I am submitting this…

I am submitting this document to express serious concerns regarding the proposed amendments to the Provincial Parks and Conservation Reserves Act supposedly to support the Town of Wasaga Beach’s tourism enhancement proposal. My concerns are for the potential negative local ecological and economic impacts to the Wasaga Beach portion of the Provincial Park and other Provincial Park non-beach natural areas. I also have major concerns that this amendment will establish and allow for a dangerous precedent that will open up the sale of other critical natural and protected portions of other provincial parks across Ontario for a narrow sited economic gain.

It is particularly difficult to comment on the posting as it provides next to no detail on the nature of the legislative amendments being pursued. As such, this posting does not represent adequate consultation. The public deserves to understand precisely what is being proposed and why. The posting indicates that the purpose for the amendments is to enable the removal of Beach Areas 1, 2, New Wasaga and Allenwood Beach from Wasaga Beach Provincial Park and sale of Crown lands in these areas to the Town of Wasaga Beach. However, the Provincial Parks and Conservation Reserves Act already provides for the disposition of provincial parks lands. Under the Act, if the proposed disposition involves 50 hectares of land or more, then new boundaries must be tabled and endorsed by the Ontario Assembly. Surely this is a reasonable, transparent approach.

As recently referenced by the Town of Wasaga Beach, the proposed disposition involves close to 60 hectares of beach lands. Why then is the province not proposing to either restrict the transfer to under 50 hectares or seek the endorsement of the Ontario Assembly per current legislative requirement? The proposed amendment approach seems to suggest two possibilities, both of which are very concerning:
• There is a plan for the disposition of additional Wasaga Beach Provincial Park lands, beyond the 60 hectares; and/or
• There is a plan for the disposition of additional provincial park lands across the province for development purposes without the approval of the Ontario Assembly.

In August of 2024, Wasaga Beach Town Council passed a motion seeking the transfer of, at a minimum, Beach Areas 1, 2, part of Beach Area 4, and all of the remaining non-beach areas and non-environmentally sensitive parcels of land in the provincial park out of the Ministry of Environment Conservation and Parks portfolio. This motion was passed after a meeting between Mayor Smith and Town officials, Premier Ford and key provincial minsters. At the recent Wasaga Beach announcement of the transfer, references were made to this transfer being a first step. It appears that the true intent is to transfer additional lands beyond the initial 60 hectares. It can be expected that the 60 hectare transfer alone would have significant negative consequences to the natural environment and possible public safety as related to flood prevention/mitigation. The proposed transfer of under 60 hectares of land, while 3% of the Park’s entire land area, represents 60% of park beach lands. Claims by the Town (June 2025) that the beach and environmentally sensitive dunes will be preserved and that no sensitive habitat is being threatened are very questionable and misleading. The Town of Wasaga Beach claims that it is really only interested in 30 hectares of land in terms of development. If this were truly the case then the transfer would have been pursued through the provisions of the current Provincial Parks and Conservation Reserves Act and the 60 hectare transfer would not have been necessary.

As a frequent camper and day use visitor to many of Ontario’s provincial parks, including Wasaga Beach Provincial Park I am impressed by the efforts of Ontario Provincial Parks management and staff across the province who strive to and with much success balance the pillars of sustainability – encouraging world class public recreation and tourism opportunities, providing nature-based education, conserving sensitive and provincially significant features and ecosystems for the benefit of current and future generations, protecting wildlife and species at risk, and protecting the public from natural hazards. Provincial parks are intended for the ongoing benefit of all Ontarians, and visitors to Ontario. They are not simply for the economic gain of local Towns and developers.

It is a well known fact that Wasaga Beach is one of only a few areas in Ontario that provides for prime habitat of the critically endangered Piping Plovers. They have primarily nested on Beach Area 1 but also at Allenwood and New Wasaga Beach Areas. Wasaga Beach has provided the most successful nesting sites in Ontario, a fact that should be celebrated and supported by Ontario and the Town. Plans to increase development adjacent to these beaches, including potentially in the existing parking lots at Beach Area 1, and increased raking and detritus removal along the beach, expected with the transfer of beach lands to the Town, will imperil the piping plovers and sensitive dune areas. Piping Plovers are also imperiled due to the threats of recent amendments to the Endangered Species Act drastically limiting the definition of habitat to nesting sites. Without protecting the true extent of their habitat, including their food sources, they will not survive. Beaches and dune areas (Beach Area 1 is a designated as a provincially significant Area of Natural and Scientific Interest (ANSI)) of Wasaga Beach Provincial Park are also home to other vulnerable species, such as the Eastern Hog Nosed Snake and Hill’s Thistle that will also be detrimentally impacted if proposed development and changes to beach management practices (e.g. increased raking) are made.

A key growing tourism market segment for Wasaga Beach includes bird watchers and nature enthusiasts of all ages who visit it in great numbers to experience the Plovers and other natural benefits of the beach. Ecotourism can and does provide for positive economic inputs for communities that have embraced it. If the habitat of plovers and other vulnerable species is destroyed, this significant economic market for Wasaga Beach will be lost.

Raking and foot traffic could over time destroy the beach itself. The Town’s tourism and development aspirations fail to appreciate the science at play at Wasaga Beach. Wasaga Beach is a relict beach (Wasaga Beach Shoreline Biodiversity Study 2016). This means that sand is not replenished to the beach. The sands of Wasaga Beach are the result of the melting glaciers of the last ice age. When raked, or when beach stabilizing Marram grass is walked upon (30 passes in 24 hours will kill it) the sand is destabilized and blows away. This causes the depth of beach sands to decline, which in turn causes wet sand as the water table is higher relative to the surface. With wet sand comes a dramatic increase in vegetation including invasive species like phragmites. Eventually the beach is lost, along with the tourism the Town so wants to attract, and the economic (and ecological) benefits of the beach. The best prevention is to protect the dunes, through designated pathways and marram grass plantings, and leaving the beach unraked and natural. Natural beaches to many are the most beautiful as they are not a sandbox but a stunning natural area that supports a wide range of plant and animal life.

Lands in question along the shoreline of Georgian Bay and the Nottawasaga River are susceptible to flooding. References by the Town to raising the elevation of Beach Drive to mitigate flooding recognize this issue but fail to adequately appreciate the science related to Great Lakes flooding and dynamic beaches. In Wasaga’s case the combined influence of fluctuating Great Lakes water levels and storm surges and riverine flooding along the Nottawasaga River mean that to ensure public safety development should not occur below the elevation of the 100 year flood with an allowance for wave uprush and the dynamic beach hazard limit. Generally this is an elevation of 181 meters. There are considerable areas of existing and proposed development in the Town that fall below this elevation and are highly flood prone. Proposed development in these areas is potentially life threatening and dangerous in light of current knowledge and science related to the need for updating flood allowances to account for increasingly unaccounted for and ever changing climatic related events and trends. Not properly addressing and planning for development will be catastrophic economically (damage, insurance rates) and socially (public safety – injuries and possible death).

I urge the government to rethink proposed changes to the Provincial Parks and Conservation Reserves Act and the transfer of lands out of the Provincial Parks system. Utilize existing legislative requirements to guide the transfer. It is imperative to fully assess, understand and to take a balanced approach to address all of the natural, economic and social vulnerabilities of the Wasaga Beach development that the proposed amendments would enable. This is essential for the mutual long-term benefit for citizens of Wasaga Beach, the public in general and healthy environment.
Gary