County's Shoreline Policy Study
The Federation's Submission

According to a newsletter distributed by the County of Simcoe,
“The County of Simcoe has initiated the preparation of a Shoreline Policy Study. The intent of the study is to review what role the County should play in controlling and managing land use in the County's shoreline areas.
“At the present time, the County Official Plan, which is intended to guide land use in each of the municipalities in the County, does not contain any specific direction on how shoreline areas should be developed and managed over time. On this basis the primary product of the study will be an Amendment to the County of Simcoe Official Plan. Such an Amendment will be the subject of public meeting(s) in the Fall of 2001.
“In order to assist with the preparation of the Official Plan Amendment, the County has retained The Planning Partnership, which is based in Barrie. Accompanying The Planning Partnership on the Study Team is Gartner Lee, who prepared the County's Greenland Study and Baird and Associates, who will provide marine engineering advice to the study team and County.”
This newsletter, which was sent to solicit comments on this initiative, posed a series of questions. A draft of the Federation's proposed response was circulated to our member associations, and modifications were made to reflect points they raised. Here is our submission:

“RE: Comments on the Shoreline Policy Study

The Federation of Tiny Township Shoreline Associations is an umbrella organization whose membership is composed of about 20 beach and community associations covering the majority of the shoreline areas of the Township of Tiny. The Tiny shoreline areas contain some 6,700 seasonal and permanent residences and provide over 80% of the tax base of the Township.

The Federation is very supportive of the planning efforts of Simcoe County in general, and specifically of your efforts to preserve the natural environment through the Greenlands Study and its related provisions in the County Official Plan.

In general, we are supportive of there being a shoreline policy in the County Official Plan, in order that the protective provisions of both the County OP and of the new Official Plan of the Township of Tiny are made clearer to all and are more effectively upheld. The new Tiny OP was, as you know, the product of an exceptionally widespread and intensive consultation process among all interests in the Township, and this led to a correspondingly wide base of support for the Plan. The Federation strongly supports the Tiny Official Plan, and looks forward to its implementation in full, as written.

Our response to each of the specific questions in your newsletter is as follows:

1. Should growth be directed to shoreline areas in your municipality? Why? We do not believe that growth should be directed to shoreline areas in Tiny, if “directed” really means “diverted” from inland areas. There is no point in having growth on the shore that is not there for some shoreline-related reason. In Tiny, however, as our new Official Plan points out, much of the growth is expected to occur in shoreline areas, since there is such a large pool of seasonal residences that have been constructed to permanent residence standards and will eventually be occupied, likely by retirees, and there is also a large pool of approved but unoccupied lots in shoreline areas that will take decades to be absorbed. (Note that the new Official Plan’s “Greenbelt” policy and the restriction of new shoreline housing to lots already designated for development are constraints in the long term.)

2. What role should the County of Simcoe play in the management and planning of shoreline areas? We do not see any role for the County in managing any shoreline areas. In the event that the County owns some block of shoreline land, it should manage it, but we do not know of any in our area. In planning shoreline areas, the role of the County should be to see that its Official Plan, and those of the area municipalities, contain adequate provisions for the protection of the environment of the area, and the health of the residents. Protection of natural areas, habitats, ANSIs, and watershed recharge areas is crucial for environmental integrity. The attainment of proper lot sizes for individual water and sewage is vital for health, especially as permanent populations in the sandy shoreline areas increase and use more water-consuming appliances.

3. Are there areas of shoreline in your municipality that are particularly sensitive to development? Yes, there certainly are such areas. The main sensitive area is the entire shoreline from the Nipissing Ridge to the shore of Nottawasaga and Georgian Bay, including those areas defined as being within the Severn Sound watershed. Many of the specific locations within this broad area that are most sensitive have been identified in both your Greenlands Study and the new Tiny OP’s greenbelt area. Spratt Point, an area of distinctive vegetation, wildlife and a significant spawning area, and the extensive dunes in parts of the shore should be rigorously protected.

