Tell Ramara Council to save Strawberry Island

From Ontario Nature

Strawberry Island in Lake Simcoe is under threat of development and local groups want your help to stop it.

Trans America Investments Ltd is asking Ramara Township Council to rezone the 10-hectare island so they can build 120 condominium units. If approved, the development would involve the removal of 5 hectares of forest and 2 wetlands, the construction of a sewage plant and increased phosphorous loading in Lake Simcoe.

The Carden Field Naturalists sent a letter to the Council asking them to keep the island’s current “rural” designation which would prohibit the development.

You can help by signing the group’s petition.

Information from petition by Pamela Fulford, Brechin

There is a development application by Trans America Group, a real estate company from Alberta that wants to build 120 condominium units on small Strawberry Island in Lake Simcoe.

This development will destroy 5 hectares (12 Ac) of significant woodlands, half of the wetlands on the island, decrease species diversity, increase phosphorus loading from current levels to Lake Simcoe, and does not recognize the Lake Simcoe lake trout or lake whitefish cold water fishery, nor its requirements.

This island was used by First Nations for centuries and remained protected in a natural state with the exception of a small Basilian Fathers monastery, shrine and retreat.  Pope John Paul II stayed at the Basilian Fathers Retreat on the island in 2002. This island is important for its woods, wetlands and untouched shoreline, all of which are disappearing rapidly in the Lake Simcoe watershed.

This small island of wilderness is home to an amazing array of wildlife: the Scarlet Tanager, Indigo Bunting, Ovenbird, American Redstart, Black and White Warbler, Veery plus the Species at Risk colonies of Barn Swallows and Little Brown Bats, as well as numerous amphibians and mammals.

In all these ways, it is part of our Canadian natural and cultural heritage. Trans America Group has applied to change the rural zoning to a special resort/condominium zoning that will destroy the island as we know it. The current rural designation allows only one homestead on the island and presently protects it. Right now, Trans America Group is asking the Township of Ramara to remove this protection.

I am not asking for money, I am just asking you to read the attached letter to Ramara Council and the developer and, if you agree, sign the petition.

Pamela Fulford’ s letter to Ramara Township Council, Planning Staff and Trans America Investments Ltd:

I wish to take this opportunity to comment on the Strawberry Island Development proposal by Trans America Investments Ltd. and its consultants. I respectfully request that these comments be included in the next Council meeting agenda to be considered by Council, Staff, Residents and Trans America Group and its consultants (Pinestone Engineering, Planscape Inc, Michalski Nielsen Associates). I request that the questions raised by my comments are answered in full by the developer and its consultants before Ramara Township Council votes on the zoning change. I also request that I have the opportunity to present a petition against this development, at a future Ramara Council meeting.

The Strawberry Island Development Proposal by Trans America reaches far beyond the carrying capacity of small Strawberry island and will increase phosphorus loading to Lake Simcoe. The time is now, while it is up for the zoning change, to carve this development down to the appropriate size and capacity. It is also unfair to the developer to encourage them to do further studies, at great cost, based on early incorrect assumptions.

As you know, this development proposal describes the construction of up to 120 condominium units scattered throughout the entire 10-hectare island. With this construction, most of the island’s 8 hectare woodland will be cut down and replaced by 2 hectares of buildings and pavement and 5 hectares of manicured lawn and 3 hectares of individual and scattered trees, some planted, some remnant (Fig. 5, App E). This currently lush and beautiful island would become bleak and bald with a narrow fringe of struggling and dying trees around the perimeter.

As a result of this development, sewage inputs will increase phosphorus loading to the lake with the cold water fishery (lake trout, whitefish and lake herring) negatively impacted by the lower oxygen levels from increased phosphorous.

My specific comments on the development design and zoning change are as follows:

1. Phosphorus Loading Limit Should be 3.35 kg/year Instead of 18.3 kg/yr: The Lake Simcoe Protection Plan (LSPP) is clear that no new non-municipal sewage treatment plant shall be established unless the plant will result in a net reduction of phosphorous loading to the watershed (4.4 D-P, LSPP).
Reducing phosphorous inputs to the lake improves the health of the cold-water fishery and increases dissolved oxygen levels for all aquatic species. The upper loading limit for future development should be based on “present day” levels and this should be the baseline for Pinestone Engineering to use and improve on.

