Nov. 17, 2010…

Nov. 17, 2010

Barton Feilders

Manager, Ministry of Natural Resources

Natural Heritage, Lands and Protected Spaces Branch

Parks and Protected Areas Policy Section

300 Water Street

Peterborough, Ontario

K9J 8M5

Dear Mr. Feilders,

Re: EBR registry No: 011-1300 Rondeau cottage leases extension

On behalf of Ontario Nature, I would like to express our strong opposition to the proposed extension of the Rondeau Provincial Park cottage leases to 2038.

Ontario Nature protects Ontario’s wild species and wild spaces through conservation, education, and public engagement. Established in 1931, Ontario Nature is a charitable, membership-based conservation organization with over 140 member groups and 30,000 individual members and supporters. We provide education and hands-on conservation activities for people of all ages and work to protect the endangered species and habitats of this province.

The proposed cottage lease extension is contrary to the government’s policies under the Provincial Parks and Conservation Reserves Act, the Biodiversity Strategy and the current Rondeau Provincial Park Management Plan. The EBR notice of the proposed extension provides no rationale for this major and highly questionable shift in the management direction for the park. There is no evidence provided that the costs and benefits of the proposed change have been weighed or that the outcome is in the public interest. Indeed, given the park’s exceptional ecological value for biodiversity conservation, it would appear that the proposed policy change will benefit only a privileged few, many of whom are not Canadian citizens and taxpayers.

Ontario Nature urges the government to immediately withdraw this proposal. Outlined below is a list of the key reasons for our position.

1. Protected areas play a vital role in conserving biodiversity at a landscape level.

As recognized in Ontario’s Biodiversity Strategy, introduced by the McGuinty government in 2005, parks and protected areas are one of the cornerstones for biodiversity conservation strategies. In southern Ontario, where less than 4% of the landscape is protected in parks and conservation lands, there are few opportunities for expansion of protected areas (Ontario Biodiversity Council. State of Ontario’s Biodiversity, 2010). This means that existing protected areas are absolutely critical in conserving biodiversity.

Rondeau is renowned for its biodiversity. Yet its small size and location within the heavily developed landscape of southern Ontario mean that there are many significant challenges to ensuring that it can fulfill its important role in biodiversity conservation. The government must therefore do its utmost to address threats to biodiversity such as habitat loss and fragmentation, incompatible development and recreational activity, pollution and non-native invasive species both within and outside park boundaries. Within Rondeau’s boundaries, cottages have contributed to all of the above threats.

While the leasing of private cottages is part of the park’s long history, the government decided in 1986 to extend the leases one last time only - until 2017 - as recommended by the Provincial Park Advisory Council at the time. Reversing this decision runs completely contrary to the government’s commitments to protect biodiversity, as outlined in the Biodiversity Strategy.

To the extent possible, Rondeau Provincial Park’s unique vegetation-landform features should be free of human structures and manicured landscaping and restored to a natural state where wild, native species thrive. Its provincially and nationally significant habitats include coastal marshes, buttonbush sloughs, oak savannah, eastern cottonwood savannah and Great Lakes shoreline sand dunes. In addition to these rare and diverse habitats the park functions as a refuge for dozens of species at risk, including the following endangered, threatened and special concern species:

Birds: prothonotary warbler; king rail; least bittern; yellow-breasted chat; Acadian flycatcher; northern bobwhite; black tern; bald eagle; cerulean warbler; Louisiana waterthrush

Plants: red mulberry; butternut; nodding pogonia; American water-willow; goldenseal; willowleaf aster; wild ginseng; common hoptree; eastern flowering dogwood; Riddell's goldenrod; swamp rose mallow; broad beech fern; Shumard oak

Reptiles and amphibians: eastern fox snake; eastern hog-nosed snake; eastern ribbon snake; spotted turtle; eastern spiny softshell turtle; musk turtle; Blanding's turtle; snapping turtle; northern map turtle; five-lined skink; Fowler's toad

Fish: lake chubsucker; spotted gar; pugnose shiner; Warmouth; silver chub

Insects: monarch butterfly

The fact that there are so many nationally significant vegetation communities and so many species at risk is of immense significance for biodiversity conservation. For example Rondeau is the only site in Ontario known to have been continuously occupied by the endangered prothonotary warbler over most of the past century (Atlas of the Breeding Birds of Ontario, 2001 – 2005). It is the only confirmed site in Canada for the endangered nodding pogonia orchid. And it is an important nesting site for the largest population of the threatened spiny softshell turtle in Ontario.