4. How should the natural environment of the shoreline be protected? We presume that the meaning of this question is “what should the County do”? The County should, as noted above, enforce its own development rules and ensure that the municipalities do likewise. (If, however, this question refers also to the municipality, then several sections of Tiny’s new OP supply answers: “Official Plan Principles: Environment First,” “Land Use Concept,” and the sections under Land Use Designations called “Environmental Protection One” and “Environmental Protection Two” and “Open Space” and “Greenbelt” and “Shoreline.”)

5. Should the conversion of cottages to permanent homes be controlled? How? Of course the conversion should be controlled, and by the existing mechanisms of building standards and health inspections of water and sewage systems. Bear in mind that many “cottages” are constructed to high standards already. Those that are not should be subject to inspection when building permits are required, or when specific problems arise.

6. Is the inland expansion of cottage developments a good thing? In Tiny, many areas have had multiple tiers of cottages for many decades. In some cases, such developments were approved more recently. Note that the “Greenbelt” section of Tiny’s new Official Plan defines the limits of shoreline development below the Nipissing Ridge to ensure that the band of wooded property between the Shoreline and the Ridge remains primarily as a natural area. There is nothing inherently wrong with multi-tier development, which when done creatively, can enable a larger number of families to enjoy the shoreline. But in future, the new Tiny OP says that such development must occur on already approved lots of record. The main factor to consider here is, we believe, whether the overall development - shoreline and inland tiers - follows a sound plan. The plan must provide for shoreline access for ‘back lots’ as well as sound development respecting the environment. Minimum lot size and other provisions of the new Tiny OP must be strictly respected.

7. Should higher density cottage areas be allowed to develop like villages, with commercial and non residential development and sewer and water services? NO. Such developments should occur only in those larger centres that want, and can handle them without adverse impacts on the environment (see q. 10).

8. Should better public access to the shoreline be a goal of the County? The question of “better public access” must be defined as to who gains “better” access, and of what kind, before the County should consider taking any role in this matter. The public access to Simcoe County shorelines must respect private ownership, just as it does in Georgian Bay and Muskoka Lakes Townships and all other cottage areas we know of.

9. What level of sewer and water services should be provided in cottage areas? Piped water and sewer systems as in cities are ideals that are literally “pipedreams” in cottage country. About 25-30 years ago the Provincial government directed that subdivision development could not proceed without a central water system for the subdivision. Most of these have now been dedicated to the Municipality and thus Tiny has come to have the largest number of municipal water systems of any municipality in Ontario! New development should only occur where lot size and character are appropriate to accommodate individual water and sewer systems. That is essentially what the new Tiny OP says, and we support it.

10. How should proposals for major shoreline developments, such as marinas and condominium housing, be treated? They should be treated as any other development proposal in the given urban municipality that wants them and can handle them without adverse impacts on the environment. They should be banned in other areas, such as is the case in Tiny, under its old and new OPs.

11. How should the character of established shoreline areas be protected from incompatible development? What do you consider to be incompatible development? We consider ‘incompatible development’ to be the items mentioned in question 10, plus new residential development that does not conform to the requirements of the new Tiny OP. Such development should be banned except in the case of urban municipalities that want and can handle them.

12. How should shoreline areas in urban areas be treated in terms of land use? Such municipalities should have strong Official Plan policies and requirements to ensure that shoreline land uses do not have an adverse impact on the water bodies on which they front. In particular, there should be no possibility of destroying fish habitats without replacement, no increased discharge of storm water runoff, and no potential runoff of pesticides or nutrients into the water bodies. It would be desirable if some form of design control, perhaps by requiring a secondary plan in all cases of waterfront development, were available to ensure that community aesthetic and amenity values were respected and enhanced. It would also be desirable if adequate public waterfront parkland were preserved for residents.

We hope that these responses will be helpful to you in your study, and we wish to be kept informed of any further developments.

Please contact the undersigned should you wish to have any further elaboration on any of these points. Thank you for the opportunity to make our views known to you.”