Neptis has found that some municipalities are planning to direct significant amounts of subdivision-style development to UBUAs and to count these developments as intensification. They include municipalities in Simcoe County, which has the largest amount - about 38 percent -of unbuilt land in UBUAs in the Outer Ring (see Figure 2). Simcoe County's Official Plan states:
Where a settlement area has an undelineated built-up area by the Province, the entire settlement area is considered to be a built-up area, and all new residential units within such settlement areas contribute towards the intensification target [emphasis added].
Figure 2: Distribution of unbuilt land in undelineated built-up areas among Outer Ring municipalities
Simcoe has planned for almost 40 percent of its growth to be in the form of intensification. But rather than directing intensification to locations with well-established urban infrastructure, institutions, and amenities - such as Collingwood, Midland, Alliston, or Wasaga Beach - a review of the County's land budgets shows that about 65 percent of the units that have been approved as intensification in Simcoe County are being directed to UBUAs; 83 percent of these units are in the form of single detached housing units.
This type of scattered development, on this scale, undermines the goals of the Growth Plan while allowing the County, on paper at least, to meet and even exceed its minimum intensification requirement (which, for Simcoe County as a whole, was adjusted to 32 percent). Figure 3 shows how intensification units have been allocated in Simcoe County.
Figure 3: How intensification units are allocated in Simcoe County
Some of the development being planned in the UBUAs in Simcoe County reflects leapfrog development pressures first identified in the early 2000s.
 Simcoe County Official Plan, Policy 3.5.24. Retrieved from http://www.simcoe.ca/Planning/Documents/SimcoeOfficialPlanText.pdf
 Neptis studied the land budgets of all 16 Simcoe County municipalities for the period 2011-2013 (http://www.simcoe.ca/dpt/pln/growth) to understand how much growth is being directed to the UBUA. The gross land budget does not identify how many intensification units are being assigned to the delineated built-up area relative to the undelineated built-up area. To understand that breakdown, Neptis looked at Registered and Draft-Approved development applications, which make up about 13,200 intensification units or 51% of all planned intensification units in Simcoe County; 8,500 unit or 65% of Registered and Draft Approved units were being directed to the UBUA, of which 83 percent were single detached houses.
 Rian Allen and Philippa Campsie, Implementing the Growth Plan for the Greater Golden Horseshoe: Has the strategic regional vision been compromised? Neptis, 2013. Retrieved from: https://www.neptis.org/publications/how-will-growth-be-accommodated/chap...
 Leah Birnbaum, Lorenzo Nicolet, Zack Taylor, Simcoe County: The New Growth Frontier, Neptis 2004. See section 3.2.1.