of system
the planning process will be subject to ongoing updates and
responses, and uses new knowledge in a timely way to modify
review at a frequency set by the Minister.
management.
Stewardship
The CWA sets out the Ontario Drinking Water Stewardship
Actions in the draft Lake Simcoe Protection Plan will focus on both
Program (ODWSP) to provide financial assistance to those
agricultural, rural and urban (non -farm) stewardship, including:
�
affected by the Act and for projects that proactively protecto
Implementing broad-based agri-environmental stewardship programs.
sources of drinking water. 28 million dollars have been
o Developing a structured educational and incentive stewardship program
allocated for the program until 2011.
for rural and urban (non -farm) landowners in the watershed.
• The current program is separated into three components —
o Establishing a Stewardship Network / Alliance.
early actions (administered by Conservation Authorities or
• A portion of the government's $20M investment in Lake Simcoe will assist
the Ontario Soil and Crop Improvement Association),
farmers with their stewardship activities through the implementation of best
education and outreach and special projects (administered
management practices and the promotion of innovative projects.
by MOE). Early Actions funding supports stewardship
Activities supported under Lake Simcoe Stewardship program will, like the
activities within eligible vulnerable areas (2 year time of
Ontario Drinking Water Stewardship Program, build on successes of best
travel around a municipal well or intake protection zone 1).
management practices under the Environmental Farm Program and the two
Farmers within these areas can access funds through the
programs are anticipated to include cost-sharing for similar activities (e.g.,
ODWSP to support the best management practices under
runoff and erosion control, fuel storage). The differences between these two
the Environmental Farm Plan —funding from both programs
programs will include their scope (municipal drinking water vs. watershed
can be stacked for up to 100 % of a project's cost, within
protection) and the areas eligible for activities.
established ceilings.
DRI N K I N6 WATER South Georgian Bay Draft
SOURCE PROTECTION Source
Simcoe(Feb. 20, 2009)
ACT FOR CLEAN WATER
Source Protection Region
�h r ✓
f,6{ Georgian Bay Muskoka Lakes
Gravenhurst
Christian Is.
.■ l
■ Municipal SW Intakes
Intake Protection Zone 1 (1 km / 120m)
Intake Protection Zone 2 (2 hr tot)
• Municipal Supply Wells
_ Well Head Protection Area (25 yr)
N 1:200,000
A0, 2 4km
Black -Severn River,`_,
P.enetariguishene •;
Midland
1A •
fy 'M
I -XII
yNi Severn 4 •
\� /
Tay Ramara
Tiny
Wasaga Beach
Severn Sound
o Oro-Medoiite,/_ Orillia
Springwater L .4
Lake Simcoe
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DRINKING WATEIN South Georgian Say Draft
SOURCE PROTECTION Lake Simcoe (Feb. 20, 2009)
ACT FOR CLEAN WATER \, Source Protection Region Tay - CoGym
.A-
m Municipal SW Intakes
A&
Intake Protection Zone 1 (1 km 120m) ti
Tiny
19
• Municipal Supply Wells
Well Head Protection Area (25yr)
Severn Sound
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1:250,000
0 2.5 5krn
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Wasaga Bea.ch
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Lake BayDRINKIN6 WATRSOURCE PROTECTioN ACT FOR CLEAN WATER en Re
■ Municipal SW Intakes
0 Intake Protection Zone 1 (1 km / 120m)
Intake Protection Zone 2 (2 hr tot)
• Municipal Supply Wells
- Well Head Protection Area (25 yr)
N l <;
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A 0 2.5 5km Oro-Medonte
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.y
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Draft
(Feb.20,, 2009)
Black -Severn River
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e Simcoe : ,1 +�
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a
Uxbridge&
ju
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a Stouffville
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a
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Richmond Hill IA
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Whitby
DRINKING WATER �4� South Georgian Bay wHPAs in
Lake Simcoe
SOURCE PROTECTION oro-Medonte
ACT FOR CLEAN WATER y �SOIIrCe Protection Region
N
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WHPA-C (5 yr)
� WHPA-C1 (10 yr) ^p0 I; `-•�
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WHPA-D (25 yr) s �G �io� (Well #1,2,3)
WHPA-D1 (25yr U)
LS Watershed
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SS Watershed 0 2 4 6 8 km
s
EBR REGISTRY NUMBER 010-4636
Draft Lake Simcoe Protection Plan
Comments On Behalf of The
Lake Simcoe Region Conservation Authority
February 12, 2009
Lake Simcoe Region Conservation Authority
EBR Registry Number 010-4636
Draft Lake Simcoe Protection Plan
Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 2 of 55
Table of Contents
Letterof Transmittal ..................................................................................................... 3
Chapter One: Ecological Health of Lake Simcoe and its Watershed ........................... 5
Chapter Two: Building On Past Actions ....................................................................... 7
ChapterThree: Aquatic Life ........................................................................................ 10
Chapter Four: Water Quality ....................................................................................... 12
Chapter Five: Water Quantity ....................................................................................... 18
Chapter Six: Shorelines And Natural Heritage .............................................................22
Chapter Seven: Other Threats and Activities ............................................................... 32
Chapter Eight: Implementation ..................................................................................... 34
Subwatershed Evaluations: .................................................................................. 34
Stewardship, Education & Outreach: ................................................................... 35
Research, Monitoring and Reporting .................................................................... 39
Coordination, Public Engagement and Aboriginal Community Engagement ........ 40
Advisory Committees under the Lake Simcoe Protection Act, 2008 ....................42
FinancingStrategy ............................................................................................... 42
PlanAmendments ................................................................................................ 44
ClosingRemarks: ......................................................................................................... 44
SUMMARY OF RECOMMENDATIONS ...................................................................... 45
Chapter One: Ecological Health of Lake Simcoe and its Watershed ...........................45
Chapter Two: Building On Past Actions ....................................................................... 45
Chapter Three: Aquatic Life ........................................................................................ 46
Chapter Four: Water Quality ....................................................................................... 46
ChapterFive: Water Quantity ....................................................................................... 49
Chapter Six: Shorelines And Natural Heritage ............................................................. 50
Chapter Seven: Other Threats and Activities ............................................................... 52
Chapter Eight: Implementation ..................................................................................... 52
Subwatershed Evaluations: .................................................................................. 52
Stewardship, Education & Outreach . ................................................................... 53
Research, Monitoring and Reporting .................................................................... 53
Coordination, Public Engagement and Aboriginal Community Engagement ........ 54
Advisory Committees under the Lake Simcoe Protection Act, 2008 .................... 54
FinancingStrategy ............................................................................................... 55
PlanAmendments ................................................................................................ 55
EBR Registry Number 010-4636
Draft Lake Simcoe Protection Plan
Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 3 of 55
FeTSTP I MITJ a q * , -*
Ms. Liz Unikel
Senior Policy Coordinator
Ministry of the Environment
Environmental Programs Division
Lake Simcoe Project Team
55 St. Clair Avenue West
Floor 7
Toronto ON M4V 2Y7
[D �_�M "92-1
Re: Draft Lake Simcoe Protection Plan - EBR Posting No. 010-4636
On behalf of the Lake Simcoe Region Conservation Authority (LSRCA), we wish to
express our congratulations to the Province of Ontario on the draft Lake Simcoe
Protection Plan (LSPP). We appreciate the opportunity to provide the province with our
comments on the draft Plan through the Environmental Bill of Rights Registry.
The LSRCA was created in 1951 under the Conservation Authorities Act. Based on
Section 20 of the Conservation Authorities Act our mission is "to provide leadership in
the restoration and protection of the environmental health and quality of Lake Simcoe
and its watershed with our community, municipal, and other government partners."
Today we represent an organization which focuses on integrated watershed
management throughout Lake Simcoe and its watershed. We have a staff of over 80
multi -disciplinary experts focused on science, research, flood forecasting and warning,
flood control, regulations, environmental planning, enforcement, source water
protection, sub watershed planning, land securement and management, stewardship,
forestry, communications and curriculum based environmental education with a focus
on the watershed.
Given our long history in integrated watershed management in the Lake Simcoe
watershed, we are respectfully submitting a series of recommendations to the province
which we believe to be critical to the success of the Plan. Included in these are
recommendations to undertake a Phosphorus Reduction Strategy as a clear priority for
Plan implementation. The development of sub -watershed phosphorus loading targets
should be completed with the expertise of the Lake Simcoe Region Conservation
Authority as a lead in this part of the strategy.
EBR Registry Number 010-4636
Draft Lake Simcoe Protection Plan
Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 4 of 55
The LSRCA has also developed a Natural Heritage Strategy with municipal support and
funding. We strongly believe that this Strategy should be incorporated into the Plan as
opposed to duplicating effort by developing a new strategy at the expense of both time
and taxpayer dollars.
Further, the Authority has a long and successful history in watershed stewardship. A
leadership role in implementing the watershed stewardship projects should be reflected
in the Plan.
In addition, we support the Plan's reflection of the lead role of the LSRCA in the sub -
watershed planning process.
We applaud the province for its vision for Lake Simcoe and want to express our desire
to assist in the implementation of the Plan to our fullest extent. In many ways, the draft
Plan reflects the philosophy, goals and objectives of the Conservation Authority's
Strategic Plan, Business Plan and Comprehensive Basin Wide Plan for the watershed.
We have provided our comments on the LSPP on a chapter by chapter basis. In each
Chapter we have provided comments which follow the format of the Plan as follows:
• Context
• Key Facts
• Targets
• Indicators
• Policies
• Recommendations.
We look forward to working with the province throughout the consultation process and
implementation of the Plan.
Yours truly,
Councillor Virginia Hackson, Chair
Lake Simcoe Region Conservation Authority
c: Conservation Ontario
Watershed Municipalities
EBR Registry Number 010-4636
Draft Lake Simcoe Protection Plan
Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 5 of 55
Chapter One: Ecological Health of Lake Simcoe and its Watershed
Chapter One of the draft Plan focuses on the "Ecological Health of Lake Simcoe and its
Watershed". It is important to note that the watershed contains many significant
features. Noteworthy among them is the Oro Moraine which does deserve mention in
this chapter (as noted on page 3).
Obiectives of the Plan:
The objectives of the Plan build upon the goals of the former Lake Simcoe
Environmental Management Strategy (LSEMS) partnership which existed from 1990 to
2007. We are pleased to see that this excellent work will be used as a foundation for
the new vision and Plan.
We generally concur with the objectives of the Plan. We understand the need to
promote environmentally sustainable land and water uses (as noted on page 6), and
would recommend that development practices within the watershed require
environmentally sustainable land and water uses.
Principles to Guide Our Efforts:
We would recommend that the term "ecosystem approach" (as noted on page 6) be
defined in the Glossary.
Further, in addition to adaptive management approaches, a principle should be added
to endorse continued use of established Best Management Practices within the
watershed.
Priorities for the Plan:
While we agree with improving ecosystem health (as noted on page 7); we would
suggest that the protection of all key natural heritage features be noted as one of the
priorities of the Plan (please refer to Chapter 6 for more detailed comments from
the I-SRCA on natural heritage).
It is recommended that sustainable growth management in the Lake Simcoe basin be
added to page 7 as a priority of the Plan.
EBR Registry Number 010-4636
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Comments from the Lake Simcoe Region Conservation Authority
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Page 6 of 55
Legal Effect of the Plan and Transition:
In relation to the legal effect of the Plan and the transition (as noted in pages 8 and 9), it
is recommended that the Ministry have specific discussions with the LSRCA with regard
to how this will impact our mandate. Specifically, Section 28 permits under The
Conservation Authorities Act will be a "prescribed instrument". The impact of this on the
Authority will require more detailed discussions.
Recommendations:
THAT Chapter One of the Lake Simcoe Protection Plan include reference to the Oro
Moraine, require that developments address environmentally sustainable land and
water uses, define "ecosystem approach", reference that best management
practices continue as a key principle and add high priority focuses on key natural
heritage features and sustainable growth management.
THAT the province host more detailed discussions with the Lake Simcoe
Region Conservation Authority regarding the impact of the Act, Plan and
Regulations on Section 21 and 28 of the Conservation Authorities Act.
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Comments from the Lake Simcoe Region Conservation Authority
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Page 7 of 55
Chapter Two: Building On Past Actions
Lake Simcoe Environmental Management Strategy (LSEMS):
The province has indicated that the Lake Simcoe Protection Plan (LSPP) would be
based on the excellent work completed by the Lake Simcoe Environmental
Management Strategy (LSEMS) partnership as a foundation. As such, it is
recommended that Chapter Two on the LSEMS partnership be further refined.
The LSEMS Implementation Partnership started in 1990 as a Cabinet endorsed
initiative with four agencies — MOE, MNR, MAFRA and LSRCA. Both MMAH and MEI
joined the partnership later (see page 11). The LSEMS Phase III Summary Report
(LSEMS, 2007) contains a history of all three phases of the partnership. Further, a
detailed progress report and list of accomplishments is included in the report. This
would be an excellent reference to include some key accomplishments on page 11 of
the Plan, such as the fact that phosphorus loadings were substantially reduced and
dissolved oxygen was increased during the LSEMS partnership.
Intergovernmental Action Plan (2006):
The draft Lake Simcoe Protection Plan refers to the Intergovernmental Action Plan
(IGAP) and the Assimilative Capacity Study (ACS) for Lake Simcoe (as addressed on
page 11). It is important to note in the Plan, that the ACS Study was completed by the
Lake Simcoe Region Conservation Authority with the Nottawasaga Valley Conservation
Authority.
Agricultural and Community Actions:
The LSPP has a section which outlines Agricultural and Community Actions (as noted
on page 12). Although the Plan addresses provincial support for these sectors, it does
not outline the significant support provided by the LSRCA and its watershed
municipalities under the Landowner Environmental Assistance Program (LEAP). Since
1990, more than 950 projects have been completed under this program leading to a
reduction of more than 17 tonnes of phosphorus from entering the lake annually. This
program has been administered by the LSRCA with the guidance of the Durham, York
and Simcoe Chapters of the Ontario Federation of Agriculture. The LSRCA program
should be noted on page 12 of the Plan.
