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OAK RIDGES
MORAINE
PARTNERSHIP FOR
2015
5/28/2015
Stronger Laws. Stronger Landscape.
Stronger Legacy.
EBR Registry 012-3256 Co-ordinated Review of the Growth Plan for the
Greater Golden Horseshoe, Greenbelt Plan, Oak Ridges Moraine
Conservation Plan and the Niagara Escarpment Plan
ACKNOWLEDGEMENT
The Oak Ridges Moraine Partnership for 2015 is comprised of Earthroots, EcoSpark, Ontario Nature and
STORM. This document is a product of collaborative multi-stakeholder efforts with contributions from
community groups, NGOs, university students, academics, and municipal councilors.
The Oak Ridges Moraine Partnership for 2015 would like to thank the following contributors:
Julie Adams, Susan Binnie, Tash-Lynn Cranston, Sarah Cranston, David Francis, Emily Goldney, Peter
Graham, Melanie Jansen, Ian McLaurin, Kirsten Melnyk, Caroline Morrow, Michael Norris, Jessica Pertilli,
Fawn Pettifer, Floyd Pinto, Isobel Ralston, Megan Rueckwald, Frank Shaw, Pat Valentine, Diana Van
Vlymen, Graham Whitelaw and Jane Zednik
How to Read this Document
This document outlines the 48 policy recommendations submitted through the Environmental Registry on
May 28, 2015 (#012-3256) on behalf of the Oak Ridges Moraine Partnership for 2015.
These recommendations are organized in three themes: Stronger Laws, Stronger Landscape and a
Stronger Legacy. The Table of Contents (Page 1) outlines the key elements that are addressed under
each theme. The order of these recommendations does not reflect our priorities and each element and
associated recommendation(s) can be read as a stand-alone chapter. A complete list of our
recommendations has been collated on pages 60-64.
We welcome an opportunity to discuss our recommendations in more detail.
The Oak Ridges Moraine Partnership for 2015:
This report would not have been possible without funding (past and present) from the Friends of the
Greenbelt Foundation and the Oak Ridges Moraine Foundation.
Oak Ridges Moraine Partnership for 2015
Table of Contents
INTRODUCTION................................................................................................................... 2
STRONGER LAWS ................................................................................................................ 6
WHAT’S WORKING ................................................................................................................................ 7
1. Land Use Designations ..................................................................................................................... 7
2. Internal Boundaries ........................................................................................................................... 8
3. Rural Settlement Boundaries in Countryside Areas ................................................................. 10
Rural Settlement Boundary Case Study………………………………………………………………………. 12
NECESSARY IMPROVEMENTS: LAND USE PLANNING ON ORM AND ACROSS THE GGH..... 13
4. Watershed Planning...................................................................................................................... 13
5. Tree-Cutting .................................................................................................................................... 15
Tree Cutting Case Study…………………………………………………………………………………...…………. 17
6. Permitted Uses and Rural Prosperity ......................................................................................... 18
7. Commercial Fill ............................................................................................................................... 20
Commercial Fill Case Study…………………………………………………………………….………...…………. 22
8. Aggregates ..................................................................................................................................... 24
9. Transitional Applications............................................................................................................... 26
10. Infrastructure ................................................................................................................................ 27
NECESSARY IMPROVEMENTS: BRINGING OTHER STATUTES IN LINE WITH THE ORMCP .... 29
11. Bringing Other Statutes In Line with the ORMCP .................................................................. 29
Water Exportation Case Study………………………………………………………………...…………………. 31
Permit To Take Water Case Study………………………………………...…………………………………… 33
Large-scale Renewable Energy Project Case Study………………………………………...………… 34
STRONGER LANDSCAPE.................................................................................................... 36
WHAT’S WORKING ............................................................................................................................. 39
12. Interplay between Conservation and Growth Plans ............................................................ 39
NECESSARY IMPROVEMENTS ............................................................................................................. 40
13. Growing the Greenbelt.............................................................................................................. 40
14. Natural Heritage System for the GGH................................................................................... 43
15. Agricultural System for the GGH ............................................................................................. 45
16. Hard Urban Boundary................................................................................................................ 46
STRONGER LEGACY .......................................................................................................... 47
WHAT’S WORKING ............................................................................................................................. 48
17. Foundation Support..................................................................................................................... 48
18. Public Access and Engagement ................................................................................................. 49
NECESSARY IMPROVEMENTS ............................................................................................................. 50
19. Governance .................................................................................................................................. 50
20. Effective Implementation of the ORMCP and GBP ............................................................... 51
21. Monitoring and Performance Measures .................................................................................. 53
22. Innovation in Stewardship and Restoration Programs.......................................................... 55
23. Engage the Next Generation Champions............................................................................... 57
RECOMMENDATIONS........................................................................................................ 60
Page 1
Oak Ridges Moraine Partnership for 2015
INTRODUCTION
The Oak Ridges Moraine, Greenbelt and Niagara Escarpment Plans play a key role in protecting the
region’s most valuable natural assets. Important changes to these plans and associated policies are
necessary in the 2015 Co-ordinated Review to ensure the water, nature and communities of the Greater
Golden Horseshoe (GGH) are protected for future generations.
This 2015 Co-ordinated Review is an important opportunity to improve the ecological and hydrological
functioning of the Oak Ridges Moraine for the benefit of the entire GGH, and the government should be
commended for taking this bold step. This review opens the door for a systematic approach to better
plan for and build an ecologically resilient region in the face of climate change and anticipated
population growth. Our policy position is centered on recommendations intended to improve the
environmental policies that protect the Greenbelt (i.e., Oak Ridges Moraine and Protected Countryside)
and build strong and resilient communities within the GGH.
The Oak Ridges Moraine Partnership for 2015 is comprised of Earthroots, EcoSpark, Ontario Nature and
Save the Oak Ridges Moraine Coalition (STORM), four committed environmental non-government
organizations that have collaborated successfully since 1991 for long-term protection of the Oak Ridges
Moraine. In 2013 our four groups again joined forces to prepare for and participate in the mandated
review of the Oak Ridges Moraine Conservation Plan (ORMCP) and Greenbelt plan (GBP). In 2014 the
province announced that it agreed with a majority of stakeholders to expand the review to include the
Growth Plan and launch a coordinated review of the Oak Ridges Moraine Conservation Plan, Niagara
Escarpment Plan, Greenbelt Plan and Growth Plan for the Greater Golden Horseshoe.
During the 2015 Co-ordinated Review, the Partnership is calling for Stronger Laws, Stronger Landscape
and a Stronger Legacy as outcomes of this review:
1. Stronger Laws: Address policy gaps and close loopholes that are not aligned with the vision and
objectives of the conservation plans that protect the Oak Ridges Moraine and Protected
Countryside of the Greenbelt
2. Stronger Landscape: Establish a Greater Golden Horseshoe bioregional strategy to help the
region, including the Greenbelt, mitigate the impacts of and adapt to climate change by extending
the protection of natural heritage and prime agricultural systems to the entire Greater Golden
Horseshoe, that is supported by a hard urban edge to stop urban sprawl and growing the
Greenbelt to provide additional protection to vulnerable water supplies and features
3. Stronger Legacy: Build stronger support for effective implementation of the Greenbelt, establish a
robust monitoring program to evaluate the health of the Greenbelt, encourage new champions of
the landscape, and a reinvestment in programs fostering long-term stewardship and restoration
and ecological and community monitoring
The Greenbelt is a cornerstone of a climate change strategy for the Greater Golden Horseshoe, and its
three plans create a solid legacy of greenspace and farmland for the health and prosperity of the
region. We are asking the government to re-commit and enhance protection for our water, nature and
communities to ensure the long-term health and prosperity of the Greater Golden Horseshoe.
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Oak Ridges Moraine Partnership for 2015
Background
When the Oak Ridges Moraine Conservation Plan (ORMCP) was passed in 2002, it was widely
considered to be one of the most progressive ecologically-based plans in Ontario. The vision of the
ORMCP is to achieve “a continuous band of green, rolling hills that provides form and structure to southcentral Ontario, while protecting the ecological and hydrological features and functions that support the
health and well-being of the region’s residents and ecosystems”. The vision of the ORMCP holds true
today, especially in the face of growth and development pressures. In 2005 the government continued
with planning and management for southern Ontario by enacting the Greenbelt Act and Greenbelt Plan
(GBP). This legislation added 400,000 hectares of protected countryside comprising an integrated
agricultural and natural heritage system. Today, the Greenbelt is the largest permanent greenbelt in the
world at nearly 2 million acres.
First and foremost, the Oak Ridges Moraine has been described as the “rain barrel” of south central
Ontario. At 195,000 hectares or ~27% of the total Greenbelt Plan area, Oak Ridges Moraine delivers
proportionately more ecosystem goods and services for the benefit of the social and ecological wellbeing of the region. Its thick layers of sands
Because of the Oak Ridges Moraine’s groundwater
and gravel are the aquifers that provide
significance, EcoSpark partnered with conservation
groundwater as drinking water supplies to
authorities, ENGOs and volunteers to monitor baseflow in
over 250,000 people directly and
15 Moraine-based watersheds from 2006 to 2010 at
indirectly to millions more. As the
1,730 sites with 428 volunteers.
headwaters to 65 river and streams, it can
Figure 1. Baseflow results from Check Your Watershed Day.
be safely argued that the highest and best
use of Oak Ridges Moraine lands is at that
initial interface between rain and snowmelt that collects and delivers this
precipitation downward into huge
underground aquifers. During hot dry
summer months, this groundwater or
“baseflow” is the primary source of water
in the region’s streams and rivers
supporting aquatic ecosystems and fish
populations, as well as providing critical
habitat for flora and fauna. The Oak
Ridges Moraine has been called one of
Canada’s most significant groundwater
sources1, situated as it is in Canada’s fastest
growing and most heavily populated area.
1
Geological Survey of Canada, Proceedings, water resource investigations of the Oak Ridges Moraine, Ontario: geology and
hydrogeology (1997)
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Oak Ridges Moraine Partnership for 2015
Groundwater is an essential resource for everything from drinking water to irrigation for growing crops
and food, watering livestock and maintaining golf courses, and rural businesses. The economy relies on
the ecological goods and services that are provided by the Oak Ridges Moraine for free.
Within the Greater Golden Horseshoe (GGH), the Oak Ridges Moraine, the Niagara Escarpment and
natural heritage system of the Protected Countryside, form the ecological backbone of our natural
heritage system, which, along with other natural areas in the Greater Golden Horseshoe, connect major
corridors in southern Ontario and eastern North America. Specifically in Ontario, the Oak Ridges Moraine
divides the watersheds that drain into Lake Ontario, Georgian Bay, Lake Simcoe and the Trent River
System. It also is connected to a broader natural heritage system in south-central Ontario. This broader
connection is noted in Section 1.2.2.2.b of the Greenbelt Plan where a goal is to maintain connections
with southern Ontario’s broader natural systems beyond the GGH such as the Great Lakes Coast, the
Carolinian Zone, the Lake Erie Basin, the Kawartha Highlands, and the Algonquin to Adirondacks
Corridor. This is further emphasized in an external connections policy in the Greenbelt Plan (Section
3.2.5).
The idea of a regional natural heritage system has always
been the vision of the government and all the supporters of
the Oak Ridges Moraine conservation movement including
senior provincial staff, conservation authorities and civil
society. These concepts were also further embedded in our
thinking through key documents including Watersheds2,
Regeneration3, Space for All4 and the Ganaraska Report
38 of the Environmental Assessment Advisory Committee5.
The Oak Ridges Moraine serves a significant role with its
unique assemblage of “environmental, ecological and
hydrological features that makes its ecosystem vital to
south-central Ontario”6. As such, the purpose of the
ORMCP is to protect these features and their functions,
which are captured in the Natural Core Area and Natural
Linkage Area designations. These high functioning cores
and corridors form the majority of the landscape (62%)
and work in tandem, buffered by the Countryside Areas.
“What can New Zealand learn from
overseas experience about the
management of icon landscapes in
peri-urban areas? Three locations were
chosen to examine land use planning
in the context of sustainable
development: the Oak Ridges Moraine
in Ontario, Canada; the Cape
Peninsula in South Africa; and the
Peak District in the United Kingdom.”
Source: Parliamentary Commissioner
for the Environment, 2003, Suburb or
Superb? International studies in
management of icon landscapes,
Wellington, NZ
It has been 13 years since the release of the ORMCP. There is a majority view that as a land use plan,
the policies of the ORMCP have been effective in accomplishing its primary purpose of establishing an
environment-first approach to land use and resource management on the Moraine. However, from our
perspective as the grassroots voice of the Moraine conservation movement, the current review
2
Royal Commission on the Future of the Toronto Waterfront, Watershed: Interim report (1990)
Royal Commission on the Future of the Toronto Waterfront, Regeneration, Toronto’s Waterfront and the Sustainable City: Final
Report (1992)
4 Ron Kanter, Space for All: Options for a Greater Toronto Area Greenlands Strategy (1990)
5 Environmental Assessment Advisory Committee, The Adequacy of the Existing Environmental Planning Approvals Process for the
Ganaraska Watershed (1989)
6 Oak Ridges Moraine Conservation Plan (2002)
3
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Oak Ridges Moraine Partnership for 2015
undervalues the natural heritage and water resources of the Oak Ridges Moraine and Niagara
Escarpment. The foresight and precedent setting nature of these plans must be celebrated and continued
as an outcome of this review.
The challenge facing the GGH is to allow land use and resource management to become more
adaptable in order to allow the social and ecological systems to be resilient to impacts of human-induced
climate change and increased population growth (see “Necessary Improvements” in the “Stronger
Landscape” section).
Figure 2. A map of the Greater Toronto Bioregion
(Source: Royal Commission on the Future of the Toronto Waterfront, Regeneration, Toronto’s Waterfront and the Sustainable
City: Final Report (1992))
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Oak Ridges Moraine Partnership for 2015
STRONGER LAWS
Over the past 13 years, the implementation of the ORMCP policies has generally been successful in
maintaining the natural heritage and hydrological systems of the Oak Ridges Moraine. Data from the
Conservation Authorities Moraine Coalition (CAMC) 2015 Report Card on the Environmental Health of the
Oak Ridges Moraine and Adjacent Greenbelt Lands shows that forest cover has been maintained in critical
areas (e.g., the Natural Core Area of the Oak Ridges Moraine and the Natural Heritage System of the
Protected Countryside) and that groundwater quality is generally locally good although there is local
variability. The Oak Ridges Moraine Foundation’s (ORMF) 2011 Watershed Health Assessment also
found there is a healthy amount of natural forest cover in the headwater areas of the Oak Ridges
Moraine as well as signification areas of forest interior habitat.
However, the ORMCP has not been successful in meeting the objective of “improving or restoring all the
elements that contribute to the ecological and hydrological function of the Oak Ridges Moraine”. The
CAMC Report Card found that there was little data to support the goals of the ORMCP and GBP to
restore and enhance forest conditions and nearly half of the subwatersheds were found to have fair to
very poor water quality. Furthermore, the ORMF Watershed Health Assessment demonstrated the need
for restoration to increase natural terrestrial cover and forest interior habitat to recommended levels.
Stream restoration was also recommended as water quality was found to be lower than what is expected
for natural, healthy stream systems.
As previously stated, it is possible that under the current planning approach, the ORMCP has gone as far
as it can go. The full intent of the ORMCP cannot be met by policy alone; it requires a complementary
suite of tools and programs, including stewardship, to achieve its vision. This is important as the need for
and value of the Oak Ridges Moraine’s ecological goods and services will continue to rise with future
stressors in the GGH.
The past 13 years has also revealed a number of policy short-comings, gaps and loopholes that are not
aligned with the purpose, vision or objectives of the ORMCP. These issues include the destruction of
neighbourhood forests, the large-scale movement and dumping of fill, the approval of large scale
energy infrastructure, and water-takings for development on and off the Oak Ridges Moraine.
The Oak Ridges Moraine Partnership for 2015 is calling for stronger laws to strengthen the Oak
Ridges Moraine’s water, land and communities for the long-term health and prosperity of the GGH.
The Partnership’s evidence-based recommendations are based on the underlying principle that the Oak
Ridges Moraine’s unique value and identity is its Natural Core Areas and Natural Linkage Areas, and
that these areas must hold primacy with respect to ecological and hydrological protection (i.e., maintain,
improve or restore) in the 2015 Co-ordinated Review.
In this Stronger Laws section, the Partnership outlines areas in the ORMCP that are working and areas
that require improvement. The recommendations build upon the existing conservation-based policy
framework of the ORMCP and where appropriate, are applied to the rest of the Greenbelt and Greater
Golden Horseshoe. Some recommendations also extend to other statutes that are not in line with the vision
of the ORMCP. The Partnership is recommending a nuanced approach to the ORMCP’s policies to allow
for the greatest collective gains in terms of a sustainability approach with environmental, social and
economic considerations.
