Comments on the Draft Official Plan (April, 2019) of Loyalist Township by the Friends of Wilton Creek Watersheds

Comments on the

Draft Official Plan (April, 2019)

of Loyalist Township

by the Friends of Wilton Creek Watersheds


The Friends of Wilton Creek Watersheds (FWCW) applaud the Draft Official Plan (2019) of Loyalist Township because it recognizes the environmental values important to the Township’s landscape, health and well-being, addressing current and future climate change challenges (2.1.9) and developing land use policies “to ensure an orderly and environmentally sensitive pattern of development and redevelopment” (2.1).


We have concern that in this Draft and the present Official Plan, mention is made that “when detailed mapping becomes available…” Then we are presented with Schedule J, Select Bedrock Overlay as prepared by the Loyalist Township Planning Department on April 2, 2019 which, to us, is confusing, inaccurate and unwelcome. We encourage the Township to take action to produce detailed, accurate mapping of the Township as soon as possible to help its politicians and planners make important decisions and ratepayers understand the basis for their decisions.


Water: Parts 4, 5 and 6

One of the Official Plan’s most important pages is Schedule K, a map provided by the Cataraqui Region Conservation Authority: Significant Groundwater Recharge-Vulnerable Aquifer Overlay showing the vulnerable aquifers in this area of limestone, much of which is karstic. Every summer numerous wells and cisterns in the rural part of the Township run dry and need to be filled with water trucked in from municipal supply points. Part 4: Growth Management recommends that new wells be drilled to avoid damage to the substrate from blasting or digging. In addition, Part 6.3.5 (h) discourages dug and blasted wells where a drilled well is not feasible. When blasting is used to create a new well there can be substantial damage to underground aquifers resulting in existing wells going dry or their loss of quantity and quality. We recommend that the Township use stronger language and either ban blasting or impose tighter restrictions on this practice that is often attractive to new rural homeowners by being less expensive than drilling. New owners are often unaware of the environmental consequences of each method.

FWCW are pleased to see that the Official Plan recognizes watershed management. Water in the township drains to Hay Bay from Wilton Creek and its sub-watersheds. It also drains to Lake Ontario through Millhaven Creek, which has one of the best wildlife areas in the Township, near Mud/Odessa Lake.

Millhaven Creek management necessitates cooperation with the City of Kingston and the Cataraqui Conservation Authority, while the Wilton Creek watershed works with South Frontenac, Greater Napanee and Quinte Conservation. Its end in Hay Bay means that the Wilton Creek Watershed is a part of the Bay of Quinte Remedial Action Program (BQRAP) that has worked since the 1960s to have water in Hay Bay, as in the rest of the Bay of Quinte, that is drinkable, in which people can swim, and from which the fish can be eaten.

When the Friends of Wilton Creek Watershed was founded this spring its members were shocked to find that our watershed receives a poor rating from the Cataraqui Region Conservation Authority (2018), scoring as “poor condition” in the quality of its ground water, its wetlands and its forests and only scoring “fair” in surface water quality. The Friends will seek to improve future conditions when and where possible. (See also 6.4.1, 6.4.2, 6.4.3 and 6.4.4.)

In Part the area of Wilton Creek Valley at Camden Braes, 401, County Road 4, Sharpe Road and Maple Road is proposed as a site for light industry. (See attached satellite image X.) Our reasons for not supporting light industry in this area include:

  • Runoff into the creek would be increased, from the main roads, from the commuter parking lot off 401, from the ONRoute, from Camden Braes Golf Club and from any new industry allowed in the area. Water quality would likely be adversely affected, as it was in a similar scenario in Kingston in an intensively studied branch of Collins Creek (immediately south of the Cataraqui Shopping Centre beside Gardiner’s Road). BQRAP aims for less runoff.
  • The area is already subject to heavy use of ground water because of the ONRoute and Camden Braes Golf Club. It is also subject to problems of waste disposal, especially at times of heavy 401 traffic.
  • Traffic in the area from 401, County Road 4, Sharpe Road, Maple Road and the parking lot (off 401) is already complex.
  • A marsh south of Sharpe Road, recognized as a breeding bird marsh by Ducks Unlimited, would be affected by changes in water quality or flow, destroying bird habitat
  • Camden Braes Resort plans expansion and tourism would be enhanced by pastoral surroundings, rather than an industrial view. The Township’s industrial park near County Road 6 and Taylor Kidd Boulevard would be better suited for light industry zoning.
  • Possible flooding due to climate change needs to be considered in both areas suggested as sites for light industry. (