Municipalities and the Lake Simcoe Region Conservation Authority:
Both municipalities and the LSRCA have made significant program contributions and
investments which have had a positive impact on the lake and its watershed (as noted
on page 12). Each of these agencies also has its distinct mandate. As such, it is
recommended that two separate sections be allocated in Chapter of the Plan for these
agencies.
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_r�l Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 8 of 55
Although the LSRCA has completed substantial work with municipalities regarding
stormwater, as noted in the Plan on page 12, its mandate and mission revolve around
the health and protection of Lake Simcoe and its watershed. Section 20 of The
Conservation Authorities Act outlines that the objects of the Authority are to "establish
and undertake, in the area over which it has jurisdiction, a program designed to further
the conservation, restoration, development and management of natural resources,
other than gas, oil, coal and minerals." Since 1951, the LSRCA has developed an
extensive program, as follows:
Science and Research
Watershed and sub watershed planning
Natural Heritage studies, strategies and mapping
Source water protection
Watershed, lake and nearshore monitoring and reporting
Stormwater management strategies
Protection and Restoration
Flood Warning and Forecasting
Flood Plain Mapping
Plan Input and Review
Development, Interference with Wetlands and Alteration to Shorelines and
Watercourses Regulations
Regulations Enforcement
Watershed Stewardship (including the Landowners Environmental
Assistance Program)
Forest Management
Land Securement
Land Management
• Education and Outreach
Curriculum based environmental education, focusing on the lake and
watershed
Education outreach
Communications
Watershed Report Card.
LSRCA programs are delivered through a multi -disciplinary team of over 80 individuals
reporting to a Board of Directors appointed by watershed municipalities. Further,
watershed municipalities have a trusted, direct and invested relationship with the
LSRCA to complete the integrated watershed management program as noted above.
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Page 9 • 55
THAT a detailed overview of the LSEMS partnership, accomplishments and key
reference reports be outlined in the Lake Simcoe Protection Plan.
THAT the Lake Simcoe Protection Plan indicate that the Intergovernmental Action
Plan - Assimilative Capacity Study was completed for the Province of Ontario by the
Lake Simcoe Region Conservation Authority with the Nottawasaga Valley
Conservation Authority.
THAT the Lake Simcoe Protection Plan reference the significant agricultural and
community stewardship programs completed and currently offered by the LSRCA,
with financial assistance from its federal, provincial, municipal, and public partners
along with the Lake Simcoe Conservation Foundation.
THAT the Lake Simcoe Protection Plan contain a separate section in Chapter Two
addressing the role and responsibilities of the Lake Simcoe Region Conservation
Authority.
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"('bz) Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 10 of 55
Chapter Three: Aquatic Life
Chapter Three of the LSPP introduces a key target for the Plan — dissolved oxygen
(DO) of 7mg/L. This is a critical foundation for the Plan. While the proposed target of
7mg/L (as noted on page 16) is potentially a good target, information is required
regarding the feasibility studies and/or analyses which have been done to evaluate
whether this target is achievable. Results from the LSRCA led Assimilative Capacity
Study indicated that with approved growth and full implementation of Best Management
Practices (BMP's) costing approximately $163 million, the lake could maintain the status
quo of approximately 5mg/L DO and on average 75 tonnes of phosphorus per annum.
Although the Plan addresses the coldwater fish communities, warm water species are
also crucial to the economic and social aspects of the fishery and could be better
described in the Plan.
Tributary contributions flowing into the lake represent a critical component to achieving
targets. This should also be noted in the context of this section of the Plan.
Tar -get:
The proposed dissolved oxygen target of 7 mg/L should also identify and describe a
corollary phosphorus target as they go hand in hand (as noted on page 17).
It is important to define what time of year (ie. late summer/fall) and where (ie.
hypolimnion) measurements will be taken regarding the DO target. It is possible to
have 7mg/L in the early/late spring but this is not the appropriate time to evaluate
against the target.
Recent scientific investigation has clearly indicated that specific areas of Lake Simcoe
represent high value or greatest sensitivity to loadings from phosphorus. We
recommend consideration of specific phosphorus loading and dissolved oxygen targets
be developed for three distinct areas of the lake — Kempenfelt Bay, Cooks Bay and the
Lake Simcoe main basin.
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Comments from the Lake Simcoe Region Conservation Authority
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Page 11 of 55
Page
Policy
Comments
Recommendations
17
3.1 -SA
This policy outlines the development of Fish
That Fish Community Objectives
Community Objectives for Lake Simcoe and its
include objectives for both
tributaries. The LSRCA concurs with this
coldwater and warmwater species.
policy, however, it is not clear if this includes
all game fish including warmwater species.
17
3.3 -SA
The value of the fishery is a driving force in
That, given the importance of the
recognizing the need for continued work to
fishery, the socioeconomic
protect and restore the lake. This policy calls
evaluation of the monetary and
for the development of a socioeconomic
ecological value of the aquatic
evaluation of the monetary and ecological
resources in the Lake Simcoe
value and impact of the aquatic resources
watershed be initiated immediately
within the Lake Simcoe watershed by 2010.
upon Plan approval.
That the socioeconomic
evaluation of the aquatic
resources should include a
cultural value component.
17
3.4 -SA
Policy 3.4 outlines that beginning in 2010, a
That baseline mapping of aquatic
baseline mapping of aquatic habitats in Lake
habitats commence immediately
Simcoe and its tributaries should commence.
upon Plan approval as some work
has already been completed by
the LSRCA and MNR.
17
3 -5 -SA
Policy 3.5 indicates that MNR, MOE and other
That the LSRCA be specifically
partners will conduct research projects on the
mentioned as an agency that
aquatic communities of Lake Simcoe and its
conducts research projects on
tributaries.
aquatic communities across the
basin in addition to MNR and
MOE.
17
3.6-M
Policy 3.6 which addresses the development
That the annual aquatic
and implementation of an annual aquatic
community monitoring program
community monitoring program, is lake centric
include the main lake, inland lakes
and does not adequately address tributaries
and tributaries.
and inland lakes.
That components of the annual
aquatic community monitoring
program include elements such as
tributary aquatic habitat,
geomorphic monitoring, and
macro phytes.
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Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 12 of 55
Chapter Four: Water Quality
Context:
Chapter Four on Water Quality focuses further on targets and objectives which will
support addressing the dissolved oxygen target of 7mg/L.
Targets within any plan should be "SMART"
and time bound. Further work on SMART
required within the LSPP.
- specific, measurable, achievable, realistic
goals, objectives, targets and policies is
The Lake Simcoe Phosphorus Sources pie chart (page 22) contains data up to 2003.
As new data produced since 2003 may impact the targets established in the Plan, they
should be incorporated when published, or at least a publishing date should be
referenced to in the Plan. This will alert the reader to understand that the data is
produced annually, analysed during certain timeframes and are subject to change due
to enhanced information.
Key Facts:
The first bullet point under key facts should indicate that the phosphorus reductions to
67 tonnes annually were achieved from 1990 to 2007 under the LSEMS partnership.
Targets:
This section of the Plan introduces the relationship of the dissolved oxygen target of
7mg/L to a phosphorus (P) loading target of 44 tonnes per year. To place the P loading
target in context, it would be valuable to outline a pre -settlement P load on page 24 (as
referenced in LSEMS Implementation Technical Report No. IMP.B.17, 1995). The
target is specific in terms of SMART objectives. Further discussion on how the target
is measured and achieved within the timeframe of the Plan is required.
Recommendation:
THAT the Plan contain a statement regarding the current state of analysis of phosphorus
loading from 2003 to the present.
THAT the Plan contain a reference that phosphorus loads decreased from 1990 to 2007, under
the LSEMS partnership from, on average 100 tonnes per year to 67 tonnes annually.
THAT the Plan reference to pre -settlement phosphorus loads to Lake Simcoe be included (as
referenced in LSEMS Implementation Technical Report No. IMP.B.17,1995).
THAT a basin wide water quality strategy be completed, which will be used to refine water
quality targets based on SMART criteria — specific, measurable, achievable, realistic and time
bound. Specifically, the strategy should identify the total phosphorus reduction available
within the watershed, the cost to achieve the reductions, the time needed to implement the
activities and the relative cosAbenefit ratio associated with each activity.
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Draft Lake Simcoe Protection Plan
Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 13 of 55
Beach postings occur when a geometric mean population of e.coli exceeds 100
organisms per 100 ml in recreational surface waters. Currently there are no strategies
to identify or address bacterial contamination of surface water impacting beaches within
the basin. In fact the current monitoring program does not include any microbiological
indicators.
Recommendation:
THAT a monitoring program focused on beach areas prone to closures be initiated to
identify and quantify sources of e.coli contamination whereupon a strategy be
devised which would address these sources to achieve the beach posting target.
The target to reduce contaminants to levels that achieve the Provincial Water Quality
Objectives (PWQO) is outlined on page 24. Indicators are then identified; however, the
indicator is not matched to the current PWQO.
Recommendation:
THAT the Provincial Water Quality Objectives (PWQO) values be inserted into the
Indicators component of the Water Quality section of the LSPP so that agencies are
held to a numerical goal rather than a broad statement when evaluating progress.
Policies:
Page
Policy
Comments
Recommendations
25
4.1 -DP
Sewage Treatment
That Policy 4.1 regarding sewage
The province already requires that expansion
treatment plants should reference
to any sewage treatment plant (STP) within
the current state of sewage
the Lake Simcoe watershed undergo an
treatment plant expansions.
Environmental Assessment.
Furthermore, municipalities are only allowed to
approve growth within settlement areas based
on existing and available servicing.
25
4.3-13P
Sewage Treatment
That Policy 4.3 -DP section b) on
This Policy limits the creation of sewage
sewage treatment plants should
treatment plants except for the purposes of
address sewage services where
servicing development currently on subsurface
the majority of effluent is
septic systems or where subsurface systems
recycled and reused and not
are failing. This policy should consider
discharged to surface waters.
allowing the creation of STP's where there is
no discharge to the lake or surface waters: for
example an STP where the discharge water is
reused or recycled.
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Pnnm id of r,1;
Page
Policy
Comments
Recommendations
Both municipal and industrial (ie paper) Sludge
That both municipal and industrial
disposal and spreading has not been
paper sludge disposal and
addressed in the Plan.
spreading information be outlined
and addressed in the Plan.
25
4.5 SA
Stormwater Management
Requires that municipalities in collaboration
That the Province be requested
with the LSRCA complete stormwater
to provide more guidance on the
management master plans within five (5) years
contents of stormwater
of the Plan taking effect. The policy then
management master plans.
outlines in subsections the works needed to be
done. The following outlines areas that will
That the Province provide
need to be addressed:
funding to the municipalities and
the LSRCA to complete
1. The responsibility for funding the
stormwater management master
development of the stormwater
plans and projects.
management master plans should be
identified.
That MOE provide guidance on
2. Section c) determination of
climate change in relation to
effectiveness of existing stormwater
preparing stormwater
management including potential
management master plans.
impacts of climate change assumes
that we have an understanding of the
impacts of climate change. This is not
yet the case.
Environmental Assessment processes are a
That the municipal class EA
barrier to completing retrofits. They are
process be amended to permit
expensive and time consuming and
efficient implementation of
sometimes impact the success of
stormwater management
implementing stormwater management
projects.
projects.
26
4.6 -SA
Stormwater Management
That the province fund the
Stormwater retrofits are currently occurring
LSRCA to establish a Stormwater
throughout the watershed and would benefit
Management Assistance
from some provincial funding assistance and
Program, in combination with
greater efficiencies in the process
municipal and other funding
requirements.
sources, to complete urban
stormwater retrofit projects.
26
4.7 -DP
Stormwater Management
That the Province provide
The intent of this policy to incorporate policies
financial assistance to the LSRCA
in official plans to reduce stormwater runoff is
for research and testing of new
supported. However funding for research and
and innovative stormwater
testing innovative stormwater management
management measures.
measures is needed.
That new technical guidelines by
Provincial policy regarding stormwater needs
MOE for Stormwater Management
to be updated. Specifically, the Stormwater
Planning and Design be created
Management Planning and Design Manual -
based on water sensitive urban
2003 requires updating. A new process
design principles for more
incorporating water sensitive urban design to
sustainable development.
C• •-i Number 010-4636
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Comments from the Lake Simcoe Region Conservation Authority
•• 12, 2009
•- • 5.9;
Page
Policy
Comments
Recommendations
ensure more sustainable development needs
to be undertaken not just for Lake Simcoe but
for the entire province.
27
4.9 -DP
Stormwater Management
That new technical guidelines for
Section (b) of this policy does not apply if
Stormwater Management
proposed stormwater management works are
Planning and Design be created
intended to serve an infill development or
by MOE within one year of Plan
redevelopment. The LSRCA does not concur
approval and be referenced as a
with this policy as this could lead to further
policy initiative.
water quality impairment.
That where infill development or
It is understandable that infill or redevelopment
redevelopment cannot comply
may not be able to meet enhanced controls;
with stormwater controls
however they should then undertake best
outlined in policy 4.9 (a), best
efforts at a minimum.
efforts be initiated to maximize
water quality control from the
site.
26
4.10 -DP
Stormwater Management
That a detailed schedule and cost
Inspecting and maintaining stormwater works
estimate to maintain existing and
is endorsed. The greater issue is the process
proposed stormwater ponds be
and cost associated with maintaining
completed as part of the LSRCA
stormwater management facilities.
SWM Strategy.
A detailed cost estimate for maintenance
should be prepared. Based on 199 existing
That the Province provide
stormwater management facilities in the
financial assistance to
watershed, the LSRCA estimates the cost to
municipalities to maintain
be in the tens of millions of dollars. Provincial
stormwater facilities.
financial assistance is required to address this
policy area.
28
4.14 -SA
Subsurface Sewage Treatment
That the province clarify who will
The policy should address and Identify who
play the lead role in the septic re -
will be responsible for undertaking and funding
inspection program and how this
the on-site sewage maintenance re-
activity will be financially
inspections.
supported.