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Oak Ridges Moraine Partnership for 2015
WHAT’S WORKING
1. Land Use Designations
Current Policies
The ORMCP organizes the Oak Ridges Moraine into four land use designations in Part II of the ORMCP:
Natural Core Areas (38% of the Moraine), Natural Linkage Areas (24% of the Moraine), Countryside
Areas (30% of the Moraine) and Settlement Areas (8% of the Moraine). The current purpose and
objectives of each land use designation are outlined in Section 11(1) and (2), Section 12(1) and (2),
Section 13(1) and (2), and Section 18(1) and (2). Municipal official plans are required to be in
conformity with the ORMCP Land Use Designation Map (Map No. 208).
Strengths & Weaknesses
These designations recognize the unique features and functions of each area and have provided an
ecologically sound framework through a systems-based approach to achieve the vision of the ORMCP:
core, corridors, buffers, and places were urban development is directed. These designations and the
amount of land in each designation accurately reflect why the Oak Ridges Moraine is important. They
have imbued a sense of pride, place and ownership among local residents, especially in relation to
Natural Core Areas. These land use designations are also complemented and supported by the protected
lands within the Niagara Escarpment and the Protected Countryside, and are part of a vital larger
natural heritage system in south-central Ontario (Section 3.2.1 and 3.2.5 in the Greenbelt Plan).
Overall the conformity process worked well with municipalities bringing their official plans in line with the
ORMCP in a timely manner (see MTM Status Reports from 2006, 2007 and 2012). For example, in the
2006 Monitoring the Moraine (MTM) Status Report, the required conformity activities, including official
plan and zoning by-law amendments were largely completed; all 24 lower tier and six upper tier
municipalities with planning functions had bought official plans into conformity with the ORMCP. The
Partnership believes the governance process model has generally proven itself in promoting good
decision-making.
Generally, the permitted uses in these land use designations are appropriate with some key exceptions
where the permitted uses are either too flexible for large-scale uses or too inflexible for small scale uses
(see Section 6, “Permitted Uses and Rural Prosperity”).
Recommendations
Recommendation 1.1 That the purpose and objectives of the four land use designations within the Oak Ridges
Moraine Conservation Plan (i.e., Natural Core Areas, Natural Linkage Areas, Countryside Areas and
Settlement Areas) be maintained
Recommendation 1.2 That all decision makers (e.g., municipalities and the Ontario Municipal Board) should
continue to conform to the Oak Ridges Moraine Conservation Plan and its land use designations
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Oak Ridges Moraine Partnership for 2015
2. Internal Boundaries
Issue
There are currently numerous requests to change the internal boundaries of the ORMCP’s land use
designations that have the potential to fragment the landscape and negatively impact the Oak Ridges
Moraine’s integrity. These requests are to increase land for growth and development. They include
expanding the Settlement Area boundaries into the ORMCP’s other land use designations, removing lands
from the ORMCP for residential development, and potentially swapping of lands in and out of the
ORMCP, in and out of the GBP, and between the ORMCP and the GBP.
Examples of boundary change requests include those in northern Vaughan in the headwaters of the
Humber River and in northern Pickering in the headwaters of East Duffins Creek. Requests to remove
lands from the Protected Countryside have also been made, e.g., in King Township and north-eastern
Whitchurch-Stouffville along the 400-series highways. Many of the proposed land swaps are in areas
with transitional applications, e.g., Maple Lake Estates in Georgina (see Section 9, “Transitional
Applications”).
As the grassroots voice for the Oak Ridges Moraine, the Partnership has a firm position that there should
be no swapping of lands associated with the Oak Ridges Moraine or the Greenbelt.
Current Policies
The Plan Review and Amendment Section of the ORMCP states that the 10-year review can be amended
to included new, updated or corrected information (subsection (a)). The review cannot remove lands from
the Natural Core Areas and the Natural Linkage Areas (subsection (b)) but can consider changes or
refinements to the Countryside Areas and Settlement Area boundaries (subsection (c)).
Any changes to the Settlement Areas must include a comprehensive justification study by the municipality
that demonstrates the need to accommodate short-term growth; that Settlement Area infilling,
intensification and redevelopment that does not negatively affect the Oak Ridges Moraine’s ecological
integrity has already been taken into account; that Settlement Areas in other municipalities and urban
areas outside of the Oak Ridges Moraine have already been taken into account; that any additions to
the Settlement Areas cannot expand in to the Nature Core Areas and Natural Linkage Areas and is kept
as small as possible; and that water budgets and conservation plans have been prepared (subsection
(d)).
In Section 5.6 of the Greenbelt Plan, a comprehensive justification or growth management study by an
upper or lower tier municipality is needed in order to consider changes to the Greenbelt’s urban
boundaries. In Section 3.4.2.5 of the Greenbelt Plan, modest growth of Towns/Villages may be
considered if the expansion meets a set of criteria including: the capacity of municipal sewage and water
services; the meeting of assimilative and water production capacities of the local environment as
determined on a (sub)watershed basis; compliance with watershed plan(s); not extending into the Natural
Heritage System or specialty crop areas; and the proper implementation of other provincial or municipal
policies, plans, strategies or regulations. Section 5.7 of the Greenbelt Plan states any plan amendments
shall not reduce the total area of the Greenbelt Plan.
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Oak Ridges Moraine Partnership for 2015
Strengths & Weaknesses
The current strengths of the policy are that they do not allow for any consideration for change unless a
number of stringent tests are met, that expansion into key areas are not permitted (e.g., Natural Core
Areas and Natural Linkage Areas of the ORMCP, and Natural Heritage System and specialty crop areas
in the Protected Countryside), and that there can be no removal of lands from the Natural Core Areas
and Natural Linkage Areas in the Moraine, as well as no reduction of the total area of the Greenbelt.
However, if these policies are not properly implemented or if they are misinterpreted (e.g., “as small as
possible” in the ORMCP and “modest growth” in the GBP are open to interpretation), it can potentially
lead to the fragmentation of the Oak Ridges Moraine and negatively impact its ecological and
hydrological integrity and compromise the Protected Countryside’s Natural and Agricultural Systems.
Boundary expansions for growth also contravene the principles of smart growth and the intent of the
ORMCP and GBP to direct and contain urban growth.
Furthermore, a 2013 Neptis Report on the implementation of the Growth Plan demonstrates that there is
more than enough land designated in the Greater Golden Horseshoe for urban expansion to meet the
2031 population growth projection.7 Additionally, Neptis’ 2014 Rethinking Sprawl report shows that the
rate of land consumption in the inner ring of the GGH has decreased (i.e., from 26% between 1991 and
2001 to 10% between 2001 and 2011).8
Land swapping overall is a weakness as it can create uncertainty about boundaries within the Oak Ridge
Moraine and Protected Countryside, bringing into question the permanence of these protected areas.
Recommendations
Recommendation 2.1 That the internal boundaries of the Oak Ridges Moraine Conservation Plan do not
change
Recommendation 2.2 That the total Greenbelt area is not decreased
Recommendation 2.3 That land swaps in the Oak Ridges Moraine Conservation Plan and Greenbelt Plan be
prohibited
Rian Allen and Philippa Campsie, Neptis Foundation, Implementing the Growth Plan for the Greater Golden Horseshoe
(2013)
8 Neptis Foundation, Rethinking Sprawl (2014)
7
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Oak Ridges Moraine Partnership for 2015
3. Rural Settlement Boundaries in Countryside Areas
Issue
Internal designations of the Countryside Areas are meeting the purpose and objectives of Section 13(1)
and (2) in the ORMCP and should be maintained. However, there is a lack of definition, transparent
process and guidance from the Province around the definitions of “minor infill” and “minor rounding-out”
in terms of new lot creation in Rural Settlements (Section 15(1), ORMCP). This lack of clarity can, is, and
will be misused and abused as an entry point for additional growth that is not aligned with the purpose
and character of the Countryside Areas. Examples of proposed changes to the rural settlement
boundaries include the Hamlet of Claremont on the Oak Ridges Moraine (see “Rural Settlement Boundary
Case Study”). Similar proposals are being made in the towns, hamlets and villages within the Protected
Countryside including in King Township and the Village of Caledon.
The Partnership believes that rural settlements (i.e., hamlets and villages) should not be considered in the
allocation of population growth.
Current Policies
The Countryside Area designation in the ORMCP was established to provide a buffer between Natural
Core Areas and Natural Linkage Areas, as well as to provide a transition between rural and agricultural
areas and urbanized Settlement Areas. The purpose of Countryside Areas includes protecting prime
agricultural areas, supporting rural land uses and normal farm practices, and to maintain the rural
character of Rural Settlements (Section 13(1), ORMCP). Rural Settlements are delineated within the
Countryside Areas of the ORMCP and defined as “existing hamlets or similar small, generally longestablished communities that are identified in official plans” (Section 10(1)-3, ORMCP). New lots may be
created in the Countryside Areas in Section 15(1) for the purposes of “minor infill within Rural
Settlements” and “minor rounding-out of Rural Settlements designated in the applicable official plan as
appropriate for this type for lot creation”.
Strengths & Weaknesses
The existing policies pertaining to Rural Settlements generally contribute to maintaining the rural
character of the Countryside Areas within the Oak Ridges Moraine as well as protecting the integrity of
the Natural Core Areas and Natural Linkage Areas. For example, new lots in Rural Settlements cannot
encroach into Natural Core Area and Natural Linkage Areas, and only small-scale uses (commercial,
industrial and institutional) are permitted in a Rural Settlement, subject to Parts II and Parts IV.
However, key terms such as “minor infill” and “minor rounding-out” are not defined in the ORMCP and
subject to misinterpretation. These undefined terms are also used in the 2014 Provincial Policy Statement
(Section 1.6.6) with respect to growth and development of settlement areas on individual on-site sewer
and water systems.
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Oak Ridges Moraine Partnership for 2015
Recommendations
Recommendation 3.1 That the Rural Settlement boundaries be maintained according to the Oak Ridges
Moraine Land Use Designation Map (Map No. 208) or as delineated in official plans and zoning bylaws
according to Section 10(2)of the Oak Ridges Moraine Conservation Plan
Recommendation 3.2 That “minor infill” and “minor rounding-out” in Rural Settlements be defined by the
Province along with the development, through an open and transparent, of a clear set of rules, criteria, and
technical guidelines to guide municipalities on implementing Section 15(1)-3 and 15(1)-4 of the Oak Ridges
Moraine Conservation Plan
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Oak Ridges Moraine Partnership for 2015
Rural Settlement Boundary Case Study: Claremont, North Pickering
Issue: In the hamlet of Claremont, a proposal has been made to upsize a 12-house transitional
application to 70+ estate homes, adding nearly a third to the hamlet’s footprint. This would require
a boundary expansion as this goes well beyond the intent of the ORMCP, i.e., “minor infill” or “minor
rounding out” (Section 15(3)). The proponent created and led a small “working group” of volunteer
residents who eventually endorsed the proposal. However, there were problems with the selection
process of the “working group” as not being transparent, open, or equitable.
Main Concerns:
Ecological/Environmental: There are major concerns with the loss of 90 acres of Class 1 agricultural
land currently in production and the cumulative effects of additional individual water-taking, septic
effluent and stormwater run-off from the proposed subdivision given that all houses are on private
services. Conversely, additional development could trigger municipal servicing, which would destroy
the historic hamlet of Claremont.
Social/Community: The application is completely out of character with the size and make-up of
Claremont. There are concerns for the loss of the working nature of the hamlet with a transition to
becoming a bedroom (commuter) community. The proposal and actions of the proponent have
divided the community and created adversarial positions about Oak Ridges Moraine and Greenbelt
protection.
Governance: There is a lack of provincial leadership in defining key policies such as “minor infill”,
“minor rounding out”, etc. There is also a lack of support for municipalities to grapple with
implications of boundary changes, for instance, urbanizing rural areas.
Relevance to 2015 Review: Should this rural settlement boundary change be allowed as an
outcome of the review, it would set a dangerous precedent for the future of other hamlets and act
against attempts to control urban sprawl within the countryside of the Oak Ridges Moraine,
Greenbelt and Greater Golden Horseshoe.
Recommendations for Improvement:
Policy changes: No change to existing policies.
Implementation changes: In the short term, clarification is needed from the Province on its rationale
of policy and on its definition of “minor infill” and “minor rounding out”. In the longer-term, the
Province needs to take the lead on developing a multi-party rural prosperity strategy.
Consequences of Inaction: Left unaddressed, there will be piecemeal applications made by
developers for the approval of rural settlement boundary expansions that could lead to an
inevitable, precedent-setting win one day. Without a formal decision, each case will be a one-off,
with a higher risk of cumulative damage to Oak Ridges Moraine and Greenbelt and less likelihood
of efforts to pursue options or innovative solutions.
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Oak Ridges Moraine Partnership for 2015
NECESSARY IMPROVEMENTS: LAND USE PLANNING ON THE ORM AND
ACROSS THE GGH
4. Watershed Planning
Issue
Many municipalities on the eastern Oak Ridges Moraine have not undertaken the development of
watershed plans which are key water resource management tools. This is problematic given that the Oak
Ridges Moraine is a significant hydrological feature and there are a number of stressors over and above
major development that can adversely impact its water quality and quantity. Furthermore, many eastern
Moraine municipalities may not have the resources to complete a costly watershed plan.
Current policies
Without a completed watershed plan, no major development commencing after April 23, 2007 can be
approved (Section 24(4), ORMCP). All upper and single tier municipalities are then required to prepare
a watershed plan for every watershed whose streams originate on the Oak Ridges Moraine within their
jurisdiction (Section 24(1), ORMCP). These watershed plans are to be integrated into the municipality’s
official plan (Section 24(2), ORMCP) and shall include a water budget and conservation plan, land and
water use and management strategies, an implementation framework, an environmental monitoring plan,
provisions requiring the use of environmental management practices and programs, and evaluation
criteria for the protection of water quality and quantity, and hydrological features and functions (Section
24(3), ORMCP).
In the Plan Review and Amendment subsection of the ORMCP, it states that there is opportunity to amend
the ORMCP to include new, updated or corrected information as well as new science, technologies, or
practices that shall improve the effectiveness of the ORMCP.
Strengths & Weaknesses
Watershed planning in the ORCMP is an overall strength as the majority of municipalities have
undertaken this process with their local conservation authority and these plans have provided invaluable
information towards the overall management of the Moraine-based watersheds. Conservation authorities
have played a crucial role in the completion of watershed plans. Anecdotally, the process of completing
these plans was beneficial as it connected people to their local watersheds.
Overall, municipal conformity for watershed planning has been good with a majority of municipalities
initiated the process by 2006.9 In 2015, 80% of the municipalities in the Oak Ridges Moraine had
completed watershed plans.10 It is our observation that the requirement of completing a watershed plan
in order to permit major development has proved to be very successful. The Partnership encourages this
kind of incentive-based policy approach wherever possible.
9
Monitoring the Moraine Project, Status Report on the Implementation of the Oak Ridges Moraine Conservation Plan (2006)
Ministry of Municipal Affairs and Housing, Performance Indicators for the Greenbelt Plan, Part 1 (2015)
10
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Oak Ridges Moraine Partnership for 2015
However, a weakness is that watershed planning is only required if major development is envisioned.
While major development may not be anticipated, there are other issues (e.g., water-taking,
infrastructure, aggregates and commercial fill) that can have a negative impact on the Oak Ridges
Moraine’s water. Furthermore, there is no provincial guidance or oversight over the technical quality of
the watershed plans. It is also unclear what watershed plan integration into official plans means, i.e.,
Section 24(2), ORMCP. The concept of tiering between watershed plans and official plans must be made
common practice so that the strategic nature of watershed plans fully informs decision making.
Provincial support is also needed to help fund the costly development of watershed plans which can
range from $150,000 to upwards of millions of dollars depending on the watershed (personal
communications). Through the Clean Water Act, 2006 the Province supported the planning of Source
Protection Plans (SPP) with $240 million and then their implementation through its Source Protection
Municipal Implementation Fund (SPMIF) with over $13.5 million over three years. 11,12 Similar investments
are needed to ensure that, regardless of municipal capacity, the hydrological integrity of the Oak Ridges
Moraine is paramount. Additionally, there are opportunities through SPP for the integration of new
methodologies and sciences into watershed plans to improve water resource management.