All consultants used the loading limit of 18.3 kg/year for their designs of the proposed septic plant and claim that the proposed phosphorous loading to the lake does not exceed existing levels (Planscape Inc, June 25, pg 11). This is not correct. The 18.3 kg/yr loading limit was based on pre 2005 estimates of the old 1984 septic system, not existing levels. As acknowledged by the consultants, the island has not been used since 2005 (March 11 email, Appendix 1). The loading limit must be based on current levels, not historical estimates.

MOE staff sent an email on March 20th, 2014 basing their recommendation on what they believed were existing conditions – not the pre 2005 estimates of the consultant. As indicated in the FSP, the MOE calculated the pre-development phosphorus load for the Strawberry Island Re-development to be 3.35 kg/yr (March 30, 2012, Appendix E). Since the MOE established the most recent loading limit in 2012, the loading limit of 3.35 kg/yr represents the most recent and relevant loading limit, upon which any new septic system should be designed.

2. Sewage Flows Must Be Under 50,000 Litres/Day:
MOE staff cautioned the consultant that the sewage flow must be less than 50,000 L/Day (March 20, Email from MOE, FSP). In fact, the consultant’s huge and above-ground septic system has been designed to handle 137,282 Litres Per Day of sewage, with a “balanced flow” of 92,978 Litres Per Day. This supersized septic system, proposed to treat the sewage from 400 to 500 people year round, would dwarf the existing 10,000 litre system built in 1984 for up to 55 people with May to Oct usage. The water table is a shallow half metre below the surface of the island (Pinestone Engineering, May 2, 2014, pg 14) which is cause for great concern. I agree with the MOE that this system is significantly oversized for the carrying capacity of this small island. This issue alone is a huge red flag and should trigger a completely revised low impact and rural density development design.

3. The Existing High Water Quality of Strawberry Island Waters Is Recognized:
As previously stated, the consultants tested the water around the island years after the Basilian Fathers had left the Island and found it to be of very high quality with the low phosphorus concentrations of 0.010 mg/L. The consultant is correct in declaring, “further phosphorous loadings that increase concentrations beyond 0.010 mg/L are not acceptable” (pg 44 EIS). This is a also a reasonable level to use in the redesign of any future development proposal.

4. The Insufficient Proposed 30 Meter Buffer Should be a 100 Metre Protection Zone:
The consultant has mistakenly proposed a 30 metre buffer, the buffer that is designated by the LSPP for Settlement Areas. The Island is not a Settlement Area. Nor is it considered a shoreline “built-up” area. A small cluster of monastery buildings were built in the 1920s, away from the shoreline, concentrated in the northern clearing of the Island. According to the County of Simcoe Official Plan, the Island is not listed as a Designated Settlement Area (Simcoe OP Pg 64). According to County of Simcoe planning staff, it is not regarded as Settlement Area (pers. com, Sept 2014). The island is zoned RURAL with the potential for one homestead (Public/Town Council Meeting, Aug 2014).

By claiming that the Island is a Settlement Area, the consultant defends proposing the minimum buffer of 30 metres. But the minimum standard is not applicable in this area. The consultant omitted the applicable Lake Simcoe Protection Plan policy and setback for this island which is: “The vegetation protection zone for the remaining Lake Simcoe shoreline, outside of existing settlement areas and outside of shoreline built-up areas, is 100 metres from the Lake Simcoe shoreline.” (LSPP, 6.2-DP p 47).

This protection zone must consist of “natural self sustaining vegetation” (6.27-DP, LSPP), and trees cannot be cut down within it “for the reasonable provision of views” as is suggested by the consultant (Planscape Inc, June 25, 2014 pg. 13). Tree cutting to provide views of the lake would destroy the form and function of the protection zone. The Lake Simcoe Protection Plan is clear – the protection zone should be 100 metres in from the shoreline for the Island. This must be incorporated into the design of any future development on Strawberry Island.

5. The Woodland is Significant and is the Foundation for the Island Ecology:
The consultant claims that the 8 hectares of woodland is insignificant and can be cut down. However, Simcoe County woodland policy deems it significant, as it is a woodland above 4 hectares in size. The Lake Simcoe Protection Plan supports and encourages the enforcement of Simcoe County’s Forest Conservation By-law (LSPP 6.46-SA). The Strawberry Island forest is twice the 4 hectares minimum needed to be deemed “significant” and further proof of its significance is below.

The consultant has acknowledged that significant wildlife habitat exists in the island’s woodland and wetlands (pg 3, EIS Letter to Trans America Investments). He describes the forest as a veritable Garden of Eden: an early mature forest with a closed canopy of white elm, black walnut, sugar maple, red oak, basswood, white pine, silver maple, trembling aspen, balsam poplar and possibly the butternut, a Species at Risk. The forest also has an extensive shrub layer of sumac, dogwood, wild grape, wild rose etc. and a rich and variable herbaceous groundcover.