28
4.16 -DP
Subsurface Sewage Treatment
That the policy addressing new
This policy indicates that new septic systems
septic systems within 100 metres
within 100 metres of the shoreline will only be
of the shoreline, be expanded to
approved if the capacity does not exceed the
enable seasonal cottages that are
capacity of the original system.
now converted to fulltime
residences to upgrade faulty and
Despite this policy, numerous seasonal
non conforming septic systems
cottages have become full time residences. In
beyond original capacity.
these cases, the capacity of their septic
systems would need to increase in order to
accommodate the full time use. Older
systems requiring replacement would need to
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Pane 16 of 55
Page
Policy
Comments
Recommendations
address this issue.
29
4.17 -SA
Construction and Mineral Aggregate
That the three year timeline to
Resource Activities
complete an atmospheric
This activity indicates that MOE will complete,
deposition study from
within three years, a study to identify sources
construction and mineral
of atmospheric deposition contributing to
aggregate activities be reduced
phosphorus loading to the lake from
and that interim measures be
construction and mineral aggregate activities.
considered such as:
This is an area where immediate gains could
0 Installing windbreaks
be made in the absence of policy through
0 Evaluating and
stewardship initiatives or municipal by-laws.
implementing dust
controls for the aggregate
and development
industries.
29
4.20 -SA
This policy recommends that the mineral
That the province require the
aggregate resources industry is encouraged to
mineral aggregate resources
adopt best management practices to reduce
industry to adopt best
water quality impairment. If targets are to be
management practices to reduce
met, industries should be required to adopt
water quality impairment.
such practices.
29
4.21 -DP
Policy 4.21 requests that vegetation removal
That the province define
be kept to a minimum as part of the
minimum removal of vegetation
subdivision and site plan agreement.
and develop sediment and control
guidelines for construction
activity within the watershed.
30
4.25 -SA
Policy 4.25 is a critical policy which requires
That the Phosphorus Reduction
the development of a Phosphorus Reduction
Strategy be a clear priority for
Strategy within one year of the date the Plan
implementation and outline roles
comes into effect. This should be the first
and responsibilities, ensure no
strategic action for this Plan; without the
duplication occurs, incorporate
strategy P reduction will not be efficiently
SMART goals, objectives and
achieved.
targets and provide a clear
indication and commitment of
funding sources to achieve the
strategy.
That the development of sub -
watershed phosphorus loading
targets be completed by the
LSRCA as part of the Phosphorus
Reduction Strategy with funding
Policy 4.25 (b) regarding the Growth Plan for
from the province.
the Greater Golden Horseshoe could result in
environmental degradation of Lake Simcoe.
That growth only proceed if
environmental targets for Lake
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Pana 17 of -9;,;;
Page
Policy
Comments
Recommendations
This policy statement may contradict
Simcoe and its watershed are
subsection 25 of the Lake Simcoe Protection
being achieved and maintained.
Act.
The findings of both the ACS and the IGAP
concluded that, at best, maintaining the status
quo target of 75 metric tonnes per annum is
only feasible with investment of approximately
$163 million for Best Management Practices.
Adding the projections from the Provincial
Growth Plan may supersede the status quo
target of 75 tonnes making the achievement of
the proposed annual P target of 44 tonnes
highly unlikely.
It appears that the timeline of one year related
to Policy 4.25 paragraph (c) item (v) may
conflict with the 3 year timeline denoted on
page 29 - policy statement 4.17 -SA.
4.25 (c) should include internal sources of
phosphorus loading.
'!N
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Comments from the Lake Simcoe Region Conservation Authority
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Page 18 of 55
Chapter Five: Water Quantity
The context regarding the Water Quantity section of the LSPP addresses the
importance of source protection planning under The Clean Water Act, 2006.
The Lake Simcoe Region Conservation Authority is pleased to be facilitating the
completion of a source protection plan for the Lake Simcoe watershed and beyond on
behalf of the Province. A recent "Partnership Information Exchange" with the Province
acknowledged that the LSRCA is completing its source water tasks with excellence.
Tar -gets:
There is no reference to targets for water quantity contrasting the previous Chapter Four
on Water Quality. Targets for water quantity are being developed by the LSRCA to
ensure that in -stream environmental flows should be maintained while providing for
water users within the watershed, subwatershed, and catchment's level. These targets
are being developed in concert with the previously indicated SMART criteria - specific,
measurable, achievable, realistic and time bound.
Challenges encountered with completing this task include the permit to take water
approval process which only requires permits for takings over 50,000 L per day and the
fact that general water taking does not require a permit. The cumulative impact from
these takings may or may not be significant. In addition, targets cannot be developed
until such a time as the modeling activities initiated under Source Water Protection are
completed. Any targets developed need to be vetted scientifically and through a public
process and should be reviewed every two to three years to see if they need to be
adjusted based on changes in climate or current water consumption. Enforcement of
water takings will be an integral task to ensure that targets are achieved. Without an
active enforcement presence there is no purpose in developing water targets.
Indicators:
The Water Quantity section outlines two key indicators:
• maintenance of stream flow and specific base flow targets, and
• effective water conservation and efficiency plans.
The second indicator (water conservation/efficiency measured through reductions in
peak demand and water use per capita) is relevant only to part of the process impacting
stream flows and base flows (demand). Further, water efficiency and conservation has
historically been viewed as a 'source' of water in municipal planning (water 'savings'
allows for growth without seeking new water supplies).
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THAT an alternative or additional indicator of water quantity be added to the Plan to
evaluate the total quantity of available water (similar to Tier 1 and Tier 2 water budgets)
and measure water consumption against that available amount, which also considers in -
stream flow needs.
THAT the LSPP include a water quantity indicator that speaks to the maintenance of
groundwater recharge to reflect the importance of recharge areas in the maintenance of
base flows (e.g. proportions of pervious cover by subwatershed, proportion of significant
recharge area under pervious cover, or measured recharge mitigation in urbanized areas).
The Plan does recognize the need for water conservation and efficiency plans and the
province needs to be commended for this. The fact that all of these recommendations
are Strategic Actions instead of Designated Policies, however, is cause for concern.
Without Designated Policies for Water Quantity, other than for recreation, water takings
will be largely uncontrolled and the setting of targets cannot be enforced.
Page
Policy
Comments
Recommendations
34
5.1 -SA
Water Supply
The province is suggesting that they will
That the policy to develop in -
develop in -stream targets for stressed
stream flow targets for water
subwatersheds within 2 years of the Plan
quantity include the LSRCA given
approval. The timeline is appropriate however
their role in source water
the scope and implementing agency is not.
protection, flood plain mapping
and low water response.
The Authority is currently completing in -stream
flow targets as part of the subwatershed
That the Authority enter into
planning initiative. Data gaps still exist but
discussions with MOE and MNR
progress has been made to fill these and
to undertake in -stream flow
produce the modeling tools necessary to
targets on their behalf dependant
undertake the required analysis. These tools
upon appropriate compensation.
currently reside with the LSRCA.
That in -stream flow analysis
The Source Protection Committee (SPC) for
should be completed for all
the Lake Simcoe watershed has expressed
subwatersheds and catchments
concern regarding their involvement with
within the Lake Simcoe basin, not
development of the Plan's policies for
just those currently under stress.
subwatersheds that are stressed and have
municipal water supplies (i.e. those where
That policies developed by the
policies may be recommended in the local
Source Protection Committee as
Source Protection Plan). The SPC is
part of the Source Protection Plan
concerned that duplication of process not
should form the foundation of
occur as a result of The Clean Water Act and
policy direction regarding in -
The Lake Simcoe Protection Act
stream flow targets.
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Paoe 20 of 55
Pae
Policy
Comments
Recommendations
35
5.2 -SA
Water Supply
The Plan recommends that municipalities
That the Authority enter into
complete Tier 2 water budgets in stressed
discussions with MOE, MNR and
subwatersheds within the basin. Given the
municipal partners to undertake
extent of stressed systems within the
Tier 2 water budgets on their
watershed, this exercise should be completed
behalf dependant upon
for all subwatersheds.
appropriate compensation.
Given that the MOE/MNR are developing in-
That in -stream flow targets as
stream targets, it would be helpful to evaluate
outlined in Policy 5.1 be
the Tier 2 water budgets against those targets
completed within one year of the
(i.e. finish those efforts before the Tier 2 water
date of the Plan coming into
budgets are completed).
effect, in order that the two year
time frame outlined in Policy 5.2
can be achieved.
35
5.3 -SA
Water Conservation and Efficiency
The LSRCA could assist the municipalities
That the Authority approach
listed who are required to undertake water
municipal partners to undertake
conservation plans, given our past role in
an analysis of water conservation
assisting municipalities (York and Durham).
plans on their behalf dependant
upon appropriate compensation.
The policy is a strategic activity therefore
many of the municipalities may not want to
That the province provide
comply with the recommendation and are not
municipalities with funding to
being regulated to do so.
complete water conservation
plans as an incentive to complete
this activity.
36
5.4 -SA
Water Conservation and Efficiency
5.5 -SA
Policies 5.4 and 5.5 recommend that IVIAFRA
That given the LSRCA's role in
assist and encourage water conservation in
the Ontario Drinking Water
the agricultural community. As these
Source Protection Early Actions
recommendations involve stewardship and
Program, it co -lead the
outreach, the Authority could assist in this area
agricultural water conservation
given our long standing stewardship program.
program with MAFRA.
LSRCA has almost 30 years of experience in
working with the agricultural community in the
watershed, and implementing projects that
benefit the watershed and the farm operation.
The LEAP program (formerly LSWQIP) was
developed in partnership with the local OFA
chapters, and continues to support on-farm
projects. On-farm projects have been
completed in partnership with the EFP, and
through consultation with OMAFRA and
OSCIA.
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Draft Lake Simcoe Protection Plan
Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Paae 21 of 55
C�
n'
Page
Policy
Comments
Recommendations
Gathering information on water takings not
That the province identify
requiring a permit would also be useful to fill a
duplication of efforts in
major data gap within the basin.
stewardship programming and
provide streamlining to ensure
effective and efficient delivery of
the prog am.
36
5.6 -DP
Water Conservation and Efficiency
Major recreational users are being required to
That all major water users be
undertake mandatory water use plans. It is
required to undertake mandatory
recommended that other major users such as
water use plans.
the aggregate industry, sod farms, muck
farmers, who use large amounts of water
That the Province define major
require a water use plan.
water users.
That monitoring of water takings
Section (g) is captured in water quality under
be mandatory as part of the Plan.
stormwater management.
That the cumulative impact of
water taking across the basin be
assessed.
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Draft Lake Simcoe Protection Plan
Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 22 of 55
Chapter Six.- Shorelines And Natural Heritage
Context:,
The Plan speaks to developing a consistent approach for the protection of Natural
Heritage. To achieve this the Plan's policies will need to dovetail with those of the
Greenbelt Plan and the Oak Ridges Moraine Conservation Plan.
There are significant aspects of the Plan, and specifically of the recommended policies
in Chapter 6 that relate to wetlands. It is critical the definition of Wetlands under the
LSPP is consistent with Ontario Regulation 179/06 — the Authority's regulation that
deals with the alteration to wetlands.
On page 41 of the LSPP, the Conservation Authorities Act permits are not limited by the
glossary terms 'development' or 'site alterations'. This sentence could cause
misrepresentation of the extent of the regulatory authority for the LSRCA.
There has been significant natural heritage work completed by the LSRCA including
detailed Ecological Land Classification (ELC), natural heritage land use mapping, and
the development of the Lake Simcoe Natural Heritage System (2007). This work provide
s for the first basin wide strategy to protect natural heritage features which is also built
on the foundation of the Provincial Policy Statement (PPS) to ensure integration with
provincial policy. Municipalities have supported this system both financially and in terms
of supporting its content and significant consultation and support from many
stakeholders has been achieved.
Recommendation:
THAT the LSPP recognize the LSRCA's significant work completed on developing an
Ecological Land Classification System (ELC, natural heritage mapping and Lake
Simcoe Natural Heritage System Report (2007)) and that the LSRCA's work be
endorsed as the system to be used in the LSPP in order to ensure that duplication of
effort and expense does not occur.
Descriptions of the term 'natural heritage' in the LSPP should be consistent with the
Provincial Policy Statement (2005).
We believe that the LSPP would benefit from the insertion of a table, such as the one
found in the ORMCP (page 58) which lists the requirements under the Lake Simcoe
Protection Plan.
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Draft Lake Simcoe Protection Plan
Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 23 of 55
An example of a table of related legislation that would be beneficial in the Plan is as
follows:
Level of Regulatory
Approval
Agency
Legislation
Type of Work
Federal
Department of
Fisheries Act
Work within a
Fisheries and Oceans
watercourse that
Canada
would have an impact
on the movement of
fish or would result in
an alteration to their
habitat
Local
Municipality
Municipal Act
Grading and Site
Alteration By-laws
Recommendation:
THAT the legislation which is applicable to the Lake Simcoe Watershed be listed in a
table with a description of the level of regulatory approval (e.g. federal, provincial, local);
the agency responsible (e.g. MNR, MOE, MMAH, DFO, CA); the legislation (e.g. Fisheries
Act, Lakes and Rivers Improvement Act, Aggregate Resources Act, Ontario Water
Resources Act, Environmental Protection Act, Oak Ridges Moraine Conservation Act
and Plan, Municipal Act, Conservation Authorities Act, Greenbelt Act and Plan, Places to
Grow Act and the Growth Plan, Environmental Assessment Act) and a description of
approval required under the various pieces of legislation.
As the lake level fluctuates by approximately 0.5 metres on a yearly basis, the location
of the shoreline also changes depending on the month of the year. The elevation of
219.15 masl is the value that has been used by the Department of Fisheries and
Oceans (DFO) and the LSRCA for a number of years.
The Plan indicates that the Lake Simcoe shoreline will be protected and restored
through a vegetative buffer. Approximately 3% of the shoreline is in public ownership.
Establishing protection policies will assist in the reduction of loss of this important
ecological unit. Restoration on private lands can be a challenge and incentive funding or
tax reduction strategies may be required to achieve this work.