Recommendations
Recommendation 4.1 That tiered watershed planning is mandatory for all municipalities across the Oak
Ridges Moraine
Recommendation 4.2 That the Oak Ridges Moraine Conservation Plan’s water resource policies be
strengthened to reflect the latest science and extend where appropriate the methodologies and findings from
Source Protection Plans
Recommendation 4.3 That watershed planning be mandatory for all municipalities in the Greater Golden
Horseshoe where there are significant groundwater sources that are under threat
Recommendation 4.4 That the Province provides support for the provision of watershed plans including
guidance with official plan integration and tiering with other policies, oversight and funding on the
development, implementation and evaluation of watershed plans
11
12
http://news.ontario.ca/ene/en/2013/11/helping-small-rural-communities-protect-drinking-water.html
http://news.ontario.ca/ene/en/2013/11/source-protection-municipal-implementation-fund-recipients.html
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Oak Ridges Moraine Partnership for 2015
5. Tree-Cutting
Issue
Many municipalities have weak tree-cutting bylaws as well as a lack of capacity for their enforcement,
resulting in the reduction of natural forest cover and the degradation and destruction of critical wildlife
habitat. Illegal tree-cutting can be hard to detect as it may take place on private property. Tree-cutting
has been a widespread issue on the Oak Ridges Moraine with incidences reported in King Township,
Aurora, Richmond Hill, Scugog, Kawartha Lakes, and Clarington through the Monitoring the Moraine
Project’s Moraine Watch.13
Current Policies
Tree-cutting bylaws are currently required under the Oak Ridges Moraine Conservation Act and
administered by lower or single tier municipalities. They are passed at the upper to lower tier level under
sections 135 to 140 of the Municipal Act. Any illegal tree-cutting is complaint-driven and the window of
enforcement by a municipal bylaw officer varies between municipalities.
Strength & Weaknesses
Twenty-four municipalities had some form of tree conservation or cutting bylaw based on the MTM’s
2006 Status Report. As of 2014, 26 of 32 municipalities had tree cutting bylaws with many other
municipalities expressing intent to develop a bylaw in the future.14 Municipal tree-cutting bylaws however
do not need to conform to the vision and objectives of the ORMCP. Furthermore, there is a plethora of
inconsistencies between municipal tree-cutting bylaws with respect to the purpose of the bylaw (tree
cutting or conservation or sustainable practices), the permitting process, the size of the tree(s) or woodlot,
the number of possible exemptions, the type of enforcement and penalty involved with non-compliance,
ranging from $500 to $100,000.15
Many woodlands in the Oak Ridges Moraine qualify as Key Natural Heritage Features (KNHFs) where
destruction is prohibited for most permitted uses. However, bylaws provide exception clauses where
councils can waive the restrictions of the tree cutting bylaw and allow the removal of features that
constitute KNHFs. Furthermore, some tree bylaws protect woodlands down to two hectares when the
ORMCP guidelines identify woodlands of 0.5 hectares or less as constituting KNHFs (i.e., significant
woodlands) that should be protected. With a lack of enforcement, it sets the precedent of non-compliance
with a lack of penalty for illegal tree-cutting activities. Furthermore, with minimal fines, some landowners
are opting to “cut now and pay later”.
As recommended with watershed plans, tiering based on strategic direction from ORMCP informing
bylaws should be required in environmental decision making. Section 24 of the ORMCP should be
amended to acknowledge the benefits of a healthy range of forest cover within a watershed (e.g.,
Monitoring the Moraine Project, 2012 Status Report: Compliance, Infrastructure and Community Concerns on the Oak Ridges
Moraine (2012)
14 Kirsten Melnyk and Diana Van Vlymen, Tree cutting in the Oak Ridges Moraine, for ENSC 801SES at Queen’s University
(2014)
15 Ibid
13
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Oak Ridges Moraine Partnership for 2015
Conservation Ontario and Environment Canada both suggest a minimum of 30% forest cover to maintain
native species and support healthy wildlife habitat) and refer to meeting specific to targets within
individual watershed plans that fall with this range. Targets for tree-cover should be established within
watershed plans whereby a municipal tree-cutting bylaw is a tool to achieve that target.
This policy approach already exists in the ORMCP where development or site alteration in subwatersheds
(with the exception of Settlement Areas) is prohibited when the percentage of impervious surface would
exceed 10% or “any lower percentage specified in the applicable watershed plan” (Section 27(1),
ORMCP).
Recommendations
Recommendation 5.1 That the Province requires stronger municipal tree-cutting bylaws that conform to the
goals and objectives of the Oak Ridges Moraine Conservation Plan
Recommendation 5.2 That the Province provides guidance to municipalities for developing strong tree-cutting
bylaws through a model tree-cutting bylaw that is informed by the Oak Ridges Moraine Conservation Plan,
its watershed plans and municipal official plans
Recommendation 5.3 That Section 24(3) in the Oak Ridges Moraine Conservation Plan be amended to
acknowledge a healthy range of forest cover (e.g., at least 30%) and prescribe that watershed plans shall
include targets for a healthy tree cover
Recommendation 5.4 That municipalities invest resources to support the proper development, implementation
and enforcement of their tree-cutting bylaws
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Oak Ridges Moraine Partnership for 2015
Tree Cutting Case Study: Beacon Hall Golf Course, Aurora
Issue: Over the last 20 years, there has been a systematic, incremental and continuous removal of
large amounts of forest by Beacon Hall Golf Course. Complete woodlots have been removed and
woodlands have been altered substantially.
Main Concerns:
Ecological/Environmental/Governance: The removal of trees in areas where bylaws do not exist or
are not relevant (e.g., golf courses are exempted from the Town of Aurora’s tree bylaw) results in
the diminished ecological integrity associated with major loss of habitat for wildlife, increased soil
erosion, and the altering of water courses.
Social/Community: The removal of trees results in: loss of privacy and diminishment of quality of life
for affected homeowners; environmental erosion and water-course changes leading to unwanted
pooling and flooding; and home values are consequently negatively impacted.
Relevance to 2015 Review: The mandate of the ORMCP requires that the inherent value of trees,
also referred to as ecological goods and services (EGS), to the social-ecological integrity of the
region be better expressed and protected. These values or EGS include stormwater management,
erosion control, pollutant absorption, wildlife habitat, energy-related savings, recreation, property
value increases, oxygen generation, and carbon dioxide sequestration.
Recommendations for Improvement:
Policy changes: It is critical that new policies regarding tree-cutting and forest protection be added
to the ORMCP in order to provide policy direction and context for municipal bylaws. This policy
direction needs to be clear and that strict guidelines be provided to municipalities to ensure
comprehensive municipal tree-cutting/forest protection bylaws.
Implementation changes: Steps must be taken to address inconsistencies in tree-cutting and forest
protection practices across the region. The province should show leadership and require
municipalities to develop tree-cutting bylaws that conform to the vision and objectives of the ORMCP
as required by the section 23f and 23f.1 of the ORMCA.
Consequences of Inaction: The removal of large amounts of forest in the Oak Ridges Moraine and
Protected Countryside Areas will result in a loss of wildlife habitat and environmental degradation.
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Oak Ridges Moraine Partnership for 2015
6. Permitted Uses and Rural Prosperity
Issue
Generally, the permitted uses within the ORMCP are in line with the purpose and objectives of the four
land use designations and are helping to achieve the intent of the ORMCP. However, there are permitted
uses that are too restrictive at a small scale, hindering rural prosperity, sustainability, innovation, and
ultimately the spirit and intent of the ORMCP. At the same time, existing permitted uses allow for a suite
of large scale uses such as mineral aggregate operations, transportation, infrastructure and major
recreational uses for example in the Countryside Areas which brings into question the equity and fairness
of the ORMCP for rural landowners. Restrictive permitted uses in rural areas are supported by the
stakeholders’ surveys commissioned by the ORMF in 201116 and 201417, as well as through the
Monitoring the Moraine Project’s Moraine Watch.
Current Policies
Permitted uses for the Natural Core Areas, Natural Linkage Areas, Countryside Areas and Settlement
Areas in the ORMCP are outlined in Section 11(3), Section 12(3), Section 13(3) and Section 18(3)
respectively. Furthermore, the permitted uses listed in Natural Core Areas, Natural Linkage Areas and the
Countryside Areas also include uses accessory to those uses. Listed permitted uses that relate to rural
prosperity include home businesses, home industries, bed and breakfast establishments, farm vacation
homes, agriculture and agricultural-related uses, as well as lower-intensity recreational uses. There are no
explicit policies to support rural prosperity in the ORMCP. Its vision however does include the health and
well-being of the region’s residents and an objective of the ORMCP includes providing for compatible
land and resource uses.
Strengths & Weaknesses
The strength in the approach of the ORMCP is that the range of permitted uses has been linked to the
land use designation, i.e., the more ecological and hydrological significant; the more stringent is the
range of permitted uses. The Partnership supports this approach. The Partnership is also encouraged by
the recent guidelines on the Provincial Policy Statement 2014 regarding permitted uses in prime
agriculture areas that speak to agricultural land use flexibility to support innovation without introducing
detrimental or incompatible uses.18
However, the ORMCP’s polices currently make certain small-scale activities (especially in rural
communities) difficult to get approved. These small-scale and compatible activities are often subject to
undue regulation including excessive time and costs on the part of the applicant and the municipality.
Restrictions in small-scale permitted uses do not foster innovation, reflect new ways of doing business, or
allow for greater rural prosperity.
Oak Ridges Moraine Foundation, Planners’ Workshop on the Oak Ridges Moraine (2011)
Enviroscape Consulting Services prepared for the Oak Ridges Moraine Foundation. Evaluation of the Oak Ridges Moraine
Conservation Plan (2014)
18 Ontario Ministry of Agriculture, Food and Rural Affairs, Guidelines on Permitted Uses in Ontario’s Prime Agricultural Areas
(2015)
16
17
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Oak Ridges Moraine Partnership for 2015
Another weakness is the lack of equity and fairness for different users based on the scale and impact of
the activity. For example, the approvals process for a new barn in the Countryside Area is comparable
to that required for a new highway in Natural Core Areas or Natural Linkage Areas. Given that over
90% of the Oak Ridge Moraine is privately owned, it is important that its residents support the
landscape and legislation as the ORMCP is only as strong as the desire for people to support it.
Rural municipalities also require the flexibility to support and diversify viable local economic
development to offset the loss of traditional revenues gained from property assessment. Currently, there
are no scale-based criteria for municipalities to manage permitted and accessory uses in pursuit of rural
prosperity.
Ultimately, the Partnership wants to promote small scale innovation with small ecological footprints that
supports sustainability (economic, environmental and social) on the Oak Ridges Moraine.
Recommendations
Recommendation 6.1 That the Oak Ridges Moraine Conservation Plan policies support innovation for rural
landowners and rural businesses through increased flexibility in permitted uses and their accessory uses
provided they do not negatively impact the ecological and hydrological integrity of the Oak Ridges Moraine
Recommendation 6.2 That rural municipalities should have flexibility to support viable local economic
development and the discretion to permit accessory uses provided they do not negatively impact the
ecological and hydrological integrity of the Oak Ridges Moraine
Recommendation 6.3 That the Province commits to initiating a multi-party rural prosperity strategy for the
Oak Ridges Moraine and Protected Countryside as an outcome of the 2015 Co-ordinated Review and that
small scale innovation issues be addressed through this strategy
Recommendation 6.4 That through an open and transparent process, the following definitions in the Oak
Ridges Moraine Conservation Plan be updated to allow for increased rural prosperity:
“agricultural uses” be amended to include such uses as apiaries
“agricultural-related uses” remains the same, i.e., keeping the “small scale” aspects of those commercial
and industrial uses that are agricultural-related
“bed and breakfast establishment” and “farm vacation home” be amended to allow for more than three
guest rooms within a single dwelling as long as it does not negatively impact the ecological and
hydrological integrity of the Oak Ridges Moraine
“home business ” be amended to allow for it to be carried out in a building accessory to the main
dwelling in addition to within a single dwelling by one or more of its residents
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Oak Ridges Moraine Partnership for 2015
7. Commercial Fill
Issue
New development and infrastructure renewal in urban areas are generating significant amounts of
excess soil materials, i.e., fill, that are being dumped on the Oak Ridges Moraine. The risk of
contamination from this material is extremely high. There are significant health issues related to
contaminated fill as several dump sites are located close to sources of drinking water. Already, some of
these sites have a level of contamination that exceeds MOECC standards (e.g., Greenbank and Lake
Ridge).
Commercial fill operations have the potential to put at risk the Oak Ridges Moraine’s ecological and
hydrological integrity, as well as the iconic character of the landform itself. Many municipal site alteration
bylaws are ineffective and do not contain provisions specific to the Oak Ridges Moraine. Furthermore,
municipalities lack the guidance and resources for bylaw enforcement. There continues to be uncertainty
about the relationship between municipal bylaws and Transport Canada’s legislation on aerodromes.
The issue of commercial fill is not unique to the Oak Ridges Moraine. Local community and municipal
concerns have been documented in over 30 sites within the Greenbelt alone, e.g., East Gwillimbury, King
Township, Aurora, Richmond Hill, Scugog, and Clarington.19
Current Policies
Site alteration bylaws are administered at the lower or single tier level. Site alteration is prohibited on
the Oak Ridges Moraine with some permitted exceptions (Section 5(b), ORMCP) whereby site alteration
must support connectivity by “identify[ing] planning, design and construction practices that ensure that no
buildings or other site alterations impede the movement of plants and animals among key natural
heritage features, hydrologically sensitive features and adjacent land within Natural Core Areas and
Natural Linkage Areas” (Section 20, ORMCP).
Site alteration is permitted in key natural heritage and hydrologically sensitive features or within the
related minimum vegetation protection zone but requires a natural heritage or hydrological evaluation
where the following are involved: forest, fish and wildlife management; conservation and flood or erosion
control projects; transportation, infrastructure and utilities where there are no alternatives; and lowintensity recreation uses (Section 22(2), Section 22(3), Section 26(2) and Section 26(3), ORMCP).
In landform conservation areas, site alteration in Category 1 and 2 shall minimize disturbance to
landform character (Section 30(5) and Section 30(6), ORMCP). A site plan is required where site
alteration is not associated with major development (Section 30(10), ORMCP) and an earth science
heritage evaluation is required where site development is in an area of natural and scientific interest
(earth science) or the related minimum area of influence (Section 30(12), ORMCP). In Category 1 and 2
in Settlement Areas, “the approval authority shall consider the importance … practices that will keep
Monitoring the Moraine Project, 2012 Status Report: Compliance, Infrastructure and Community Concerns on the Oak Ridges
Moraine (2012)
19
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Oak Ridges Moraine Partnership for 2015
disturbance to landform character to a minimum, so as to satisfy the requirements of subsections (5) to
(11) if possible” (Section 30(13), ORMCP).
Site alteration is also considered in stormwater management where water resources are to be protected,
e.g., minimizing vegetation removal, grading and soil compaction, and minimizing stormwater volumes
and contaminant loads, e.g., reducing impervious surfaces and increasing areas in a natural undisturbed
state (Section 45(2) and Section 45(3), ORMCP).
Strength & Weaknesses
There are many policies related to site alteration embedded within the ORMCP and which take into
consideration the ecological and hydrological integrity of the Oak Ridges Moraine, e.g., its connectivity,
natural heritage features, hydrological features, subwatersheds, landform conservation and stormwater
management. There are many municipalities with site alteration bylaws i.e., 21 of the lower/single tier
municipalities have site alteration or fill bylaws.20
However, conformity to the vision of the ORMCP is not a requirement resulting in a lack of consistency
between municipalities. There is a lack of municipal enforcement and many do not specifically identify the
large scale movement and disposal of fill in their bylaws. Furthermore, definitions of what constitutes
large scale vary across the province.
Currently, on the Oak Ridges Moraine, there are many non-compliant large scale fill operations.
Contaminated fill is being dumped across the province with minimal recourse, given the scale of the
negative impact. “There is no single [statute] that applies directly to the definition, removal,
transportation, placement and grading of fill in the context of addressing the total potential impacts
associated with this activity”.21
Recommendations
Recommendation 7.1 That new policies be developed for large-scale movement and disposal of fill with
requirements for municipal bylaw conformity to the Oak Ridges Moraine Conservation Plan
Recommendation 7.2 That the disposal of large-scale fill is prohibited in key natural heritage features,
hydrologically sensitive features, Areas of Natural and Scientific Interest (Earth Science) and their minimum
areas of influence, wellhead protection areas, areas of high aquifer vulnerability, and landform conservation
areas as defined in the Oak Ridges Moraine Conservation Plan
Recommendation 7.3 That the disposal of large-scale fill is prohibited in specialty crop areas, prime
agricultural areas, key natural heritage features, and key hydrologic features as defined in the Greenbelt
Plan
20
Monitoring the Moraine Project, 2012 Status Report: Compliance, Infrastructure and Community Concerns on the Oak Ridges
Moraine (2012)
21 http://thefinalapproach.net/lccw/wp-content/uploads/2013/06/conservation-ontario-report1.pdf
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Oak Ridges Moraine Partnership for 2015
Recommendation 7.4 That the Province adopts a clear provincial position and appropriate strategy for the
management of fill and develop technical guidelines to assist municipalities in the development and
implementation of appropriate site alteration guidelines
Commercial Fill Case Study: Greenbank Airways, Greenbank Ontario
Issue: A commercial fill operation importing 2.5 million cubic meters for an aerodrome expansion is
covering approximately 15 hectares and is up to 17 meters deep. It is located in the Township of
Scugog in the Protected Countryside of the Greenbelt, less than 300 meters from an identified
watercourse. Despite close scrutiny by a municipality responding to an engaged public and by a
third party monitoring company, recent borehole testing found chemical concentrations in half of the
samples exceeding the allowable standard for soils over groundwater for any land use –
residential, agricultural, or industrial.
