From Friends of Strawberry Island, adddressed to the Ramara Township Council
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.
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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
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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.
Sincerely,
Pamela Fulford, on behalf of Friends of Strawberry Island
2925 Suntrac Drive
Brechin, Ontario, L0K 1B0
Ph: 705 426-4200
Email: pamfulford@gmail.com