P52  the park delivers the management plan   - - responses  - - - - -last update Oct 17 07

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links 

Kawartha Highlands Signature Site of Ontario Parks with links to the Charter, EBR posting and the management plan and the access road study (environmental assessment). Note the road study is listed as Potential road study and can be read under the title Draft ESR (environmental study report  - we assume)

The EBR page (Environment board review- -we think) requires the input Kawartha Highlands and will deliver the following number PB05E6008 and page wherein you can submit directly your comments.

items on this page
Readers should note that some letters are direct copy-over or OCR's of documents in which case the formatting may not be copied (text only).

Linked are the documents that were sent in on behalf of the CCRAI regarding the draft environmental study response and the Preliminary Park Management Plan (PPMP)response. These are on this page below. Direct links to the .pdf of these Management plan and environmental/road studydocuments are also held on this site
SGKH to D Coulas re- 8.7.1 Access Roads  --on this page---  direct view pdf   in this folder.
STAKEHOLDER GROUPS OF THE KAWARTHA HIGHLANDS (SGKH) to Dave Coulas   the submission-- on this page---  direct view pdf   in this folder - - support is withdrawn!!!
FOCA submission to EBR
Letter to
Ms. Ireland Smith: parks Ontario from SGKH to cover EBR submission
Comments from the Township Galway, Cavendish and Harvey
Letter to all LLCA cottagers from Rick Meridew with 3 attachments (copy of) Backgrounder and Letter to L Scott 
Major concerns identified  by the Stakeholder Groups of the Kawartha Highlands.
Our written response 
LONG LAKE AND LOUCKS LAKE AND AREA COTTAGERS’ ASSOCIATION response
Ontario Federation of Anglers and Hunters (OFAH) response to the plan.   Please note they withdraw support and see the CC list.
If some of the readers should wonder, who exactly,  is responsible for the  Preliminary Park Management plan we have linked an SGKH set of  minutes  that should clairify the situation  held on this file. We give you the following quote:
<SGKH:  - asked Kim Dunford, Chair - The Management Advisory Board if the MAB had a reasonable time-line to study The Preliminary Management Plan and give its input.
 K. Dunford:  - replied that the MAB had very little time and felt when it saw the Plan that their input was not addressed.  It was felt that The Plan was basically an ‘off-the-shelf’ … ‘made-for-Ontario’ (Ontario Parks) Plan … not particularly, a ‘made-for-KHSS’ Plan.>

Aftermath
As a result of the above, as of 2008,  the herein linked letters have been sent to the Minister Natural resources from SGKH (letter and appendix) and Ontario Federation of Anglers and Hunters (OFAH). requesting a meeting and outlining some of the issues. We understand these meetings will go forward. The readers should note the OFAH letter is from their legal council wherein they officially withdraw their support. We can not help but think the Minister has a clear understanding of the failure of the Management plan (PPMP).
A background to the KHSS is linked and is on this site.  It is a compedium of the information on the many previous pages. A review of the  history of the Access Road on the West side is also linked.






October 21, 2007

Mr. David Coulas
Park Superintendent
Kawartha Highlands Signature Site Park
106 Monck Street, P.O. Box 500
Bancroft, Ontario
K0L 1C0

SENT VIA EMAIL AND CANADA POST

David,

I am writing to you on behalf of the Cavendish Community Ratepayers Association (CCRAI), which represents approximately 400 property owners in the on the west side of the KHSS. This letter represents the comments from the CCRAI regarding the KHSS PPMP EBR#PB05E6008.

As a member of the Stakeholder Groups of the Kawartha Highlands (SGKH), the CCRAI reviewed the response being sent in by that organization, and in principle, we support their document. Our primary concern with the PPMP is that there have been some fundamental changes in both intent and spirit, as it relates to the KHSS Charter and the KHSSP Act. The CCRAI supports the recommendations of the SGKH in this area of their comment document. 