Main Concerns:
Ecological/Environmental: The chemical pollutants are a concern to surface and groundwater
impacting human health. A planned expansion will cover a neighbouring farm. The natural rolling
hills are removed and this is against the spirit of the ORMCA and ORMCP.
Social/Community: The traffic, dust, and noise of several hundred trucks a day for a few years have
affected the quality of life and livelihoods of neighbours. It has become a highly charged political
issue; public and council meetings are standing room only and the issue of fill has had an effect on
the outcomes of the last municipal election.
Governance: The large-scale movement and disposal of fill crosses all levels of government:
federally through Transport Canada and the regulation of aerodromes; provincially through the
Ministry of the Environment and Climate Change and the setting and enforcement of pollution
standards and voluntary guidelines; and municipally through fill or site alteration bylaws. There is a
lack of clarity at all levels. For example, does Transport Canada’s aerodrome designation trump
other levels of government? Does the lack of a provincial definition of “clean fill” allow dirty soil to
go undetected? Does a municipal bylaw have the teeth to protect against contamination of
groundwater and surface water? Is a commercial fill operation classified as a “land use” thus
triggering the Planning Act and municipal zoning bylaws? The three conservation plans of the
Greenbelt (including NEP and ORMCP) are silent on the issue of fill.
(continued on the next page)
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Oak Ridges Moraine Partnership for 2015
Commercial Fill Case Study: Greenbank Airways, Greenbank Ontario (continued)
Relevance to 2015 Review: At the time of the writing the Oak Ridges Moraine Conservation Plan,
the large-scale movement and disposal of fill was not a prominent problem. Commercial fill is
raising red flags in affected communities across the landscape where dirt that is too dirty for the
city is being dumped onto farmers’ fields and over groundwater aquifers. Given the respective
visions of the ORMCP and GBP (with an emphasis on the importance of restoring, enhancing and
protecting ecological and hydrological integrity and the protection of farmland), now is the time to
address this issue. The three conservation plans must be amended to at a minimum set the context for
managing the movement and disposal of fill within their boundaries. However, solving this problem
will require an open, transparent, and integrated approach that crosses levels of government.
Recommendations for Improvement:
Policy changes: The conservation plans should identify commercial fill operations as an industrial use
and commercial fill operations should be prohibited in Natural Core Areas and Natural Linkage
Areas, the Natural Heritage System in the Protected Countryside and in all sensitive ecological and
hydrological features. Commercial fill operations should be a prohibited activity in Areas of High
Aquifer Vulnerability.
Implementation changes: A comprehensive public educational program is required to raise
awareness of threats associated with contaminated fill. Provincial support is needed to assist with
municipal understanding and implementation of fill policies/regulations as well as oversight to
ensure that new fill policies/regulations are followed.
Consequences of Inaction: Greenbank Airways is merely the tip of the iceberg; citizens have
identified approximately 30 existing sites within the Greenbelt and an industry estimate that 25
million cubic meters of soil are excavated from the GTA each year will be dumped as close to
Toronto as possible, i.e., the Greenbelt. With no mechanism to stop commercial fill operations, the
natural character of Greenbelt lands will be altered. There is a very real potential for the long term
contamination of the region’s groundwater systems, putting into peril the health and livelihoods of
thousands of people as well as endangering the headwaters of the region’s river and stream
systems.
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Oak Ridges Moraine Partnership for 2015
8. Aggregates
Issue
New aggregate extraction is not permitted in Natural Core Areas to protect its key natural heritage
features. However this protection is not afforded to Natural Linkage Areas, despite them being a key
feature in the Oak Ridges Moraine’s natural heritage system. The creation of new aggregate operations
and the expansion of existing aggregate operations are of concern to the Oak Ridges Moraine’s water
quality and quantity. Furthermore, there is neither a standard nor a comprehensive bioregional strategy
for the rehabilitation of retired and neighbouring aggregate pits on the Moraine.
Current Policies
No new aggregate extraction is permitted in Natural Core Areas and existing operations cannot expand
beyond the boundary of the area under license or permit (Section 6(3), ORMCP). In the current permitted
uses, mineral aggregate operations are permitted in Natural Linkage Areas (Section 12(3)-11, ORMCP)
and Countryside Areas (Section 13(3)-11, ORMCP) and are required to meet stringent review and
approval standards including the maintenance, improvement or restoration of groundwater and surface
water quantity and quality and key natural heritage feature health, diversity size and connectivity,
rehabilitation of as much of the site as possible, and the protection of the geological or geomorphologic
attributes of areas of natural and scientific interest or ANSIs (earth science) (Section 35(1), ORMCP).
Additionally, if an application is in a Natural Linkage Area, extraction cannot take place within 1.5
metres of the water table, must be completed as soon as possible, and the entire site must be
rehabilitated in stages as quickly as possible (Section 35(2), ORMCP). In the Natural Linkage Areas,
connectivity must also be maintained through an excluded area outside of the activity or unrehabilitated
parts of the site that is at least 1.25 kilometres wide and connects to the Natural Linkage Area outside of
the aggregate operation (Section 35(3), ORMCP).
In landform conservation areas, mineral aggregate operations are exempt from keeping disturbance to
the landform character (e.g., steep slopes, kames, ravines and ridges) to a minimum (Section 30(7),
ORMCP) and site plans where the development is not classified as major development (Section 30(11),
ORMCP). Applicants must be able to demonstrate that rehabilitation blends with the landform character
and pattern, as well as maintains, improves or restores the long term ecological integrity of the ORMCP
Area (Section 35(6), ORMCP).
In key natural heritage features (KNHFs), mineral aggregate operations may be approved if the features
contain young plantations or early successional habitat, and that the applicant demonstrates the long
term ecological integrity of the ORMCP Area with respect to maintain, improve or restore as well as
immediate rehabilitation of KNHFs and establishing/restoring natural self-sustaining vegetation of equal
or greater ecological value (Section 35(4), ORMCP).
Comprehensive rehabilitation plans are encouraged between municipalities and the mineral aggregate
industry (Section 36, ORMCP).
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Oak Ridges Moraine Partnership for 2015
The Plan Review and Amendment Section, subsection (e) of the ORMCP states that a 10-year review can
consider changes to the ORMCP’s aggregate policies including whether to permit new or expand existing
mineral aggregate operations and wayside pits in the Nature Core Areas where the ecological integrity
can be maintained or improved. For a more complete list, refer the ORMCP.
Mineral aggregate operations and management are subject to the Aggregate Resources Act.
Strength & Weaknesses
The current aggregate policies take into consideration Nature Core Areas of the Oak Ridges Moraine
through prohibition. The same kind of consideration should be afforded for Natural Linkage Areas
because of the critical role they play as natural and open space linkages and the lifespan of an
aggregate pit (about 20 years).
Although comprehensive rehabilitation plans are encouraged in Section 36, they are not mandatory.
Furthermore, they do not take into account a bioregional approach that considers the cumulative impacts
of neighbouring pits. Therefore proper cumulative effects assessment should be an integral part of a
comprehensive rehabilitation strategy.
Recommendations
Recommendation 8.1 That new aggregate mining in Natural Linkage Areas of the Oak Ridge Moraine be
prohibited without any exemptions
Recommendation 8.2 That new mineral aggregate operations continue to be prohibited in Natural Core
Areas and the expansion of existing mineral aggregate operations in Natural Core Areas be prohibited
Recommendation 8.3 That the Province amend the Oak Ridges Moraine Conservation Plan to “require”
rather than to “encourage” the completion of comprehensive rehabilitation plans. It is further recommended
that the Province issue a Technical Guideline to provide direction and advice in preparing comprehensive
rehabilitation plans to ensure there is a clear benefit to the natural heritage system
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Oak Ridges Moraine Partnership for 2015
9. Transitional Applications
Issue
Development applications that pre-date the plan, i.e., transitional applications, can currently proceed
regardless of whether they would be considered a “permitted use” under the ORMCP. Transitional
applications have no deadline for proceeding and their number, size and scope is unknown. This can lead
to the potential degradation and destruction of the Oak Ridges Moraine’s ecological and hydrological
features and functions.
Current Policies
Transitional applications are applications, defined by Section 4(2), ORMCP, that have commenced as
described in Section 4(1), ORMCP and in subsection 15(4), ORMCA, but where no council decisions have
been made prior to November 17, 2001 (subsection 15(2), ORMCA). Transitional applications in Natural
Core Areas, Natural Linkage Areas and Countryside Areas must conform to the prescribed provisions of
the ORMCP: connectivity must be supported; key natural heritage features (KNHFs) and hydrologically
sensitive features (HSFs) must be taken into account; natural heritage evaluations are to be conducted;
ground and surface water quality and quantity must be maintained; and disposal into kettle lakes, new
stormwater management ponds in KFNHs and HSFs; and new rapid infiltration basins and columns are
prohibited (Section 48, ORMCP).
Strength & Weaknesses
Policies around transitional applications in the ORMCA and ORMCP take into account Natural Core
Areas, Natural Linkage Areas and Countryside Areas of the Oak Ridges Moraine, requiring certain
provisions in the ORMCP and sections in the ORMCA will apply. Despite these considerations, a major
weakness is the lack of certainty on the part of the community and the ecological and hydrological
integrity of the Oak Ridges Moraine where there is no deadline for transitional applications to move
forward. Furthermore, there is no database of the number, type or size of transitional applications, so the
scope of their potential impact is unknown. In addition, implementation details are vague, i.e., when a
natural heritage evaluation is to be completed, what timeframe is used in terms of maintaining water
quality and quantity, and what are the consequences of non-compliance to these prescribed provisions in
Part V of the ORMCP.
Recommendations
Recommendation 9.1 That a sunset clause on development applications that pre-date the Oak Ridges
Moraine Conservation Plan, i.e. transitional applications, be implemented and enforced
Recommendation 9.2 That in Natural Core Areas and Natural Linkage Areas, transitional development must
take into account the Oak Ridges Moraine Conservation Plan to its full extent where applicable
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Oak Ridges Moraine Partnership for 2015
10. Infrastructure
Issue
Infrastructure projects on the Oak Ridges Moraine must conform to Section 41 of the ORMCP. However,
these infrastructure projects are approved through the environmental assessment (EA) approvals process
regardless of the protected status of the Oak Ridges Moraine. Infrastructure is essentially permitted on
the moraine if “need” has been demonstrated and there are “no reasonable alternatives”. Furthermore,
industrial energy projects such as wind and solar farms are not required to conform to Section 41 of the
ORMCP.
Current Policies
Section 41 in the ORMCP addresses transportation, infrastructure and utilities on the Oak Ridges
Moraine. These include: public highways; transit lines; railways and related facilities; gas and oil
pipelines; sewage and water service systems and lines and stormwater management facilities; power
transmission lines; telecommunications lines and facilities; bridges, interchanges, stations, and other
structures required for the aforementioned facilities (its construction, operation or use); and the right of
way for all aforementioned facilities (Section 41(1), ORMCP).
Transportation, infrastructure or utilities applications may be approved in Natural Linkage Areas
provided that “the need for the project has been demonstrated and there is no reasonable alternative”
and “to the extent that is possible” minimizes the construction disturbance and right of way widths, locates
the land use within a single corridor “as possible”, allows for wildlife movement, focuses lighting down
and away from Natural Core Areas, and minimizes the adverse effects on the ecological integrity of the
Oak Ridges Moraine Plan Area (Section 41(2), ORMCP).
Transportation, infrastructure or utilities applications may also be approved in Natural Core Areas with
the same requirements as in Natural Linkage Areas. In addition, the project cannot include a highway
interchange or a transit or railways station (currently or in the future) and it must be located as close to
the edge of Natural Core Areas as possible (Section 41(4), ORMCP).
In Key Natural Heritage Features (KNHFs) or Hydrologically Sensitive Features (HSFs), applications may
also be approved if the need is demonstrated without reasonable alternatives; if the adverse effects on
the Moraine’s ecological integrity is minimized through the planning, design and construction practices; if
key ecological and recreational linkages are maintained, improved or restored; if the landscape design
is adapted to the site and native plants will be used; and the long-term management will maintain,
improve or restore the health, diversity, seize and connectivity of the KNFHs or HSFs (Section 41(5),
ORMCP). Lastly, disruption of groundwater flow is to be minimized for service and utility trenches for
these projects (Section 41(6), ORMCP).
Strength & Weaknesses
Transportation, infrastructure and utilities projects are needed to accommodate existing and growing
communities in and around the Oak Ridges Moraine. However, the polices outlined in Section 41 of the
ORMCP essentially allow for these projects in Natural Core Areas, Natural Linkage Areas, KNFHs or HSFs
on the Moraine – the very things that make this landscape unique and the primary source of its valuable
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Oak Ridges Moraine Partnership for 2015
ecological goods and services. In addition, transportation, infrastructure and utilities projects also entails
associated activities such as water-taking, site alteration, and the need to locate a receiving site for fill.
Additionally, there is vague language that allows for a wide range of interpretation and subjectivity.
Terms such as “the need for the project has been demonstrated”, “reasonable alternative” and “to the
extent that is possible” are not well defined.
Through the Monitoring the Moraine Project’s Moraine Watch, EcoSpark and STORM have tracked these
projects that were of concern to community members in the Oak Ridges Moraine. These have been
compiled in our 2012 Status Report and demonstrate that these large scale projects are happening
across the landscape and that their collective impact on the landscape is not being assessed.22
In addition, there are new types of infrastructure projects that were not foreseen when the ORMCP was
created. The Green Energy Act was passed in 2009 to expand renewable energy generation, encourage
energy conservation and promote jobs in this sector. Industrial energy projects such as wind and solar
farms are not required to conform to Section 41 of the ORMCP.
While the Partnership supports appropriately scaled green energy development on the Oak Ridges
Moraine, the many industrial-scaled green energy projects are putting the Moraine’s ecological and
hydrological integrity at risk. The Environmental Review Tribunal is not capable of carrying out the
proper cumulative effects assessment (CEA) of multiple industrial green energy projects. The Ministry of
Environment and Climate Change has not carried out any CEA studies of large scale infrastructure. The
time to do these types of assessments is now as part of the 2015 Co-ordinated Review (see Section 11
“Necessary Improvements: Bringing other Statues In line with the ORMCP”).
Recommendations
Recommendation 10 That a moratorium on infrastructure development, including industrial scale energy
plants, 400-series highways and airports, be placed on the Oak Ridges Moraine until such time that a proper
cumulative effects assessment that evaluates large scale infrastructure is completed
Monitoring the Moraine Project, 2012 Status Report: Compliance, Infrastructure and Community Concerns on the Oak Ridges
Moraine (2012)
22
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Oak Ridges Moraine Partnership for 2015
NECESSARY IMPROVEMENTS: BRINGING OTHER STATUTES IN LINE WITH
THE ORMCP
11. Bringing Other Statutes In Line with the ORMCP
Issue
Governance processes are extremely complex with linkages to multiple legislations, associated
regulations and technical guidelines. The Greenbelt Plan is particularly complex, knitting together as it
has the Niagara Escarpment Plan, the ORMCP, and 400,000 hectares of Protected Countryside Areas.
These bio-regional planning initiatives provided the context for the government to address smart growth
through the Places to Grow legislation. All of these Acts and Plans intersect with and are influenced by
other long-standing statutes such as the Planning Act, Municipal Act, Ontario Water Resources Act, Clean
Water Act, Aggregate Resources Act, Endangered Species Act, Green Energy Act, etc.
Furthermore, there are number of other provincial initiatives that are relevant to the implementation of
the ORMCP and the 2015 Co-ordinated Review. These include the Big Move, Lake Simcoe Protection
Plan, Long-term Affordable Housing Strategy, Climate Ready, Ontario’s Great Lakes Strategy, Ontario’s
Rural Roadmap, and Ontario’s Biodiversity Strategy.