Rondeau Provincial Park is unmatched for its biodiversity values, and protecting and enhancing these values should be the top priority of policy and management decisions. Extending the cottage leases runs contrary to this mandate, and to Ontario’s Biodiversity Strategy.

2. Maintaining ecological integrity is the guiding management principle for Ontario’s provincial parks. Ontario’s Provincial Parks and Conservation Reserves Act, passed in 2006 under the McGuinty government, enshrined the maintenance of ecological integrity as the first objective and the first guiding principle of park management. Extending the cottage leases would contravene this clear, legislated mandate for the park system in Ontario.

The first objective of the Act (section 2) is: “To permanently protect representative ecosystems, biodiversity and provincially significant elements of Ontario’s natural and cultural heritage and to manage these areas to ensure that ecological integrity is maintained.” The first principle, which is to guide all aspects of the planning and management of Ontario’s system of provincial parks and conservation reserves, according to the Act (section 3), is: “Maintenance of ecological integrity shall be the first priority and the restoration of ecological integrity shall be considered.”

In passing this ground-breaking legislation, the McGuinty government demonstrated outstanding leadership. Yet its commitment to upholding the spirit and intent of the Act is called into question by the proposed lease extension. The proposal simply does not make sense if the objective of management is to maintain and restore ecological integrity.

Maintaining Rondeau’s ecological integrity is an enormous challenge, given its small size and location within the heavily developed landscape of southern Ontario. Terminating the cottage leases in 2017, as per current policy, would be an important step in the right direction.

3. The current approved park management plan states that the cottage leases will be terminated in 2017. The current park management plan for Rondeau is the result of considerable public consultation on the desired management direction for the park. The extension of the cottage leases was a highly contentious issue during the preparation of the plan (late 1980s/ early 1990s), and the extension of the cottage leases to 2017 was a huge concession to cottagers at the time, strongly opposed by conservation organizations. Another such concession is simply unacceptable, especially given current government commitments to protecting biodiversity, recovering endangered species and maintaining the ecological integrity of protected areas.

Further, this proposal constitutes a major shift in management direction and should only be made within the context of a management plan review where costs and benefits are carefully weighed and submitted to public scrutiny. It is inappropriate to be considering such a change in the absence of a full management plan review, calling into question the integrity of the entire park management planning process for Ontario Provincial Parks.

4. The cottages have a negative ecological impact. The cottages in Rondeau, which extend along most of the park’s western shoreline and a portion of the eastern shoreline, are located on some of the most environmentally significant portions of the park. Simply by occupying a good portion of the landbase, the cottages impede its use by wildlife. Direct harm to wildlife has also been documented. The recovery strategy for the threatened eastern fox snake (2010) notes, for example, that some cottage owners have admitted to killing fox snakes when encountered on their property. Another negative impact has been the introduction of invasive non-native species, identified as a key threat to various species at risk and rare habitats found within the park. A 2008 survey of the eastern dunes of the park found, for instance, numerous invasive non-native plant species, many intentionally introduced by cottage leaseholders.

5. The extension of the cottage leases is not in the broad public interest. There are currently 287 leaseholds in Rondeau, over half of which have changed ownership since the final lease extension in 1986. All cottagers entered into their leases with full knowledge that they would not be renewed after 2017. Regardless, many of the cottagers have proceeded to expand buildings on their properties, perhaps assuming that it would help build the case for a further lease extension.

The extension of cottage leases is not in the public interest. Cottages currently restrict public access to the beach and lake. Further, it is our understanding that the leases have been subsidized by Ontario taxpayers for decades: cottagers pay the government far less than market value for their leases; and their property taxes are also far lower than those paid for properties just outside the park.

The Rondeau Cottagers’ Association wants cottage leases to be extended even beyond the proposed 2038 proposed deadline, as indicated in a paid advertisement in the Chatham Daily News, October 26, 2010. In other words, if the government does not decide to terminate the leases in 2017, as per current policy, it can be expected that the cottagers will fight the 2038 deadline in the years to come. From a public policy perspective, there simply is no rationale to extend the leases.

Conclusion:

Rondeau Provincial Park is acclaimed internationally for its spectacular biodiversity and rare ecosystems and for the habitat that it provides for numerous species at risk. It is a place of special significance and beauty held in the public trust for all generations to come. Cottages within this tiny provincial park are an anachronism from the past that serve the interests of only a privileged few. The government should hold firm on the well founded decision to terminate the leases in 2017. This is the only choice in keeping with spirit and intent of the Provincial Parks and Conservation Reserves Act, the Biodiversity Strategy and the current Rondeau Provincial Park Management Plan.

[Original Comment ID: 129041]