Policies 6.20 to 6.28 outline how to address Key Natural Heritage Features (KNHF) very
clearly. These sections outline the permitted uses, specify that KNHF policies are not
triggered in settlement areas (similar to the Greenbelt Plan), define the Minimal
Vegetation Protection Zone (MVPZ) and require a Natural Heritage Evaluation (NHE)
when proposals are within 120m. There are also stipulations (e.g. restoration and
enhancement plans) to follow if development is permitted within the 120m. The
requested restoration within 30m of KNHF's and adjacent areas is an improvement on
other applicable Plans and Regulations in place within the watershed.
EBR Registry Number 010-4636
Draft Lake Simcoe Protection Plan
Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 24 of 55
Climate change also affects the frequency and intensity of rainfall events. Rainfall
events in recent history have been of high intensity and short duration, which has
caused significant flooding events. These flooding events have resulted in significant
damages including the failure of shorelines and streambanks — resulting in the delivery
of more sediment to watercourses — this sediment also serves as a transport
mechanism for non -point source pollutants and nutrients to area water bodies.
That the LSPP contain definitions for key natural heritage features, key hydrologic
features, significant recharge areas, vegetation protection zones, and low intensity
recreational uses.
Targets and Indicators:
We would recommend that the Plan define the difference between natural shorelines
and naturalized riparian areas on Lake Simcoe.
The targets would also benefit from being more specific, measurable, achievable,
realistic and time bound.
Roles and responsibilities should be further defined, for example for the responsibility
for identifying 'high quality' habitat should be addressed, as well as who will monitor
change over time and how "integrity' measured?
The Plan concludes that the landscape is significantly fragmented. A target regarding
"degree of fragmentation" would be beneficial.
Currently, the designated policies reflect Planning Act requirements, which do not
address the regulatory authority of Section 28 of the Conservation Authorities Act
Recommendations:
That all policy statements in the LSPP's Chapter on Shorelines and Natural Heritage
be reviewed in light of Section 28 of the Conservation Authorities Act.
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Draft Lake Simcoe Protection Plan
Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 25 of 55
Page #
Policy #
Comments
Recommendations
43
6.1 - DP
Lake Simcoe Shoreline
A plan showing all existing "Existing
That policies in relation to the Lake
Settlement Areas" and "Shoreline Built-
Simcoe shoreline be consistent with
Up Areas" should be provided.
Section 28 of the Conservation
Authorities Act.
Policy 6.1 a. should read: "Forest (in
accordance with provincial silviculture
guidelines and by members of the
Ontario Professional Foresters'
Association (OPFA), fish and wildlife..."
43
6.1 c.- DIP
The clause on prohibiting the
That Policy 6.1 c. include the
construction of stormwater retrofits is a
construction of retrofit stormwater
potential barrier to water quality
management facilities as a permitted
improvement.
activity.
43
6.1 d. - DP
This policy refers to infrastructure
That Policy 6.1 d. recommend that
development outside settlement areas.
Infrastructure include the
requirement for review under the
Environmental Assessment Act.
43
6.1 e. - DIP
It would be useful to have definitions for
`low intensity recreational use' and
`natural heritage appreciation'.
Clarity is required on whether this Policy
includes the construction of
boathouses, decks, and storage sheds
which would be an accessory use to an
existing cottage or home.
43
6.2 - DP
A map or schedule showing all existing
"Existing Settlement Areas" and
"Shoreline Built -Up Areas" should be
provided.
The requirements and Terms of
Reference for the 'Natural Heritage
Evaluation' need to be established.
43
6.3 - DP
As this is a designated policy, roles,
responsibilities and lead(s) need to be
defined with regard to NHEs.
The requirements and Terms of
Reference for the 'Natural Heritage
Evaluation' need to be established.
r.
EBR Registry Number 010-4636
Draft Lake Simcoe Protection Plan
Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Pnmn 9r, eAf RI;
Paj=e#
Policy #
Comments
Recommendations
43
6.4 — DP
Roles, responsibilities and Lead(s) need
to be defined regarding shoreline policy
permitting.
A definition is needed far `structure'.
43
6.4 c. — DIP
While the use of pervious materials is a
good idea in general, there is the
potential that use of these materials
may not be suitable for all locations and
could result in geo-technical instability.
43
6.5 — DP
Clarity is required for the term 'adjacent
or close to Lake Simcoe'.
44
6.6 — DP
Clarity is required for the term 'minor
rounding out of the area'.
44
6.8 - bp
Policies Applying to both Lake
Simcoe and Streams
Clarity is required regarding the need
for the replacement of existing
That the Shoreline Management Plan
structures for a variety of reasons (e.g.
determine where structures,
fire, ice damage, age).
including boathouses should and
should not be allowed.
This section would allow raised
structures such as boathouses and non-
That the LSPP address policies
habitable storage buildings on piers to
related to historic lots of records
be built over the waters of Lake Simcoe
within both shoreline and stream
("in Lake Simcoe") subject to a number
regulated areas.
of conditions.
44
6.9 DIP
Clarity is required whether a vegetative
riparian area is mandatory.
44
6.10 DIP
It may be impossible to integrate
development or site alterations with
existing parks in existing developed
areas.
Clarity is required regarding the
statement 'shall not constrain ongoing
or planned stewardship and remediation
efforts'.
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Pana 27 of 55
Page #
Policy #
Comments
Recommendations
44
6.12 - SA
The completion of a Shoreline
Management Strategy should be a
That the Shoreline Management Plan
priority of this Plan and should be acted
be completed within one year of the
upon immediately with interim policies
date the Plan comes into effect and
established until it has been completed.
include collaborations with the
This information will be necessary to
federal government.
establish the Regulations noted in
Policy 6.15.
That the Shoreline Management Plan
be completed before shoreline policy
The LSRCA has commenced with this
statements are finalized.
activity.
45
6.14 - SA
Clarity is required whether funding will
be made available to assist landowners
to re -naturalize shorelines.
45
6.15 - SA
Proposed Shoreline Regulation
That the lead role for shoreline
regulation be clearly identified, that
Clarity is required whether consultation
no duplication occur with Section 28
will include MMAH, LSRCA and
regulations of the Conservation
municipalities regarding draft
Authorities Act and that enforcement
regulations under Section 26 of the
funding be provided to the LSRCA
LSPP.
for any identified enforcement role.
The LSRCA is presently regulating the
shoreline — clarity is required as to who
will be responsible for the new
regulation.
45
6.16 - SA
Definition is required for "on -land" areas
near the shoreline, and clarification is
needed on how far this area will extend
back from the shoreline.
The 'littoral zone' of Lake Simcoe is
vast and dynamic requiring further
clarity on this term.
45
6.17c. - SA
Policy 6.17 c. and on peat extraction in
wetlands and draining of wetlands
located under the heading of Proposed
Shoreline Regulation. It may be more
beneficial to move these policies to the
section on Key Natural Heritage
Features since wetlands are KNHFs
(bottom of pg.45). We understand that
the proposed shoreline regulation is
meant for the protection of shoreline
ecological functions, yet 6.17c. is
referring to all wetlands in the
watershed.
I(DFEBR Registry NumberO1O468O —
Draft Lake SimcoeProtection Plan
Commentmfm|hmLeke�imuo*RegionConmo�ionAutho�y
--- mwFebruary 12.2OOg
pnrl"9oAf C;R
Page #
Policy #
Comments
Recommendations
The definition of 'wetland' as defined in
the Plan does not lend itself to being
applicable to active peat extraction
sites, as the extraction area is often
devoid of hydrophytic vegetation
(therefore not meeting the definition of
wetland) while activities are ongoing.
Further discussion on this area is
45
6.17 e - SA
Clarity is required on whether the
removal of vegetation f rom the
shoreline applies to marinas.
It is recommended that the type of
shoreline protection or restoration
techniques and technologies be
described in the Plan.
45
6.18 - DID
Key Natural Heritage and Key
That the LSRCA's Natural Heritage
Hydrological Features
System be used as the foundation for
the Plan's policies on natural
The development and adoption of
heritage as the work has already
technical guidelines (and mapping) is
been completed and will avoid
key to the Plan's success, especially for
unnecessary duplication and
defining and regulating significant
expense.
woodlands. We would suggest that
the task of defining provincially and
watershed significant woodlands and
other KNHF has been completed
through LSRCA's NHS.
Other unique features such as fens,
bogs and alvars should be identified.
45
6.19 - DP
Discharge/ recharge areas and areas
of groundwater upwelling adjacent to a
stream should be included as key
hydrologic features.
46
6.21 - DP
Clarification is required if a minimum
vegetative protection zone (MVPZ) is
applicable for all KNHF regardless of
whether it is in an existing settlement
A
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Comments from the Lake Simcoe Region Conservation Authority
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P.nn 90 of RR
Page #
Policy #
Comments
Recommendations
46
6.23 — DP
The LSPP should indicate who will have
responsibility for reviewing Natural
Heritage Evaluations and ensuring that
the conditions are met and studies are
sufficient.
The requirements for the Natural
Heritage Evaluation should be included
as an appendix and reference should
be made to these requirements under
the appropriate policies (e.g. Policy
6.3).
47
6.24 — DP
It is recommended that the term "natural
self sustaining vegetation" be replaced
by "native, non-invasive, non-cultivar
plant species" as the first term (as per
Glossary definition) would appear to
allow non-native species and native
species to be used provided that the
native species dominate. This
comment applies to wherever the term
"natural self sustaining vegetation" is
used.
47
6.26 — DP
The reestablishment of vegetation as
part of construction activities should
also require maintenance for a period of
time to ensure the replaced vegetation
survives to a point to be self sustaining.
47
6.27 — SA
Policy 6.27 refers to the definition of key
natural heritage and hydrologic features
on the watershed.
As previously indicated, this work has
been completed with considerable
municipal funding, endorsement and
stakeholder consultation. This work
should not be duplicated.
47
6.28 - SA
The terms, 'natural areas' and 'adjacent'
need to be defined at a site-specific
level.
48
6.29 - IDP
Settlement Areas
Policies should be developed which
address the issue of requests for
settlement area expansions.
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Page 30 of 55
Page #
Policy #
Comments
Recommendations
49
6.37 a.- DID
Mineral Aggregates
A definition is required for significant
wetlands.
49
6.38 b.- DP
An enhanced definition is required for
restoration to provide greater clarity on
restoration works.
49
6.39 b.- DP
Losses of key natural heritage features
should be avoided.
50
6.40 d.- DP
Existing Uses
That the LSPP incorporate a new
A definition of "accessory structures"
section that deals with policies
should be included in the Glossary in
related to existing and historic
relation to existing uses.
landfills.
50
6.40e.- IDP
Expansion, maintenance or
replacement of existing infrastructure
should also be subject to BMP's to
promote the objectives of the Plan to
the greatest possible extent.
50
6.41 - SA
Site Alteration and Tree Cutting
That the LSPP identify municipalities
Bylaws
as the leads in developing site
Implementation and enforcement of
alteration and tree cutting bylaws.
municipal tree bylaws fall under the
jurisdiction of municipalities.
Furthermore, some municipalities have
already developed and implemented
progressive bylaws that may be used as
models for other jurisdictions.
50
6.42 - SA
Natural Heritage Protection
Improvement and Enhancement
That Policy 6.42 delineating natural
This policy state that within two years of
heritage features for protection,
the date of the Plan coming into effect,
improvement, restoration and
MNR and LSRCA, in collaboration will
enhancement incorporate the
delineate priority areas for natural
existing LSRCA Natural Heritage
heritage protection.
System work and not duplicate this
effort.
It would be beneficial to include land
securement as a protection strategy.
As indicated previously, the work has
been completed by the LSRCA and
should not be duplicated.
EBR Registry Number 010-4636
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February 12, 2009
Pane *11 of 55
Page #
Policy #
Comments
Recommendations
50
6.43 - SA
The LSRCA should be included as a
partner in natural heritage work as the
LSRCA has completed this work as part
of Phase I of our Natural Heritage
System. Municipalities should also
identified in this policy given their
financial support and commitment to the
current LSRCA Natural Heritage
System.
50
6.44 - SA
Stressed subwatersheds within the
Lake Simcoe basin have been identified
by the LSRCA based on various criteria.
51
6.45 - SA
The timeline for the expansion of
That the Province provide the LSRCA
Ontario Regulation 179 outside the
and its member municipalities with
LSRCA's area of jurisdiction has not
full provincial funding to complete
been specified.
mapping in areas outside its
jurisdiction as well as to introduce
Funding for this exercise must be
Section 28 regulation to those areas.
provided.
51
6.46 - M
A natural heritage and hydrologic
That the LSRCA support Policy 6.46
features monitoring program is highly
to develop and implement a
supported.
monitoring program in relation to the
targets and indicators associated
Funding support from the province will
with natural heritage and hydrologic
be required.
features and areas.
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Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 32 of 55
Chapter Seven: Other Threats and Activities
The LSRCA applauds the Province for introducing a Chapter in the Lake Simcoe
Protection Plan on invasive species, climate change and recreational activities.
Page #
Policy #
Comments
Recommendations
55
7.1 -SA
Invasive Species
That the Province add a strategic
The LSRCA would be pleased to
action to Policy 7.1 that directs
collaborate on the delivery of information
partners to develop a stewardship
and education programs as it has 30
program to address invasive
years of experience in this area.
species.
Based on the real threats to the provincial
economy of invasive species, funding for
this program should be provided by the
Province.
55
7.2 -SA
The Plan recommends a community based
That Policy 7.2 include the LSRCA
social marketing project targeted at
as a collaborative partner regarding
invasive species to be conducted with the
community based social marketing
MNR, the OFAH, First Nations and Metis
on invasive species.
communities.
As the LSRCA has had experience in
community based social marketing, it is
recommended that this policy initiative be
completed in conjunction with the
LSRCA's broader recommendation in
Chapter 8 regarding the community based
social marketing project targeted at a
wider range of stewardship behaviours.
56
7.7 -SA
This policy indicates that within six year of
That Policy 7.7 regarding the
the Plan taking effect, the MNR will
invasive species assessment in
evaluate the level of risk related to ponds
floodplains completed within one
in the floodplain contributing to the spread
year of the date the Plan takes
of invasive species.
effect, in cooperation with the
LSRCA.