Current Policies
The ORMCP refers to other statutes in terms of decision making conformity and definitions. Decisions
made under the Planning Act or the Condominium Act for example must conform to the ORMCP.
Development on the Oak Ridges Moraine also requires the approval under the Planning Act, the
Environmental Assessment Act, or the Drainage Act with some exceptions. Endangered species are defined
in relation to the Endangered Species Act. Mineral aggregate and its operation are defined and
operated under the Aggregate Resources Act.
Strengths & Weaknesses
Without proper integration and consideration for other policies
that impact the lands within the Greenbelt, there is a missed
opportunity to truly meet the visions of the Acts, Plans and
Strategies for a healthy and prosperous Greater Golden
Horseshoe.
For example, in Ontario, permits are required by law if
50,000+ litres of water per day are taken from a lake, stream,
river, pond or groundwater source (with exemptions). Permits to
Take Water (PTTWs) are governed by the Ontario Water
Resources Act as regulated by the Ministry of Environment and
Climate Change. Water taking is not considered a land use and
therefore is not required to comply with the ORMCP. The current
PTTW framework does not recognize the unique hydrological
The extent to which the Oak
Ridges Moraine is considered in
the Permit To Take Water (PTTW)
process is a yes/no question on
the permit:
“Is the site where water taking will
occur located on the Oak Ridges
Moraine Conservation Area as
defined by the Oak Ridges Moraine
Conservation Plan (a regulation
made under the Oak Ridges
Moraine Conservation Act)?”
It is not clear if this information is
tracked and how it is being used.
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Oak Ridges Moraine Partnership for 2015
features and function of the Oak Ridges Moraine or take into account the cumulative effects of watertaking.
For the Oak Ridges Moraine, there have already been a number of reported issues with infrastructure
development including industrial-scale energy plants, 400-series highways and airports that will directly
and negatively impact the ecological and hydrological integrity of the Oak Ridges Moraine. This lack of
policy integration also calls in to question the faith and confidence of communities in the policies of the
ORMCP.
Recommendation
The Partnership recommends that the government take a more strategic approach to tiering (vertical
integration) in order to meet the objectives of the conservation plans. We are advocating for more than a
simple conformity exercise, that is, that contentious issues such as fill (see Section 7 “Commercial Fill”) and
infrastructure (see Section 10 “Infrastructure”) must more closely align with the intent and vision of the
conservation plans. This requires not only changes to the ORMCP and GBP but also commensurate
changes to other related statutes, such as the Environmental Assessment Act. However, this will require a
well-resourced, strategic, open and transparent review of the necessary changes to all relevant
legislation. The Partnership recognizes that lies is outside the mandate of this review but seeks a
commitment from the government to initiate an open and transparent process to address these
deficiencies.
Recommendation 11 That the Province makes a commitment to a systematic policy review to evaluate other
legislation that may be negatively impacting the ecological and hydrological integrity of the Oak Ridges
Moraine
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Oak Ridges Moraine Partnership for 2015
Water Exportation Case Study: Village of Millbrook, Township of Cavan -Monaghan
Issue: A municipal Class Environmental Assessment (2009) was undertaken for a proposal to divert
water from three municipal production wells located within the Oak Ridges Moraine in Millbrook to
a service mega-development located 12 kms away off the Moraine.
Main Concerns:
Ecological/Environmental: The production wells in the designated Area of High Aquifer Vulnerability
and recharge area are located next to contaminated lands on the Oak Ridges Moraine which are
owned by Infrastructure Ontario. Pump tests resulted in area wells and spring flow being greatly
diminished as well as a decrease in flow in an aquifer connected to Baxter Creek (a coldwater trout
stream). This decrease could impact baseflow and increase stream temperature which would be
detrimental for trout populations. The “solution” as recommended by the developer’s peer review
was to cap all artesian wells to ensure water security for the diversion project. This “solution” did not
consider the destruction of fish habitat, habitats of threatened or endangered flora and fauna, and
interference with pioneer and ancient aboriginal sites.
Social/Community: The public’s right for access to potable drinking water was in jeopardy. Baxter
Creek is an integral part of the culture and character of Millbrook; it supplies the Millbrook pond
which is a centerpiece attraction and symbol of the village that dates back to the 1820s. The
hydraulic connection between the aquifer and Baxter Creek is of utmost importance to the
sustainability of the village of Millbrook.
Governance: No watershed plan has been developed for Baxter Creek (none is required as the
major development is off the Oak Ridges Moraine) despite all impacts of the water taking would be
experienced in the headwaters area. There is also jurisdictional “silo-ing” between provincial
Ministry of Environment (MOE) and Infrastructure Ontario (whose lands adjacent to the wellheads
are contaminated). Request for an EA Part II Order included a complete cleanup of contaminated
lands and streams on the Oak Ridges Moraine but the request was denied by the MOE leaving
Infrastructure Ontario to only monitor contaminant movement.
(continued on next page)
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Oak Ridges Moraine Partnership for 2015
Water Exportation Case Study: Village of Millbrook, Township of Cavan -Monaghan
(continued)
Relevance to 2015 Review: Given the significance of the Oak Ridges Moraine’s hydrological
features and functions, it is a major flaw that the ORMCP policies do not consider large water
takings as sufficient to trigger the need for watershed plans. Despite the ecological integrity
mandate of the ORMCP, government-owned lands on the Oak Ridges Moraine are allowed to
remain contaminated.
Recommendations for Improvement:
Policy changes: Stronger policies are needed to safeguard hydrogeological features on the Oak
Ridges Moraine. Requests for large water-takings of the Oak Ridges Moraine’s aquifers should only
be allowed if watershed plans have been completed. A cumulative impact assessment should also
be required for large-scale water takings as part of the Permit to Take Water (PTTW) process.
PTTWs need to consider the protection of water sources on the Oak Ridges Moraine and known
contamination must be a provincial priority with the province showing leadership for its affected
lands.
Implementation changes: The PTTW process, as well as other regulations of related statutes, needs
to conform to the intent of the ORMCP and protect the hydrological integrity of the Oak Ridges
Moraine. This conformity is important given a recent policy proposal to increase the threshold of
50,000 litres per day to 400,000 litres per day for short-term, non-recurring water taking activities
(EBR Registry Number: 012-0580).
Consequences of Inaction: There will be the potential for localized destruction of a complex and
not well-understood hydrogeological system that may have far-reaching ramifications outside the
immediate area of the Oak Ridges Moraine.
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Oak Ridges Moraine Partnership for 2015
Permit To Take Water Case Study: Hamlet of Colgan, Township of AdjalaTosorontio
Issue: Colgan is delineated as a Community Improvement Area in the Township’s official plan. The
Ontario Municipal Board (OMB) has approved a draft plan for 700+ homes, however only 362 can
be built at this time due to water supply constraints (the OMB heard there is only enough water for
a total of 362 homes, which must include the existing 72 and the local school). The OMB has
subsequently approved the draft plan on the condition that there will be sufficient water and sewer
services. The Township has applied for 262 m3 through the Permit To Take Water (PTTW) process,
which states that this 262 m3 is sufficient for the existing 72 homes and an additional 300 homes.
The Township had applied to increase the PTTW to 1,300 m3, which was not granted by the
MOECC. However, it appears as though the Township is attempting to circumvent this refusal by
incrementally submitting new permits for 850 m3 then gradually increasing the PTTW to 1,300 m3.
This would be seen as meeting the conditions imposed by the OMB that would allow for the full
build-out of 700+ homes.
There are some members of council as well as the public who are extremely concerned that the
PTTW process cannot be relied upon to safeguard against the cumulative impacts of multiple water
takings. Colgan is a case in point in that council has been assured by consulting experts that a new
source of water has been found. When questioned about this “new” source, it was revealed that it
was in fact a second well in the same moraine aquifer.
Main Concerns:
Ecological/Environmental: This could have serious environmental implications as the aquifer in
question has the characteristics of being groundwater under direct influence or a GUDI. GUDI’s
share similar traits as nearby surface waters and are more prone to contamination. Also excessive
water-taking could severely impair the ability of this system to sustain the swamp habitat for the
area’s flora and fauna.
Social/Community: Many residents complained about the impact that the pump tests had on their
drinking water wells. From all accounts, the community has lost confidence in their elected officials
and the whole PTTW process to safeguard their interests.
Governance: This is similar to the Millbrook case study whereby moraine-based water is being
exploited to service off-moraine development. In many people’s minds this abrogates and subverts
the vision, purpose and objectives of the ORMCP.
Recommendations for Improvement:
Policy changes: An outcome of this 2015 review should be to elevate the PTTW discussion to ensure
that cumulative effects are comprehensively addressed. As well, there should be stricter policies to
ensure that moraine waters are not exploited to service off-moraine developments.
Implementation changes: Any loss of public confidence in the laws and regulations enacted to
protect the environment and safeguard public health is a serious problem. The Colgan issue has
been going on for a long time and illustrates a number of problems. At this stage, provincial
intervention in this specific case may be necessary. However it serves as an example of the need for
greater oversight of municipal decision-making.
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Oak Ridges Moraine Partnership for 2015
Large-scale Renewable Energy Project Case Study: “Sumac Ridge” wind project,
between Bethany and Pontypool, Ontario
Issue: Five (5) turbines for a Class 4 Wind Facility on the Oak Ridges Moraine with a total
expected generation capacity of 10.25 megawatts (MW). The Sumac Ridge project was severed
from an original (2009) proposal for 15 turbines in the same and adjacent areas. The original
proposal was split into three proposals, each with five turbines. The second five turbines from the
original project (Settlers Landing) is now under appeal and the third five of 15 (Snowy Ridge) has
not yet been approved. There are also repeated changes of ownership (seven changes in the case
of the latter two projects).
Main Concerns:
Ecological/Environmental: Two of the five turbines lie within an Area of High Aquifer Vulnerability
on the Oak Ridges Moraine. No hydrogeological studies have been carried out by the developer,
except for a belated desk-top study. ‘Water reports’ for the Renewable Energy Approval (REA)
application was untaken by a consulting firm of biologists and not hydrogeologists; local knowledge
points to a number of water features that were missed. There was no evaluation of the impact on
the Oak Ridges Moraine and the headwaters of Fleetwood Creek, despite the fact that two
tributaries run within minimum setback distances from one turbine site.
Social/Community: The project ignores concerns and wishes of the community, and many others, who
responded in defense of the ORM: 700 people turned out to one meeting and over 3,000
objections were filed at EBR (environmental bill of rights) stage. The developer has chosen to bypass the right of the municipality to refuse to grant road access to an unopened road allowance.
The wind developer has proceeded to sue that body, refusing to accept no as an answer.
Governance: The ORMCP has been by-passed in approving projects such as Sumac Ridge. Even for
turbines and the secondary infrastructure such as transmission lines, which are sited off the Oak
Ridges Moraine, water resources were ignored and no estimates provided for the amount of water
to be pumped out during construction of a turbine and electrical lines in area where the water table
is at the surface. This is unacceptable on and next to the Oak Ridges Moraine.
Relevance to 2015 Review: The Freedom of Information (FOI) disclosures for this project clarify
that MOECC staff did recognize the Oak Ridges Moraine as a special case but lip service has only
been paid to its significance and its environmental fragility. Neither the Green Energy Act nor the
REA process includes any geographical exemptions such as the Oak Ridges Moraine. Instead, wind
developers are able to choose their own sites in their own best interests. In the Sumac Ridge case,
the minimum cost (proximity to Hydro substation), maximum convenience (proximity to Greater
Toronto Area) and opportunism in demanding to develop open green spaces on the Oak Ridges
Moraine took precedence.
(continued on next page)
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Oak Ridges Moraine Partnership for 2015
Large-scale Renewable Energy Project Case Study: “Sumac Ridge” wind project,
between Bethany and Pontypool, Ontario (continued)
Relevance to 2015 Review (continued): The appeals process, in the case of the Environmental
Review Tribunal (ERT) for projects under the Green Energy Act, is not designed to correct errors in the
approvals process by MOECC or other government ministries. Errors stand uncorrected until or unless
opponents go to court or use other legal measures. If opponents go to court to sue the MOECC, the
developer then threatens to sue them for costs of delays to the project, i.e., for millions of dollars.
In the same appeal, the ERT recommended that all future Oak Ridges Moraine projects be required
to submit full hydrogeological studies, however this is not binding on the MOECC.
In the case of the Sumac Ridge project, MOECC staff did not enforce ORMCP setback policies, in
this case from a turbine site to two streambeds. While the ERT panel did not accept the proponent’s
counter argument that the streambeds were not actually streambeds (instead referring to them as
“the headwaters of Fleetwood Creek”), the panel accepted the evidence and allowed the project.
Recommendations for Improvement:
Policy changes: At a minimum, protection provisions within O.Reg. 359/09 should be strengthened
by increasing setback requirements for the Oak Ridges Moraine and providing for enforcement
measures; there are none at present. Also, MOECC should require onsite verification of significant
features with the developer and community representatives present.
Much more importantly, ORMCP should be updated to exclude development of industrial wind
turbines and solar farms on Oak Ridges by amending Section 41 of the ORMCP to only allow
essential infrastructure to cross the Oak Ridges Moraine (i.e., linear infrastructure).
Consequence of Inaction: The Oak Ridges Moraine suffers a “death by a thousand cuts” from the
dozens of wind turbines already in development (over 50 at last count in Manvers and adjoining
townships). Our legacy to future generations will be irretrievably damaged groundwater and
surface waters and threatened water supplies.
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Oak Ridges Moraine Partnership for 2015
STRONGER LANDSCAPE
“Early in the work of the Royal Commission, it became apparent
that the Toronto waterfront could not be viewed as simply a
narrow band along the shore: it is linked by Lake Ontario to the
other Great lakes, by rivers and creeks to the watersheds….
These examples illustrate a fundamental point – everything is
connected to everything else.”23
At the time of the release of Watershed in 1990 the label
“Greater Toronto Area” emerged to define a stand-alone
planning domain that included Metro Toronto and the regions of
Halton, Peel, York and Durham. Urban development was marching
north towards the Oak Ridges Moraine, putting the headwaters to
the south-flowing rivers in jeopardy. “Bioregional
planning/ecosystem approach” to planning became the new
mantra as planners and ecologists jostled to put their respective
stamps on this new domain.
The rationale behind the Oak Ridges Moraine legislation was
primarily to protect the unique concentration of environmental,
geological and hydrological features in the face of increased
population moving into the GTA. However it was also recognized
that a “green line boundary” was not sufficient on its own to stop
sprawl and to protect essential ecological features and functions.
Instead a regional growth management (i.e., smart growth)
strategy was needed to stop leapfrog development outside the
Oak Ridges Moraine. In 2004/2005 the province introduced the
Greater Golden Horseshoe as the new planning region, adding
Hamilton, Waterloo, Barrie and Peterborough to the old GTA. The
Greenbelt Plan, 2005 was designed to buffer and extend the
ecological connections out from the Niagara Escarpment and Oak
Ridges Moraine but to also act as a larger green line to contain
urban growth and to refocus the economy towards a rural and
agricultural base. The Growth Plan for the GGH, 2005 was
designed as a complementary piece to the Greenbelt to, in a
nutshell, curb urban sprawl through smart planning tools and
Figure 3. Ecosystems
policies. It was considered a landmark in Ontario planning and won
(Source: Royal Commission on the
several international awards.
Future of the Toronto Waterfront,
Regeneration, Toronto’s Waterfront
and the Sustainable City: Final Report
(1992))
23
Royal Commission on the Future of the Toronto Waterfront, Watershed: Interim report (1990)
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Oak Ridges Moraine Partnership for 2015
Stay the Course and Finish the Job
It is 10 years later and the reviews on the state of the GGH are mixed. Based on study findings from the
Neptis Foundation, there are a number of identifiable reasons why the Growth Plan has not lived up to its
initial expectations, i.e., two amendments to the Growth Plan and municipal exemptions that have
watered down the goal of protecting agricultural lands and stopping sprawl. There are other concerns
about the lack of progress in developing a more robust GGH “bioregion”. 24
There is the unfortunate perception that the Greenbelt lands are sufficient on their own for agriculture to
thrive and prosper within the GGH, for biodiversity targets to be met, and for the region to remain selfsufficient with respect to food production, availability of potable water, and the delivery of necessary
ecological goods and services (EGS) to build resilient communities. As discussed in the section above, the
conservation plans have been effective in maintaining key natural heritage features over the past 10
years but there have been little to no improvements in overall ecosystem health. This does not bode well
for the prosperity of a region that will see an additional 2 million people by 2031 coupled by the
uncertainty associated with the effects of climate change.