The wildlife species supported by the woodland, wetlands and shorelands include: river otter, beaver, red squirrel, muskrat, raccoon, chipmunk, a roosting colony of little brown bat (a Species at Risk), spring peeper, wood frog, gray tree frog, American Toad, monarch butterfly and many more. The consultant’s two day bird survey surprised the consultant into claiming, “the Island appears to be supporting a reasonably large number of area sensitive species”.

The 40 bird species heard and seen on the Island include forest interior birds: Black and White Warbler, Barn Swallow (Species At Risk), American Redstart, Ovenbird, Pileated Woodpecker, Hairy Woodpecker, Scarlet Tanager, Veery, White-Breasted Nuthatch. Other birds inventoried on the Island are: Indigo Bunting, Belted Kingfisher, Common Yellowthroat, Eastern Phoebe, Great Blue Heron, Eastern Kingbird, Spotted Sandpiper, Song Sparrow, Tree Swallow, White-throated sparrow, Yellow Warbler and Yellow Bellied Sapsucker and of course the ever- present cardinal and blue jay, plus many more.

More than the 40 bird species would have been inventoried if the two short surveys taken by the consultant had been scheduled for peak breeding. The woodland and wetlands support a remarkably high diversity of wildlife, many of which will die or leave the Island due to the proposed construction and extensive footprint of this proposal. Wildlife habitat also presently on the Island exists for other Species at Risk, namely the Red Headed Woodpecker, Five-Lined Skink and Jefferson Salamander, however surveys were not done for these Species at Risk observed in the area. The Island also provides fall migration stop-over habitat for many species of ducks and other water and migratory birds and a winter stop-over area for fox, snowy owl, hare and coyote, species we often seen traversing or resting on the winter/spring ice close to the Island.

I strongly disagree with the consultant that “the features and habitat functions would not be lost or eliminated with the proposed development in place.” (Pg 4, EIS letter). This is not true. Most of the forest will be cleared and many of these species will die or leave the island as a direct result of loss of their habitat through the building of this development. Only edge and non-native, invasive species will be able to survive on the Island.

6. Interior Forest Habitat Exists Now on the Island:
Many of the species observed on the Island are interior forest indicator species, even though the consultant has stated that there is no interior forest on the Island. I believe he has used the incorrect definition of interior forest. He states that interior forest must be at least “200 metres from the edge of the feature” (pg 5, EIS letter). The Ministry of Natural Resources defines interior forest as a woodland larger than 4 hectares with an area inside the forest defined by 100 metres from the woodland edge (MNR Extension Note: Conserving the Forest Interior, A Threatened Forest Habitat, 2000). The fact remains that this forest sustains interior forest species.

7. Rarity of Species:
There are likely more protected species on and around the island (EIS pg 41-42), including lake whitefish and lake herring. The consultant is not sure if Butternut, endangered both federally and provincially, is on the island but suggests the possibility. The consultant claims “The Species at Risk known to occur within the vicinity of Strawberry Island are almost impossible to observe, even when known to be present in an area. Because of the very low probability of encountering them, the most efficient and effective way to investigate the Island’s attributes is to look at habitat affinities, rather than conduct intensive searches for the species itself.” (Pg 67, EIS). The consultant concludes that “endangered and threatened species exist on the Island” and that the developer “must consult with the MNR prior to undertaking site work”. But by then, it will be too late. The woodland and the wetlands sustaining the Species at Risk and interior forest species will be gone. Under this inconclusive and vague understanding of Species at Risk on the island, alluded to in the consultant’s reports, it would be prudent of Ramara Township to protect the woodland and existing wetlands that support the majority of these rare species by keeping the rural zoning.

Seasonal Occupancy or Full Year Occupancy?
The consultants claims that the development is “seasonal” “10 months maximum operation” (Planscape Inc, June 25, 2014 pages 1 and 11). However, in the consultant’s draft of the Strawberry Island Proposed Official Plan Amendment, June 18, 2014, Section 9.12.5, they assert, “The occupancy of the accommodation units may occur during any seasonal period in any calendar year”. This seasonal/full year-round issue is important in many ways and it is another red flag for the commenting agencies. The proposed septic capacity is based on 365 days per year and this is a full year round residential development (Pinestone Engineering FSP pg 16). The Township of Ramara needs to realize that this development will be occupied in all seasons.