-8-7.11-SA
Climate Change
That the LSRCA express its support
The LSRCA endorses the climate change
to the Province of Policy 7.11 on
policy statements and would note that it
developing a Climate Change
has taken a lead role in some climate
Adaptation Strategy.
change studies such as: the regional
climate change model with CANWET and
working with EnCan on the
intensity/frequency /duration curve.
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jf Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Pape 33 of 55
Page#
Policy#
Comments
Recommendations
The LSRCA concurs with our continued
role in working in collaboration with the
Province and other partners on an
adaptive policy on climate change.
61
7.12 -SA
Recreational Activities
That the lead role to conduct a
This policy states that the LSRCA is
recreational carrying capacity study
encouraged to conduct an assessment of
rest with the Province of Ontario
the recreational carrying capacity of Lake
through the MTOUR and not the
Simcoe and develop sustainable
LSRCA as the Authority's core
recreational policies.
mandate relates to integrated
watershed management, as
opposed to recreational
management.
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Draft Lake Simcoe Protection Plan
Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 34 of 55
Chapter Eight: t.- Implementation
i�, h
Context:,
The implementation section of the Plan deals with a variety of topics — subwatershed
evaluations, stewardship, education, outreach, research, monitoring, reporting, advisory
committees public engagement, financial strategy and Plan amendments. These are all
valuable sections of the Plan.
Subwatershed Evaluations:
Page #
Policy#
Comments
Recommendations
64
8.1 — SA
The LSRCA supports this policy,
That Policy 8.1 developing
however, given our mandate for
guidelines for subwatershed
watershed and subwastershed planning
planning be co -led by MOE and the
a co -lead with MOE in this area would be
LSRCA in collaboration with
appropriate.
agencies, municipalities and
stakeholders.
64
8.1 a.- SA
Subwatersheds in the basin are well
That the Province utilize the
defined and have been so for over 25
sublake areas and subwatershed
years. These delineations have been
areas that have been defined by
used as a standard including everything
the LSRCA.
from ACS, nutrient loading reports,
stewardship planning, etc.
64
8.1 b.- SA
Clarification is required as to whether
subwatershed plans completed under the
ORMCP will meet the requirements as
developed under the LSPP.
64
8.1 —c. -SA
Priorities for subwatershed planning
That the Province provide funding
should be based on pressures for
for subwatershed planning to the
growth, land use change, results from
LSRCA.
ACS, SW and other related
information. This information exists and
could be completed quickly.
64
8.3 - SA
The LSRCA concurs with this Policy and
That the LSRCA concur that
can achieve the timeline subject to
subwatershed planning and
funding being provided for these plans.
evaluations can be completed
within 5 years of the date the Plan
comes into effect subject to
funding support.
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Draft Lake Simcoe Protection Plan
Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 35 of 55
Stewardship, Education & Outreach:
There is no direct mention of formal education in the Plan, beyond stewardship
outreach. The policies will be more effective if the people of the watershed are better
educated with an understanding of the consequences of their past and current actions,
and their required contributions and responsibilities to solve the problem for the future.
Understanding the issues of the lake will encourage individuals to make some
substantive changes in their behaviours to do their part in protecting the lake. This type
of realization, understanding, commitment and caring for the lake is founded on a
citizenry that has been educated and feels personally connected to the situation.
Recommendation:
THAT the Plan recommend formal education programming as part of the
implementation plan, supporting curriculum and place -based education programs,
and provide financial resources to agencies and groups that have programs that meet
those criteria.
Much of what the Protection Plan speaks of in relation to "education and outreach"
deals with promoting best management practices (page 36: education and outreach
under the Environmental Farm Plan), controlling invasive species (page 54: using
public education, outreach and stewardship to prevent the introduction of new invasive
species) and connecting directly with rural, agricultural, urban and shoreline residents
etc. (pages 66 and 67).
Section 1: Lake Simcoe Stewardship Network/Alliance
Enhancing collaboration of programs and activities is a good strategic direction,
ensuring efficiency for residents of the watershed — facilitating dialogue between
stewardship groups in all areas of focus (agriculturaVurban, household/business,
municipal/private resident) would ensure that each group might "sell" the programs of
other groups. This group, if chaired effectively, would also allow individual groups to
enhance their own programs by facilitating the exchange of
ideas/knowledge/experience (page 66).
It is agreed that all organizations must work together to establish priorities, reduce
duplication, enhance program delivery and create a strong and holistic approach to
stewardship that involves the entire community.
Involving the grass-roots, local community in the discussions will be critical to success.
Involving First Nations and the M6tis communities in this dialogue is also critical.
EBR Registry Number 010-4636
Draft Lake Simcoe Protection Plan
Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 36 of 55
To be effective, each partner in the network will need clear and defined roles and
responsibilities. As many stewardship groups already have successful stewardship
funding programs in place, the proposed network/alliance would need to have detailed
outlines of the lead roles and responsibilities, financial contributions and program
objectives for all partners involved.
Section 2: Agricultural Stewardship
It is agreed that additional funding is required for operators to meet environmental
challenges on the farms (page 67). With market pressures, farmers will need access to
significant, consistent, long-term funding for new projects
Page 67 describes LEAP as a program of LSRCA. This should reference the municipal
support for the program and their funding commitment.
Funding through OMAFRA and AAC programs requires the completion of an approved
Environmental Farm Plan (EFP). The Plan recommends enhancing the EFP program.
The EFP program is a valuable and important tool for educating farmers, and protecting
the environment. This program should be encouraged. That said, funds for operators
through other agricultural stewardship programs should not be tied to EFP criteria, as
valuable projects may be completed by operators who may not qualify or wish to pursue
EFP completion.
Clear roles and responsibilities need to be defined between the myriad agencies that
are involved in the delivery of stewardship programs in order to ensure that duplication
does not occur. It is also recommended that the Province consider providing enhanced
funding to leverage the LSRCA's LEAP program.
Section 3: Rural Stewardship
The rural stewardship program addresses both rural and urban landowners, but focuses
largely on rural programming. In general, throughout the Plan, references to urban
based stewardship, in both the community education and infrastructure fields, is limited.
Specific descriptions of urban -related activities are required.
This section describes "reducing duplication". Current programs, such as LEAP, EFP,
and Ontario Stewardship (OS) Council projects currently complement each other.
Beyond making "simple behavioural changes" and implementing "on -the -ground
restoration projects", the Plan should also recommend new initiatives aimed at improved
land stewardship, such as Alternative Land Use Systems (ALUS) and other recognition
for Ecological Goods and Services.
BR Registry Number 010-4636
Draft Lake Simcoe Protection Plan
Comments from the Lake S|mooeRegion Conservation Authority
--
February 12.2O0S
Page 37nf55
Page #
Policy #
Comments
Recommendations
68
8.5 -SA
Policy 8.5 indicates that the MNR and
That the Stewardship "Alliance"
other ministries will collaborate with
develop a common reporting
watershed groups to establish a broad-
framework so the end products of
based stewardship network — the
all members' contributions are
purpose includes to "strengthen the
recorded with appropriate
strategic focus of ... stewardship
recognition to all partners.
That the Network/All lance be
It should be noted that the Stewardship
consulted when developing a
Councils rely on CA projects in large part
subwatershed plan and program;
to support programs like the Ontario
but the development of the Plan
Stewardship Rangers. The LSRCA has
rest with the technical experts
almost 30 years of active stewardship
within the LSRCA.
program operations in the watershed,
completing more than 950 projects.
8.6 -SA
The LSRCA has almost 30 years of
That a timeline for the
experience in working with the
implementation of Policy 8.6 on
agricultural community in the watershed,
agricultural stewardship be
and implementing projects that benefit
established and be concurrent with
the watershed and the farm operation.
Policy 8.5.
The LEAP program (formerly LSWQIP)
was developed in partnership with the
local OFA chapters, and continues to
support on-farm projects. On-farm
projects have been completed in
partnership with the EFP, and through
consultation with OMAFRA and OSCIA.
8.7 -SA
Under 8.5 -SA, MNR is to lead the
That the LSRCA participate in the
development of a network/alliance that
review of the agri-envi ron mental
will "strengthen the strategic focus
stewardship programs.
of ... stewardship programs". However,
this policy indicates that MAFRA will lead
the reassessment of "stewardship
This policy requires that in 3 years
"stewardship programming" be
reassessed, and that "priority areas" will
be "modified". Ares subject to review and
stewardship program types should be
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Comments from the Lake Simcoe Region Conservation Authority
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pnno 'AA of RR
#
Policy #
Comments
Recommendations
—Page
8.8 -SA
The Stewardship Guide developed in
partnership with IVINFI, CAs, University of
That the Plan indicate that
Guelph, and others, is a valuable tool for
municipalities and Boards of
rural non-farm residents who seek to gain
Education be involved in
a better understanding of their property,
educational and incentive based
and develop a plan of action for
stewardship programs for rural and
implementing improvements. Tying
urban landowners in the
access to funding for restoration projects
watershed.
to the implementation of this guide may
not be as successful as has been the
case with farm operators under the EFP.
Willingness to self -identify issues, and
the conflict between 'environmental
improvements' versus investments that
affect property resale value may limit
uptake by landowners.
Developing one program that meets the
needs of suburban, urban, and rural non-
farm residents may prove challenging.
Incorporating municipalities in this
program will be critical to ensure the
widest range of landowners possible is
benefited. Programs exist in
municipalities and should be reflected in
the Plan.
A clear lead for the implementation of this
program must be identified, including on -
the -ground support for landowner
outreach. Funding to support technical
services must be identified, and technical
service providers identified.
8.9 -SA
LSRCA has established, through the
That the LSRCA co -lead the
Watershed Excellence Showcase,
promotion of Best Management
launched in 2008, a series of
Practices supporting agricultural
demonstration sites to show BIVIPs for a
stewardship activities.
wide range of Stewardship projects. This
program could be expanded and
enhanced through support from the
Province.
zO
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Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
n..-- On -4 rr
Page #
Policy #
Comments
Recommendations
.Page#..
69
8.10 -SA
Section 8.3 of the Plan identifies that one
That Policy 8.10 on Best
of the goals is to "encourage non-farm
Management Practices incorporate
landowners in rural and urban areas to
urban communities and
engage in activities that protect and
municipalities in the discussion to
improve water quality". Strategic actions
reduce phosphorus and other
8.5 to 8.11 focus on the rural non-farm
chemical/pollutant loadings from
and farm landowner, with minimal focus
urban activities.
on urban residents/landowners. This
may include street sweeping, lawn care,
That the Best Management
car washing, etc.
Practices Study to reduce
phosphorus loading be lead by the
LSRCA with provincial funding.
8.11 -SA
It is noted that the LSRCA's new building
That in addition to SEED design in
was constructed to LEED Silver
new buildings, site -level storm
designation standards.
water controls such as rain barrels,
permeable pavements, and other
innovative designs be encouraged.
Research, Monitoring and Reporting
a
Policy#
Comments
Recommendations
.Page#..
69
8.12
Policy 8.12 supports the focus of a
Policy 8.12 is supported which
science, monitoring and research event
requires an organized scientific
every two years in the watershed.
monitoring and research event
every two years. The LSRCA is
supportive of co -leading this
initiative.
cv
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Comments from the Lake Simcoe Region Conservation Authority
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Page 40 of 55
P IS U* 1:1 7 _11 1 0 0 4 A
The two primary questions in a successful communications strategy are: who are we
trying to reach, and what are we asking them to do. In the draft Plan, a wide range of
players, stakeholders and participants are mentioned as partners in the development
and delivery of actions to accomplish the goals of the draft Plan, and most often these
groups are not specifically named. Much of the language in Chapter Eight speaks to
concepts of engagement, coordination, involvement, information sharing and behavioral
change, and does not address the communications that would be required to support
them.
Because the audiences are so diverse, and represent varied demographics and
interests, a meaningful communications plan would need to answer the two primary
questions in relation to all groups. While the draft Plan mentions individual components,
the concept of broad organizational communications has not matured in this preliminary
document.
More than 80% of the policy statements included in the draft Plan indicate that
implementation will be conducted in collaboration with partner organizations.
Irrespective of specific partners named, the draft Plan recognizes the need for collective
effort, coordination of current partners, enhanced collaboration opportunities,
community -wide involvement and participation, and the need to avoid duplication. The
draft Plan notes that "public engagement with all stakeholders is an integral part of both
developing and implementing the Plan". Communication and information management
will play a key role in this collaboration, involvement, participation and engagement.
Involvement and participation of program partners is often mentioned in the draft Plan,
as are stakeholder groups and the public. Implied, although not specifically mentioned,
are municipalities. Municipal governments are considered to be key partners in the
delivery and funding of many of the actions called for in the draft Plan, and are critical to
reaching and engaging their constituents. Successful communications would keep these
partners informed, engaged and supportive.
In addition to the ongoing connection with program partners, the draft Plan specifically
mentions mechanisms for connecting directly with residents, government, industry, and
business, "helping them understand their influence on the Lake Simcoe watershed and
encouraging them to voluntarily engage in responsible and sustainable actions" (p66).
No specific mechanisms are mentioned.
The draft Plan mentions that education and outreach programs "help to improve
community acceptance and encourage positive changes in people's behaviour" (p66).
Examples include projects and community-based monitoring programs. No mention is
made in the document of the significant communication and program support that this
will require, and its attendant need for resources.
Under Stewardship, Education and Outreach, the draft Plan proposes the establishment
of a new alliance and a series of actions to promote agricultural and rural land
stewardship.
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Draft Lake Simcoe Protection Plan
Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 41 of 55
The proposed Lake Simcoe Stewardship Alliance would have broad watershed
representation and a comprehensive mandate including identification of restoration
priorities, provision of support through funding and other resources, championing, and
influencing. This could be interpreted as a program support function and communication
would play a vital and central role in the coordination and sharing of information and
resources among all partners, including watershed residents and businesses.
The proposed Rural Community Landowner Stewardship Program would make changes
to programs, functions and accessibility of the actions of partner stewardship
organizations. This will require significant alignment of partner programs and
communication to ensure they evolve in support of the draft Plan's overall goals. The
program would also ultimately involve community-based activities and innovative
programs, requiring program development, promotion and communication support.