A lack of watershed planning in the past has allowed development of housing along the courses of creeks, which are often also the line of roads and hydro lines. Both wells and septic systems are also concentrated along these lines. The Township has insisted on a somewhat large acreage for new severed lots, but it has ignored the grouping of new wells and septic systems linearly described above. (See attached map Y as a typical example of a linear pattern). We suggest that climate change now presents a hazard where this pattern occurs. The septic systems could become overloaded and leak during frequent, very wet periods. (Think of the Muskoka area this last spring.) Bacterial contamination could spread to neighboring wells and into the creek by flow down the sides of the valley.


Land: Parts 4 and 5

Environmentally sensitive areas and environmental protection areas are listed. We welcome this extended list in the Draft Official Plan of 2019. Schedules A, C, D and E include environmentally protected areas, ANSIs, significant provincial wetlands, all other MNRF evaluated wetlands, significant habitat of threatened or endangered species, fish habitat, lands with hazards such as poor drainage, organic soil, steep slopes, dynamic beaches and areas subject to flooding or erosion. In lists of sensitive areas unevaluated wetlands and woodlands are now included, as are groundwater exchange and discharge areas and significant valley lands. Wisely, soil conservation is recommended. We look forward to future maps and definitions from the Township, for example for sites and terms such as “unevaluated wetlands”.

We believe the Official Plan’s language should give greater or better protection for environmentally sensitive areas. The present language seems to demand proof that a development has caused damage, rather than trying to forestall or prevent any environmental damage.

Part states that the Township does not have to protect an environmentally sensitive area if protection is too expensive, and that such areas can also be re-designated. What exactly is “too expensive” and who decides? While states that sensitive areas can be in parks, Part 7.4.2. states than they cannot. Should such areas be considered individually? We believe the acquisition of parkland (Part 10.15) does not need to be tied to any residential development.

ANSIs. Areas of Natural and Scientific Interest

In the 1960s the Ontario Ministry of Natural Resources and Fisheries (MNRF) designated and mapped two ANSIs in the Township — Camden East (including Thorpe) and Asselstine. They are alvars, sensitive areas on limestone or dolostone, with thin soils which may be lacking in places, subject to droughts and flooding and with a characteristic assemblage of plants and invertebrates. See. Crowder, A., H. Knack and T. Norris. 2006: A multispecies recovery strategy for the Alvar Ecosystems of the Napanee – Prince Edward Plain in southeastern Ontario. This MNRF report identified 50 sites of which Loyalist Township has 5, with Camden East and Asselstine rated highly. A conservation area of about 100 acres has generously been created in Camden East by Loyalist Township, Lennox & Addington Stewardship Council and the Nature Conservancy of Canada (NCC) this year. It is now owned and managed by the NCC. The alvars contain rock pavements, sedge-grass meadows, shrublands, savannas with red cedars and some very dry treed barrens.


Alvars should be listed in Parts 4.2.2, 5.2.1 and 5.2.2 as well as Schedule E1. They are recognized in as habitat for grassland birds and are not “idle lands”.

The current state of Asselstine Alvar is threatened because ATVs and other vehicles have been allowed to drive over it, killing plants. Despite its private ownership, may we draw the attention of the Township to its importance in relation to the plans for Odessa (see Schedules E and E1) because:

  • The ANSI, by definition, needs protection
  • Sites of mills and houses are of historical interest
  • The right-of-way from Odessa to Caton Road is a favourite walking route
  • The shore of Millhaven Creek is attractive and needs protection
  • Open space needs to be preserved. (

Wildlife corridors win popular approval, but the potential corridor shown on Schedule C1 might require funding for bridges or overpasses to allow deer and other animals across County Road 6, then the CN line, and then Taylor Kidd Boulevard.

