I am strongly opposed to the…

I am strongly opposed to the proposed extension of cottage leases at Rondeau Provincial Park. As an ecologist with extensive experience in parks and natural heritage systems planning, natural heritage protection and Species At Risk recovery projects in Ontario, I find this proposal in direct conflict with provincial policies and legislation intended to protect our natural heritage and recover Species At Risk populations.

I am in full agreement with a colleague who states these points extremely well as follows:

"This proposal demonstrates a complete lack of accountability to the people of Canada, and a blatant disregard for numerous provincial policies and legislations. I hereby formally request that you withdraw this proposal and suggest that this action alone will demonstrate leadership consistent with the provincefs stated commitment to:

"1. Promote the efirst priority for resource management in Rondeau (that) will emphasize the protection of the parkfs natural forest, wetland, and beach communities, including all associated flora and faunah (RPP Management Plan, 1991);

"2. Manage Rondeau Provincial Park in accordance with the general planning and management principles for Natural Environment Class Provincial Parks (RPP Management Plan, 1991). This class aims to gprotect the landscapes and special features of the natural region in which they are located, while providing ample opportunities for activities such as swimming and campingh;

"3. Manage Rondeau Provincial Park consistent with the primary purpose of the Provincial Parks and Conservation Reserves Act (2006): gcto 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;

"4. Adhere to the statement on the The Ontario Parks website that this new Provincial Parks and Conservation Reserves gAct is a key initiative in support of Ontariofs Biodiversity Strategy and also complements the provincefs Natural Spaces program and the Greenbelt Act. Ontario is now positioned as a Canadian leader in protected areas legislation. Our world]renowned system of provincial parks, conservation reserves and wilderness areas support natural heritage protection, and provide significant recreational and tourism benefits. The Provincial Parks and Conservation Reserves Act will guide how these special areas are planned and managed ] ensuring that future generations will benefit from a cleaner, healthier and more diverse natural environment.h;

"5. That gParks and Protected Areash are one of the foundations upon which to build actions to protect biodiversity (Ontariofs Biodiversity Strategy, 2005);

"6. To gprotect species that are at risk and their habitats, and to promote the recovery of species that are at riskh (Endangered Species Act, 2007). With specific reference to the ESA, it is worth reminding both your office and that of the federal Environment Minister that the federal SARA states the following (Section 34 (2 and 3)):

"The Governor in Council may, on the recommendation of the Minister, by order, provide that Sections 32 and 33, or either of them, apply in lands in province that are not federal lands with respect to individuals of a listed wildlife species that is not an aquatic species or a species of birds that are migratory birds protected by the MBCA, 1994. The Minister must recommend that the order be made if the Minister is of the opinion that the laws of the province do not effectively protect the species or the residences of its individuals. While the ESA does theoretically fully protect all of the listed SAR found within RPP, the ability of this legislation to fulfill its mandate to eeffectively protect the speciesf is conditional on political will or in this case the very clear lack thereof.

"Invasive Alien Plant Species (IAPS) have been identified as a key threat to various at risk species (federally and provincially designated) and rare habitats found at Rondeau Provincial Park by the Lake Erie Sandspit Savanna Recovery Team (in addition to recovery teams for Fowlerfs Toad, Eastern Foxsnake, and Eastern hognosed snake). A survey conducted in 2008 and focused on the eastern dunes of Rondeau Provincial Park found over 100 invasive alien plant species, with many having been intentionally introduced by cottage leaseholders. In fact, the distribution of a significant number of these IAPS can be directly correlated to trails, campgrounds, and cottage lots within the park boundaries.

"The establishment of Rondeau Provincial Park in 1894 is directly attributable to the eforesight of local residents and governmentf in recognition of its unique evegetation]landform features not represented elsewhere in Canadaf (RPP Management Plan, 1991). The Park is recognized to provide habitat for over 300 nationally, provincially, or locally significant plant species, in addition to globally rare habitat types, and the foresight of past generations is being seriously jeopardized by the poor judgment of the current government.

"This proposed policy provides no rationale for the extension to the current lease termination date ] December 31, 2017 ] for another 21 years. There are certainly no defensible ecological or even broader recreational/tourism benefits resulting from the aforementioned proposal, and the benefits to a small number of elite leaseholders cannot be seen to outweigh the continued detrimental effects to the health of the park and its associated fauna and flora.

"It is truly ironic that the public open house for this proposal is scheduled for today, coincident with the first day of the COP10 meeting in Nagoya, Japan. The very foundation of this global meeting centres on what measures the over 190 signatories to the Biodiversity Convention are taking to reverse trends in biodiversity loss. If the Province of Ontario cannot even manage to achieve this objective on Crown land, how can it possibly justify asking anything of individual landowners in the province?"

Thank you for considering these comments and I trust that the Province of Ontario will make a wise and informed decision on this matter.

[Original Comment ID: 128968]