Comments on the Ministry of…

Comments on the Ministry of Natural Resources Proposal to Extend the Cottage Leases in Rondeau Provincial Park beyond their Current Expiry Date of 2017.

The long term extension of the cottage leases at Rondeau Provincial Park is a bad idea and should be allowed. I will outline my personal and professional reasons for this position.

First, all such major decisions should be made within the context of a management plan review. Given the gravity of the situation of creating long-term negative environmental and social impact from housing in a provincial park, it is entirely inappropriate to be considering such a change in the absence of a full management plan review. If this decision moves forward on the current path, it makes a mockery of the entire management plan process for Ontario Provincial Parks. If a major decision like this occurs outside of the management planning process then it reveals that process to be entirely ineffective.

Second, the extension of long term private housing in a provincial park must now be evaluated within the context of Section 2 of the Provincial Parks and Conservation Reserves Act, 2006. This section states that it is the goal of the act that “natural regions and the rates of change and ecosystem processes are unimpeded.” Section 2(1) subsection states that the management of all provincial parks must ensure that: “ecological integrity is maintained.” Section 2 (1) of the Act states that: “Maintenance of ecological integrity shall be the first priority and the restoration of ecological integrity shall be considered.” Therefore, an extension of cottage leases must have passed a full review of the impact of this change in land use on the maintenance of ecological integrity. There is no evidence that this review has been undertaken, therefore the extension of the leases would be in contravention of the ecological integrity section of the governing Act. Therefore, the current proposal is ultra vires and cannot move forward.

Third, in my professional opinion it is clear that the cottages in Rondeau Provincial Park have major negative ecological and recreational impacts on this park. Their presence disturbs a major portion of the park’s sensitive Carolinian ecosystems. Their presence precludes the use of the land by Ontario citizens who are not lease holders. The only reasonable approach therefore is to remove the cottages when their current lease expires.

Fourth, from 1954 to the early 1990s cottages were removed from Rondeau as their leases expired. This was the appropriate policy. This policy needs to be instated.

Fifth, many, and possibly a majority, of the cottage lease holders are not Canadian citizens. They therefore provide no taxes to the Ontario government to be used in park management. They do not vote in municipal, provincial or national elections. This fact reduces the value of cottage owner political importance in Ontario. Therefore, it is odd that that the Ontario cabinet is denigrating park benefits to Ontario citizens while at the same time providing such benefit to foreigners.

Sixth, the cottagers pay an abysmally low level of rent for the use of some of the most natural significant land in southwestern Ontario. Their use of the land has been subsidized by the Ontario taxpayers and by the other recreationist payments for decades. This subsidy must be stopped. How much money do they pay now? How much money will they pay in the future? How much cost does Ontario Parks incur for the management of a over 250 private homes inside the Provincial Park? It is important to note that the MNR has completely omitted any reference to costs and benefits of this decision on park management.

Seventh, the major policy change was made with virtually no widespread public consultation effort in Ontario. This also may be in contravention of the governing Act which states that opportunities for consultation shall be provided.

Eighth, it is inappropriate that permanent homes of private citizens are allowed in an Ontario Provincial Park. This is the current situation at Rondeau. They must all be removed.

Ninth, a policy change of this magnitude should be fully reviewed under the Environmental Assessment Act of Ontario. There is no evidence that this has been done. Therefore, the effort must be halted until this full Environmental Assessment is undertaken and reviewed.

Tenth, during the Harris Government period a group of cottage owners at Rondeau lobbied secretly for Rondeau Provincial Park to be deregulated as a provincial park and turned over to the municipality as a municipal park. Then they wanted their leased land to be sold to them. Fortunately, the Harris Government had the good sense to not accept this proposal. But this action showed clearly that this group does not have the best interests of Rondeau Provincial Park in mind. They are clearly only interested in occupying some of the most valuable Carolinian landscape in Canada for personal benefit.

Therefore, the current proposal must not be approved.

[Original Comment ID: 128920]