March 11, 2022 Kendra…

March 11, 2022

Kendra Couling

Ontario Parks - Southeast Parks Zone

300 Water Street
4th Floor North
Peterborough, ON
K9J 3C7

Dear Ms. Couling,

RE. Creation of conservation reserve on south shore of Prince Edward County, ERO #019-4597

The 40 undersigned organizations are pleased to support the proposal to create a conservation reserve along the south shore of Prince Edward County. We agree that the creation of this conservation reserve will provide greater protection for the important biodiversity values documented at this site as well as continued access for ecologically sustainable outdoor activities.

The proposed conservation reserve will be an important addition to Ontario’s protected areas system. As noted by the South Shore Joint Initiative (www.ssji.ca), the area is host to 28 regionally rare plant species and important concentrations of migrating bats, butterflies and dragonflies, and species at risk such as monarch butterfly, Blanding’s turtle, least bittern, eastern whip-poor-will, barn swallow, and Canada warbler. Various conservation designations signal the ecological importance of the diverse habitats it provides, including an International Monarch Butterfly Reserve, the Point Petre Provincial Wildlife Area, an Area of Natural and Scientific Interest (ANSI), a candidate ANSI and Provincially Significant Wetland complexes. The South Shore has also been identified as an area of high biodiversity in the Draft Canadian Wildlife Service Ontario Landscape Conservation Atlas and Plan (Environment and Climate Change Canada 2017).

While we fully support the creation of this conservation reserve, we are concerned, nevertheless, that the ERO posting does not mention consultation with or consent from Indigenous communities. We believe that the establishment of new protected areas in Ontario should be premised on 1) appropriate consultation, as triggered by the recognition and affirmation of Indigenous and treaty rights in section 35(1) of the Constitution Act, 1982, and 2) the free, prior and informed consent of affected Indigenous communities, as set out in the United Nations Declaration on the Rights of Indigenous Peoples. We would appreciate confirmation from the Ministry of Environment, Conservation and Parks (MECP) that it has or will meet both of these requirements.

We agree that it will be important to provide opportunities to “enjoy the area’s natural beauty, including hiking, hunting and birdwatching, while strengthening the long-term protection of biodiversity.” As set out in section 3 of the Provincial Parks and Conservation Reserves Act, 2006, the maintenance of ecological restoration must be the priority in the planning and management of the conservation reserve. Indigenous traditional cultural practices must be accommodated, as per the constitutionally protected rights of Indigenous Peoples. Activities which threaten the ecological or cultural values of the conservation reserve should be prohibited.

We agree with the proposed boundaries for the conservation reserve, which would include both the Ostrander Point Crown Land Block and Point Petre Provincial Wildlife Area. Regarding a name for this conservation reserve, we suggest that MECP consult with affected Indigenous communities to determine whether there is a preferred Indigenous name that they would recommend.

Thank you for the opportunity to comment on this proposal.