However, we (collectively) have the natural assets, planning and policy tools, and governance structures
that are needed to ensure the continued prosperity of the GGH as follows:
The key ingredients for a connected regional natural heritage system are in place – the Niagara
Escarpment and Oak Ridges Moraine as the ecological cornerstones, the Protected Countryside
natural heritage system as the ecological connectors to Lake Ontario and beyond
Approximately 75% of the best farmland of the Toronto Metropolitan Region (a region slightly
smaller than the GGH), and about 70% of the region’s greenlands lie outside the Greenbelt Plan
Area25
Existing policies in both the Growth Plan and Greenbelt Plan for extending and completing
natural heritage system mapping and protection in the GGH
Existing policies in the Growth Plan to identify and protect a prime agricultural system in the GGH
An award-winning planning tool designed to direct growth to established growth centres and
municipal implementation established
A highly engaged non-governmental sector (civil society, general public, private sector) willing to
work collaboratively with government
A window of opportunity i.e., this Co-ordinated Review to build the political capital to move
forward
It is also important to take a larger perspective of the entire GGH region as the 80% that lies outside the
Greenbelt comprises major urban areas, smaller urban centres, rural settlement areas and some of
Canada’s finest prime agricultural lands. What happens in these areas will have an impact not only on
the health of the Greenbelt but also on the health of the entire region. The population of the GGH is
24
25
Rian Allen and Philippa Campsie, Neptis Foundation, Implementing the Growth Plan for the Greater Golden Horseshoe (2013)
Michael Bunce, Neptis Foundation, Prospects for Agriculture in the Toronto Region (2005)
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Oak Ridges Moraine Partnership for 2015
expected to grow from today’s nine million to possibly 13 million by 2041. Therefore it is essential that
we take a more strategic approach to long-term planning within the GGH that allows for improved social
and ecological resiliency in the face of climate change and anticipated population growth.
Strengthening protection for this larger system is essential to creating a stronger landscape and a
stronger Oak Ridges Moraine.
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Oak Ridges Moraine Partnership for 2015
WHAT’S WORKING
12. Interplay between Conservation and Growth Plans
The complementary nature of the four plans provides the building blocks for a prosperous region. The
Niagara Escarpment Plan and ORMCP embed the ecological and hydrological aspects, which are
complemented by the social, environmental and agriculturally-focused policies of the Protected
Countryside Areas of the Greenbelt Plan. The Growth Plan sets direction for where growth in the region is
to go and has established intensification policies and density targets. This regional approach is
recognized internationally as an innovative approach to creating a sustainable region. For this reason,
the Growth Plan and Greenbelt have won numerous awards for its vision and leadership in to improve
the social, economic and environmental well being of a community.
Recommendation
Recommendation 12.1 That future reviews of the provincial plans related to conservation and growth in the
Greater Golden Horseshoe continue to be co-ordinated
Recommendation 12.2 That provincial plans related to transportation (i.e., the Big Move) and climate change
also be co-ordinated with future reviews of the Growth Plan for the Greater Golden Horseshoe, Greenbelt
Plan, Oak Ridges Moraine Conservation Plan and the Niagara Escarpment Plan
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Oak Ridges Moraine Partnership for 2015
NECESSARY IMPROVEMENTS
13. Growing the Greenbelt
Rationale
Growing the Greenbelt will be an important outcome of this review. We are pleased to see that
the government is seeking the public’s advice on where to expand the Greenbelt. We note that this
goal was also listed in the Premier’s mandate letter to the Minster of Municipal and Affairs and
Housing. This review represents an important opportunity to include and protect areas with high
ecological and hydrological significance in the Greenbelt. Greenbelt policies have proven very
effective in protecting the region’s natural heritage system and features. For example, according to
a report by Ducks Unlimited Canada, Earthroots, EcoJustice and Ontario Nature, there was “clear
evidence that land use policy in effect across the Greenbelt is protecting wetlands from most forms
of development.”26 Local experts and community groups throughout the GGH have identified many
areas where the Greenbelt should be expanded to provide the same high level of protection.
These include:
1. Key headwater features of Carruthers Creek, the Humber River and the Rouge River. These
headwater features are extremely sensitive areas that reduce downstream flooding and
provide critical habitat for native plants and animals.
2. Significant groundwater recharge areas, including:
o The Paris-Galt, Waterloo, Orangeville, Oro moraines. These moraines play an
important role in groundwater recharge and in filtering and maintaining drinking
water for many communities throughout the GGH. They also provide important
habitat functions and migratory corridors for wildlife.
o The Lake Iroquois shoreline which includes many features that provide important
groundwater functions and help sustain groundwater baseflow. The shoreline plain
and beach features represent an important ecological corridor, extending east
through Northumberland and into Prince Edward County.
3. Surface water features (including Lake Gibson): Lake Gibson supplies drinking water to half
of Niagara Region, including St. Catharines, and is an important source of cold water brook
trout streams.
4. Urban river valley connections (including those running through Halton, Peel, Durham, Hamilton
and Toronto). These provide important physical, ecological and hydrological connections between
the Greenbelt, Oak Ridges Moraine, and Great Lakes, enabling wildlife movement and
adaptation, and increasing the resilience of downstream areas to climate change.
Ducks Unlimited Canada, Earthroots, Ecojustice and Ontario Nature, Protecting Greenbelt Wetlands: How Effective is Policy?
(2012)
26
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Oak Ridges Moraine Partnership for 2015
Recommendation
This review is a great opportunity to expand Greenbelt protection into adjoining areas of high
ecological and hydrological value in order to ensure the GGH’s critical source water lands are
protected. Important places to grow the Greenbelt include: headwater features of the Carruthers
Creek, the east Humber and the Rouge River; the Paris-Galt Moraine, Waterloo Moraine,
Orangeville Moraine and Oro Moraine; the Lake Iroquois Shoreline; urban river valley connections
between the Greenbelt and Great Lakes; and Lake Gibson (see Map 1). These areas should be
clearly delineated in mapping layers that are produced by MMAH, in cooperation with the
Ministry of Natural Resources and Forestry and relevant municipalities.
Recommendation 13 That the Greenbelt Plan ‘Schedule 1: Greenbelt Plan Area’ and all other
associated schedules be amended to include headwater features of Carruthers Creek, the Humber and
Rouge Rivers; the Paris-Galt Moraine, Waterloo Moraine, Orangeville Moraine and Oro Moraine; the
Lake Iroquois Shoreline; Lake Gibson; and Urban River Valleys running through Halton, Peel, Durham,
Hamilton and Toronto per Map 1
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MAP 1. VULERABLE WATER SOURCES OUTSIDE OF THE GREEBELT AND WITHIN THE GREATER GOLDEN HORSESHOE.
Oak Ridges Moraine Partnership for 2015
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14. Natural Heritage System for the GGH
Rationale
A protected and connected natural heritage system throughout the GGH is vital to conserving landscape
health and resilience in the face of ongoing biodiversity loss and the impacts of climate change. It will
help ensure we have clean air, clean water and a rich diversity of plant and animal life to sustain present
and future generations.
Establishing a protected natural heritage system throughout the GGH is necessary to ensure that
important ecosystem services, which benefit all GGH communities, are preserved and enhanced in this
densely populated region. These ecosystem services include the provisioning of clean water, the
regulating of floods, the enabling of outdoor recreation and supporting of soil formation. They have been
conservatively valued at over $2.6 billion/year within the Greenbelt area27 and over $84 billion for
southern and eastern Ontario28.
In terms of policy commitments, a protected natural heritage system throughout the GGH will help the
Province meet commitments made in the Ontario Biodiversity Strategy, including especially target 13:
“By 2020, at least 17 percent of terrestrial and aquatic systems are conserved through wellconnected networks of protected areas and other effective area-based conservation measures.” 29
Such a system will also help achieve the Province’s vision for the region as laid out in the Growth Plan,
Section1.2.1: “a healthy natural environment with clean air, land and water will characterize the GGH …
the GGH’s rivers, streams, forests and natural areas will be protected and accessible for residents to
enjoy their beauty.”
Protecting natural heritage systems ensures we are planning for more prosperous, healthy and resilient
communities.
Recommendations
To establish a regional Natural Heritage System for the Greater Golden Horseshoe the
government should revise and implement Section 4.2.1 of the Growth Plan. Currently the Growth
Plan policy 4.2.1 contains language intended to lead to the identification and protection of natural
systems through sub-area assessments. To date, however, this has not been implemented.
To drive implementation and ensure that the intent of the policy is realized, the policy should be
revised to assign clear responsibility to the Minister of Municipal Affairs and Housing and to include
a fixed deadline for completion of the sub-area assessments.
David Suzuki Foundation, Ontario’s Wealth, Canada’s Future: Appreciating the Value of Greenbelt’s Eco-services (2008)
Spatial Informatics Group, Austin Troy and Ken Bagstad, Estimating Ecosystem System Services in Southern Ontario (2009)
29 Ontario Biodiversity Council, Ontario’s Biodiversity Strategy: Protecting What Sustains Us (2011)
27
28
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Recommendation 14.1 That the existing Growth Plan policies be revised to assign responsibility for the
identification and protection of a regional natural heritage system across the Greater Golden
Horseshoe to the Minister of Municipal Affairs and Housing
Recommendation 14.2 That the Greenbelt Plan be revised to assign responsibility to the Minister of
Municipal Affairs and Housing to: consider impact of activities, promote and undertake appropriate
planning, and undertake watershed based planning that relates to these areas identified as external
connections
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15. Agricultural System for the GGH
Rationale
There are significant differences between the agricultural policies covering lands within the Greenbelt
Plan Area and those outside this area but still within the GGH. Most importantly, the Greenbelt Plan
identifies an agricultural system that provides a continuous and permanent land base necessary to
support long-term agricultural production and economic activity. The Greenbelt Plan has explicitly
identified agricultural lands and agriculture as a system.
On the other hand, agricultural lands outside the Greenbelt Plan Area are under greater pressure from
development, have weaker protection against this threat than agricultural lands within the Greenbelt Plan
Area, and are more likely to be lost due to urban sprawl.
Reframing the language in terms of asking for an agricultural system makes this consistent with the
Greenbelt Plan and lays the groundwork for more strategic and targeted planning and design of
activities, investments and opportunities for sustainable agriculture and rural prosperity. A strong
agricultural system therefore is a necessary component to building a more resilient region. Such lands
provide valuable ecosystem goods and services, represent an important component of Ontario’s
economy, and are essential to ensuring local food security. They therefore require stronger protection
from development.
Recommendations
To establish a prime agricultural system for the Greater Golden Horseshoe the government should
revise and implement section 4.2.2 of the Growth Plan. Currently the Growth Plan policy 4.2.2
contains language intended to lead to the identification and protection of prime agricultural areas
through sub-area assessments. To date, however, this has not been implemented.
To drive implementation and ensure that the intent of the policy is realized, the policy wording
should be amended to describe a prime agricultural system, and revised to assign clear
responsibility to the Minister of Municipal Affairs and Housing and to include a fixed deadline for
completion of the sub-area assessments.
Recommendation 15 That the existing Growth Plan policies be revised to assign responsibility for the
identification and protection of a prime agricultural system across the Greater Golden Horseshoe to
the Minister of Municipal Affairs and Housing
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16. Hard Urban Boundary
Rationale
Assessments of municipal land budgets show that there is a surplus of designated lands to
accommodate growth projections to 2031 and beyond.30 This surplus land, coupled with
demographic changes and higher intensification targets, creates an opportunity to implement smart
growth policies and create transit-friendly communities. To this end, the Province should place a
moratorium or ‘freeze’ on any urban boundary expansions in the GGH until the next public review
of the Growth Plan.
One issue commonly identified with greenbelts or green line boundaries in the literature is 'leapfrog'
development, or development beyond the plan area's boundaries. Fung and Conway (2007) caution that
the Greenbelt Plan's allowance of the construction of transportation and utilities corridors through even
ecologically sensitive areas of the Greenbelt enables such leapfrog development, indicating that the
green and agricultural lands external to the plan area will likely experience increased development
pressure due to the protective policies of the Greenbelt Plan.31 However, these lands are protected only
by the protective policies of the Provincial Policy Statement (PPS) and municipal plans, which are less
strict and thus less effective.32
Recommendations
Recommendation 16.1 That section 2.2.8 of the Growth Plan be revised to place a moratorium or
‘freeze’ on any settlement area boundary expansions during municipal comprehensive reviews (official
plan review or amendment) until the next public review of the Growth Plan
Recommendation 16.2 That section 2.2.3 of the Growth Plan be revised to increase intensification
targets to direct more growth into existing built-up areas and designated greenfield areas already
planned for in MMAH approved Official Plans
Neptis Foundation, Understanding the Fundamentals of the Growth Plan (2015)
Fung, F., & Conway, T., Greenbelts as an environmental planning tool: A case study of Southern Ontario, Canada. Journal of
Environmental Policy & Planning (2007)
32 Neptis Foundation, Neptis Commentary on the Draft Greenbelt Plan (2005)
30
31
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Oak Ridges Moraine Partnership for 2015
STRONGER LEGACY
The innovation of the ORMCP is that “protect” encompasses a three-part approach of “maintaining,
improving or restoring” all the elements that contribute to the ecological and hydrological functions of the
Oak Ridges Moraine. Similarly the Greenbelt Plan has a vision of permanent protection for natural
heritage and water resource systems by protecting, improving and restoring natural and open space
connections and ground- and surface-water systems.
These goals and objectives aptly describe a multi-pronged approach of complementary actions that are
needed to achieve the desired outcome, i.e., a robust regulatory regime complemented by nonregulatory mechanisms that foster stewardship, restoration and that support municipalities in the
implementation of its policies. This requires strong policy directives, government investment of human and
financial resources, a collaborative stakeholder approach, and meaningful opportunities for public
engagement.
The Conservation Authorities Moraine Coalition (CAMC) 2015 Report Card Summary demonstrates a
gap in ability to meet the ORMCP and GBP goals to restore or enhance the Greenbelt.
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WHAT’S WORKING
17. Foundation Support
The provincial government should be commended for its vision in the establishment of the Oak Ridges
Moraine Foundation (ORMF) and the Friends of the Greenbelt Foundation (FGBF). These two highly
effective organizations with very different but complementary mandates, have contributed to a strong
legacy for the Greenbelt. They have between them championed their respective plan areas and built
capacities in the non-regulatory aspects of advancing sustainability and resiliency for the benefit of the
larger community.
The ORMF was established in 2002 to complement the goals of the ORMCP. They were tasked with
fostering private landowner and public sector stewardship and restoration efforts of the Oak Ridges
Moraine’s ecological and hydrological integrity. The ORMF also supported education, research, land
securement and trail projects across the Moraine. It leveraged the initial $15 million from the province
into over $50 million of on-the-ground work. In focusing on going beyond “maintaining” the ecological
and hydrological considerations, the ORMF also developed innovative ways for different organizations
to work collaboratively in delivering stewardship, and land securement programs (e.g., the ORMF’s
Caring for the Moraine project). The ORMF is an example of what worked in helping to meet new targets
for stewardship, restoration and land securement.
Established shortly after the Greenbelt Plan in 2005, the FGBF helps keep farmers successful, strengthens
local economies, and protects and grows natural features in the Greenbelt. Through two provincial grants,
the FGBF has been highly successful in raising the profile of the Greenbelt and supporting efforts at all
levels in making local food, local wine, local economies viable. Since 2006, the FGBF has funded and
leveraged over $43 million in innovative projects.33
Both foundations have also played a key role in funding research to assess and evaluate the Oak Ridges
Moraine and Greenbelt from various perspectives. The ORMF commissioned a series of Measuring
Success reports that provided information on the environmental health of the Oak Ridges Moraine and
the implementation of the ORMCP. The FGBF has supported research in the area of food and farming,
environment, economy, and growth and planning. Both foundations also supported the work of the
Conservation Authorities Moraine Coalition (CAMC) in their watershed report card on the environmental
health of the Oak Ridges Moraine and adjacent Greenbelt Lands. With limited data from the province to
evaluate the ORMCP and GBP, the ORMF and FGBF have helped to fill a big gap in the implementation
of these provincial policies (see Section 21 “Monitoring and Performance Measures”).
Recommendation 17 That the Oak Ridges Moraine and Friends of the Greenbelt Foundations receive
provincial investment to continue to support the essential non-regulatory aspects of Oak Ridges Moraine and
Greenbelt protection, e.g., stewardship, research, education, monitoring, and land securement
33
http://www.greenbelt.ca/foundation
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18. Public Access and Engagement
Similar to the Niagara Escarpment lands, public access to the Oak Ridges Moraine’s countryside was
identified as a priority in the ORMCP. In both cases public access has been achieved with government,
foundation and NGO contributions. Furthermore, there have been many opportunities for public
engagement to increase awareness and appreciation of these important greenspaces in the Greenbelt.
