I am writing to express my…

I am writing to express my concern over ERO proposal #025-0694. All thoughts are my own, and I am not representing any organization. Wasaga Beach is more than Ontario’s summer playground; it is an invaluable, globally rare natural heritage feature. The transfer of Nancy Island Historic Site to the Ministry of Tourism is a sensible choice that will ensure the site remains under provincial oversight and is restored for the public to enjoy. However, removing ecologically sensitive beachfront land from the provincial park and selling it to the town for development and tourism is a change that will put the future of Wasaga Beach at risk.

The purpose of the Provincial Parks and Conservation Reserves Act is to “permanently protect a system of provincial parks and conservation reserves that includes ecosystems that are representative of all of Ontario’s natural regions, protects provincially significant elements of Ontario’s natural and cultural heritage, maintains biodiversity and provides opportunities for compatible, ecologically sustainable recreation.” This definition clearly lays out exactly why the land that was expropriated to create Wasaga Beach Provincial Park needs to remain under provincial ownership, forever and always.

As a remnant beach, the sand at Wasaga does not replenish naturally. The globally rare freshwater dunes, vegetation, and driftwood help keep that sand on the beach, protecting the shoreline for future generations to enjoy. Excessive grooming and raking, shoreline development, and unchecked recreation can destroy the very features that are currently maintaining Wasaga Beach for the public to enjoy. These features cost us nothing. Such valuable and sensitive natural features should remain under the oversight and care of the province and their skilled biologists.

The habitat within the areas to be removed from the provincial park are home to numerous provincially and federally listed species at risk. For migratory birds and aquatic species, the protection afforded by the PPCRA is the only provincial legal protection remaining for themselves, their eggs/nests, and their habitat (habitat referring to an area on which a species depends directly or indirectly to carry out its life processes). By removing the land from the provincial park, the province is eliminating all provincial protection for even the most endangered birds and aquatic species, leaving the town subject to federal intervention. For the MECP to state that any endangered species habitat will continue to be protected under provincial laws if this land transfer goes through, as they have several times, is false. Federal legislation only automatically protects habitat on federally owned land. Therefore, it will not apply at Wasaga Beach unless the federal government issues emergency habitat protection orders. This proposal will result in gaps in protection for many species.

The best example of this is the Piping Plover, a species that was extirpated from Ontario for 30 years, before returning as a result of intensive conservation efforts in 2007. Wasaga Beach Provincial Park is their best and most productive habitat in Ontario, and the park dedicates several full time seasonal staff to their conservation every season. Such a busy location requires nearly constant monitoring, enforcement, and outreach to ensure Piping Plovers are not disturbed and can raise their family successfully. Taking away this support, along with removing legal protections for their habitat, will severely compromise conservation efforts that have taken place over the past 18 years. These efforts can only continue if equal or increased funding is provided to the town and Birds Canada to replace this severe loss of support. Conservation efforts are best accompanied by strong legal protections; if this sale goes through, as the town expects, there must be strict conditions that provide legal protection for Piping Plovers and their habitat and prohibit activities that may harm them or their habitat; most importantly, the mechanical raking or grooming of the beach.

Wasaga Beach Provincial Park has been underfunded, despite it being one of the most highly visited provincial parks in Ontario. Choosing to invest millions in the town and sell them the most valuable portions of the park for pennies, rather than simply investing in the park and maintaining facilities to a higher standard, does not make sense. There is no guarantee that once this land is sold to the town of Wasaga Beach, it will not be sold to private interests. In town meetings, it has been repeatedly stated that the areas of non-beach land are full of development potential, with residential and commercial development being suggested to replace parking areas. While the beachfront is to remain public according to this proposal, removing infrastructure like parking areas and public bathrooms and replacing them with storefronts and private homes will make access more difficult. Simply upgrading existing facilities and adding recreational infrastructure such as playgrounds, splash pads, educational signage, and shaded picnic areas and trails would accomplish the goal of improving tourism and local economic outcomes without making the area too expensive for a regular family to enjoy or causing damage to sensitive ecosystems. This can all happen without selling the land and risking the loss of public space. Overall, it is unclear how exactly this proposal would benefit the Province of Ontario any more than restoring and maintaining the existing park areas would. In fact, the province will lose income by selling this land to the town.

Lastly, I am deeply uncomfortable with the lack of transparency in the ERO proposal. The ERO fails to mention the presence of globally rare ecosystems and critically endangered species within the areas to be removed. The Environmental Registry exists to allow the public to partake in meaningful consultation on environmentally significant decision making. If the province wants informed input, this information should be included in the written proposal. Additionally, the choice to make unspecified amendments to the PPCRA to allow for this removal, rather than going through the established protocols to remove more than 1% of land from a provincial park, is concerning. The proposed amendments must be made public in the initial proposal stage to allow for informed comment.

Removing land from Wasaga Beach Provincial Park sets a dangerous precedent for the entire Province of Ontario; it shows that cherished, accessible, and environmentally sensitive public land can be extracted at will despite being “permanently protected”, and then sold to the highest bidder. It shows us that the province believes even globally rare habitat where a tiny, vulnerable bird with a provincial population of less than 15 individuals nests annually does not deserve protection and oversight. It shows us that if land can be developed, it will be, no matter what we lose in the process. It shows us that nothing is sacred.

Thank you.