From Friends of Strawberry Island, adddressed to the Ramara Township Council

by / Wednesday, 04 March 2015 / Published in Uncategorized

February 22, 2015

Friends of Strawberry Island

c/o Pamela Fulford

2925 Suntrac Drive

Brechin, Ontario

L0K 1B0

Ramara Township Council and Staff

Ramara Town Hall

2297 Hwy 12

Brechin, Ontario

L0K 1B0

To Ramara Township Council and Staff:

Re: New Document Review on the Strawberry Island Development Proposal

Trans America Investments Ltd. and its consultants have sent in a revised Strawberry Island

Functional Servicing Report (FSR Jan 2015), Archaeological Assessment of Strawberry Island (Dec

2014), Hydrogeology Study (Dec 2014) and Strawberry Island Traffic Impact Study (Dec 2014).

We respectfully request that the developer responds to the comments below, prior to Ramara

Township Council voting on this development. We also ask Council, at their convenience, to allow

Pamela Fulford on behalf of Friends of Strawberry Island to present a petition signed by over 500

people supporting Council to keep the current rural zoning. A deputation request form has already

been sent in and has been received by Township staff.

This development proposal depicts “a perfect storm” of development impacts. It reaches far beyond

the carrying capacity of this small island in the following ways:

1. The Density is Too High with no Shoreline Protection: The developer persists in planning a

high density, 120-condominium unit development covering the 10-hectare island (Jan 2015 FSR, p

34). With this construction, most of the island’s 8 hectare woodland will be cut down and replaced

with buildings, asphalt, manicured lawn, a thin line of trees along the shoreline and scattered trees

among houses and three story buildings (Fig. 6, App E). The developer’s proposed 40 metre “filter

strip” (p 31) will replace the existing woodland, which in fact, should be protected by a 100 metre

deep protection zone extending from the shoreline to the island interior. According to the Lake

Simcoe Protection Plan (LSPP) “The vegetation protection zone for the remaining Lake Simcoe

shoreline, outside of existing settlement areas and outside of shoreline built-up areas, is 100 metres

from the Lake Simcoe shoreline.” (LSPP, 6.2-DP p 47). The Lake Simcoe Protection Plan is the law.

In addition, development or alterations are not permitted within a vegetation protection zone (LSPP

6.23-DP, p 50). The protection zone must consist of “natural self-sustaining vegetation” (LSPP 6.27-

DP), and trees cannot be cut down within it “for the reasonable provision of views” as is suggested by

the consultant (Planscape, June 25, 2014 p 13). Tree cutting to provide views of the lake would

destroy the function of the protection zone. The Lake Simcoe Protection Plan is clear – the protection

zone should extend 100 metres in from the shoreline. This clearly applies to the design of any future

development on Strawberry Island.


2. Significant Woodlands and Significant Wildlife Habitat Used as a “Filter Strip”: The

developer claims that their proposed Stormwater Best Management Practices (BMPs) can reduce

their phosphorous load by 1024% (Jan 2015 FSR, p 28) partially by using the existing significant

wildlife habitat (forest and wetlands) as a “filter strip” (Jan 2015 FSR, p 29). Furthermore, the

consultant proposes siltation control work and “maintenance” of the significant forest and significant

wildlife habitat (Jan 2015 FSR, p 32). This “maintenance” is not defined but could mean anything

from using the natural areas for dewatering, filtering sediment and pollutants, soil storage or

equipment staging areas. Any of these actions will destroy the function of the existing significant

forest and wildlife habitat. New stormwater management works or alterations are not permitted within

a significant woodland, wildlife habitat or vegetation protection zone (LSPP 6.23-DP, p 50). In

addition, an appropriate buffer (10 m + drip line) should surround all naturally significant areas.

3. Calculating P Loads based on Irrelevant Estimates, not Existing Conditions: The revised

FSP incorrectly claims that the “existing system” contributes 12.2 kg total phosphorous annually to

Lake Simcoe (Jan 2015 FSR, p 16). This load calculation is invalid as it is based on an estimate – not

actual samples – from an inactive septic system that was built in the 1980s and has not been used for

a decade. Current and correct data show that the pre-development total phosphorous load is 0.71

kg/yr. (App. E). The Lake Simcoe Protection Act does not allow new non-municipal sewage

treatment plants to be established unless “the plant will result in a net reduction of phosphorous

loadings to the watershed from the baseline conditions for the property that would be serviced”

(LSPP 4.4-DP, p 28). This net reduction has not been demonstrated in the FSR and must be proven

prior to the approval of any new development. The proponent must clearly show how such a radical

reduction of phosphorus to below 0.71 kg/yr could be achieved in the new development.