Designation of Prime Agricultural Land, Agricultural Land and Rural Land:

In Part 5.3 Resource Lands Policies, section 5.3.2 Prime Agricultural Area notes “it is the intent of this Plan to preserve prime agricultural areas to ensure its availability for food production on a long-term basis by protecting it from incompatible uses.” The Provincial Policy Statement defines prime agricultural areas as those where prime agricultural lands predominate, which includes specialty crop areas and/or land where Canada Land Inventory Class 1, 2 and 3 lands exist.” However, this draft Official Plan now includes with this category of Prime Agricultural Areas: a) associated Canada Land Inventory Class 4 through 7 lands; and b) additional areas where there is a local concentration of farms which exhibit characteristics of ongoing viable agriculture. No mention of these added categories is made in Part 10.22.39.

We think the Township should amend Part 10.22.39 definition to include a) associated Canada Land Inventory Class 4 through 7 lands; and b) additional areas where there is a local concentration of farms.


The Plan has many lands designated as Rural, not Prime Agricultural, whereon long-established, historical farming operations and hobby farming occur. These rural agricultural lands are not well protected from “incompatible” uses such as residential severances, light industry and aggregate operations. We encourage the Township to recognize and protect these important rural lands.



In Part and Schedule ‘J’ Bedrock Resource Areas, it is indicated that most of Loyalist Township lies within an area of high potential for bedrock extraction with only two exceptions: 1) Settlement areas and 2) Rural Clusters (groupings of 4-6+ residential and other non-agricultural units).


We believe that agricultural areas should also be excluded from bedrock extraction, and the Official Plan should recognize the importance of agriculture by adding this exception. This harmonizes well with another section of the Official Plan, Part, Resource Management Objectives: “To strengthen the agricultural function through land use policies which protect farmlands from incompatible uses and from the fragmentation of ownership of the land base into uneconomic units.”

Application of Policies

In Part, under d) of this section, VII the wording states that “the Township may waive the requirement for a study/assessment provided they are satisfied of the following: “The nature and location of any sensitive surface water and ground water features in the area and its impact on mineral aggregate operations.” It appears to us that the Township is giving more value to water needs for aggregate extraction than to the sensitive surface or ground water itself. Or perhaps, it is more worried about how water might adversely affect an aggregate operation than to the water supply of nearby homes and farms. No waivers of studies or assessments of potential damage to the environment should be given.


Rural Policy Area

Part 5.5 states that “rural lands are defined as lands which are located outside settlement areas and are outside prime agricultural areas”. Within the Rural designation there are agricultural activities, but they tend to be dispersed. Use of lands for these purposes (residential, seasonal residential and other non-farm uses) is desirable as long as it takes place within a planning framework.”


However, Part 6.4.8 Soil Preservation states: “Soil is a valuable resource in the municipality as evidenced by the ongoing viable agricultural activity”.


It is our assertion that there are areas within the rural designation that have many long-term, productive farms in operation and cannot be described as “dispersed”. This terminology gives the sense that the rural area of the Township is merely dotted with rural residences and an occasional farm that is not very productive. This is not an accurate reflection of our rural area and fails to recognize land use on improved soil for locally grown produce (organic or not) and an increasing demand for such produce. Is the Plan stating that Township soil is a valuable resource only if it exists in the areas currently designated as Prime Agricultural Land? We see confusion in the Official Plan as to what constitutes agricultural lands, viable agricultural activity and lands with high agricultural capabilities.


In order to deal with this confusion, we recommend that the Township create an inventory of the active farms in the “rural” areas and assign definitions to each property after an actual “feet-on-the-ground” survey to clearly identify agricultural lands, viable agricultural activity and lands with high agricultural capabilities (


Permitted Uses

In Part 5.5.2, the Plan states that within the Rural designation, “the predominant use of the land shall be for agricultural, conservation, forestry, public and private recreation”.


The Official Plan notes that there is pressure on the Township to allow more severances in the rural areas. If the Township grants more rural severances, it will become more difficult to uphold the predominant use of the land for agriculture, conservation, forestry and recreation. This could also result in more demands on the Township to provide services to these areas with higher concentrations of residential dwellings, conflicts between farms and individuals who just wish to live on a small property in the rural area, increased traffic on the rural roads and conflict between land use priorities. (See also page 2 of this report and Map Y.)


