Thank you for the…

Thank you for the opportunity to comment on Proposal 019 9306. After reviewing the proposal and the supporting material, I have several concerns with the plan to regulate an additional 43 parcels under the Provincial Parks and Conservation Reserves Act, 2006 (PPCRA). The supplemental document confirms that all parcels would be brought under O. Reg. 315 07 or O. Reg. 316 07, which would permanently remove these lands from the Public Lands Act system. Once regulated under the PPCRA, industrial land uses such as mining and prospecting, aggregate extraction, commercial forestry and hydroelectric development are automatically prohibited. These prohibitions are statutory and do not depend on future management planning. The proposal does not provide evidence showing that these areas are incompatible with those uses or why their removal from the working Crown land base is necessary.

The proposal also states that Ontario already has more than 9.8 million hectares regulated under the PPCRA. Given the scale of the existing protected areas system, the ministry has not demonstrated a clear need for expanding PPCRA regulated lands at this time, especially when doing so reduces the availability of multiple use Crown land that supports a wide range of economic and community based activities.

The proposal identifies several new provincial parks and additions where hunting will be prohibited, including Hay Marsh, Misery Bay additions, Bon Echo addition, Ferris addition, Awenda, Duncan Escarpment, Hockley Valley, Turkey Point and Nottawasaga Lookout. In areas where hunting will continue, activities will be governed by the schedules and firearm conditions in O. Reg. 665 98 rather than the more flexible framework that applies on Crown land. The proposal does not assess how these changes will affect hunting access within the affected Wildlife Management Units or whether sufficient alternative land will remain available.

Many of the parcels proposed for regulation, including large northern additions such as the Grassy River Halliday Lake Forests and Lowlands and the Tatachikapika River Plain, have long been used for hunting, trapping, snowmobiling, backcountry access and other lawful activities permitted under the Public Lands Act. Converting these areas into PPCRA regulated land introduces new restrictions, additional approval processes or management planning requirements that may limit or alter existing uses. The proposal does not evaluate these impacts or explain how they will be addressed.

The supplemental document also notes that many of the parcels were identified in the 1999 Ontario’s Living Legacy process but were not regulated at that time because of incomplete planning or unresolved land use considerations. The current proposal provides no explanation of how these issues have been resolved or why regulation is now justified.

The proposal also states that hiking, canoeing, fishing and wildlife viewing already take place on these parcels and would continue if they are regulated. This shows that the Public Lands Act already supports the recreational uses the ministry cites as justification for converting these areas into parks and conservation reserves. What the proposal does not address is that PPCRA regulation would reduce the broader range of recreation and land use that currently exist, including hunting in several proposed parks, certain forms of motorized access, the maintenance of existing trail networks and long established backcountry uses. In practice, recreation already occurs today without conflict, and regulation would narrow rather than expand the activities permitted.

For these reasons, I do not support Proposal 019 9306. A broader review of Crown land supply, regional impacts and long term land use needs should be conducted before converting additional parcels into PPCRA regulated areas, particularly when the existing Public Lands Act framework already permits the recreational uses identified in the proposal without removing flexibility or imposing permanent restrictions.