The Sauble Beach Piping…

The Sauble Beach Piping Plover Recovery Program Experience under Municipal Governance
This submission provides the comments of the Plover Lovers of Sauble Beach on this proposal. Plover Lovers are a group of volunteers charged with delivering the public Outreach and Educational component of the Ontario Piping Plover Recovery program. Program Volunteers have numbered in the 100’s since 2007 when Piping Plovers first nested in Sauble Beach Ontario after a 30-year absence. Collectively since 2007, our Volunteers have engaged, educated and entertained 1000’s of beachgoers with the history of the endangered Piping Plover and the efforts to maintain its place in our environment. Beachgoers have consistently advised us this enhances and expands their beachgoing experience.
Sauble Beach is unique among the Ontario beaches most frequented by Piping Plovers (PIPL) in that it is a municipally owned and operated beach. It is not provincial park-owned and managed such as Wasaga, Presqu’ile and Darlington beaches. Together these four beaches have been the most consistent PIPL recovery strongholds in Ontario, with Wasaga being the most productive in plover recruitment.
With Sauble Beach being municipally governed, it does not have the benefit of the staff or various protections inherent in a provincial park setting. The following comments outline a chronology of local municipal government decisions that have seriously impacted the plovers nesting success and their critical habitat at Sauble Beach. Some of these decisions have even been found, by the Ontario Provincial Offenses Court, as well as in Appeal courts, to be breaking the laws of the Ontario Endangered Species Act.
Since the return of the Piping Plover to Sauble Beach in 2007, MNRF worked with the Council of the Town of South Bruce Peninsula to accommodate provisions under the Endangered Species Act which offered protection to nesting PIPL and their associated beach habitat, while also addressing the busy nature of this popular, and municipally profitable, public beach. These provisions included, during the PIPL breeding season, limited light raking outside protected habitat (500m diameter from a nest) in the mid-beach area (between the drift/wrack line and the base of the dunes), with limited vegetation removal. Spring raking was not supported, however, spring beach cleanup of winter washed-in large logs and hazardous debris was permitted, as was digging out and straight-lining numerous municipal drains that crossed the beach, for health reasons.
For several years these measures were followed by the municipality under previous Councils. Additionally, the Municipal council(s) of those early years were supportive of the Volunteer Outreach and Education component of the PIPL Recovery Program. Town staff reported plover sightings to the Ministry (MNRF) and the Plover Lovers group, provided free beachside parking for volunteers, assisted in erecting exclosures and perimeter roping, provided municipal storage space for the outreach materials, and provided free use of a room in the Sauble Beach Community Centre for our informational and educational evening sessions. In 2012 the Municipality passed a ‘raking’ by-law which provided for beach maintenance in alignment with the plover habitat protection strategies.
In 2015 however, a new Council began undertaking actions to address issues evolving from rising lake levels, a narrowed beach and emerging vegetative growth over the previously more heavily raked beach. These changing conditions were part of the natural processes of a dynamic beach and dynamic lake levels. However, Council felt that increased raking to ‘clean’ (i.e. remove vegetative growth from the beach sands) the beach was required to support tourism. Council proceeded to amend its Dynamic Beach maintenance by-law to allow raking of the beach to the water's edge and to level out some foredunes. Under the former by-law policy raking was only permitted up to 30 feet from the water's edge and up to 30 feet from the dunes. This new policy effectively removed much of the beach wrackline, a vital foraging area for PIPL, as well as nesting, resting, shelter and foraging areas provided by the foredunes.
Shortly after, Environmental Defense, an organization that administers the “Blue Flag” program in Canada, pulled Sauble Beach’s Blue Flag status because of this new damaging beach maintenance policy.
In 2016, Council revoked its support for the Volunteer outreach program by no longer providing free parking, or the use of their storage facility, or their Community Centre space. This lack of support significantly impacted the volunteer plover monitors who through the years had spent endless hours of their time on the beach engaging beachgoers on the PIPL, with a documented public support rate of over 95%.
In 2017, the Council amended the existing “dog” by-law, to allow dogs to be on the beach throughout the month of May. Previously dogs were prohibited from being on the beach (for beachgoers health and safety reasons) as of May 1. Allowing dogs to be on the beach throughout the month of May impacted the critical time for PIPL to arrive, stake territory, form pair bonds and establish nests. Although the by-law required dogs on the beach to be leashed, numerous daily surveys throughout many Mays noted numerous unleashed dogs running at large, throughout such PIPL nesting territories.

In April, August & September 2017 Council then authorized heavy “disking” of the beach, with a bulldozer, stripping the beach of virtually all natural, sand-stabilizing vegetation. The beach was flattened, leaving nests more vulnerable to storm surge. Foredunes were cut back in areas where piping plovers nested, rested, and used to escape threats on the beach. The work significantly altered the beach sands invertebrate habitat plovers rely on for food, diminished the wrackline at the water’s edge, also a vital plover food-foraging area, removed all beach driftwood and vegetation the plovers rely on for shelter, and loosened the surface and substrate sand to alter the nest-site conditions, and make sites more prone to wind erosion.
In 2018, MNRF issued three Stop Work Orders to prevent municipal work on the beach that was damaging to PIPL habitat, as the Town continued to proceed with further such works. This was supported by Ecojustice, who filed a motion to have the works stopped.
Also in 2018, MNRF laid two charges under the Provincial Offences Act against the Town for damaging PIPL habitat.
In 2019, the Ontario Court of Justice found the Town guilty of the charges, as well noting they were in conflict with their own bylaw. The Town continued to be found guilty after three appeals. These lengthy and costly court proceedings came at much cost to the local taxpayers – an economic hardship, rather than a benefit, for residents of Sauble Beach.
In 2020, the Town Council obtained a permit to construct a 469m long retaining wall along the dunes, and to cut back and reshape the dunes and their vegetative growth, purportedly to facilitate public parking. Charges were brought against this work, citing damage to the fragile dune system, the trees, the plants and the habitat for PIPL. Court quashed the permit. Again, the local taxpayers paid heavily for the Town Council’s endorsement of this work and their subsequent involvement in the court proceedings.
In 2020, the global pandemic closed Sauble Beach for various time periods in spring and summer. One PIPL nest was found in June, however, no adult plovers were attending the nest or observed on the beach and the nest was determined abandoned. No further nests, or plovers were found on the beach for the remainder of the 2020 season.
In 2021, a single pair nested unsuccessfully at Sauble Beach.
From 2022 to 2025, no PIPL established territory or nested at Sauble Beach. The few PIPL that landed on the beach stayed for very minimal 1-2 day periods and departed to other beaches. The now ecologically- degraded condition of the beach has been considered as at least one factor in why the PIPL have abandoned this formerly extremely suitable and critical PIPL breeding nesting habitat.
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This sequence of Municipal decisions, year after year, clearly illustrates how decisions can be at the whim of a pro-development Council which serves to promote development or tourism, while blatantly and repeatedly ignoring environmental and biological advice, policies, regulations, and law, as well as ignoring the environmental, economic, social, health and other ecotourism benefits that such mandates support.
We implore the Ontario Government to leave our parklands in the hands of those most vested in preserving and managing them for the people of Ontario and for maintaining our precious natural resources and biodiversity, in this case, in the hands of Ontario Parks, MNRF.

Sincerely,
Plover Lovers