The main concern that the CCRAI has with respect to the PPMP, is that there is no long term commitment for funding for the park operations, infrastructure and resources. In the absence of this commitment, no real planning can be done on a forward looking basis as everything becomes projections or conjecture. Secondly, the absence of funding precipitates concerns over many other issues related to services, site management, road access, facilities, ecological and environmental issues, negative impacts to private land owners in the park and around the park, health and safety, natural heritage and tourism. Thirdly, the absence of funding could result in additional costs and expenses to be borne by the local townships and municipalities which will result in additional increases in realty taxes in areas where there have already been significant increases over the last several years.
Much like any project or initiative, be it private sector or public sector, with a long range plan, there has to be an associated commitment to fund that project or initiative in the long term, otherwise, the result will be a short lived and unsuccessful endeavor.

We have also sent in comments to Karin Wall with respect to the draft environmental study and you were copied on that communication as well. There are concerns being raised by property owners, cottage associations and land owners regarding the proposed use of Beaver Lake Road as the primary western access road to the park. In summary, our concerns with the draft environmental study are;

1. It uses a weighting formula that is fundamentally flawed because it does not balance the interest of all constituents and factors impacted by the KHSS and the recommended access roads.
2. The comparison between the access road alternatives for the west side is not a fair comparison as Beaver Lake Road is not as sensitive an area in terms of ecological and environmental impacts as the area for the proposed new access road to Bottle Lake. Coupled with a weighting formula that is flawed, the outcome of the study can only result in one answer.
3. It assumes a funding commitment to support the recommended activities, which is not the case and will ultimately lead to increased expenses at the township and municipality level. The will most certainly result in an increase in realty taxes to all land owners in the surrounding area to support those new and unplanned for expenses.
4. The very ecological and environmental impact that the study is trying to avoid by not recommending the proposed new access road to Bottle Lake, is already starting to happen and will happen. There is a five year forest management plan that will conduct selective deforestation/harvesting of trees the area north of Lake Catchacoma which will require that logging roads be built. In addition, there has already been a road built into that area by a local mining company that has mineral and exploration rights in the same area.

The larger and most concerning issue is that the output of the draft environmental study re-confirms our concerns relating to the lack of long term funding for the park operations, infrastructure and resources. The recommendation to utilize Beaver Lake Road and Anstruther Lake Road is clearly the least cost alternatives for the Ministry of Natural Resources and thereby Ontario Parks. While anyone can debate the environmental and ecological issues, the cost issue is fairly simple. If the Ministry of Natural Resources and thereby Parks Ontario are following the least cost alternative, the we can only assume that the park will likely never have the budget required for staff and infrastructure to properly manage a park covering this large of a land mass, and enforce the proper usage of the park given the number of campsites and projected park visitors. As a result, all constituents will lose, the public looking to enjoy the park, land owners, cottagers and residents who want to minimize traffic, garbage and noise, and environmentalist, who will see the area be impacted by additional visitors as the park moves towards operational status without adequate measures in place to protect the lands.

Further, we are also very concerned about the “Do nothing” alternative, which is not a viable option as the community has already been experiencing issues relating to park visitors and this trend will only continue with a “Do nothing” approach. In addition, the “Do nothing” alternative will only result in more expense to the local township and municipality for which there is no plan for or budget for. Further, if the township does have to absorb additional unplanned expenses, it will ultimately result in increased realty taxes for land owners in the area.

We believe the first priority should be securing a long term commitment for funding for park operations, infrastructure and staff. The funding needs to be sufficient for the KHSS to be self funding. The KHSS project should not require local township or municipality funding to become a reality. This is a provincial project and it should be properly funded as one by the province. Once this is done, then the issue of access roads, services and facilities required, operational requirements, staffing, and any cost sharing proposals with local townships and municipalities can be discussed with a greater level of certainty. In the absence of a long term commitment to funding, we recommend that KHHS not proceed any further with respect to increased operational status and not undertake any other new initiatives in that regard. 

If you would like to discuss any of our comments in more detail, please feel free to contact me at your convenience.

Sincerely,

 
   
Gary W. Jarosz
President, Cavendish Community Ratepayers Association
c/o 181 Fincham Avenue
Markham,  Ontario
L3P 4B4

c.    Mr. T. Flynn – Township of Galway-Cavendish-Harvey
    Ms. I. Smith – Ontario Parks
    Mr. D. Ramsay – Ministry Of Natural Resources
   


October 21, 2007

Ms. Karin Wall
Project Manager
Totten Sims Hubicki Associates
2000 Argentia Road, Plaza II, Suite 320
Mississauga, Ontario
L5N 1V8

VIA EMAIL AND CANADA POST

Karin,

I am writing to you on behalf of the Cavendish Community Ratepayers Association (CCRAI), which represents approximately 400 property owners in the on the west side of the KHSS. This letter represents the comments from the CCRAI regarding the draft environmental study report published August 2007.

