Comments on the proposed…

Comments on the proposed Amethyst Highlands Enhanced Management Area

Thank you for the opportunity to provide comment on this important initiative. I commend you for your efforts to save our declining brook trout populations.

I offer the following comments from the perspective of a fisheries biologist who has worked on brook trout for over 30 years.

Brook trout populations are disappearing from their native North American range at a catastrophic rate. In the mid 1980s an MNR assessment indicated that 80% of southern Ontario populations and 10-15% of northern populations had already been lost.
Since that survey, in Zone 6, brook trout lakes have further decreased from 105 lakes to 35-37. This is an additional 60% decrease in just 35 years. Lakes that had brook trout in them when I started work here are no longer brook trout lakes. This is alarming, but unfortunately this is not news.

MNR identified the need to stop this decline in the 1980s and the three District Fisheries Management Plans that I worked on in the 1980s (Algonquin Park, Tweed, and Nipigon) all had strategies to stop this decline. The decline has continued because the actions were not restrictive enough to be meaningful.

It is my professional opinion that this proposal for the Amethyst Highlands Enhanced Management Area (EMA), with some modifications, has the potential to truly protect this group of relatively pristine brook trout lakes.

Roads, with the associated increased access, leading to overfishing and introductions, as well as the associated physical disturbance to groundwater, and streamflow, have been shown to be one of the main causes of brook trout decline.

Although this proposal places some restrictions on roads in the EMA, it does not go far enough.

No new roads, either winter or temporary, should be allowed in the EMA boundaries. The risk to the EMA brook trout populations is just too great.

In terms of physical disturbance, because of the excellent work conducted over many years by a Thunder Bay District MNRF biologist, in locating spawning areas, and in mapping the groundwater sources, it is possible that most of the groundwater to the spawning areas may be protected even with the current proposal.

Unfortunately there is another critical habitat component about which nothing has been documented in these lakes- the location of groundwater seeps and flows used as nursery areas by young-of-year brook trout. These nursery area groundwater flows are of equal importance to spawning groundwater in the maintenance of a brook trout population.
Without this information it is unknown how roads will affect the groundwater flow to these nursery areas. There is a risk that these critical nursery areas could be altered by road disturbance and the population could be lost.

Many areas in this EMA have shallow soils and subsequently shallow groundwater. I acknowledge that in some circumstances allowing only winter roads and no ditching may reduce the chances of intercepting groundwater flow. However, on shallow soils where groundwater is shallow, such as these, it is nearly impossible to avoid shallow groundwater disturbance. Again, because of the high risk to altering groundwater flow patterns these roads should not be allowed.

Preventing access, after roads are no longer required, is extremely difficult on shallow soils such as these. In many cases, roads cannot be successfully rehabilitated to the point where access is removed. There are many examples locally where we have tried and failed to rehabilitate roads to this level, even on rich sites. It is often decades before a road becomes impassable on shallow sites such as these. Gates have only rarely been successful at controlling access. Roads of any kind in the EMA are likely to increase access for many years.

Successfully implementing the proposal as presented will require tremendous staff effort, vigilance, expert knowledge of groundwater movement, road rehabilitation techniques, on -the -ground monitoring and enforcement to ensure that no damage is done to the brook trout populations. Deferring the discussions about road placement and gates to forest management planning will only lead to deferred arguments. Having worked at the district level for many years, I know that it can be a huge challenge to dedicate this amount of effort to one area and issue.

I realize that it is incredibly difficult to weigh the needs of brook trout populations against forestry, mining and other industries. In this case, because of the high value of these brook trout lakes, the serious state of brook trout in Ontario and because there appears to be relatively low timber values, I urge you to rule on the side of conservation- on the side of brook trout.

This relatively pristine group of brook trout lakes will only become exponentially more important as time goes by and more populations disappear. This is a chance to do something meaningful for our brook trout populations. It will take serious efforts like this to ensure that our children and their children have brook trout to enjoy. It will be a missed opportunity to go to this trouble and not go the extra bit to ensure the best protection possible.

Protecting the EMA from new roads now, while it is still possible, would be a huge step towards preserving brook trout in Ontario.

Thanks for the opportunity to comment.