One example of development in a UBUA that is being counted as intensification can be found in Innisfil, where small, discontiguous rural communities with relatively small amounts of projected growth are being connected to distant water and wastewater treatment plants.
The settlement of Lefroy-Belle Ewart is partially serviced with well water and septic tanks, but pipes are being extended from a wastewater treatment plant in Alcona, a nearby urban settlement, to service a subdivision being developed in the unbuilt portion of the UBUA, shown in Figure 4.
Figure 4: Recent residential development in Lefroy, an undelineated built-up area in the Town of Innisfil
Lefroy is not the only UBUA that will be connected to Alcona. The multi-million-dollar expansion of the Water Treatment Plan in Alcona, planned for completion in 2018, links scattered settlement areas across Innisfil and Bradford West Gwillimbury, including Big Bay Point/Friday Harbour in northeast Innisfil, the Bradford West Gwillimbury employment lands on Highway 400, and planned growth in the rural settlement area of Bond Head, where the population is expected to increase to 4,400 people from about 500 people.
The planning under way represents the pattern of growth that the Growth Plan explicitly discourages, that is, leapfrog development – the building of expensive new infrastructure to serve far-flung developments across vast stretches of rural and agricultural land when growth should be directed to existing areas with servicing capacity.
If municipalities are allowed to count new subdivisions in unbuilt areas of rural settlements as intensification, this will contribute to pressure to bring in piped services from distant treatment plants at considerable cost, even though a relatively small amount of population and employment growth has been allocated to UBUAs. This, in turn, will create pressure to add more development along or near the path of these pipes.
Another example of development in a rural settlement being counted as intensification can be found in Horseshoe Valley in Oro-Medonte. The settlement has grown around a resort community far from any urban areas. Expansion plans for the UBUA exceed the capacity of its small-scale communal wastewater collection system. The municipality is now considering interim wastewater options, since municipal-scale systems are still only in the early planning stages. Paying first for interim wastewater treatment and later investing in municipal-scale infrastructure is another type of outcome the Growth Plan was intended to prevent.
Both examples show that scattered development comes at considerable costs in water and wastewater servicing. Moreover, as these small communities add new subdivisions, demand will grow for other types of services and amenities (schools, libraries, recreational facilities, and community centres), creating further costs for municipalities.
As we have shown, subdivisions are being built on the outskirts of small towns, villages, and hamlets; more have been approved for development. If these subdivisions are allowed to be counted as “intensification,” then the distinction between intensification and greenfield development in the Growth Plan becomes utterly meaningless.
 See Amendment no. 16 to the Official Plan of the Town of Bradford West Gwillimbury: Bond Head Settlement Area Secondary Plan, section 188.8.131.52. Retrieved from http://www.townofbwg.com/Shared%20Documents/Planning/Official%20Plan%20A...
 Township of Oro-Medonte, 2015, Horseshoe Valley Lands Horseshoe Ridge Phases 4 and 5 – Interim Wastewater Master Servicing Study Summary Report in Support of the Horseshoe Ridge Phase 4 Draft Plan of Subdivision and Zoning By-Law Amendment, retrieved from http://www.oro-medonte.ca/Shared%20Documents/Public%20Notices%20and%20Me...
 The township has only just launched the Environment Assessment process for the Horseshoe Craighurst Corridor Water, Wastewater and Transportation Master Plan. See http://www.oro-medonte.ca/community/horseshoe-craighurst-master-plan