Summary:
- Ontario wants to extend Rondeau Provincial Park private leases to the end of 2038.
- There is no evidence that Ontario is respecting Indigenous rights to Free, Prior and Informed Consent (FPIC) in this proposal.
- Wildlands League has opposed the extension of private leases in Rondeau for 50 years. Phase-out has been provincial policy since the 1970s and part of the management plan
- Rondeau has the greatest concentration of species at risk of any park in Ontario and private leases are the single biggest threat, according to Ministry of Natural Resources reports.
- These threats are against provincial law.
- Ontario is subsidizing these recreation leases during a housing crisis when so many are struggling to afford a primary residence.
- Ontario needs to consult with Indigenous Communities seeking Free, Prior and Informed Consent on how to phase-out leases, restore the Park to natural conditions and implement a comprehensive ecological integrity plan for Rondeau Provincial Park. It is the only responsible action for a livable planet, fairness for Ontario citizens and reconciliation with Indigenous Peoples.
Wildlands League is one of Canada’s pre-eminent conservation organizations with over 28,000. We protect wilderness. We collaborate with communities, governments, First Nations, scientists, and progressive industry to protect nature and find solutions that work for the planet and for all. We are a not-for-profit charity that has been working in the public interest since 1968, beginning with a campaign to protect Algonquin Park from development. We are a team of relentless policy experts protecting Canada’s natural world.
This proposal is coming at the worst possible time for the planet. As you are aware, the Earth is currently going through an extinction crisis. Southern Ontario has the highest species diversity, the greatest developmental threats, and the lowest amount of protection (1%) of any ecoregion in Canada. Rondeau has the greatest concentration of species at risk of any park in Ontario. Instead of writing off a significant area of nationally rare and endangered ecosystems like savannahs and freshwater dunes (where most of the lots are located) Ontario should be expanding protection. Given this context, extending private leases and their associated harm to imperiled species and habitats is frighteningly irresponsible.
There is robust evidence of the harm caused by private leases to the ecological integrity of the park (see MNRF, A Summary of Ecological Values and Pressures Associated with Cottage Lot Tenure in Rondeau Provincial Park, 2015). These studies, commissioned by MNRF, highlight numerous and significant environmental problems with these leases. The impacts of the lease lots are significantly greater than other uses of the park. Rondeau is a biodiversity hotspot and includes Canada’s only remaining representation of Carolinian forest on a cuspate sand spit formation. Moreover, approximately 50% of Canada’s endangered Prothonotary Warblers nest in Rondeau. They are being out-competed by House Wrens, which are hyper-abundant because of nest boxes erected by leaseholders. Other endangered creatures like the Eastern Fox snake, Common Five Lined Skink and Blanding’s Turtle are directly threatened by increased mortality of individuals. This includes intentional killing of snakes by leaseholders, according to the MNRF-commissioned report.
Such impacts within a public park are clearly against the law. Section 3 of the Provincial Parks and Conservation Reserves Act, 2006 (PPCRA) makes it clear that ecological integrity is the overriding management priority for parks and conservation reserves in Ontario.
Economic studies indicate that the Crown and by extension, the public, are not earning a fair return on the leases. It is inappropriate that Ontario taxpayers are subsidizing these private lots while leaseholders continue to negatively impact the ecological integrity of a public resource such as a provincial park Ontario is subsidizing vacation homes in Rondeau Provincial Park during a housing crisis when people are struggling to find and afford a primary residence.
Further, it is important to note that Ontario has a legal obligation to seek endorsement from the Legislature for the new disposition of park lands to leaseholders, per subsection 9(4) of the PPCRA. Two percent of the park’s terrestrial area are subject to the proposed leases, which exceeds the 1% threshold triggering the requirement for the Legislature’s endorsement.
There is no evidence that Ontario is respecting Indigenous rights to Free Prior and Informed Consent (FPIC) in this proposal.
In light of these concerns, Ontario must:
- Abandon the current proposal to extend private leases in Rondeau Provincial Park;
- Immediately engage with First Nations to seek Free, Prior and Informed Consent for the Management Plan and how to remove private leases;
- Subject to FPIC engagement, begin to phase out the subsidized private leases;
- Require leaseholders, upon phase out, to remove all buildings and return the sites to natural conditions and native vegetative cover to improve ecological integrity
Sincerely,
Jan Sumner, Executive Director