During the LSRCA's work to promote property owner early actions as part of the
drinking water source protection program, the need for personal contact was clearly
reinforced. Across the province, successful attempts to reach property owners involved
personal visits; the use of literature and promotional materials alone was insufficient.
Successful landowner uptake of stewardship programs requires a significant investment
in personal visits, requiring time, personnel and funding.
A stated goal of the Rural Community Landowner Stewardship Program is "to
encourage landowners to engage in activities that protect and improve water quality and
natural heritage features, ranging from simple behavioral changes to on -the -ground
restoration projects" (p67). Research into social marketing indicates that behavior
changes are not simple: they have a most effective long term impact, they require
significant investment to achieve, and they require ongoing reinforcement and support.
Education of our youth, and its key role in a comprehensive solution to stewardship and
sustainable lifestyle, is not addressed in the draft Plan.
Recommendations:
THAT a comprehensive and strategic communications plan be developed to address the
information needs of all target audience groups, as well as the promotional needs of the
partners; and further that this plan include specific deliverables and accountabilities by
year so they can be monitored and adequately financed.
THAT, in the development of the communications plan, electronic and social media be
considered in the ongoing dialogue and sharing of information that is encouraged among
groups and organizations.
THAT, considering the scope and importance of communications, and with respect for the
desire to avoid duplication, the communications work required by all agencies be
supported and supplemented by financial resources from key partners, especially the four
named ministries of the Province.
THAT, in addition to other efforts to inform, a community-based social marketing initiative
be undertaken to engage residents and businesses in the watershed in behavioral actions
that will protect and enhance the environment. This would begin with meaningful research
conducted by a partnership of the LSRCA, the Province and key stakeholders.
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Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
MUO
THAT funding be provided to enhance the education of young watershed residents and
that, considering the LSRCA's long-standing experience and existing place -based facilities,
the conservation authority continue to lead in this role with the support of partners and
additional resources.
THAT, as enhanced opportunities are developed to support agricultural stewardship, the
work being done by the LSRCA's LEAP program and others not be duplicated, and further
that the proposed additional funding to support and enhance agricultural stewardship
actions include increased investment in the LSRCA's LEAP program.
Advisory Committees under the Lake Simcoe Protection Act, 2008
Chapter Eight notes that the Lake Simcoe Protection Act allows for the establishment of
two Advisory Committees — the Lake Simcoe Science Committee and the Lake Simcoe
Coordinating Committee. Given the Authority's strong role in science, and it many
partnerships with the province on Lake Simcoe initiatives, a seat on the Science
Committee should be afforded to a LSRCA representative.
The LSRCA is appreciative of a seat on the Lake Simcoe Coordinating Committee and
believes that it can assist the province well in this capacity.
Recommendations:
THAT the Lake Simcoe Science Committee afford one seat to a science representative
from the Lake Simcoe Region Conservation Authority.
Financing Strategy
It would be very helpful to have a breakdown as to how the early estimates regarding
costs to implement the Plan have been calculated. For example the estimate for
operating costs for the first 10 years is estimated at $100 to $135 million. In order to
maximize the probability of success in implementation it would be useful to analyze and
ensure that those responsible for operational leadership and support are adequately
resourced relative to the estimated funding noted above.
The Plan indicates that funding will be based on funding those priority actions that are
most critical to achieving the targets and objectives set out in the Plan. In order to
ensure that funding is used in the accordance with this objective it is important to first
prioritize the actions required. The priority actions then need to be assigned target time
lines and funding requirements can then be defined by year of planned implementation.
The Plan indicates that "Wherever possible" cost effective solutions will be employed. In
order to maximize the return on the investment it is important that the most cost
effective solutions known always be used.
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Page 43 of 55
There is a general statement indicating that the funding approach will be based on
partnerships where no one organization will have to bear the burden of all costs and this
appears to be a good general philosophy. The challenge will be to arrive at a specific
cost allocation model which at this point in time is unknown. There needs to be a
process for the various parties that are identified and/or expected to fund the
implementation of the Plan to dialogue and negotiate a reasonable cost allocation plan.
The Plan also indicates that the Province will amend the Plan and the financing strategy
to include further details as the Plan is implemented. It then indicates that the Plan is
intended for review and will be potentially amended at least every ten years. Depending
on the desired time lines to achieve stated targets, the time line for review and
amendments appears excessively long, particularly in the initial stages of the
implementation of the Plan. The question of priority actions and related funding is a
critical question that must be addressed early in the implementation process. In ideal
circumstances this question would be answered first.
The sources and amounts of funding that have been identified in the Plan are a good
start. (MUNICIPAL - In order to provide meaningful comments regarding the provinces
commitment to work with municipalities toward a full cost recovery model and user pay
principle, it would be necessary to understand what this means, how it would work and
who would be considered the users from the province's perspective.)
Innovative approaches to funding priority actions that address targeted watershed
protection and improvement objectives in a cost effective manner should be promoted.
With regard to the prospect of a water trading model, prior to promotion, there needs to
be a process to first identify and assess the specific watershed trading opportunities and
feasibility relative to the established targets, which appears to be in addition to the
scope of policy statement #4.27 SA.
Recommendations:
THAT the breakdown of projected operating costs be circulated to those identified as
sharing the responsibility for implementation and reviewed to ensure it reflects a
reasonable cost allocation relative to the identified responsibility.
THAT the policy statements and actions identified in the Plan be prioritized relative to
the identified targets.
THAT the resource requirements be estimated and quantified by specific policy
statement or group of related policy statements noted in the Plan.
THAT the estimated resource requirements be summarized and aligned with specific
target time lines.
THAT a process be established for the various parties that are identified and/or
expected to fund the implementation of the Plan to dialogue and negotiate a reasonable
cost allocation plan.
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Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 44 of 55
Fartffl�s�
The Lake Simcoe Protection Plan calls for a Plan review to take place at least every ten
years. Given the dynamic environment in which we live, it is recommended that the
Plan be reviewed at least very five years. In particular, issues such as climate change
can result in a need to constantly review and potentially update targets.
Recommendation:
THAT the Lake Simcoe Protection Plan be reviewed at least every five years.
Closing Remarks:
The Lake Simcoe Protection Plan is an essential document required to protect and
restore Lake Simcoe and its watershed. We applaud and appreciate the Province's
hard work and commitment to developing this important initiative.
On behalf of the Lake Simcoe Region Conservation Authority, we respectfully submit
our comments for consideration and provide our commitment to working with the
Province to implement the Plan.
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Draft Lake Simcoe Protection Plan
Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 45 of 55
SUMMARY OF RECOMMENDATIONS
Chapter One: Ecological Health of Lake Simcoe and its Watershed
THAT Chapter One of the Lake Simcoe Protection Plan include reference to the Oro
Moraine, require that developments address environmentally sustainable land and water
uses, define "ecosystem approach", reference that best management practices continue
as a key principle and add high priority focuses on key natural heritage features and
sustainable growth management.
THAT the province host more detailed discussions with the Lake Simcoe Region
Conservation Authority regarding the impact of the Act, Plan and Regulations on
Sections 21 and 28 of the Conservation Authorities Act.
THAT a detailed overview of the LSEMS partnership, accomplishments and key reference
reports be outlined in the Lake Simcoe Protection Plan.
THAT the Lake Simcoe Protection Plan indicate that the Intergovernmental Action Plan -
Assimilative Capacity Study was completed for the Province of Ontario by the Lake
Simcoe Region Conservation Authority with the Nottawasaga Valley Conservation
Authority.
THAT the Lake Simcoe Protection Plan reference the significant agricultural and
community stewardship programs completed and currently offered by the LSRCA, with
financial assistance from its federal, provincial, municipal, and public partners along
with the Lake Simcoe Conservation Foundation.
THAT the Lake Simcoe Protection Plan contain a separate section in Chapter Two
addressing the role and responsibilities of the Lake Simcoe Region Conservation
Authority.
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Draft Lake Simcoe Protection Plan
Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 46 of 55
Policy #
Recommendation
3.1 -SA
That Fish Community Objectives include objectives for both coldwater and
warmwater species.
3.3 -SA
That, given the importance of the fishery, the socioeconomic evaluation of the
monetary and ecological value of the aquatic resources in the Lake Simcoe
watershed be initiated immediately upon Plan approval.
That the socioeconomic evaluation of the aquatic resources should include a
cultural value component.
3.4 -SA
That —baseline mapping of aquatic habitats commence immediately upon Plan
approval as some work has already been completed by the LSRCA and MNR.
3.5 -SA
That the LSRCA be specifically mentioned as an agency that conducts
research projects on aquatic communities across the basin in addition to MNR
and MOE.
3.6-M
That the annual aquatic community monitoring program include the main lake,
inland lakes and tributaries.
That components of the annual aquatic community monitoring program
include elements such as tributary aquatic habitat, geomorphic monitoring,
and macrophytes.
Chapter Four: Water Quality
THAT the Plan contain a statement regarding the current state of analysis of phosphorus
loading from 2003 to the present.
THAT the Plan contain a reference that phosphorus loads decreased from 1990 to 2007,
under the LSEMS partnership from, on average 100 tonnes per year to 67 tonnes
annually.
THAT the Plan reference pre -settlement phosphorus loads to Lake Simcoe (as
referenced in LSEMS Implementation Technical Report No. IMP.B.17,1995).
THAT a basin wide water quality strategy be completed, which will be used to refine
water quality targets based on all of the SMART criteria — specific, measurable,
achievable, realistic and time bound. Specifically, the strategy should identify the total
phosphorus reduction available within the watershed, the cost to achieve the
reductions, the time needed to implement the activities and the relative cost\benefit ratio
associated with each activity.
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THAT a monitoring program focused on beach areas prone to closures be initiated to
identify and quantify sources of ecoli contamination whereupon a strategy be devised
which would address these sources to achieve the beach posting target.
THAT the PWOO values be inserted into the Indicators component of the Water Quality
section of the LSPP so that agencies are held to a numerical goal rather than a broad
statement when evaluating progress.
Policy #
Recommendation
4.1 DP
That Policy 4.1 regarding sewage treatment plants should reference the
current state of sewage treatment plant expansions.
4.3DP
That Policy 4.3 -DP section b) on sewage treatment plants should address
sewage services where the majority of effluent is recycled and reused and not
discharged to surface waters.
4.5SA
That the Province be requested to provide more guidance on the contents of
stormwater management master plans.
That the Province provide funding to the municipalities and the LSRCA to
complete stormwater management master plans and projects.
That MOE provide guidance on climate change in relation to preparing
stormwater management master plans.
That the municipal class EA process be amended to permit efficient
implementation of stormwater management projects.
That both municipal and industrial paper sludge disposal and spreading
information be outlined and addressed in the Plan.
4.6SA
That the province fund the LSRCA to establish a Stormwater Management
Assistance Program, in combination with municipal and other funding
sources, to complete urban stormwater retrofit projects.
4.7DP
That the Province provide financial assistance to the LSRCA for research and
testing of new and innovative stormwater management measures.
That new technical guidelines by MOE for Stormwater Management Planning
and Design be created based on water sensitive urban design principles for
more sustainable development.
4.9DP
That new technical guidelines for Stormwater Management Planning and
Design be created by MOE within one year of Plan approval and be
referenced as a policy initiative.
That where infill development or redevelopment cannot comply with
stormwater controls outlined in policy 4.9 (a), best efforts be initiated to
maximize water quality control from the site.
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4. 1 ODP
That a detailed schedule and cost estimate to maintain existing and proposed
stormwater ponds be completed as part of the LSRCA SWM Strategy.
That the Province provide financial assistance to municipalities to maintain
stormwater facilities.
4.14SA
That the province clarify who will play the lead role in the septic re -inspection
program and how this activity will be financially supported.
4.16DP
That the policy addressing new septic systems within 100 metres of the
shoreline, be expanded to enable seasonal cottages that are now converted to
fulltime residences to upgrade faulty and non -conforming septic systems
beyond original capacity.
4.17 -SA
That the three year timeline to complete an atmospheric deposition study
from construction and mineral aggregate activities be reduced and that
interim measures be considered such as:
• Installing windbreaks
• Evaluating and implementing dust controls for the aggregate and
development industries.
4.20 -SA
That the province require the mineral aggregate resources industry to adopt
best management practices to reduce water quality impairment.
4.21 -DP
That the province define minimum removal of vegetation and develop
sediment and control guidelines for construction activity within the
4.25 -SA
That the Phosphorus Reduction Strategy be a clear priority for
implementation and outline roles and responsibilities, ensure no duplication
occurs, incorporate SMART goals, objectives and targets and provide a clear
indication and commitment of funding sources to achieve the strategy.
That the development of sub -watershed phosphorus loading targets be
completed by the LSRCA as part of the Phosphorus Reduction Strategy with
funding from the province.
That growth only proceed if environmental targets for Lake Simcoe and its
watershed are being achieved and maintained.
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I(,- D011 Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 49 of 55
THAT an alternative or additional indicator of water quantity be added to the Plan to
evaluate the total quantity of available water (similar to Tier 1 and Tier 2 water budgets)
and measure water consumption against that available amount, which also considers in -
stream flow needs.
THAT the LSPP include a water quantity indicator that speaks to the maintenance of
groundwater recharge to reflect the importance of recharge areas in the maintenance of
base flows (e.g. proportions of pervious cover by subwatershed, proportion of
significant recharge area under pervious cover, or measured recharge mitigation in
urbanized areas).
Policy #
Recommendation
5.1 -SA
That the policy to develop in -stream flow targets for water quantity include
the LSRCA given their role in source water protection, flood plain mapping
and low water response.
That the Authority enter into discussions with MOE and MNR to undertake in -
stream flow targets on their behalf dependant upon appropriate
compensation.
That in -stream flow analysis should be completed for all subwatersheds and
catchments within the Lake Simcoe basin, not just those currently under
stress.
That policies developed by the Source Protection Committee as part of the
Source Protection Plan should form the foundation of policy direction
regarding in -stream flow targets.
5.2 -SA
That the Authority enter into discussions with MOE, MNR and municipal
partners to undertake Tier 2 water budgets on their behalf dependant upon
appropriate compensation.
That in -stream flow targets as outlined in Policy 5.1 be completed within one
year of the date of the Plan coming into effect, in order that the two year time
frame outlined in Policy 5.2 can be achieved.