4. Significant Finds in the Archaeological Assessment: Two Woodland Period archaeological

resources were found on the island and therefore supplementary work and a second report is

mandatory, according to Ontario legislation. However, the developer’s consultant declares that this

information is not to be made public (Planscape memo, Jan 27, 2015). It is important to protect the

location of the finds, but how are local First Nations people and other residents to know if these

resources are actually protected if we are not allowed to review the final report?

5. Traffic Study is based on 2005 data and does not address Local Concerns: The Strawberry

Island Traffic Impact Study (TIS) is based on outdated 2005 count data and appears to be a limited

“desktop” exercise focusing on one intersection. It ignores local residential streets, Glen Cedar Drive

and Bayview Avenue, which will be impacted by traffic for the development. It does not address local

concerns voiced at the public meeting, such as the one raised by Mayor Clarke about inadequate

parking space on Glen Cedar Drive. It ignores whether the Township will need to widen or resurface

these local roads, create turning lanes or install traffic lights – all potential upgrades specifically

linked to this development. It does not specify who will pay for this. It also does not address the

McRae Pt. Provincial Park potential traffic congestion on a Friday or Sunday night when mixed with

the 500 new residents from Strawberry Island.

It may be outside the scope of the TIS but other concerns raised by residents at the Public Meeting

need to be answered: loading dock locations for deliveries; shuttle boat size, frequency and timing;

increased boat traffic and wake; docking facilities for 500 people; hovercraft or helicopter use and

noise; pedestrians at risk with increased traffic and no sidewalks on residential streets; shoreline

erosion and sinkholes along the canal; garbage transport and storage; Emergency Services access

and cost. These will become township problems should the development proceed as planned.

6. The Hydrogeology Study does not Address Water Table Seasonal Variation: The May 2014

FSR suggested the water table was approximately 0.5m below ground surface. The Hydrogeology


Study (Dec 2014, p 6), which sampled a limited area around the proposed septic bed late last fall,

found water levels at 1.8 m below ground surface. Seasonal variability in groundwater levels is

common. Groundwater levels are higher during spring melt and reach their lowest levels in autumn

and early winter. Testing in November, as the developer has done, is not representative of other

months and seasons when the water table is likely to be higher. If there is not sufficient separation

from the high ground water table to the constructed infiltration trenches, the trenches will not work

and contamination of the water table will result. The proposed new sewage system is designed for a

total daily flow of 137,282 litres of sewage per day. Failure is not an option. Therefore, a baseline of

seasonal normal groundwater levels must be established prior to any approval, to ensure that the

infiltration and sewage system controls do not fail and that the development will not result in the

addition of contaminants to the groundwater and phosphorous to the lake.

7. Seasonal Occupancy or Full Year Occupancy Confusion: The consultants claim that the

development will be open for an even shorter season “8 months maximum operation” (FSR Jan 2015

p 18) than the previously reported “10 months maximum operation” (Planscape, June 25, 2014, p

11). However, the Strawberry Island Proposed Official Plan Amendment asserts, “The occupancy of

the accommodation units may occur during any seasonal period in any calendar year” (June 2014

Sec 9.12.5). This seasonal / full year-round confusion has numerous planning and septic implications

and should be another red flag for the commenting agencies. The proposed septic capacity and

phosphorous loading is now based on 243 days per year (Jan 2015 FSR p16). How can the

developer guarantee that this development will be seasonal, with water and sewer shut off in the

winter, once the condominium board takes over the management of the island if there are no

requirements outlined in the official plan amendment that restricts this?

8. In Conclusion: We continue to urge our Council to keep the Rural Zoning for this island so that

the following conditions are met for any development of Strawberry Island:

1. Stay within the existing clearing for any future development;

2. Phosphorus loading from future development stays below the 0.71 kg/year;

3. Water quality around the island during and after construction remains at the pre-development

level at 0.010 mg/L for concentration of phosphorus;

4. The shoreline protection zone is 100 metres from the Lake Simcoe shoreline;

5. The woodland is protected in its entirety and a Tree Preservation Plan is prepared;

6. The four existing wetlands are protected and their function is preserved to help sustain the

Significant Wildlife Habitat on the Island and sufficient protective buffers are implemented.

The above elements will protect the ecological function of Strawberry Island, reduce phosphorus

loading as dictated by the Lake Simcoe Protection Plan, allow the appropriate level of development

on this small island and sustain it for future generations. We are in favour of sustainable and smart

development, which ensures our essential use and enjoyment of Lake Simcoe water for the future.


Pamela Fulford, on behalf of Friends of Strawberry Island

2925 Suntrac Drive

Brechin, Ontario, L0K 1B0

Ph: 705 426-4200


Our website is under construction