To: The Ministry of Environment, Conservation & Parks, Ministry of Natural Resources & Forestry, TRCA, City of Toronto, and local Councillors

🛑 STOP THE ROAD – SAVE BALMY BEACH 🛑
A 4-Metre-Wide Road Will Replace Our Beach — Unless We Stop It!
The city is proposing to build a 4.3 km long, 4-metre-wide paved road and multi-use trail stretching from Silver Birch Avenue to Bluffer’s Park — directly along the existing beach.
For over 30 years, Balmy Beach has been a peaceful retreat for families, wildlife, and generations of Torontonians. But now, this rare stretch of natural shoreline is at risk of being paved over — permanently.

 

SEE FULL PROJECT HERE: https://www.toronto.ca/community-people/get-involved/public-consultations/infrastructure-projects/scarborough-bluffs-west-revitalization/

The City of Toronto and TRCA are proposing a massive shoreline construction project called the Scarborough Bluffs West Revitalization. Under this plan, they will build a 4.3 km long, 4-metre-wide paved road and multi-use trail stretching from Silver Birch Avenue to Bluffer’s Park — directly along the existing beach.

To do this, they’ll dump hundreds of thousands of tons of lakefill onto the shoreline — burying and replacing our beach with artificial structures and hardscape. This is not just a trail upgrade. This is a road. A massive, permanent road.

What This Project Will Do:
🚧 Pave a 4-metre-wide corridor where dunes, grasses, and wildlife live

🚧 Threaten the Silver Birch Off-Leash Dog Park, which may be fenced or relocated
🚧 Displace bank swallows, a federally protected Threatened Species, which nest in the soft bluffs and are sensitive to shoreline disturbance
🚧 Ignore Indigenous rights and knowledge — meaningful consultation has not been properly undertaken
🚧 Introduce traffic, erosion, and urban noise to one of the last quiet waterfronts in Toronto
🚧 Move forward without a completed Environmental Assessment despite triggering shoreline alteration and lakefill thresholds
🚧 Greenlight destruction before alternatives are presented — no final design has been released, yet irreversible changes are already in motion

The City and TRCA claim this isn't a “dynamic beach” — but that’s a technical term. In reality, this is a functioning, living beach that protects our shoreline, supports wildlife, and brings joy to thousands of people every year. And it’s about to be destroyed.

ADDITIONALLY THE CITY IS IGNORING: 
1. Endangered Species Act (ESA), 2007 – Bank Swallow Protections
    •    Bank swallows (Riparia riparia) are listed as Threatened under Ontario’s ESA and Schedule 1 of Canada’s Species at Risk Act (SARA).
    •    Their nesting sites cannot be destroyed, altered, or disturbed under the law — even if they are located on engineered or “non-natural” bluffs.
    •    Habitat disruption during breeding season or shoreline construction that prevents nesting could constitute a legal violation unless an ESA permit is issued — which should not be granted lightly.
→ The presence of bank swallow colonies near or within the study area is reason enough to require species-specific studies and a permit review under the ESA and SARA.
Participation
    •    Ontario law (EA Act, R.S.O. 1990, c. E.18) requires:
    ◦    Evaluation of reasonable alternatives
    ◦    Early and meaningful public engagement
    ◦    Identification of preferred options with rationale
    •    This EA has no detailed concepts or costed alternatives yet, but the City is soliciting feedback as though a decision is near.
    •    This undermines procedural fairness and may render the Terms of Reference incomplete or non-compliant.
3. Provincial Policy Statement (PPS), 2020 – Natural Heritage and Shoreline Development
    •    Section 2.1 of the PPS mandates:
    ◦    Protection of significant wildlife habitat
    ◦    Conservation of shoreline ecosystems
    ◦    Prevention of development that negatively impacts natural features
    •    Using lakefill to bury existing beaches may contravene these policies, especially without proof that less intrusive alternatives were considered.
→ The City and TRCA have not demonstrated that road construction is the only way to prevent erosion or improve access.
4. Lack of Free, Prior, and Informed Consent (FPIC) – Indigenous Rights Obligations
    •    Under both Canadian constitutional law (Section 35) and international commitments like the UN Declaration on the Rights of Indigenous Peoples (UNDRIP) (which Ontario has committed to implement), the Crown has a duty to:
    ◦    Consult Indigenous communities early
    ◦    Accommodate their concerns
    ◦    Avoid development on culturally significant lands without consent
    •    Archaeological evidence shows human use of the Bluffs for 10,000+ years. If this area includes burial grounds, hunting lands, or cultural heritage sites, duty to consult is engaged.
→ The City admits that consultation has only “begun” — this may not meet the legal standard.
5. Precedent: Stopped or Modified Projects Due to Shoreline and Wildlife Impact
    •    Hanlan’s Point Beach (Toronto) – public backlash led to project revision due to threat to naturalized waterfront
    •    Big Island Wetland Complex (Prince Edward County) – projects delayed due to protected habitat
    •    Port Weller (Niagara) – shoreline access plan rejected partly over bank swallow colony disturbance
→ These show the province has precedent to intervene when public shoreline and species at risk are at stake.