The ORMCP has policies around an accessible and continuous recreational trail system with continuous
access (Section 39). Public access is explicitly mentioned as part of the Greenbelt Plan’s Parkland, Open
Space and Trail Policies (Section 3.3.2) and Municipal Parkland, Open Spaces and Trail Strategies
(Section 3.3.3).
The Oak Ridges Moraine Foundation (ORMF) included the ORM trail as a strategic priority, allocating
funds for the completion of a fully accessible trail from west to east. Connections have been made
between the Bruce Trail, TransCanada Trail, the Oak Ridges Moraine Trail and subsequent Greenbelt
Walks providing a regional network of publicly accessible trail systems. This network has been
established through a series of mechanisms such as easements, land-owner agreements and fee-simple
arrangements. It offers an incredible opportunity to extend this trail network, and public accessibility in
general, across the entire the Greater Golden Horseshoe.
The ORMF also helped to support the Ganaraska Forest Centre and the Oak Ridges Moraine EcoCentre.
The Ganaraska Forest Centre is located in the Ganaraska Forest, the largest tract of forested land in
southern Ontario and the catalyst for the conservation movement in Ontario. The Forest Centre is open
during the weekdays and weekends, offering access to its trails, recreation and education programs
throughout the year. The Oak Ridges Moraine EcoCentre, in the Town of Richmond Hill, overlooks Lake
Wilcox, one of the largest kettle lakes in the area. The EcoCentre provides a variety of resources,
displays and interactive activities that focus on the Oak Ridges Moraine’s natural and cultural history.34
The funding from the ORMF helped to establish the Relay Adventure across the Oak Ridges Moraine as a
highly successful, annual event of the Oak Ridges Trails Association. Likewise, funding from the Friends of
the Greenbelt Foundation to the Waterfront Trust has resulted in a Greenbelt cycling route. The foresight
that the government had in establishing these two foundations has resulted in increased public access to
these important landscapes, under-scoring the efforts of the government to protect these landscapes in
the first place.
Recommendation 18 That the Province recognize the significant role played by the Oak Ridges Moraine and
Friends of the Greenbelt Foundations in promoting public access through the development and promotion of
trails, educational centres and festivals, and recommit to further investment of these foundations
34
http://www.richmondhill.ca/subpage.asp?pageid=parks_oak_ridges_Moraine_eco_centre
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NECESSARY IMPROVEMENTS
19. Governance
The Partnership supports the continued model of municipal implementation of the plans and the
maintenance of the separate branding that highlights the uniqueness of each of the NEP, ORMCP and
GBP. Each statute should be recognized for the advances made in regional and landscape planning: the
Niagara Escarpment for its focus on accessibility, open landscape character and environmental
protection; the ORMCP for its recognition of the Oak Ridges Moraine’s natural heritage and water
resources; and, the Greenbelt for its recognition of agricultural land management, ecological connections
and smart growth. Building on this innovative conservation planning regime, we are advocating for both a
focus on improving the three existing plans, while also enhancing social-ecological systems of the Niagara
Escarpment, Oak Ridges Moraine and Greenbelt but also through development of a new planning
domain focused on the “Greater Golden Horseshoe”.
The Oak Ridges Moraine needs a champion “organization” similar to the role the Niagara Escarpment
Commission plays for the escarpment, but without the land use planning implementation role; we are
satisfied with the municipalities being the primary implementators of the ORMCP. In the past the ORMF
was the closest entity to fulfilling the non-regulatory requirements as originally envisioned when the
ORMCP was developed. With renewed funding, the ORMF would be well-positioned to carry on in an
enhanced capacity – this would include taking the lead on the development of a multi-party communitybased monitoring initiative tied in closely with municipal land use planning and conservation authority
decision-making. Annual state of the environment reports could include reporting back on how well
municipalities have implemented the ORMCP. This would lead to developing the foundations of an
adaptive environmental management (AEM) approach.
The Partnership recognizes that these Greater Golden Horseshoe lands are among the traditional
territories of the Mississaugas of the New Credit, Curve Lake, Alderville and Scugog First Nations. We
are encouraged by the improvements made in the final Provincial Policy Statement, 2014 regarding duty
to consult and we look forward to further innovations with respect to indigenous planning in southern
Ontario.
Recommendation 19.1 That the Province maintains the three plan areas and associated regimes as separate
but complementary
Recommendation 19.2 That the Province enhance the breadth and capacity of the Oak Ridges Moraine
Foundation to not only deliver on supporting stewardship but also to take on additional roles as leader in
community-based monitoring that will lead to improved adaptive environmental management
Recommendation 19.3 That the Province empower the Oak Ridges Moraine Foundation to work with regional
governments to produce and report on annual municipal implementation of the Oak Ridges Moraine
Conservation Plan policies with a focus on the broader water and natural heritage system values
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20. Effective Implementation of the ORMCP and GBP
Issue
Over the past 13 years, municipalities on the Oak Ridges Moraine have been struggling to understand
some of the more technical aspects of these complex policy documents and there has been a lack of
technical support from the province to effectively implement the ORMCP. There has also been confusion in
interpreting policies among municipalities and individual properties that contain both the Oak Ridges
Moraine and the Protected Countryside.
Current Policies
In the Implementation Section of the ORMCP, under Provincial Obligations and Technical Support, the
province shall provide technical information, technical guidelines and develop a data management
system. Specifically, technical information is to be provided on Key Natural Heritage Features (KNHFs),
Hydrological Features, Landform Conservation Areas, and Areas of High Aquifer Vulnerability. In
addition, criteria are to be provided to help identify and map KNFHs. Furthermore, technical guidelines
are to be provided on areas including natural heritage, stormwater management planning, design and
implementation, water budget and water conservation plan preparation, watershed and subwatershed
plan preparation. Lastly, the province is to lead a database management system with appropriate
stakeholders to collect, store, update and share data to interpret, apply and monitoring the policies of
the ORMCP.
Strengths & Weaknesses
The current policies outline a comprehensive suite of technical support from the province to guide users of
the ORMCP. In addition, appropriate stakeholders such as municipalities and conservation authorities
were identified as partners in a data management system to inform the ORMCP. The province conducted
a multi-party exercise and produced an excellent series of 17 technical papers related to the natural
heritage policies in the ORMCP including the identification of KNHFs, identification and protection of
significant woodlands, watersheds plans and stormwater management plans. These technical papers were
not released however until the summer of 2007 or five years after the release of the ORMCP. In addition
to the technical papers, a broad collection of digital data related to natural heritage and hydrological
features have been made available by the province to support the implementation of the ORMCP.
There were expectations however that the province would produce additional guidance materials, e.g.,
model tree-cutting and site-alteration bylaws to support municipalities in implementing the ORMCP.
Furthermore there was the expectation amongst municipalities that when they asked for specific advice on
how to interpret the ORMCP’s land use planning policies that the province would be there as a resource.
There has been frustration experienced at the municipal level that has resulted in questionable decisionmaking and approvals (e.g., severance approvals in the Township of Alnwick-Haldimand that triggered
five third-party OMB appeals which were all successful).
The province also produced a similar technical paper to identify and protect Key Natural Heritage
Features in the Protected Countryside’s Natural Heritage System. This was released at the end of 2012,
seven years after the Greenbelt Plan was passed.
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Recommendation
Recommendation 20 That the Province reconvenes an interministerial committee to examine the gaps in
technical information supporting Oak Ridges Moraine Conservation Plan and Greenbelt Plan policy
implementation and make public a prioritized list of areas that require technical support and guidance for
municipalities
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21. Monitoring and Performance Measures
Issue
The policies of the ORMCP, GBP and Growth Plan must be evaluated for their effectiveness in achieving
their respective visions and objectives. Despite a clear directive that this was the responsibility of the
province in the ORMCP and GBP, the government has not taken the necessary steps to provide the
capacity within its ministries to achieve this.
Current Policies
In the Performance Indicators and Monitoring subsection of the ORMCP under Implementation, the
government is to identify performance indicators in consultation with municipalities to monitor the
effectiveness of the ORMCP as well as establish a monitoring network with appropriate stakeholders to
gather information on these indicators for the purpose of assessing the ecological integrity of the Moraine
and the effectiveness of the ORMCP’s policies, as well as identifying areas to improve the implementation
of the ORMCP.
Section 5.8 of the Greenbelt Plan, the government, with other ministries and stakeholders, will identify
performance indicators to measure the GBP’s effectiveness, identify roles and responsibilities in the data
collection and analysis of indicators and collate, publish and discuss the results.
Policy 5.4.3 of the Growth Plan also states that a set of performance indicators will be developed and
tracked with municipalities also monitoring and reporting on the Growth Plan’s implementation.
Strengths & Weaknesses
The strength of the performance indicators’ policies is that they emphasize the inclusion of other
appropriate stakeholders in the process. However, opportunity to build community-based monitoring
capacity was missed and indicators were never specifically determined for the ORMCP or the GBP. A
discussion paper on the Greenbelt Plan Performance Monitoring Framework was created and further
supported by two Greenbelt Plan Performance Monitoring Technical workshops in 2009. The draft
framework was open for comment until mid-2010. However, a final framework was not released until this
year. Part 1 of the Performance indicators for the Greenbelt Plan was not released until 2015, during
the Regional Town Hall Meetings. Of the 10 performance indicators for the Greenbelt, only two provide
the ability to measure future changes in natural processes, i.e., the percentage of woodland cover and
the percentage of mapped wetland cover. These currently provide only baseline data from the period
between 2000 and 2002.35 There is only one indicator for water which is the percentage of watershed
plan coverage in the Greenbelt.
This was a missed opportunity to establish meaningful indicators and baseline data to track changes over
time. There is no data to determine how well the natural environment is doing under this policy regime.
This was also a missed opportunity to engage with different sectors to develop a broad-based
performance measures framework and network to truly determine how well the region is doing. Without
that community-based approach to resource management and monitoring, we will continue to be
35
Ministry of Municipal Affairs and Housing, Performance Indicators for the Greenbelt Plan, Part 1(2015)
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Oak Ridges Moraine Partnership for 2015
vulnerable to political and financial shifts. This is particularly concerning considering the relative
robustness of the social and economic performance indicators developed for the Growth Plan. It is
unacceptable that in 2015 a major co-ordinated review such as this cannot answer simple questions
about the health of our natural world.
This should in no way detract from the value of the existing work by the Conservation Authorities Moraine
Coalition’s Report Card on the Environmental Health of the Oak Ridges Moraine and Adjacent Greenbelt
Lands (funded by the Friends of Greenbelt and Oak Ridges Moraine Foundations). Without this report
card, there would be virtually no science on how the conservation plan policies have impacted the
ecological and hydrological functions of the Greenbelt. Learning to develop adaptive management
techniques requires better control of cause and effect, which require good baseline information and good
control over ecological indicators. Despite this, the province still has the opportunity to build upon this
effort and re-emerge as a leader to initiate a true community-based monitoring network.
“Genuine monitoring of performance
can identify when objectives are not
being met and amendments are
required. Nearly ten years after the
Plan’s approval, MMAH has failed to
monitor the effectiveness or
implementation of Plan policies, leaving
the job to environmental organizations,
such as the Oak Ridges Moraine
Foundation and Monitoring the
Moraine.”
Source: ECO, 2012/2013 Annual
Report
For example, between 2005 and 2012, the Monitoring the
Moraine Project (a collaborative between EcoSpark and
STORM) created a multi-party monitoring framework with
indicators to measure the effectiveness of the ORMCP against
its vision and objectives. It was created in collaboration with a
25-member advisory committee which included government,
industry, ENGOs, academics and community groups. It was
also populated with baseline data from our series of status
reports on the implementation of the ORMCP, community
concerns from our Moraine Watch program, citizen science
baseflow data from Check Your Watershed Day (20062010), and a number of long-term terrestrial plots (similar to
those established in the Niagara Escarpment) on the Oak
Ridges Moraine.
The Province must demonstrate leadership in finding innovative ways to incentivize community-based
monitoring and adaptive management processes. While this may require an initial financial investment,
the success of this approach has already been demonstrated with the two foundations concerned with
ecological and community capacity building. There are untapped opportunities with both the private and
civil society sectors and with the two foundations that were created for this very purpose.
Recommendation
Recommendation 21 That the Province demonstrates leadership in finding innovative ways to build capacity
for developing a long-term monitoring framework, a collaborative multi-stakeholder network and database
to evaluate the health of the natural environment and general prosperity of the Greater Golden Horseshoe
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22. Innovation in Stewardship and Restoration Programs
Issue
A robust natural system requires more than a regulatory regime, no matter how progressive, in order to
thrive. Evidence shows that in order for the Oak Ridges Moraine’s ecological and hydrological health and
integrity to be improved and enhanced, targeted ecological stewardship and restoration programs are
needed. This is even more urgent in the face of climate change and population growth. Furthermore,
climate change strategies for the Greater Golden Horseshoe are required that will shift focus towards
green infrastructure to help mitigate against the impacts of extreme weather events.
Current Policies
An objective in the ORMCP includes “maintaining, improving or
restoring all elements that contribute to the ecological and
hydrological foundation of the Oak Ridge Moraine”. This
approach is echoed in the land use designations where the
purpose or objective of Natural Core Areas, Natural Linkage
Areas and Countryside Areas are to maintain, and where possible
improve and restore the ecological integrity of the Oak Ridges
Moraine Plan Area. There are also references to this approach
with respect to development or site alteration and natural selfsustaining vegetation.
Policy 1.2.2.2.d in the Greenbelt Plan speaks to a goal under
environmental protection to provide long-term guidance of
managing natural heritage and water resources with respect to
private or public stewardship programs. The Greenbelt Plan also
speaks to the importance of farm stewardship in relation to
agricultural production, economic activity, as well as natural
heritage and hydrological features, emphasizing the importance
and connectedness of the natural and agricultural systems (Section
3.1.1). Stewardship, remediation along urban river valleys is
mentioned (Section 3.2.5, Greenbelt Plan) as well as shorelines
areas (Section 4.1.3).
“It is recommended that a new
arms-length partnership body
…implement the non-regulatory
aspects of the plan, including tools
to protect water resources and
create a continuous natural
corridor.”
“Achieving the plan’s goals would
require more than effective policy
and legislation. Since the majority
of lands on the moraine are
privately owned, there is a need
to support voluntary action and
good stewardship that will, over
time, achieve desired goals.”
Source: The Government of
Ontario. Share Your Vision for the
Oak Ridges Moraine, AugustSeptember 2001
Strengths & Weaknesses
The Oak Ridges Moraine Foundation (ORMF) has worked closely with many stakeholders to develop a
comprehensive, science-based stewardship strategy. This strategy is guided by a set of conservation
priority areas that focus on increasing the Oak Ridges Moraine's natural land cover, protecting its water
resources and systems and raising landowner awareness and recognition. An example includes the
Caring for the Moraine Project (CMP), a partnership of 30 organizations including EcoSpark, STORM and
Ontario Nature. The CMP offered conservation and stewardship services to private landowners on the
Oak Ridges Moraine. With the implementation of the ORMF’s stewardship strategy, 5,582+ acres of
conservation lands were protected through acquisition or conservation easements, over 1,000 acres of
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Oak Ridges Moraine Partnership for 2015
conservation lands enhanced through stewardship projects, nearly16 kilometres of stream or stream-bank
restoration completed and more than 85,500 landowners have received stewardship advice.36
In addition, the conservation authorities and land trusts have been able to complete numerous securement,
stewardship and restoration activities on the Oak Ridges Moraine. However, despite these efforts,
research shows that the implementation of the policies and the associated stewardship and restoration
efforts are only minimally maintaining the integrity of the Oak Ridges Moraine and Greenbelt areas.
This illustrates, in part, the limitations of land use planning on its own to achieve the kinds of outcomes we
have come to expect and demand. Instead, there is a need for innovative programs from collaborative
multi-stakeholder efforts to achieve the goal of “improving” and “restoring” the natural systems within the
Oak Ridges Moraine and Protected Countryside.
Recommendation
Recommendation 22 That the Province show leadership through the sharing of resources (e.g., financial and
expertise) that will fund community-based grassroots initiatives that are multi-stakeholder and that draw from
expertise of foundations, government staff, private sector and civil society to fund ecological stewardship
and restoration
36
http://moraineforlife.org/projects/AbouttheProgram.php
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23. Engage the Next Generation of Champions
Issue
Public and formal education is needed to build the awareness and appreciation of the Greenbelt to
ensure that it remains permanently protected and stewarded for generations to come. While the
conservation plans within the Greenbelt provide spaces for public interaction with the landscape, there is
no strategy to coordinate efforts to facilitate this interaction for a longer-term impact. Decisions made
through the 2015 Co-ordinated Review will affect - for better or worse - the children and youth of
today. They should be prepared to face the upcoming challenges ahead in the Greenbelt and Greater
Golden Horseshoe.