Year round occupancy also has implications for transportation to and from the island and island emergency rescue of the residents during all seasons. It is well known that Lake Simcoe can be extremely unforgiving and dangerous at spring ice break up and early winter ice formation times. Many people have died crossing to and from Lake Simcoe islands. The safety of the residents crossing on treacherous ice, rough water and stormy conditions year-round is a concern. In addition, mainland parking and gravel road access for the potential 400 to 500 residents is woefully inadequate. All of these issues need to be fully addressed before a zoning change is even contemplated. At the Public Meeting in August 2014 at the Township of Ramara and in the consultants’ reports, these questions were not answered sufficiently.

8. Cold Shoulder Treatment of the Cold Water Fishery: The consultants describe the lake trout, lake whitefish and lake herring (cold water fishery) as “collapsed”. The Lake Simcoe cold water fishery is not collapsed. It is a vibrant, improving, multi-million dollar industry. Natural recruitment of natural lake trout and whitefish is increasing (MNR pers. comm.) with the clean up of Lake Simcoe and under the Lake Simcoe Protection Plan. The consultant needs to update his facts or just accept the existence of the thriving fish populations and strong cold and warm water fishing industry on Lake Simcoe and protect them.

Likewise, the consultant claims, “No special fish habitat features are known for the nearshore waters of Strawberry Island.” The Ministry of Natural Resources first mapped the lake trout and lake whitefish spawning shoals in 1978. They were re-evaluated in the early 1990s. The shoals are extensive, stretching across to McGinnis Point on the mainland and cover the entire eastern and southern near shore zone of Strawberry Island. Larval lake whitefish and lake trout have been caught in larval trawls by the Ministry of Natural Resources and millions of spawning, healthy lake trout, lake whitefish and lake herring, all cold water species, have been caught in trap nets by the Ministry of Natural Resources for decades off the famous Strawberry Island shoals. Local fishermen also know these shoals as some of the best smallmouth bass shoals for summer fishing in Lake Simcoe. These special shoals warrant protection.

9. The Island Ecosystem Is Important: The island ecosystem is not recognized as important by the consultant. Pieces are discussed and dealt with as separate, unrelated entities. However, the woodlands, wetlands, shorelands, shoals, island hydrology, fish and wildlife species all fit together in a fully functioning island ecosystem which will be completely destroyed by the current proposal. It will become an ecologically barren place with manicured lawns, houses, asphalt and at the centre of it all, one very large sewage system.

10. Further Studies? I look forward to reviewing the hydrogeological and archaeological reports that I have heard are forthcoming. I expect these reports will likely further substantiate the need to radically scale this development down.

The above section describes only some of the inconsistencies and miscalculations in the development proposal. There are more that can be raised in the future.

In conclusion, our Council needs to keep the Rural Zoning for this island so that the following conditions are met for any development of Strawberry Island:

1. Stay within the existing footprint of the present buildings and septic system
2. Phosphorus loading from future development stays below the 3.35 kg/year
3. Water quality around the island during and after construction remains at the pre-development level at 0.010 mg/L for concentration of phosphorus
4. The shoreline protection zone is 100 metres from the Lake Simcoe shoreline
5. The woodland is protected in its entirety and a Tree/Woodland Protection Plan will be prepared by the developer to be reviewed by Council and Staff
6. The four existing wetlands are protected and their function is preserved to help sustain the Significant Wildlife Habitat on the Island.

The above elements followed in future development design will protect the form and function of Strawberry Island, reduce phosphorus loading as dictated by the LSPP and allow the appropriate level of development on this small island. This is not the only island under the jurisdiction of Ramara that may be developed. How we proceed with Strawberry Island will set a precedent for the other islands under development pressure and also with the development of shoreline areas in the future. Following the above elements as a guide but tailored to each new proposal will guarantee the environmental health of the watershed, in regard to future growth.

I believe that Ramara Council would be wise to keep the Strawberry Island zoning designation that will protect the natural form and function of the island. Allowing the cutting down of the 8 hectares of existing significant woodland, filling in the wetlands, increasing phosphorous loading thus threatening the cold water fishery, destroying habitat for the Species at Risk that live on the Island, will destroy this island.

Ramara needs development, but the RIGHT development in the RIGHT place. A much scaled down development that truly respects the natural character of the Island and stays within the footprint of the existing buildings, will protect the ecology of the island and lake and also provide enjoyment of this island and sustain it for future generations.

Sincerely,

Pamla Fulford, Brechin, ON

Link to TransAmerica website posting

Link to Basilian historical account