Please accept the following…

Please accept the following comments on behalf of Council for the Township of Algonquin Highlands regarding proposed changes to the Public Lands Act with respect to the use of floating accommodations and camping on water over public lands in Ontario.

Council and Staff have reviewed the proposed changes and are generally in support of the proposed clarifications. We share similar concerns raised on the potential impact of floating accommodation units including:

• disturbance to lake beds and sensitive aquatic habitats caused by pile anchors;
• impact of greywater (i.e., wash water) discharge on water quality and aquatic plants and wildlife;
• pollution from household garbage falling into waterways;
• risk of fuel and/or oil spills;
• insufficient sunlight into water caused by extended periods of shade from floating accommodations; and,
• disturbance to local fisheries and/or wildlife.

We would respectfully request further clarification on the following:

• How will the Ministry enforce compliance with the Public Lands Act should a non-permitted structure be utilized?
• Can the Ministry provide further clarification on how it will be determined which "camping units" would be permitted to camp on water over public land?
• Can the Ministry restrict camping on water over public land for any floating accommodation unit, including vessels specifically designed for overnight accommodation, to waterbodies where direct access to appropriate sewage pump-out facilities exist?
• Can the ministry clarify that with respect to limiting the number of days a person can camp on water over public land that the same would apply to the structure itself?

The Township further requests that the Ministry reintroduce the recently removed additional conditions that must be met when camping on water over public land in Ontario. Those conditions included the following:

• reducing the number of days that a person can camp on water over public land(per location, per calendar year) from 21 days to 7 days;

• increasing the distance that a person camping on water must move their camping unit to be occupying a different location from 100 metres to 1 kilometre;

• adding a new condition to prohibit camping on water within 300 metres of a developed shoreline, including any waterfront structure, dock, boathouse, erosion control structure, altered shoreline, boat launch and/or fill;

• harmonizing the conditions for camping on public land so that residents and non-residents are required to follow the same conditions when camping on water over public lands or on public lands;

• specifying conditions for swim rafts, jumps, ramps for water sports, heat loops and water intake pipes;

• clarifying that camping on a road, trail, parking lot or boat launch is prohibited; and,

• amending the regulation to add the following to the list of excluded public lands to which section 21.1 of the Public Lands Act and Ontario Regulation 161/17 do not apply:

- lands subject to an agreement authorizing the use of those lands
- lands subject to an authorization under the Aggregate Resources Act.

On behalf of Council for the Township of Algonquin Highlands thank you for your consideration of the above comments and for being provided with an opportunity to review and comment on the proposed changes.