A new review of the Strawberry Island development application
Letter from Pamela Fulford, on behalf of Friends of Strawberry Island to Ramara Township Council and Staff posted at change.org
Re: New Document Review on the Strawberry Island Development Proposal
Trans America Investments Ltd. and its consultants have sent in a revised Strawberry Island Functional Servicing Report (FSR Jan 2015), Archaeological Assessment of Strawberry Island (Dec 2014), Hydrogeology Study (Dec 2014) and Strawberry Island Traffic Impact Study (Dec 2014). We respectfully request that the developer responds to the comments below, prior to Ramara Township Council voting on this development. We also ask Council, at their convenience, to allow Pamela Fulford on behalf of Friends of Strawberry Island to present a petition signed by over 500 people supporting Council to keep the current rural zoning. A deputation request form has already been sent in and has been received by Township staff.
This development proposal depicts “a perfect storm” of development impacts. It reaches far beyond the carrying capacity of this small island in the following ways:
1. The Density is Too High with no Shoreline Protection: The developer persists in planning a high density, 120-condominium unit development covering the 10-hectare island (Jan 2015 FSR, p 34). With this construction, most of the island’s 8 hectare woodland will be cut down and replaced with buildings, asphalt, manicured lawn, a thin line of trees along the shoreline and scattered trees among houses and three story buildings (Fig. 6, App E). The developer’s proposed 40 metre “filter strip” (p 31) will replace the existing woodland, which in fact, should be protected by a 100 metre deep protection zone extending from the shoreline to the island interior. According to the Lake Simcoe Protection Plan (LSPP) “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). The Lake Simcoe Protection Plan is the law.
In addition, development or alterations are not permitted within a vegetation protection zone (LSPP 6.23-DP, p 50). The protection zone must consist of “natural self-sustaining vegetation” (LSPP 6.27-DP), and trees cannot be cut down within it “for the reasonable provision of views” as is suggested by the consultant (Planscape, June 25, 2014 p 13). Tree cutting to provide views of the lake would destroy the function of the protection zone. The Lake Simcoe Protection Plan is clear – the protection zone should extend 100 metres in from the shoreline. This clearly applies to the design of any future development on Strawberry Island.
2. Significant Woodlands and Significant Wildlife Habitat Used as a “Filter Strip”: The developer claims that their proposed Stormwater Best Management Practices (BMPs) can reduce their phosphorous load by 1024% (Jan 2015 FSR, p 28) partially by using the existing significant wildlife habitat (forest and wetlands) as a “filter strip” (Jan 2015 FSR, p 29). Furthermore, the consultant proposes siltation control work and “maintenance” of the significant forest and significant wildlife habitat (Jan 2015 FSR, p 32). This “maintenance” is not defined but could mean anything from using the natural areas for dewatering, filtering sediment and pollutants, soil storage or equipment staging areas. Any of these actions will destroy the function of the existing significant forest and wildlife habitat. New stormwater management works or alterations are not permitted within a significant woodland, wildlife habitat or vegetation protection zone (LSPP 6.23-DP, p 50). In addition, an appropriate buffer (10 m + drip line) should surround all naturally significant areas.
3. Calculating P Loads based on Irrelevant Estimates, not Existing Conditions: The revised FSP incorrectly claims that the “existing system” contributes 12.2 kg total phosphorous annually to Lake Simcoe (Jan 2015 FSR, p 16). This load calculation is invalid as it is based on an estimate – not actual samples – from an inactive septic system that was built in the 1980s and has not been used for a decade. Current and correct data show that the pre-development total phosphorous load is 0.71 kg/yr. (App. E). The Lake Simcoe Protection Act does not allow new non-municipal sewage treatment plants to be established unless “the plant will result in a net reduction of phosphorous loadings to the watershed from the baseline conditions for the property that would be serviced” (LSPP 4.4-DP, p 28). This net reduction has not been demonstrated in the FSR and must be proven prior to the approval of any new development. The proponent must clearly show how such a radical reduction of phosphorus to below 0.71 kg/yr could be achieved in the new development.
