A Pressing Matter: The Proposed Expansion of the Lovesick Lake Trailer Park

In early February 2024 Environment Council sent the following letter to Peterborough County, Selwyn Township and ORCA, and shared it with the lake associations.

 

Re:  Application for Official Plan Amendment (File No. 15OP-22011) and Application for Zoning By-law Amendment (File No. C-14-20)

 

Further to our letter of November 22, 2022, we are writing in support of the Lovesick Lake Association and its Preservation Committee regarding the above Applications, and to draw to your attention our own continuing concerns about the proposed new trailer park development. 

 

The Environment Council is a volunteer, not-for-profit organization dedicated to protecting the health of our lakes and surrounding natural environment.  We are supported in this work by seven local lake associations and several partner organizations.  Our membership includes representatives from the associations and from the four municipalities having jurisdiction on Clear, Stoney and White Lakes.

 

Having reviewed the updated submission from the proponent, pertinent attached correspondence and the 2020 Environmental Impact Statement (EIS), we remain concerned that there has not been adequate study of the impacts on the shoreline and lake of the proposed 38 to 40 new trailer sites on top of the escarpment, particularly the direct human impacts of the occupants.

 

Most notably, there is no indication that the Capacity Study called for during the August 21, 2017 pre-consultation meeting has been initiated or carried out.  ORCA has asked for the status of this study more than once, but no satisfactory response is evident in the application documentation.

As stated by MECP in the Agency Comments included in the updated submission, Lovesick Lake does not meet Provincial Water Quality Objectives regarding phosphorus, the lake “shall not be degraded further” and total phosphorus must be reduced.  

 

High total phosphorus (TP) concentrations are regularly recorded in Lovesick Lake and immediately downstream in the Burleigh Channel of Stony Lake.  Concerns about high boating traffic in Lovesick Lake and parts of Stony Lake, and the need for protection of shorelines, were identified by TSW as far back as 1991.  TSW recently reported a five-year average of 6,530 boats at the Burleigh lock and 6,581 at the Lovesick lock.  

 

Therefore, it is essential that Lakeshore Capacity and Lake Carrying Capacity assessments be carried out and their findings carefully considered as part of the Application review process.  The 2017 pre-consultation meeting called for a Capacity Study to be submitted as part of a complete Application, as required by the Provincial Policy Statement (Section 2.2.1) and the Growth Plan for the Greater Golden Horseshoe (Section 4.2.4.5c).

 

Municipalities have authority under the PPS to require such studies as part of resort development proposals, and we urge Selwyn Township and Peterborough County to require that these essential studies be provided by the Applicant.  There is sufficient existing MECP and “citizen science” data to indicate that professional study is warranted.  Guidance is provided by MECP handbooks and modelling on Lakeshore Capacity Assessment and Lake Carrying Capacity; and advice on study scoping should be sought from ORCA and other appropriate authorities. 

 

We note that the September 28, 2020 Environmental Impact Statement and the November 27, 2023 EIS Addendum do not provide any description of the current state of the shoreline and near-shore waters of the existing trailer park (previously Stricker’s Resort) below the escarpment.  No data or illustration is given as to the length of shoreline, what parts of it are vegetated or degraded, how much of the area within 30 metres of the shore is taken up by existing trailers and other structures, or what in-water structures, boat launches, etc. exist.  Nor do these reports contain any assessment of the direct impacts that an additional 40 new trailer occupants would have on shoreline areas and near-shore waters.

 

The EIS does recommend a shoreline enhancement plan, and we agree that shoreline restoration and enhancement should be undertaken at every opportunity, whether on this property or elsewhere.  But given the presence of at least two dozen existing trailers and structures within 30m of the shore (see satellite image appended to 2020 EIS, p. 53), the beach, and docking for 82 boats, we do not see how the shoreline “enhancement” recommendations in the EIS could effectively mitigate the direct human impacts of the existing trailer park occupants, even without additional impacts from another 40 new trailer occupants, their families and guests.

 

A thorough assessment, as described above, should be required of the Applicant, and the shoreline enhancement plan recommended in the EIS should be developed now and made a condition of approval of the Application.

We are encouraged to see in the updated submission that the Applicant plans to upgrade the existing septic system below the escarpment, and we urge the Township to require that these upgrades be made immediately, independent of the approval process for the new trailer park Application.  This is essential, given the high phosphorus levels recorded in Lovesick Lake and the Burleigh Channel, and the damage that excessive phosphorus levels cause to the lake ecosystem by “fertilizing” the growth of algae and invasive aquatic plants, and depleting dissolved oxygen. 

  

We urge the County and Township to act on the issues we have raised, and not to proceed with the approvals process for the OPA and ZBA Applications until the necessary capacity assessments have been completed.  We do not find that “need” for this development has been demonstrated, as required for an Official Plan Amendment, and there is no evidence of community support for it.  We believe that any possible benefits are outweighed by the potential negative impacts on the lake environment. 

 

Please continue to notify us of all significant steps in the consideration of these applications, particularly receipt of the peer review of the EIS and Addendum, the statutory public meeting, and any County and/or Township Council meeting agenda items regarding this matter.  We would also greatly appreciate you forwarding this letter to the peer reviewer of the EIS and Addendum, and to the appropriate contact at TSW.

 

Thank you for your attention.

 

Lois Wallace

Executive Member, Environment Council for Clear, Ston(e)y and White Lakes