Your document states that “The purpose of the future access roads is to provide access to the park that maximizes opportunities for the recreational activities within the park and minimizes potential conflicts between park users and private property owners, while not seriously compromising the ecological integrity along access routes”. Our position is that the recommendation of the draft environmental study, stating that the preferred plan to utilize Beaver Lake Road as the primary access road to KHSS on the west side, fails to accomplish any of the stated purposes.

1. Beaver Lake in its current state will not maximize opportunities for the recreational activities. This road was built by cottagers many years ago and was not built to normal road safety standards. While the municipality has taken over maintenance of the road, it has not been upgraded to meet normal road safety standards. The increased traffic and the forecasted increase in traffic by KHSS users will create a safety hazard and thereby negatively impact opportunities for recreational activities. 
2. KHSS users have been using Beaver Lake Road for the last number of years and this has caused many documented conflicts with private property owners and the number of these incidents has been escalating recently.
3. While the area surrounding Beaver Lake Road has been ecologically impacted by the road itself, cottage construction and normal rural activity that is normal for cottage country, upgrading the road and bridges as proposed in the environmental draft study, will not only ecologically impact the area further, it will also negatively impact the private property owners along the road and in the area around Beaver Lake Road.

In addition, the draft environmental study, assumes that there is a long term commitment of funding for the park operations, personnel, and for the required upgrades to Beaver Lake Road and the bridges. In reality, there is no long term commitment for funding, and this will negatively impact the private property owners on the west side of KHSS as the cost of any road and bridge upgrades could be down loaded to the tax payers in the area. Further, without appropriate long term funding there will be a lack of resources to enforce park regulations regarding noise, garbage and ecological vandalism caused by park visitors, and the number of these incidents will continue to grow with additional park visitors.

We would also like to point out a number of other issues relating to the draft environmental study.

1. Section 9 of the KHSS Charter, Restrictions on New Park Development, states “No facility that is intended to be used by the public shall be erected or constructed by the Ministry at a location that is within 100 metres of private property that is surrounded by Park lands or abuts Park lands on or after the day this section comes into force.” Upgrades to Beaver Lake Road and to the bridges on Beaver Lake Road will violate this part of the charter.
2. The stated Project Objectives include “to minimize potential conflicts with existing residents/developments”. The use of Beaver Lake Road as an access route to the park has caused many documented conflicts for existing residents over the last number of years, therefore, recommending that Beaver Lake Road be the primary access road on the west side will only result in more conflicts for existing residents. The fact that the park is not yet operational is not a good rationale as to why there have not been the resources to address these conflicts. Again, without a long term funding commitment for the park, the number of these incidents will likely increase.
3. The project alternatives mention the “possibility of additional facilities at the terminus of the road. These facilities included washrooms, a Parks Administration office, visitor centre, garbage and recycling facilities, etc.” Without long term funding for park operations, infrastructure, and personnel, these facilities will not be provided and this could escalate the potential conflicts with park users and area residents.
4. The draft study states in section 3.3.3 Community Character and Cottage Associations, “Many of the cottaging areas in the Kawartha Highlands were originally water access only. These water access cottages supported the development of many small marinas in the area. However, over the last few decades more and more cottages have become road accessible (Plug, 2003).” Interestingly enough, there is no mention of any major ecological impact that these new roads have caused, and therefore in the absence of any indicators, one can only assume that the ecological impact of these roads has been minimal. The Ministry of Natural Resources must have been involved in these road decisions and must have approved them in the past. This begs the question on why the new access road to Bottle Lake would be any different than some of these roads that have built over the last few decades.
5. In section 3.3.5 Public Health and Safety, your report mentions that a parking lot of 20-25 vehicles was constructed. While this was an interim arrangement, it was the best of a bad situation. With no funding commitment for KHSS, something had to be done about the parking issues that were causing conflicts between the park users and the residents in the area and safety issues. This was a concession that the cottagers and resident in the areas agreed to even though it was not in their best interest without any long term funding for KHSS.
6. In Section 5.4.1 West Side of Park, the report states that utilizing Beaver Lake Road is more reasonable than constructing a new road, and also that is seen as serving the greater good for the Kawartha Highlands as compared to the “do nothing” alternative. In Section 6.3 Roadway Improvements, the report states “in an effort to minimize impacts and because traffic volumes are not expected to increase (based on current Park Management Planning goals and objectives) no improvements to the plan or profile of the existing roadway alignments are being recommended at this time”. By not planning road improvements, the report is advocating a “do nothing” alternative. This contradicts your earlier recommendation.
7. In section 6.6, the report talks about the use of signage to control parking, directing visitors to park sites and away from private property. It has been well documented over the last number of years that signage does not work and can only work if there is park staff to enforce it. Without any long term funding for KHSS, it is unlikely that there will be appropriate staff to enforce the signage.