4. Significant Finds in the Archaeological Assessment: Two Woodland Period archaeological resources were found on the island and therefore supplementary work and a second report is mandatory, according to Ontario legislation. However, the developer’s consultant declares that this information is not to be made public (Planscape memo, Jan 27, 2015). It is important to protect the location of the finds, but how are local First Nations people and other residents to know if these resources are actually protected if we are not allowed to review the final report?
5. Traffic Study is based on 2005 data and does not address Local Concerns: The Strawberry Island Traffic Impact Study (TIS) is based on outdated 2005 count data and appears to be a limited “desktop” exercise focusing on one intersection. It ignores local residential streets, Glen Cedar Drive and Bayview Avenue, which will be impacted by traffic for the development. It does not address local concerns voiced at the public meeting, such as the one raised by Mayor Clarke about inadequate parking space on Glen Cedar Drive. It ignores whether the Township will need to widen or resurface these local roads, create turning lanes or install traffic lights – all potential upgrades specifically linked to this development. It does not specify who will pay for this. It also does not address the McRae Pt. Provincial Park potential traffic congestion on a Friday or Sunday night when mixed with the 500 new residents from Strawberry Island.
It may be outside the scope of the TIS but other concerns raised by residents at the Public Meeting need to be answered: loading dock locations for deliveries; shuttle boat size, frequency and timing; increased boat traffic and wake; docking facilities for 500 people; hovercraft or helicopter use and noise; pedestrians at risk with increased traffic and no sidewalks on residential streets; shoreline erosion and sinkholes along the canal; garbage transport and storage; Emergency Services access and cost. These will become township problems should the development proceed as planned.
6. The Hydrogeology Study does not Address Water Table Seasonal Variation: The May 2014 FSR suggested the water table was approximately 0.5m below ground surface. The Hydrogeology Study (Dec 2014, p 6), which sampled a limited area around the proposed septic bed late last fall, found water levels at 1.8 m below ground surface. Seasonal variability in groundwater levels is common. Groundwater levels are higher during spring melt and reach their lowest levels in autumn and early winter. Testing in November, as the developer has done, is not representative of other months and seasons when the water table is likely to be higher. If there is not sufficient separation from the high ground water table to the constructed infiltration trenches, the trenches will not work and contamination of the water table will result. The proposed new sewage system is designed for a total daily flow of 137,282 litres of sewage per day. Failure is not an option. Therefore, a baseline of seasonal normal groundwater levels must be established prior to any approval, to ensure that the infiltration and sewage system controls do not fail and that the development will not result in the addition of contaminants to the groundwater and phosphorous to the lake.
7. Seasonal Occupancy or Full Year Occupancy Confusion: The consultants claim that the development will be open for an even shorter season “8 months maximum operation” (FSR Jan 2015 p 18) than the previously reported “10 months maximum operation” (Planscape, June 25, 2014, p 11). However, the Strawberry Island Proposed Official Plan Amendment asserts, “The occupancy of the accommodation units may occur during any seasonal period in any calendar year” (June 2014 Sec 9.12.5). This seasonal / full year-round confusion has numerous planning and septic implications and should be another red flag for the commenting agencies. The proposed septic capacity and phosphorous loading is now based on 243 days per year (Jan 2015 FSR p16). How can the developer guarantee that this development will be seasonal, with water and sewer shut off in the winter, once the condominium board takes over the management of the island if there are no requirements outlined in the official plan amendment that restricts this?
8. In Conclusion: We continue to urge our Council 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 clearing for any future development;
2. Phosphorus loading from future development stays below the 0.71 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 Preservation Plan is prepared;
6. The four existing wetlands are protected and their function is preserved to help sustain the Significant Wildlife Habitat on the Island and sufficient protective buffers are implemented.
The above elements will protect the ecological function of Strawberry Island, reduce phosphorus loading as dictated by the Lake Simcoe Protection Plan, allow the appropriate level of development on this small island and sustain it for future generations. We are in favour of sustainable and smart development, which ensures our essential use and enjoyment of Lake Simcoe water for the future.
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