Environmental Management: Part 6.4


The Bay of Quinte Remedial Action Plan (BQRAP)

Part 6.4.2: We applaud the Township for supporting the BQRAP. It demonstrates an awareness of the importance of our water systems and watersheds to the overall health of our environment and our communities. Perhaps this part could include a statement about ensuring that contamination from septic systems does not occur, just as stated in 6.4.3 Stormwater Management to prevent a negative impact on the Bay of Quinte.



Part 6.4.6 The Township is demonstrating very forward thinking in supporting and encouraging forestry as a use of land. The Official Plan could enhance this section further by including a statement of the importance of forests and tree planting to the broader Climate Change challenges of lowering C02 emissions.


Recreation: Part 7.1

The Council does an excellent job in providing facilities for many kinds of recreation and sometimes the facilities are provided to channel an activity into an area where it is welcome and is not irritating to neighbours. Greater Napanee has an example of such a facility in its skateboard park.

The activities of ATV enthusiasts give the riders pleasure, but they also damage some land, often not owned by the riders. Such areas need protection because they are sensitive or environmentally important. An example of such an area it the alvar grassland and shrubland lying parallel to Highway 6 south of Odessa, which is part of Asselstine ANSI. In the spring of 2019 this area of significant vegetation looked like a ploughed field. We suggest that the Township consider providing ATV enthusiasts with areas devoted to their sport where they can race, have water jumps, etc. — an ATV Park.


Implementation and Interpretation: Part 10

Part 10.22.30. This definition should be expanded beyond fruit or fruit juice used in the production of wine. With the increase of organic farms across the township and/or farms selling their produce and livestock as “locally grown” the Township needs to include some definition that recognizes these products. Increasing numbers of farmers’ markets demonstrate the popularity of food that is grown locally.


Noticed Errors or Omissions

  • Page 56-57, A paragraph in (d) is repeated verbatim in (e). Is this an error or intentional for emphasis?
  • Page 90, Part 5.6.1: The Official Plan directs the reader to “urban settlement area as outlined in Part 5.6 below.” This should read “urban settlement area as outlined in Part 5.7. The rural settlement area is outlined in Part 5.8”.
  • Page 124, Part 6.7: There is no item iii). Is anything missing or is there an error in numbering?


Respectfully submitted for Friends of Wilton Creek Watersheds (FWCW),

Laurie Davey-Quantick, President


Adèle Crowder, Founder,

Liaison, Lennox & Addington Stewardship Council


Jane McDonald, Secretary/Publicity

Map X

The area proposed for light industry in Part showing Camden Braes Resort, Wilton Creek, the ONRoute and Ducks Unlimited Marsh




Map Y

A portion of the Wilton Creek Watersheds. Yellow dots are civic addresses. Each is likely to have at least one well and one septic tank. Note the linear pattern of these wells and septic tanks along the sides of the Valley.



Notice of Pesticide Use for Roadside Weed Control 2018

The County of Lennox & Addington will again be doing spray applications of pesticide to control noxious weeds (especially Wild Parsnip) along some rural roadsides.

The 2018 roadside spraying is scheduled to commence on June 04, and at least one other day, likely June 11.

For full info, see

County office: 613-354-4883

No Roadside Spraying Agreements

There are “No Roadside Spraying Program Agreements” available for this year – if you want your property not to be sprayed.

If you wish to sign the Agreement, you need to go to the county office at 97 Thomas Street East in
Napanee. They are located in the basement office.

If you elect to sign the Agreement, please remember to bring a birds eye view/satellite image of your property with the boundary markings as well as your Tax Roll number and legal property description (e.g., RR#/Concession Rd., Lot #, Part#).

Well and Septic Event…Download Workbook

Quinte Conservation’s Maya Navrot showing the flow of contamination in groundwater

On January 15 in Napanee, the Lennox & Addington Stewardship Council (and partners) brought together a range of knowledgeable speakers to share their learnings and best practices about well and septic systems with homeowners. More than 280 people attended this very interactive and successful evening!

The Groundwater Protection Workbook was developed for local landowners as a property-specific self-assessment tool to understand risks to groundwater on their property.