⚠️ What the Ministry of Natural Resources & Forestry Must Investigate:
We urge the Ministry of Natural Resources and Forestry (MNRF) and the Ministry of Environment, Conservation & Parks (MECP) to halt this project based on:
    •    Presence of Bank Swallows, a Threatened species under the Endangered Species Act, nesting in the project area. Construction may violate habitat protections.
    •    Potential impact to aquatic and terrestrial Species at Risk identified in TRCA’s own Biological Inventory (2017).
    •    Incomplete Indigenous consultation: While the City claims engagement has occurred, many Indigenous voices have not been adequately included.
    •    Violation of Provincial shoreline policy: Lake Ontario’s shore is a protected natural heritage system. Lakefill, seawalls, and groynes are not the only erosion control methods.
    •    Lack of completed Environmental Assessment: No final alternatives have been shared. Public feedback is being sought before options are presented, rendering it meaningless.
    •    No funding secured for construction: This project is not inevitable. It can still be stopped.

.
They call it revitalization. But make no mistake:
This is not a trail upgrade. This is a road. A massive, permanent road.
TRCA already uses erosion control structures like groynes and revetments to manage the shoreline. These tools can continue to be used — without adding a road or destroying the beach.
The City of Toronto claims this area is not a “dynamic beach” — but that’s a technical loophole. These are real beaches, used by real people, with sand, wildlife, and beauty that can’t be replicated once they’re gone.

📆 ACT BEFORE JULY 20, 2025
The Environmental Assessment Terms of Reference is open for public comment until July 20, 2025. This is your chance to speak up before it’s too late.
✉️ Send your concerns directly:
Stephen Deneault
Project Officer, Ministry of Environment, Conservation & Parks
📩 Stephen.Deneault@ontario.ca
✅ We Are Calling On:
    •    The Ministry of Natural Resources & Forestry
    •    The Ministry of Environment, Conservation & Parks (MECP)
    •    The City of Toronto and TRCA
    •    Toronto City Council and local Councillor Brad Bradford
    •    Mayor Olivia Chow
To:
    1    Pause the project immediately
    2    Deny approval of the Terms of Reference
    3    Require independent environmental and species-at-risk impact studies
    4    Mandate Indigenous engagement before decisions move forward
    5    Explore ways to preserve the bluffs that do not destroy our waterfront and cost over 150 MILLION.

If you’ve ever walked this beach, felt peace in the wind off the lake, or watched a bird disappear into the Bluffs — you know this place matters.
Don’t let it be paved over in the name of access.
📢 STOP THE ROAD. SAVE THE BEACH. PROTECT BALMY BEACH.
✍️ Sign the petition today. Let’s show decision-makers this shoreline has a voice.

📆 ACT NOW – Public Comments Close July 20, 2025
The project is currently in the Terms of Reference stage — the first step in a multi-year Environmental Assessment. If we don’t act now, they will move forward with shoreline “enhancements” that erase the beach entirely.

📧 Send your concerns directly to the Ministry of Environment:
Stephen Deneault – Environmental Assessment Officer
📩 Stephen.Deneault@ontario.ca
📞 437-637-3443