COMMENTS ON GREY HIGHLANDS 2024/5 MASTER SERVICING PLAN UPDATE

Comments on Grey Highlands 2024/5 Master Servicing Plan Update

February 10, 2025

Escarpment Corridor Alliance is a registered charity with a mandate to preserve a core part of the Niagara Escarpment across South 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.

We provide the following comments on the recommended alternatives as set out in the memo to the Municipality of Grey Highlands (“MGH”) by its consultants dated December 27, 2024.

Kimberley Amik Talisman (KAT) Water and Wastewater Systems

We recommend that MGH exclude from the Master Servicing Plan any consideration of the two proposed large-scale developments of the defunct Talisman ski hill lands which are at the early stages of the regulatory process in any alternative adopted for the KAT Water System and Wastewater System for the following reasons:

1. Existing System Adequate for Current Users: 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.

2. Consistent with Council Direction: This option is consistent with the resolution of MGH Council which specifically directed the consultants to not consider the subdivision application by Beaver Valley Development Group for the defunct Talisman golf course lands.

3. 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? These funds should be used to benefit the Markdale community and its growing needs. Worse yet, the cost might be paid for by all taxpayers out of general MGH funds.

4. Developers Can Request Developer Funded Studies At Any Time: If the high level development concepts are approved in the future and the developers have finalized their plans and determined 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.

5. Development Applications are Very Early Stage – Will Not Be Finalized Until After the 5- Year Plan Horizon: There are now two development applications for large scale developments at the former Talisman Ski Resort. Both are speculative and at the very preliminary stages of the approval process for any actual new housing or commercial buildings requiring servicing. Neither development is likely to obtain approval for actual development requiring a major expansion for the KAT water and sewage system within the 5-year planning horizon of the study. Rather, both are the very preliminary zoning applications needed to create the foundation for further applications for actual developments. For example, MGH planning staff have recently recommended a deferral of consideration of the zoning bylaw amendment proposed by the application as many of the reports filed by the applicant are incomplete and need revision.

6. Size of Developments Unknown and Is Speculative: 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.

7. Lands Are in Niagara Escarpment Plan Area – Very Different Process Than a Routine Subdivision Approval: 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 (NEP or the Plan), which, as a provincial land use plan, 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.

8. NEC Comments – Proposals Are Not Permitted by Plan: Based on the preliminary comments from the Niagara Escarpment Commission (NEC), it is clear that the two developments, as proposed, are unlikely to be approved because they are not consistent with the Plan and its strict requirements for the use and development of Escarpment Recreation Area lands. The NEC has stated that both developers are required to make application to the NEC for Development Permits. This begins a lengthy and very thorough review process that must be completed before the County or MGH can make any decisions on the planning applications before them. Any decision by the NEC is appealable by residents and community groups, potentially adding many months or even years to the approval process. To date, neither developer has made an application to the NEC and it is not known if they intend to do so.

9. Massive New System with Current Environmental Protections Would be Required: The current system has limited excess capacity and was designed in the 1970’s for the now closed Talisman Hotel operation (about 100 rooms) and the Amik subdivision. The two

proposed developments of 800 hotel rooms, the largest outdoor Nordic spa in North America and over 370 townhomes would require a new water and wastewater system to be built. Combined, as a potential new Minor Urban Centre in the NEP, this would require systems of approximately the size of the current Markdale systems. There is no valid approval to expand the KAT wastewater system and the approval obtained a number of years ago would not be approved by the Ministry of Environment again (as per its comments on the 2017 Master Servicing Plan). 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 seems unlikely for the 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.

10. 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.

Thank you for the opportunity to submit comments on this crucial matter.

Sincerely,