November 12, 2010…

November 12, 2010

Mr Barton Feilders

Manager, MNR Policy Division – Natural Heritage, Lands and Protected Spaces Branch

Parks and Protected Areas: Policy Section

Ministry of Natural Resources

300 Water Street

Peterborough, ON K9J 8M5

Dear Mr Feilders:

Re: EBR Registry Number 011-1300: Proposed Extension of Cottage Leases at Rondeau Provincial Park.

Nature London (known formally as The McIlwraith Field Naturalists of London, Ontario Inc.), with origins dating back to 1864, has as its motto “To Preserve and Enjoy Nature”. The organization now sees an extended threat to conservation in Canada’s Carolinian Life Zone in the proposed policy (EBR Registry Number 011-1300) to allow an additional 21-year extension of the leases held by existing private cottage owners at Rondeau Park beyond December 31, 2017. This would be inconsistent with, and a disregard for, statements and policies of the Ontario Government to protect the natural environment in existing guideline documents such as the Rondeau Provincial Park Management Plan, 1991; Ontario’s Biodiversity Strategy, 2005; the Provincial Parks and Conservation Reserves Act (2006), and the Endangered Species Act, 2007, in sections outlined below. In the interest of the hundreds of nationally, provincially, or locally significant plant species, globally rare habitat types, migratory and resident birds, other fauna, and several species at risk at Rondeau, Nature London requests that you withdraw this proposed extension. (The extension of the cottage leases was a particularly contentious issue during the preparation of the Rondeau Park Management Plan in the late 1980s/ early 1990s, and the extension of the cottage leases to 2017 was strongly opposed by conservation organizations. As you know, although 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 – until 2017 – as recommended by the Provincial Park Advisory Council.)

1. Rondeau Provincial Park Management Plan, 1991

In 2.0 (Park Policies), 2.3 (Objectives), 2.3.1 (Protection) it is stated that

"Rondeau is a cuspate sandspit formation supporting a Carolinian forest together with significant wetland environments. This particular vegetation-landform feature is not represented elsewhere in Canada. The first priority for resource management in Rondeau will emphasize the protection of the park’s natural forest, wetland and beach communities, including all associated flora and fauna. The objective will be to ensure that these provincially and nationally significant natural landscapes are not lost or further degraded."

It has already been demonstrated (2008 survey of the eastern dunes at Rondeau), that more than 100 invasive alien plant species (IAPS) are present, and many of these can be directly linked to cottage lots, as well as trails and campgrounds. This suggests that Policy 2.3.1 above is not being adhered to effectively to protect native species and eradicate alien species. An extension of cottage leases is only likely to exacerbate the problem. Furthermore, roads and trails associated with the cottages create fragmentation of the environment. To enhance the natural features of Rondeau and protect the fauna and flora there, these should be reduced in number or removed, followed by re-naturalization of the area with native species, after 2017.

2. Ontario’s Biodiversity Strategy, 2005

In 2.2, Biodiversity Goals, it is stated that Goal 1 is to "Protect the genetic, species and ecosystem diversity of Ontario".

In Rondeau, biodiversity can be, and already has been, degraded by both habitat loss and invasive species, two of the threats outlined in the Biodiversity Strategy document. By ending the leases of cottages in 2017, closing trails and roads associated with them, and re-naturalizing the area, the Ministry will improve the overall health and ecological integrity of Rondeau’s forests and wetlands. The Strategy also states that “Wetlands are among the most productive and biologically diverse habitats on earth and are an essential component of healthy natural ecosystems.” With the end of cottage leases in 2017, there would also be a reduction in the number of boats using Rondeau, which would mean less disturbance of vegetation and wildlife, and less pollution of the wetland areas. Together with the active removal of IAPS by Parks staff, this would serve to benefit the natural environment and fulfill Goal 1 above. Removal of the cottage-associated infrastructure and replacing it with native plantings would increase carbon-storage ability and reduce greenhouse gas production in Rondeau, both important mitigating measures to address climate change.

In 5.0, Addressing Ontario’s Biodiversity Challenge, 2005-2010, 5.5, Prevention, dealing with Ecosystem Representation and Integrity, Item 23 states “Enact updated provincial protected areas legislation that enhances ecological integrity and implement the updated legislation by: Reviewing and updating provincial protected areas policy accordingly.”

Recent legislation to protect the environment for future generations should take precedence over the relatively short-term interests of cottage leaseholders.

3. Provincial Parks and Conservation Reserves Act (2006)

“The purpose of this 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.”

Natural Environment Class Parks aim to “protect the landscapes and special features of the natural region in which they are located . . . .”

This Act is meant to support Ontario’s Biodiversity Strategy, and is consistent with Ontario’s Natural Spaces program and Greenbelt Act. When an opportunity arises, such as the ending of private cottage leases at Rondeau, to enhance the natural environment of a protected area, the Ontario government should set an example by sticking to its principles and guidelines to ensure that future generations will have a healthier and biodiverse natural environment. The Act states that “Maintenance of ecological integrity shall be the first priority, and the restoration of ecological integrity shall be considered.” IAPS and fragmented vegetation communities are not consistent with this principle. The Act also states that “. . .ecological integrity includes, but is not limited to, (a) healthy and viable populations of native species, including species at risk, and maintenance of the habitat on which the species depend; and (b) levels of air and water quality consistent with protection of biodiversity and recreational enjoyment.”

It bears repeating that the vested interests of cottage leaseholders, who have had fair notice that their leases will end on December 31. 2017, should not take precedence over protection of unique environmental features and functions for future generations.

4. Endangered Species Act, 2007 (ESA)

The Endangered Species Act, 2007, was legislated to “protect species that are at risk and their habitats”.

The Eastern Fox Snake, a listed species under the ESA, is found in Rondeau Park and some residents have admitted to killing fox snakes. Invasive plant species which threaten native plant species and the habitat of native fauna have not been dealt with effectively in Rondeau. The Ontario government should demonstrate a strong will to enforce its own regulations for species at risk under the ESA, and to fully comply with the federal Species at Risk Act as it applies to Rondeau Park.

Nature London urges you to give careful consideration to the comments made above, and to reject the proposed policy to extend the private cottage leases at Rondeau Park.

[Original Comment ID: 128954]