Current Policies
There are no current policies with the express intent of engaging the future champions of the Greenbelt
Area. However, the Oak Ridges Moraine and Greenbelt Foundations have contributed to numerous
programs that foster public and formal education and engagement.
Strengths & Weaknesses
The Oak Ridges Moraine evokes a strong sense of place as made evident through its grassroots legacy
and its many place-based groups and initiatives. It is important therefore that the Oak Ridges Moraine
remain recognized as a distinct landform with a distinct conservation plan within a larger system of
protected greenspace and Greater Golden Horseshoe lands.
Foundations have played a major role in facilitating public and formal education. One of the primary
objectives of the Oak Ridges Moraine Foundation (ORMF) is to share information and research with local
schools and the general public. An example is their Oak Ridges Moraine School Education Program
where over 5,700 school children where educated about the importance of the Oak Ridges Moraine with
classroom presentations.37 The ORMF also supported the Moraine Research Coalition to promote the
coordination and collaboration between researchers whose work focuses on the Oak Ridges Moraine
while fostering linkages between researchers and practitioners. Unfortunately, neither of these initiatives
exists today due to lack of funding.
The Friends of the Greenbelt Foundation (FGBF) has been successful in raising awareness and celebrating
the Greenbelt. Recent polling demonstrated that 93% of Ontarians support the Greenbelt.38 The FGBF
has also funded many grantees for hikes, festivals and forums across the Greenbelt. The FGBF itself has
also initiated a number of public awareness raising/tourism events to celebrate the Greenbelt such as the
annual Greenbelt Harvest Picnic, Greenbelt Walks (wayfinding, trail and interpretative signage), cycling
routes and displays at farmer’s markets.
As natural systems need to be maintained, improved and restored, champions of these systems must also
be nurtured, facilitated through meaningful opportunities for engagement at various stages (e.g.,
childhood to adulthood). All efforts must be made to help people stay connected to the landscape so that
37
38
http://www.moraineforlife.org/
Friends of the Greenbelt Foundation, 2012/2013 Annual Report (2013)
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Oak Ridges Moraine Partnership for 2015
they continue to understand why the environment is important and why it needs to be protected. The
province has a number of initiatives where meaningful linkages can be made that would allow the
province to leverage its own programs to increase the impact of its collective strategies and initiatives.
These include different program areas within the Ministry of Education and the Ministry of Citizenship and
Immigration.
In 2009, Acting Today, Shaping Tomorrow, a policy framework for environmental education (EE) in
Ontario schools, was published by the Ministry of Education with a vision of preparing students “with the
knowledge, skills, perspectives, and practices they need to be environmentally responsible citizens.”39 This
framework infuses EE, i.e., education about the environment, for the environment and in the environment,
in all curricula regardless of grade or subject. The Ministry of Education has been implementing this
framework by integrating EE into the curriculum. For example, the secondary school curriculum includes the
following: the Greenbelt is mentioned in Grade 12 Green Industries, i.e., describe legislation that affects
operations in the green industries (e.g., Greenbelt Act); the Niagara Escarpment is mentioned in Grade 10
Hospitality and Tourism, i.e., identify the types of tourist attractions associated with the various
geographic regions of Ontario (e.g., wineries in the Niagara region); the Oak Ridges Moraine and
Niagara Escarpment appear in Grade 9 Science under Sustainable Ecosystems: how has suburban
development on the Niagara Escarpment or the Oak Ridges Moraine affected local ecosystems?
In addition, the Ministry of Education is also implementing Acting Today, Shaping Tomorrow, through its
Specialist High Skills Major (SHSM), a specialized program which allows Grade 11 and 12 students to
experience a range of customized, career-focused learning opportunities while meeting the requirements
to graduate from secondary school. Students can currently complete SHSMs in the area of agriculture,
energy, environment, food processing, and forestry among many other topics.
The Ministry of Citizenship and Immigration also has a number of initiatives whose goals can be met
through awareness and education programs based on the Greenbelt, including increasing volunteerism,
supporting newcomers to Canada and building strong, inclusive and diverse communities. With the need
for restoration and stewardship to meet the objective of “improving” or “restoring” ecological and
hydrological integrity, there is a large role volunteers can play to support these efforts. With the many
gaps in data to support performance indicators, volunteers can also play a valuable role as they did in
the Monitoring the Moraine Project in gathering information about the health of our protected
landscapes. Opportunities for environmental volunteerism in the Greenbelt should be integrated into any
provincial volunteer-recruitment strategy. Programs to engage newcomers to Canada including new
Canadians can include visits, hikes, and tours of the valuable natural assets within the GGH including the
Oak Ridges Moraine, Niagara Escarpment and the Protected Countryside. The more informed newcomers
are the more engaged they can become in appreciating and protecting the natural assets of the
Greenbelt and Greater Golden Horseshoe.
Much like the aforementioned tiering of environmental policies, there are clearly many areas where there
can be more intentional and strategic integration of provincial programs that will efficiently and
effectively meet the goals and objectives of those individual programs.
39
Ministry of Education, Acting Today, Shaping Tomorrow (2009) from Shaping Our Schools, Shaping Our Future p.4. (2007)
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Recommendation
Recommendation 23.1 That the Province continues to recognize the Oak Ridges Moraine as a unique
landform within the Greenbelt
Recommendation 23.2 That the Province show leadership by supporting a public and formal education and
engagement strategy for the Greenbelt developed by a multi-stakeholder group including the Ministry of
Education, the Ministry of Citizenship and Immigration, foundations, government staff, private sector and
civil society
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RECOMMENDATIONS
STRONGER LAWS
1. Land Use Designations
Recommendation 1.1 That the purpose and objectives of the four land use designations within Oak
Ridges Moraine Conservation Plan (i.e., Natural Core Areas, Natural Linkage Areas, Countryside Areas
and Settlement Areas) be maintained
Recommendation 1.2 That all decision makers (e.g., municipalities and the Ontario Municipal Board)
should continue to conform to the Oak Ridges Moraine Conservation Plan and its land use designations
2. Internal Boundaries
Recommendation 2.1 That the internal boundaries of the Oak Ridges Moraine Conservation Plan do not
change
Recommendation 2.2 That the total Greenbelt area is not decreased
Recommendation 2.3 That land swaps in the Oak Ridges Moraine Conservation Plan and Greenbelt Plan
be prohibited
3. Rural Settlement Boundaries in Countryside Areas
Recommendation 3.1 That the Rural Settlement boundaries be maintained according to the Oak Ridges
Moraine Land Use Designation Map (Map No. 208) or as delineated in official plans and zoning bylaws
according to Section 10(2)of the Oak Ridges Moraine Conservation Plan
Recommendation 3.2 That “minor infill” and “minor rounding-out” in Rural Settlements be defined by the
Province along with a clear set of rules, criteria, and technical guidelines through an open and
transparent process to guide municipalities on implementing Section 15(1)-3 and 15(1)-4 of the Oak
Ridges Moraine Conservation Plan
4. Watershed Planning
Recommendation 4.1 That tiered watershed planning is mandatory for all municipalities across the Oak
Ridges Moraine
Recommendation 4.2 That the Oak Ridges Moraine Conservation Plan’s water resource policies be
strengthened to reflect the latest science and extend where appropriate the methodologies and findings
from Source Protection Plans
Recommendation 4.3 That watershed planning be mandatory for all municipalities in the Greater Golden
Horseshoe where there are significant groundwater sources that are under threat
Recommendation 4.4 That the Province provides support for the provision of watershed plans including
guidance with official plan integration and tiering with other policies, oversight and funding on the
development, implementation and evaluation of watershed plans
5. Tree-Cutting
Recommendation 5.1 That the Province requires stronger municipal tree-cutting bylaws that conform to
the goals and objectives of the Oak Ridges Moraine Conservation Plan
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Recommendation 5.2 That the Province provides guidance to municipalities for developing strong treecutting bylaws through a model tree-cutting bylaw that is informed by the Oak Ridges Moraine
Conservation Plan, its watershed plans and municipal official plans
Recommendation 5.3 That Section 24(3) in the Oak Ridges Moraine Conservation Plan be amended to
acknowledge a healthy range of forest cover (e.g., at least 30%) and prescribe that watershed plan
shall include targets for a healthy tree cover
Recommendation 5.4 That municipalities invest resources to support the proper development,
implementation and enforcement of their tree-cutting bylaws
6. Permitted Uses and Rural Prosperity
Recommendation 6.1 That the Oak Ridges Moraine Conservation Plan policies support innovation for
rural landowners and rural businesses through increased flexibility in permitted uses and their accessory
uses provided they do not negatively impact the ecological and hydrological integrity of the Oak Ridges
Moraine
Recommendation 6.2 That rural municipalities should have flexibility to support viable local economic
development and the discretion to permit accessory uses provided they do not negatively impact the
ecological and hydrological integrity of the Oak Ridges Moraine
Recommendation 6.3 That the Province commits to initiating a multi-party rural prosperity strategy for
the Oak Ridges Moraine and Protected Countryside as an outcome of the 2015 Co-ordinated Review
and that small scale innovation issues be addressed through this strategy
Recommendation 6.4 That through an open and transparent process, the following definitions in the Oak
Ridges Moraine Conservation Plan be updated to allow for increased rural prosperity:
o “agricultural uses” be amended to include such uses as apiaries
o “agricultural-related uses” remains the same, i.e., keeping the “small scale” aspects of those
commercial and industrial uses that are agricultural-related
o “bed and breakfast establishment” and “farm vacation home” be amended to allow for more
than three guest rooms within a single dwelling as long as it does not negatively impact the
ecological and hydrological integrity of the Oak Ridges Moraine
o “home business ” be amended to allow for it to be carried out in a building accessory to the main
dwelling in addition to within a single dwelling by one or more of its residents
7. Commercial Fill
Recommendation 7.1 That new policies be developed for large-scale movement and disposal of fill with
requirements for municipal bylaw conformity to the Oak Ridges Moraine Conservation Plan
Recommendation 7.2 That the disposal of large-scale fill is prohibited in key natural heritage features,
hydrologically sensitive features, Areas of Natural and Scientific Interest (Earth Science) and their
minimum areas of influence, wellhead protection areas, areas of high aquifer vulnerability, and landform
conservation areas as defined in the Oak Ridges Moraine Conservation Plan
Recommendation 7.3 That the disposal of large-scale fill is prohibited in specialty crop areas, prime
agricultural areas, key natural heritage features, and key hydrologic features as defined in the Greenbelt
Plan
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Recommendation 7.4 That the Province adopts a clear provincial position and appropriate strategy for
the management of fill and develop technical guidelines to assist municipalities in the development and
implementation of appropriate site alteration guidelines
8. Aggregates
Recommendation 8.1 That new aggregate mining in Natural Linkage Areas of the Oak Ridge Moraine be
prohibited without any exemptions
Recommendation 8.2 That new mineral aggregate operations continue to be prohibited in Natural Core
Areas and the expansion of existing mineral aggregate operations in Natural Core Areas be prohibited
Recommendation 8.3 That the Province amend the Oak Ridges Moraine Conservation Plan to “require”
rather than to “encourage” the completion of comprehensive rehabilitation plans. It is further
recommended that the Province issue a Technical Guideline to provide direction and advice in preparing
comprehensive rehabilitation plans to ensure there is a clear benefit to the natural heritage system
9. Transitional Applications
Recommendation 9.1 That a sunset clause on development applications that pre-date the Oak Ridges
Moraine Conservation Plan, i.e. transitional applications, be implemented enforced
Recommendation 9.2 That in Natural Core Areas and Natural Linkage Areas, transitional development
must take into account the Oak Ridges Moraine Conservation Plan to its full extent where applicable
10. Infrastructure
Recommendation 10 That a moratorium on infrastructure development, including industrial scale energy
plants, 400-series highways and airports, be placed on the Oak Ridges Moraine until such time that a
proper cumulative effects assessment is completed that evaluates large scale infrastructure
11. Bringing Other Statutes In Line with the ORMCP
Recommendation 11 That the Province makes a commitment to a systematic policy review to evaluate
other legislation that may be negatively impacting the ecological and hydrological integrity of the Oak
Ridges Moraine
STRONGER LANDSCAPE
12. Interplay between Conservation and Growth Plans
Recommendation 12.1 That future reviews of the provincial plans related to conservation and growth in
the Greater Golden Horseshoe continued to be co-ordinated
Recommendation 12.2 That provincial plans related to transportation (i.e., the Big Move) and climate
change also be co-ordinated with future reviews of the Growth Plan for the Greater Golden Horseshoe,
Greenbelt Plan, Oak Ridges Moraine Conservation Plan and the Niagara Escarpment Plan
13. Growing the Greenbelt
Recommendation 13 That the Greenbelt Plan ‘Schedule 1: Greenbelt Plan Area’ and all other
associated schedules be amended to include headwater features of the Carruthers Creek, the
Humber River and the Rouge River; the Paris-Galt Moraine, Waterloo Moraine, Orangeville
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Oak Ridges Moraine Partnership for 2015
Moraine and Oro Moraine; the Lake Iroquois Shoreline; Urban River Valleys running through
Halton, Hamilton and Toronto; and Lake Gibson
14. Natural Heritage System for the GGH
Recommendation 14.1 That the existing Growth Plan policies be revised to assign responsibility for
the identification and protection of a regional natural heritage system across the Greater Golden
Horseshoe to the Minister of Municipal Affairs and Housing
Recommendation 14.2 That the Greenbelt Plan be revised to assign responsibility to the Minister of
Municipal Affairs and Housing to: consider impact of activities, promote and undertake
appropriate planning, and undertake watershed based planning that relates to these areas
identified as external connections
15. Agricultural System for the GGH
Recommendation 15 That the existing Growth Plan policies be revised to assign responsibility for
the identification and protection of a prime agricultural system across the Greater Golden
Horseshoe to the Minister of Municipal Affairs and Housing
16. Hard Urban Boundary
Recommendation 16.1 That section 2.2.8 of the Growth Plan be revised to place a moratorium or
‘freeze’ on any settlement area boundary expansions during municipal comprehensive reviews
(official plan review or amendment) until the next public review of the Growth Plan
Recommendation 16.2 That section 2.2.3 of the Growth Plan be revised to increase intensification
targets to direct more growth into existing built-up areas and designated greenfield areas already
planned for in MMAH approved Official Plans
STRONGER LEGACY
17. Foundation Support
Recommendation 17 That the Oak Ridges Moraine and Friends of the Greenbelt Foundations receive
provincial investment to continue to support the essential non-regulatory aspects of Oak Ridges Moraine
and Greenbelt protection, e.g., stewardship, research, education, monitoring, and land securement
18. Public Access and Engagement
Recommendation 18 That the Province recognize the significant role played by the Oak Ridges Moraine
and Friends of the Greenbelt Foundations in promoting public access through the development and
promotion of trails, educational centres and festivals, and recommit to further investment of these
foundations
19. Governance
Recommendation 19.1 That the Province maintains the three plans areas and associated regimes as
separate but complementary
Recommendation 19.2 That the Province enhance the breadth and capacity of the Oak Ridges Moraine
Foundation to not only deliver on supporting stewardship but also to take on additional roles as leader in
community-based monitoring that will lead to improved adaptive environmental management
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Recommendation 19.3 That the Province empower the Oak Ridges Moraine Foundation to work with
regional governments to produce and report on annual municipal implementation of the Oak Ridges
Moraine Conservation Plan policies with a focus on the broader water and natural heritage system values
20. Effective Implementation of the ORMCP and GBP
Recommendation 20 That the Province reconvenes an interministerial committee to examine the gaps in
technical information supporting Oak Ridges Moraine Conservation Plan and Greenbelt Plan policy
implementation and make public a prioritized list of areas that require technical support and guidance
for municipalities
21. Monitoring and Performance Measures
Recommendation 21 That the Province demonstrates leadership in finding innovative ways to build
capacity for developing a long-term monitoring framework, a collaborative multi-stakeholder network
and database to evaluate the health of the natural environment and general prosperity of the Greater
Golden Horseshoe
22. Innovation in Stewardship and Restoration Programs
Recommendation 22 That the Province show leadership through the sharing of resources (e.g., financial
and expertise) that will fund community-based grassroots initiatives that are multi-stakeholder and that
draw from expertise of foundations, government staff, private sector and civil society to fund ecological
stewardship and restoration
23. Engage the Next Generation of Champions
Recommendation 23.1 That the Province continues to recognize the Oak Ridges Moraine as a unique
landform within the Greenbelt
Recommendation 23.2 That the Province show leadership by supporting a public and formal education
and engagement strategy for the Greenbelt developed by a multi-stakeholder group including the
Ministry of Education, the Ministry of Citizenship and Immigration, foundations, government staff,
private sector and civil society
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