Please find below the comments of Escarpment Corridor Alliance on the Grey Highlands Master Servicing Study.
Comments on Grey Highlands 2024/5 Master Servicing Plan Update August 25, 2025
TO: Shawn Moyer, Director of Environmental Services at [email protected] GEI Consultants at [email protected]
We provide the following comments on the recommended alternatives as set out in the proposed Water and Wastewater Master Servicing Plan presented to the Council of the Municipality of Grey Highlands (“MGH”) by its consultants on August 6, 2025.
General
We agree with the general approach to delay further studies proposed for the systems in Markdale and Flesherton. Given the current economic environment, there is no need to expand these systems for some time and there is ample available supply in these systems for the developments that are likely to be proceeded within Markdale.
Kimberley Amik Talisman (KAT) Water and Wastewater Systems
We recommend that MGH take the same approach for the KAT system and not spend any public funds on studies to expand the systems at this time as any expansion study would also be premature.
The existing KAT water and wastewater systems are adequate for the current users and any likely additional Kimberley or Amik residential users in the next number of years. Other than the two Talisman proposed development projects, there is no known added demand for the systems.
The proposed Master Servicing Plan assumes for KAT that the two proposed large-scale developments of the defunct Talisman ski hill lands are reasonably likely to be proceeded with by the developers within the time horizon of the Plan. This is a faulty assumption as each of these proposals are in the early stages of an unusually complex regulatory process and the proposals are at a very high level.
While it may be the convention to study the capacity required for all development applications made for routine subdivisions (which are generally municipally approved), these lands are within the Niagara Escarpment Plan which, as a provincial land use plan,
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takes precedence and provides the highest level of protection in Ontario. Even in the most optimistic scenarios, these developments are at the very early stages of a highly complex regulatory process. There is no reason to expect that they will require water and sewage capacity in the next five years, being the planning horizon for the Master Servicing Plan.
Neither developer has made any commitment as to what they might build or when or how they may be phased. Rather, both have tabled broad ideas of what they might do in the future. In both cases, they are indicating that other adjacent lands will also be developed but have given no details. Until such plans are committed to by the developers in applications that will be made in a number of years (if ever), it is premature to do any studies on the types and scale of servicing required.
There is very significant doubt that either will be permitted, particularly by the Niagara Escarpment Commission (“NEC”), the highest level of regulator for these lands. NEC staff have been clear that the Niagara Escarpment Plan would require the former Talisman ski hill and golf course to be operational before any added development can occur, and that any added development must be consistent with and scaled to only support the ski hill and golf course. Neither of the proposals meet these requirements and the developers have made it clear that they have no intention of rebuilding the ski hill operation or the golf course.
As to timing, neither developer has applied for the required NEC Development Permits and have made no substantive progress with their MGH and County applications in over a year. From the public records, it appears that both of these projects have been shelved by the developers at least for the foreseeable future.
Given this, absent the developers making firm commitments to move forward and actually doing so, there is no rational reason to assume that these projects will require servicing within the time horizon of the Plan.
Other Comments
We also reiterate our prior comments as follows:
1. Inconsistent with Council Direction: This proposed Plan is inconsistent with the resolution of MGH Council which specifically directed the consultants not to consider the subdivision application by Beaver Valley Development Group for the defunct Talisman golf course lands.
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2. Study Cost Would be Paid for by Current Users and Taxpayers, Not Developers Who Would be the Prime Beneficiaries: There is clearly no need to study an expansion of the KAT systems other than to consider the needs of the two early stage proposed developments. Yet it would be funded either by existing users of all MGH water and sewage systems, or from development charges paid by other developments that should be used for municipal services such as parks or improving other existing systems. Why should development charges paid primarily by Markdale developments be used to benefit these two Talisman developers?
3. Developers Can Request Developer Funded Studies At Any Time: If the development concepts are approved in the future and the developers finalize their plans and determine the number of units and the phasing of development, either or both can request MGH to commission a developer funded study to determine how their identified servicing needs can be met, the cost of the required infrastructure and enter into agreements with MGH to pay the full cost of the new infrastructure. Without having full visibility as to what is to be proposed – rather than what might be – MGH should wait for the developers to firm up their plans, determine through detailed studies the actual water uses of their proposals and ask MGH to undertake a developer funded study.
4. Massive New System with Current Environmental Protections Would be Required: Any study would be expensive and highly complex. The current system was designed in the 1970’s for the now closed Talisman Hotel operation (about 100 rooms) and the Amik subdivision. There is no valid approval to expand the KAT wastewater system, and the approval obtained a number of years ago (but now expired) would not be approved by the Ministry of Environment again (as per its comments on the 2017 Master Servicing Plan). The two proposed developments of 800 hotel rooms, the largest outdoor Nordic spa in North America and over 370 townhomes would require a large new water and wastewater system to be built. Combined, this would require systems of approximately the size of the current Markdale systems. A recent similar (but larger) wastewater system was approved and is about to open in the Town of Erin. The $118 million Erin system was funded by $90 million from the developers who benefited from it who each were required to sign a funding agreement and post an irrevocable letter of credit well in advance of construction. While this system is larger than what would likely be required at Amik, it is clearly not possible for MGH to contemplate a capital investment of this scale and neither of the Talisman developers have demonstrated the financial capacity to pay for a water and wastewater system of the required size.
5. Karst Study Underway: Approval of any option concerning the Talisman lands is premature given the ongoing Grey Sauble Conservation Authority’s Karst Study on the upper escarpment of this property and adjacent lands. Any study now of KAT water servicing, prior to completing this study of its source area, would be a waste of public property taxes and unnecessary duplication.
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Escarpment Corridor Alliance is a registered charity with a mandate to preserve a core part of the Niagara Escarpment across Southern Georgian Bay and to protect it from inappropriate development. ECA represents taxpayers who live, work and enjoy the Niagara Escarpment throughout the Municipality of Grey Highlands, Town of Meaford, Town of The Blue Mountains, Collingwood and throughout Ontario.
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