We now have the 40-page Workbook available online at the following link:


Large file (8 MB) – have a cup of tea!

​ The hard copy is not yet available. We will keep you informed of the progress.


Feel free to also download these Speaker Presentations:

1/  Cataraqui Region Conservation Authority

CRCA_Groundwater Vulnerability with notes

Holly Evans, Watershed Planning Coordinator and Katrina Furlanetto, Source Protection Coordinator

  • Groundwater vulnerability, unique features of our region
  • Groundwater Protection Workbook







2/  Ministry of the Environment and Climate Change 

Warren Lusk, Natalie Spina, and Andrew Mobberley

MOECC Well Construction, Maintenance & Abandonment

  • Ontario Wells Program
  • Well construction and maintenance







3/  KFL&A Public Health

Gordon Mitchell, Public Health Inspector

KFLA Public Health. On-site Sewage Disposal_A Primer

  • Set-up of a standard septic system
  • Maintenance
  • Alternative technologies









4/  Public Health Ontario

Dr. Anna Majury

PHO. Research on environmental health and microbiology with a focus on water

Basics of water sample collection and testing

Water-borne disease in Canada

PowerPoint presentation in PDF format (6.1 mb) Public Health Ontario_Private Drinking Water_17.04.18

5/ Quinte Conservation

Groundwater Monitoring

Lynette Lambert, Watershed Monitoring Coordinator, Quinte Conservation

Monitoring Programs throughout the Quinte watershed

Water Quantity

Water Quality

PowerPoint presentation in PDF format (1.7 mb) Quinte CA Monitoring – Jan 2018


Groundwater Protection Workbook will be available soon.

Monarch Breeding Kits for Schools Project 2017

Monarch butterflies will again be experienced first-hand in 15 elementary schools in Lennox & Addington County this fall.

Monarch butterfly

The Monarch butterfly population is dwindling and all of our pollinators need help. The pilot project began in 2015 when 20 Monarch kits were supplied to 13 elementary schools in L&A County. Students and teachers have been thrilled to witness the entire life cycle of the Monarch from caterpillar to adult.

Monarch Breeding Kit

Monarch Breeding Kit

From a local classroom teacher, on the Monarch 2015 program:
This experience was incredible for my Grade One students.  We hit so many areas of the curriculum while studying our monarch friends, BUT the best part was the wonder that we saw in our children and just how fantastic it was to see the changes from each stage of a butterfly’s life first-hand.  They treated the butterflies with care and respect and felt like they were helping our world by protecting them.  Amazing!

Nine schools planted gardens in 2016 to help attract pollinators of all kinds: butterflies, birds and insects.

J.J. O'Neill school kids with aviary

J.J. O’Neill school kids with aviary

Partners are essential to our program. Maya Navrot, Educational Outreach leader at Quinte Conservation, will again assist schools with advice on native plantings. Funding for this program has been gratefully received from the Napanee District Community Foundation, as well as the contributions from participating schools.

Monarch in classroom

Monarch in classroom

For more information, contact Marilyn Murray, manager of the Monarch program, at

​Lyme disease: get ticked off

Ticks that can cause Lyme disease are muscling in on greater Kingston and Lennox & Addington areas. The last few years have seen a big increase in tick populations here. A local vet cites 169 reported cases of Lyme disease in pets in Lennox & Addington County over the last 5 years. And, there are all the unreported cases…

Black Legged Tick

On April 25 in Napanee, the Lennox & Addington Stewardship Council hosted a presentation on Ticks and Lyme disease with Dr. Andrew Peregrine, a welcome authority on the topic.

Please watch this video as it shows how to identify and protect yourself.


Lyme disease is an infection transmitted by the bite of an infected tick: in Ontario, the offender is the blacklegged (or deer) tick. Ticks that carry the bacteria, Borrelia< burgdorferi, may convey the infection to people and certain animals.


Dr. Andrew Peregrine (PhD, DVM) has been a professor in clinical parasitology at the Ontario Veterinary College, University of Guelph for 20 years, where he teaches Doctor of Veterinary Medicine students. His research interests include emerging parasitic infections in animals and people.

Dr. Andrew Peregrine

For more information, visit Public Health at or the Canadian Lyme Disease Foundation at