5.3 -SA
That the Authority approach municipal partners to undertake an analysis of
water conservation plans on their behalf dependant upon appropriate
compensation.
That the province provide municipalities with funding to complete water
conservation plans as an incentive to complete this activity.
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Page 50 of 55
5.4 -SA
That given the LSRCA's role in the Ontario Drinking Water Source Protection
5.5 -SA
Early Actions Program, it co -lead the agricultural water conservation program
with MAFRA.
That the province identify duplication of efforts in stewardship programming
and provide streamlining to ensure effective and efficient delivery of the
program.
5.6 -DP
That all major water users be required to undertake mandatory water use
plans.
That the Province define major water users.
That monitoring of water takings be mandatory as part of the Plan.
That the cumulative impact of water taking across the basin be assessed.
Chapter Six: Shorelines And Natural Heritage
THAT the LSPP recognize the LSRCA's significant work completed on developing an
Ecological Land Classification System (ELC, natural heritage mapping and Lake Simcoe
Natural Heritage System Report (2007)) and that the LSRCA's work be endorsed as the
system to be used in the LSPP in order to ensure that duplication of effort and expense
does not occur.
THAT the legislation which is applicable to the Lake Simcoe Watershed be listed in a
table with a description of the level of regulatory approval (e.g. federal, provincial, local);
the agency responsible (e.g. MNR, MOE, MMAH, DFO, CA); the legislation (e.g. Fisheries
Act, Lakes and Rivers Improvement Act, Aggregate Resources Act, Ontario Water
Resources Act, Environmental Protection Act, Oak Ridges Moraine Conservation Act and
Plan, Municipal Act, Conservation Authorities Act, Greenbelt Act and Plan, Places to
Grow Act and the Growth Plan, Environmental Assessment Act) and a description of
approval required under the various pieces of legislation.
That the LSPP contain definitions for key natural heritage features, key hydrologic
features, significant recharge areas, vegetation protection zones, and low intensity
recreational uses.
That all policy statements in the LSPP's Chapter on Shorelines and Natural Heritage be
reviewed in light of Section 28 of the Conservation Authorities Act.
lY
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Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 51 of 55
Policy #
Recommendation
6.1 -DP
That policies in relation to the Lake Simcoe shoreline be consistent with
Section 28 of the Conservation Authorities Act.
6.1c -DP
That Policy 6.1 c. include the construction of retrofit stormwater management
facilities as a permitted activity.
6.1d -DP
That Policy 6.1 d. recommend that Infrastructure include the requirement for
review under the Environmental Assessment Act.
6.8 -DP
That the Shoreline Management Plan determine where structures, including
boathouses should and should not be allowed.
That the LSPP address policies related to historic lots of records within both
shoreline and stream regulated areas.
6.12 -SA
That the Shoreline Management Plan be completed within one year of the
date the Plan comes into effect and include collaborations with the federal
government.
That the Shoreline Management Plan be completed before shoreline policy
statements are finalized.
6.15 -SA
That the lead role for shoreline regulation be clearly identified, that no
duplication occur with Section 28 regulations of the Conservation Authorities
Act and that enforcement funding be provided to the LSRCA for any identified
enforcement role.
6.18 -DP
That the LSRCA's Natural Heritage System be used as the foundation for the
Plan's policies on natural heritage as the work has already been completed
and will avoid unnecessary duplication and expense.
6.40d -DP
That the LSPP incorporate a new section that deals with policies related to
existing and historic landfills.
6.41 -SA
That the LSPP identify municipalities as the leads in developing site alteration
and tree cutting bylaws.
—6-.-42-SA
That Policy 6.42 delineating natural heritage features for protection,
improvement, restoration and enhancement incorporate the existing LSRCA
Natural Heritage System work and not duplicate this effort.
6.45 -SA
That the Province provide the LSRCA and its member municipalities with full
provincial funding to complete mapping in areas outside its jurisdiction as
well as to introduce Section 28 regulation to those areas.
6.46-M
That the LSRCA support Policy 6.46 to develop and implement a monitoring
program in relation to the targets and indicators associated with natural
heritage and hydrologic features and areas.
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Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 52 of 55
Chapter Seven: Other Threats and Activities
Policy #
Recommendation
7.1 -SA
That the Province add a strategic action to Policy 7.1 that directs partners to
develop a stewardship program to address invasive species.
7.2 -SA
That Policy 7.2 include the LSRCA as a collaborative partner regarding
8.1 a. -SA
community based social marketing on invasive species.
7.7 -SA
That Policy 7.7 regarding the invasive species assessment in floodplains be
8.1 c. -SA
completed within one year of the date the Plan takes effect, in cooperation
8.3 -SA
with the LSRCA.
7.11 -SA
That the LSRCA express its support to the Province of Policy 7.11 on
developing a Climate Change Adaptation Strategy.
7.12 -SA
That the lead role to conduct a recreational carrying capacity study rest with
the Province of Ontario through the MTOUR and not the LSRCA as the
Authority's core mandate relates to integrated watershed management, as
opposed to recreational management.
Chapter Eight: Implementation
Subwatershed Evaluations:
Policy #
Recommendation
8.1 -SA
That Policy 8.1 developing guidelines for subwatershed planning be co -led by
MOE and the LSRCA in collaboration with agencies, municipalities and
stakeholders.
8.1 a. -SA
That the Province utilize the sublake areas and subwatershed areas that have
been defined by the LSRCA.
8.1 c. -SA
That the Province provide funding for subwatershed planning to the LSRCA.
8.3 -SA
That the LSRCA concur that subwatershed planning and evaluations can be
completed within 5 years of the date the Plan comes into effect subject to
funding support.
bEBR Registry Number 010-4636
Draft Lake Simcoe Protection Plan
Comments from the Lake Simcoe Region Conservation Authority J
February 12, 2009
Page 53 of 55
Stewardship, Education & Outreach:
That the Plan recommend formal education programming as part of the implementation
plan, supporting curriculum and place -based education programs, and provide financial
resources to agencies and groups that have programs that meet those criteria.
Policy #
Recommendation
8.5 -SA
That the Stewardship "Alliance" develop a common reporting framework so
the end products of all members' contributions are recorded with appropriate
recognition to all partners.
That the Network/Alliance be consulted when developing a subwatershed plan
and program but the development of the Plan rest with the technical experts
within the LSRCA_
8.6 -SA
That a timeline for the implementation of Policy 8.6 on agricultural
stewardship be established and be concurrent with Policy 8.5.
8.7 -SA
That the LSRCA participate in the review of the agri-environmental
stewardship programs.
8.8 -SA
That the Plan indicate that municipalities and Boards of Education be
involved in educational and incentive based stewardship programs for rural
and urban landowners in the watershed.
8.9 -SA
That the LSRCA co -lead the promotion of Best Management Practices
supporting agricultural stewardship activities.
8.10 -SA
That Policy 8.10 on Best Management Practices incorporate urban
communities and municipalities in the discussion to reduce phosphorus and
other chemical/pollutant loadings from urban activities.
That the Best Management Practices Study to reduce phosphorus loading be
lead by the LSRCA with provincial funding.
8.11 -SA
That, in addition to LEED design in new buildings, site -level storm water
controls such as rain barrels, permeable pavements, and other innovative
designs be encouraged.
Research, Monitoring and Reporting
Policy #
Recommendation
8.12
Policy 8.12 is supported which requires an organized scientific monitoring and
research event every two years. 'The LSRCA is supportive of co -leading this
initiative.
EBR Registry Number 010-4636
Draft Lake Simcoe Protection Plan j
Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 54 of 55
Coordination, Public Engagement and Aboriginal Community Engagement
THAT a comprehensive and strategic communications plan be developed to address the
information needs of all target audience groups, as well as the promotional needs of the
partners; and further that this Plan include specific deliverables and accountabilities by
year so they can be monitored and adequately financed.
THAT, in the development of the communications plan, electronic and social media be
considered in the ongoing dialogue and sharing of information that is encouraged
among groups and organizations.
THAT, considering the scope and importance of communications, and with respect for
the desire to avoid duplication, the communications work required by all agencies be
supported and supplemented by financial resources from key partners, especially the
four named ministries of the Province.
THAT, in addition to other efforts to inform, a community-based social marketing
initiative be undertaken to engage residents and businesses in the watershed in
behavioral actions that will protect and enhance the environment. This would begin with
meaningful research conducted by a partnership of the LSRCA, the Province and key
stakeholders.
THAT funding be provided to enhance the education of young watershed residents and
that, considering the LSRCA's long-standing experience and existing place -based
facilities, the conservation authority continue to lead in this role with the support of
partners and additional resources.
THAT, as enhanced opportunities are developed to support agricultural stewardship, the
work being done by the LSRCA's LEAP program and others not be duplicated, and
further that the proposed additional funding to support and enhance agricultural
stewardship actions include increased investment in the LSRCA's LEAP program.
Advisory Committees under the Lake Simcoe Protection Act, 2008
THAT the Lake Simcoe Science Committee afford one seat to a science representative
from the Lake Simcoe Region Conservation Authority.
EBR Registry Number 010-4636
Draft Lake Simcoe Protection Plan
Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 55 of 55
Financing Strategy
THAT the breakdown of projected operating costs be circulated to those identified as
sharing the responsibility for implementation and reviewed to ensure it reflects a
reasonable cost allocation relative to the identified responsibility.
THAT the policy statements and actions identified in the Plan be prioritized relative to the
identified targets.
THAT the resource requirements be estimated and quantified by specific policy
statement or group of related policy statements noted in the Plan.
THAT the estimated resource requirements be summarized and aligned with specific
target time lines.
THAT a process be established for the various parties that are identified and/or expected
to fund the implementation of the Plan to dialogue and negotiate a reasonable cost
allocation plan.
Plan Amendments
THAT the Lake Simcoe Protection Plan be reviewed at least every five years.
-4636
EBR Regist5� Number 010
ratt LaKe Simcoe Frotection Ran
Comments from the Lake Simcoe Region Conservation Authority
%
Februar y 12, 2009
Page 1 of 11
SUMMARYOFRECO TIONS
i'
a -� M , -, I : I i I I on I M M NUTSM I
THAT Chapter One of the Lake Simcoe Protection Plan include reference to the Oro
Moraine, require that developments address environmentally sustainable land and water
uses, define "ecosystem approach", reference that best management practices continue
as a key principle and add high priority focuses on key natural heritage features and
sustainable growth management.
THAT the province host more detailed discussions with the Lake Simcoe Region
Conservation Authority regarding the impact of the Act, Plan and Regulations on
Sections 21 and 28 of the Conservation Authorities Act.
Chapter Two: Building On Past Actions
THAT a detailed overview of the LSEMS partnership, accomplishments and key reference
reports be outlined in the Lake Simcoe Protection Plan.
THAT the Lake Simcoe Protection Plan indicate that the Intergovernmental Action Plan -
Assimilative Capacity Study was completed for the Province of Ontario by the Lake
Simcoe Region Conservation Authority with the Nottawasaga Valley Conservation
Authority.
THAT the Lake Simcoe Protection Plan reference the significant agricultural and
community stewardship programs completed and currently offered by the LSRCA, with
financial assistance from its federal, provincial, municipal, and public partners along
with the Lake Simcoe Conservation Foundation.
THAT the Lake Simcoe Protection Plan contain a separate section in Chapter Two
addressing the role and responsibilities of the Lake Simcoe Region Conservation
Authority.
EBR Registry Number 010-4636
Draft Lake Simcoe Protection Plan
Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 2 of 11
Policy #
Recommendation
3.1 -SA
That Fish Community Objectives include objectives for both Coldwaterand
warmwater species.
3.3-§A
That, given the importance of the fishery, the socioeconomic evaluation of the
monetary and ecological value of the aquatic resources in the Lake Simcoe
watershed be initiated immediately upon Plan approval.
That the socioeconomic evaluation of the aquatic resources should include a
cultural value component.
3.4 -SA
That baseline mapping of aquatic habitats commence immediately upon Plan
approval as some work has already been completed by the LSRCA and MNR.
3.5 -SA
That the LSRCA be specifically mentioned as an agency that conducts
research projects on aquatic communities across the basin in addition to MNR
and MOE.
3.6-M
That That the annual aquatic community monitoring program include the main lake,
inland lakes and tributaries.
That components of the annual aquatic community monitoring program
include elements such as tributary aquatic habitat, geomorphic monitoring,
and macrophytes.
Chapter Four: Water Quality
THAT the Plan contain a statement regarding the current state of analysis of phosphorus
loading from 2003 to the present.
THAT the Plan contain a reference that phosphorus loads decreased from 1990 to 2007,
under the LSEMS partnership from, on average 100 tonnes per year to 67 tonnes
annually.
THAT the Plan reference pre -settlement phosphorus loads to Lake Simcoe (as
referenced in LSEMS Implementation Technical Report No. IMP.B.17,1995).
THAT a basin wide water quality strategy be completed, which will be used to refine
water quality targets based on all of the SMART criteria — specific, measurable,
achievable, realistic and time bound. Specifically, the strategy should identify the total
phosphorus reduction available within the watershed, the cost to achieve the
reductions, the time needed to implement the activities and the relative costkbenefit ratio
associated with each activity.
EBR Registry Number 010-4636
Draft Lake Simcoe Protection Plan
Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
aul 11
THAT a monitoring program focused on beach areas prone to closures be initiated to
identify and quantify sources of e.coli contamination whereupon a strategy be devised
which would address these sources to achieve the beach posting target.
THAT the PWQO values be inserted into the Indicators component of the Water Quality
section of the LSPP so that agencies are held to a numerical goal rather than a broad
statement when evaluating progress.
Policy #
Recommendation
4.1 -DP
That Policy 4.1 regarding sewage treatment plants should reference the
current state of sewage treatment plant expansions.
4.3DP
That Policy 4.3 -DP section b) on sewage treatment plants should address
sewage services where the majority of effluent is recycled and reused and not
discharged to surface waters.
4.5SA
That the Province be requested to provide more guidance on the contents of
stormwater management master plans.
That the Province provide funding to the municipalities and the I-SRCA to
complete stormwater management master plans and projects.
That MOE provide guidance on climate change in relation to preparing
stormwater management master plans.
That the municipal class EA process be amended to permit efficient
implementation of stormwater management projects.
That both municipal and industrial paper sludge disposal and spreading
information be outlined and addressed in the Plan.
4.6SA
That the province fund the I-SRCA to establish a Stormwater Management
Assistance Program, in combination with municipal and other funding
sources, to complete urban stormwater retrofit projects.
4.7DP
That the Province provide financial assistance to the I-SRCA for research and
testing of new and innovative stormwater management measures.
That new technical guidelines by MOE for Stormwater Management Planning
and Design be created based on water sensitive urban design principles for
more sustainable development.
4.9DP
That new technical guidelines for Stormwater Management Planning and
Design be created by MOE within one year of Plan approval and be
referenced as a policy initiative.
That where infill development or redevelopment cannot comply with
stormwater controls outlined in policy 4.9 (a), best efforts be initiated to
maximize water quality control from the site.
EBR Registry NumberO10~488S
Draft Lake SimcoeProtection Plan
Comments from the Lake 8imcmaRegion Conservation Authority
--
February 12.20OS
PmQa 4 o 11
4.10DP
That a detailed schedule and cost estimate to maintain existing and proposed
stormwater ponds be completed as part of the LSRCA SWM Strategy.
That the Province provide financial assistance to municipalities to maintain
stormwater facilities.
4.14SA
That the province clarify who will play the lead role in the septic re -inspection
program and how this activity will be financially supported.
4.16DP
That the policy addressing new septic systems within 100 metres of the
shoreline, be expanded to enable seasonal cottages that are now converted to
fulltime residences to upgrade faulty and non -conforming septic systems
beyond original capacity.
4.17 -SA
That the three year timeline to complete an atmospheric deposition study
from construction and mineral aggregate activities be reduced and that
interim measures be considered such as:
• Installing windbreaks
• Evaluating and implementing dust controls for the aggregate and
development industries.
4.20 -SA
That the province require the mineral aggregate resources industry to adopt
best management practices to reduce water quality impairment.
4.21 -DP
That the province define minimum removal of vegetation and develop
sediment and control guidelines for construction activity within the
4.25 -SA
That the Phosphorus Reduction Strategy be a clear priority for
implementation and outline roles and responsibilities, ensure no duplication
occurs, incorporate SMART goals, objectives and targets and provide a clear
indication and commitment of funding sources to achieve the strategy.
That the development of sub -watershed phosphorus loading targets be
completed by the LSRCA as part of the Phosphorus Reduction Strategy with
funding from the province.
That growth only proceed if environmental targets for Lake Simcoe and its
watershed are being achieved and maintained.
EBR Registry Number 010-4636
Draft Lake Simcoe Protection Plan
Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 5 of 11
Chapter Five: Water Quantity
THAT an alternative or additional indicator of water quantity be added to the Plan to
evaluate the total quantity of available water (similar to Tier 1 and Tier 2 water budgets)
and measure water consumption against that available amount, which also considers in -
stream flow needs.
THAT the LSPP include a water quantity indicator that speaks to the maintenance of
groundwater recharge to reflect the importance of recharge areas in the maintenance of
base flows (e.g. proportions of pervious cover by subwatershed, proportion of
significant recharge area under pervious cover, or measured recharge mitigation in
urbanized areas).
Policy #
Recommendation
5.1 -SA
That the policy to develop in -stream flow targets for water quantity include
the LSRCA given their role in source water protection, flood plain mapping
and low water response.
That the Authority enter into discussions with MOE and MNR to undertake in -
stream flow targets on their behalf dependant upon appropriate
compensation.
That in -stream flow analysis should be completed for all subwatersheds and
catchments within the Lake Simcoe basin, not just those currently under
stress.
That policies developed by the Source Protection Committee as part of the
Source Protection Plan should form the foundation of policy direction
regarding in -stream flow targets.
5.2 -SA
That the Authority enter into discussions with MOE, MNR and municipal
partners to undertake Tier 2 water budgets on their behalf dependant upon
appropriate compensation.
That in -stream flow targets as outlined in Policy 5.1 be completed within one
year of the date of the Plan coming into effect, in order that the two year time
frame outlined in Policy 5.2 can be achieved.
5.3 -SA
That the Authority approach municipal partners to undertake an analysis of
water conservation plans on their behalf dependant upon appropriate
compensation.
That the province provide municipalities with funding to complete water
conservation plans as an incentive to complete this activity.
EBR Registry Number 010-4636
Draft Lake Simcoe Protection Plan
Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 6 of 11
5.4 -SA
That given the LSRCA's role in the Ontario Drinking Water Source Protection
5.5 -SA
Early Actions Program, it co -lead the agricultural water conservation program
with MAFRA.
That the province identify duplication of efforts in stewardship programming
and provide streamlining to ensure effective and efficient delivery of the
program.
5.6 -DP
That all major water users be required to undertake mandatory water use
plans.
That the Province define major water users.
That monitoring of water takings be mandatory as part of the Plan.
That the cumulative impact of water taking across the basin be assessed.
Chapter Six: Shorelines And Natural Heritage
THAT the LSPP recognize the LSRCA's significant work completed on developing an
Ecological Land Classification System (ELC, natural heritage mapping and Lake Simcoe
Natural Heritage System Report (2007)) and that the LSRCA's work be endorsed as the
system to be used in the LSPP in order to ensure that duplication of effort and expense
does not occur.
THAT the legislation which is applicable to the Lake Simcoe Watershed be listed in a
table with a description of the level of regulatory approval (e.g. federal, provincial, local);
the agency responsible (e.g. MNR, MOE, MMAH, DFO, CA); the legislation (e.g. Fisheries
Act, Lakes and Rivers Improvement Act, Aggregate Resources Act, Ontario Water
Resources Act, Environmental Protection Act, Oak Ridges Moraine Conservation Act and
Plan, Municipal Act, Conservation Authorities Act, Greenbelt Act and Plan, Places to
Grow Act and the Growth Plan, Environmental Assessment Act) and a description of
approval required under the various pieces of legislation.
That the LSPP contain definitions for key natural heritage features, key hydrologic
features, significant recharge areas, vegetation protection zones, and low intensity
recreational uses.
That all policy statements in the LSPP's Chapter on Shorelines and Natural Heritage be
reviewed in light of Section 28 of the Conservation Authorities Act.
EBR Registry Number 010-4636
Draft Lake Simcoe Protection Plan
Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 7 of 11
Policy #
Recommendation
6.1 -DP
That policies in relation to the Lake Simcoe shoreline be consistent with
Section 28 of the Conservation Authorities Act.
6.lc-DP
ThatPolicy6.1 c. include the construction of retrofit stormwater management
facilities as a permitted activity.
6.1d -DP
That Policy 6.1 d. recommend that Infrastructure include the requirement for
review under the Environmental Assessment Act.
6.8 -DP
That the Shoreline Management Plan determine where structures, including
boathouses should and should not be allowed.
That the LSPP address policies related to historic lots of records within both
shoreline and stream regulated areas.
6.12 -SA
That the Shoreline Management Plan be completed within one year of the
date the Plan comes into effect and include collaborations with the federal
government.
That the Shoreline Management Plan be completed before shoreline policy
statements are finalized.
6.15 -SA
That the lead role for shoreline regulation be clearly identified, that no
duplication occur with Section 28 regulations of the Conservation Authorities
Act and that enforcement funding be provided to the LSRCA for any identified
enforcement role.
6.18 -DP
That the LSRCA's Natural Heritage System be used as the foundation for the
Plan's policies on natural heritage as the work has already been completed
and will avoid unnecessary duplication and expense.
6.40d -DP
That the LSPP incorporate a new section that deals with policies related to
existingand historic landfills.
6.41 -SA
That the LSPP identify municipalities as the leads in developing site alteration
and tree cutting bylaws.
—6—.42 -SA
That Policy 6.42 delineating natural heritage features for protection,
improvement, restoration and enhancement incorporate the existing LSRCA
Natural Heritage System work and not duplicate this effort.
6.45 -SA
That the Province provide the LSRCA and its member municipalities with full
provincial funding to complete mapping in areas outside its jurisdiction as
well as to introduce Section 28 regulation to those areas.
6.46-M
That the LSRCA support Policy 6.46 to develop and implement a monitoring
program in relation to the targets and indicators associated with natural
heritage and hydrologic features and areas.
EBR Registry Number 010-4636
Draft Lake Simcoe Protection Plan
(DOF Comments from the Lake Simcoe Region Conservation Authority
-
February 12, 2009
Page 8 of 11
Policy #
Recommendation
7.1 -SA
That the Province add a strategic action to Policy 7.1 that directs partners to
develop a stewardship program to address invasive species.
7.2 -SA
That Policy 7.2 include the LSRCA as a collaborative partner regarding
8.1a. -SA
community based social marketing on invasive species.
7.7 -SA
That Policy 7.7 regarding the invasive species assessment in floodplains be
--6.1c --SA
completed within one year of the date the Plan takes effect, in cooperation
8.3 -SA
with the LSRCA.
7.11 -SA
That the LSRCA express its support to the Province of Policy 7.11 on
developing a Climate Change Adaptation Strategy.
7.12 -SA
That the lead role to conduct a recreational carrying capacity study rest with
the Province of Ontario through the MTOUR and not the LSRCA as the
Authority's core mandate relates to integrated watershed management, as
opposed to recreational management.
Chapter Eight: Implementation
Subwatershed Evaluations:
Policy #
Recommendation
8.1 -SA
That Policy 8.1 developing guidelines for subwatershed planning be co -led by
MOE and the LSRCA in collaboration with agencies, municipalities and
stakeholders.
8.1a. -SA
That the Province utilize the sublake areas and subwatershed areas that have
been defined by the LSRCA-
--6.1c --SA
That the Province provide funding for subwatershed planning to the LSRCA.
8.3 -SA
That the LSRCA concur that subwatershed planning and evaluations can be
completed within 5 years of the date the Plan comes into effect subject to
funding support.
EBR Registry Number 010-4636
Draft Lake Simcoe Protection Plan
Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 9 of 11
That the Plan recommend formal education programming as part of the implementation
plan, supporting curriculum and place -based education programs, and provide financial
resources to agencies and groups that have programs that meet those criteria.
Policy #
Recommendation
8.5 -SA
That the Stewardship "Alliance" develop a common reporting framework so
the end products of all members' contributions are recorded with appropriate
recognition to all partners.
That the NetworktAlliance be consulted when developing a subwatershed plan
and program but the development of the Plan rest with the technical experts
within the LSRCA.
8.6 -SA
That a timeline for the implementation of Policy 8.6 on agricultural
stewardship be established and be concurrent with Policy 8.5.
8.7 -SA
That the LSRCA participate in the review of the agri-environmental
stewardship programs.
8.8 -SA
That the Plan indicate that municipalities and Boards of Education be
involved in educational and incentive based stewardship programs for rural
and urban landowners in the watershed.
8.9 -SA
That the LSRCA co -lead the promotion of Best Management Practices
supporting agricultural stewardship activities.
8.10 -SA
That Policy 8.10 on Best Management Practices incorporate urban
communities and municipalities in the discussion to reduce phosphorus and
other chemical/pollutant loadings from urban activities.
That the Best Management Practices Study to reduce phosphorus loading be
lead by the LSRCA with provincial funding.
8.11 -SA
That, in addition to LEED design in new buildings, site -level storm water
controls such as rain barrels, permeable pavements, and other innovative
designs be encouraged.
Research, Monitoring and Reporting
Policy #
Recommendation
8.12
Policy 8.12 is supported which requires an organized scientific monitoring and
research event every two years. The LSRCA is supportive of co -leading this
initiative.
EBR Registry Number 010-4636
Draft Lake Simcoe Protection Plan
Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 10 of 11
THAT a comprehensive and strategic communications plan be developed to address the
information needs of all target audience groups, as well as the promotional needs of the
partners; and further that this Plan include specific deliverables and accountabilities by
year so they can be monitored and adequately financed.
THAT, in the development of the communications plan, electronic and social media be
considered in the ongoing dialogue and sharing of information that is encouraged
among groups and organizations.
THAT, considering the scope and importance of communications, and with respect for
the desire to avoid duplication, the communications work required by all agencies be
supported and supplemented by financial resources from key partners, especially the
four named ministries of the Province.
THAT, in addition to other efforts to inform, a community-based social marketing
initiative be undertaken to engage residents and businesses in the watershed in
behavioral actions that will protect and enhance the environment. This would begin with
meaningful research conducted by a partnership of the LSRCA, the Province and key
stakeholders.
THAT funding be provided to enhance the education of young watershed residents and
that, considering the LSRCA's long-standing experience and existing place -based
facilities, the conservation authority continue to lead in this role with the support of
partners and additional resources.
THAT, as enhanced opportunities are developed to support agricultural stewardship, the
work being done by the LSRCA's LEAP program and others not be duplicated, and
further that the proposed additional funding to support and enhance agricultural
stewardship actions include increased investment in the LSRCA's LEAP program.
Advisory Committees under the Lake Simcoe Protection Act, 2008
THAT the Lake Simcoe Science Committee afford one seat to a science representative
from the Lake Simcoe Region Conservation Authority.
EBR Registry Number 010-4636
Draft Lake Simcoe Protection Plan
Comments from the Lake Simcoe Region Conservation Authority
February 12, 2009
Page 11 of 11
Financing Strategy
THAT the breakdown of projected operating costs be circulated to those identified as
sharing the responsibility for implementation and reviewed to ensure it reflects a
reasonable cost allocation relative to the identified responsibility.
THAT the policy statements and actions identified in the Plan be prioritized relative to the
identified targets.
THAT the resource requirements be estimated and quantified by specific policy
statement or group of related policy statements noted in the Plan.
THAT the estimated resource requirements be summarized and aligned with specific
target time lines.
THAT a process be established for the various parties that are identified and/or expected
to fund the implementation of the Plan to dialogue and negotiate a reasonable cost
allocation plan.
Plan Amendments
THAT the Lake Simcoe Protection Plan be reviewed at least every five years.