In regards to the alternative of building a new access road north of Lake Catchacoma to Bottle Lake, we would like to present the following information as it relates to the disadvantages of this alternative as detailed in the study.

1. A five year forest management plan has been put in place by the Ministry of Natural Resources in which the Bancroft Minden Forest Company manage the allocation of the tree harvest on the north end of Lake Catchacoma. This will require a road to be built and while this will be a logging road, it will have the same environmental and ecological impact to that area as a new access road going to Bottle Lake. The planned logging area will cover more than half of the proposed new access road to Bottle Lake. Perhaps, the Ministry of Natural Resources could evaluate these two initiatives together as one by leveraging the existing requirement to construct the road for logging, and evaluate it as the long term solution for western access to KHSS. This would help minimize costs as they would be shared by two projects. This forest management plan and planned harvest will likely see every one of the disadvantages noted in the study regarding the new access road to Bottle Lake to happen.
2. There has also been a road constructed this summer by Regis Resources into an area where they have mineral rights. This road traverses east from Highway 507, travels north and then east again into the area of the planned forest harvest north of Lake Catchacoma. While this road was built with the proper approvals, rights and remediation requirements, the ecological and environmental impact into the area of the proposed new access road to Bottle Lake has already commenced. This project and any future ones will likely have every disadvantage listed in the study regarding the new access road to Bottle Lake to happen. 
3. The proposed new access road to Bottle Lake ends at the north end of Bottle Lake and not to the south end where the Bottle Creek ANSI area is located. In addition, regardless of the access route, with additional visitors over the years as forecasted in the area of Bottle Lake area, it is only a matter of time before significant impact to natural heritage, ANSI, and Atlantic Coastal Plain will occur. In fact, it may occur due to the planned logging harvest and approved mineral exploration in the area.
4. The report mentions that the new access road will cross five watercourses and three large wetlands. While this may be the case, we have many examples of the technology and expertise required to achieve this with minimal ecological and environmental impact. The technology and expertise required for this exists today and this is evidenced by many roads and highways in the Kawartha Highlands are and in Ontario.

The study also uses a weighting methodology that is neither appropriate for this project nor reflective of the alternatives evaluated. Firstly, the study uses this methodology to score the environmental and ecological impact of Beaver Lake Road vs a new access road to Bottle Lake. This is akin to comparing apples and oranges. The Beaver Lake Road area is not as sensitive ecologically or environmentally as compared to the area of the proposed new access road to Bottle Lake because the road has been built, there is decades of cottage construction in the area and there are commercial businesses in the area.  Therefore, even without the draft environmental study, a layman could predict that the outcome of the weighting exercise would indicate a higher ecological and environmental impact with the proposed new access road to Bottle Lake.

The weighting criteria do not balance the potential impact to all constituents. Firstly, there is no one weighting criteria to focuses only on the impact to residents or property owners in the area of Beaver Lake Road. Secondly, there are only two weighting criteria that have any focus on property at all, and they are “Community character, enjoyment of property, or local amenities” and “Other projects, uses, persons or property outside the park”. In both of these examples property is not the sole focus but one of many in that weighting criteria. Both of these weighting criteria are valued at 3% respectively, which one could then ascertain, that the total weighting for property is valued at less than 6%. This means that the weightings for Species at Risk, Natural Heritage, Fish or Aquatic Species, Terrestrial wildlife, Natural Vegetation, Land subject to natural or human made hazards, Remoteness, Public or Private recreation, are all weighted more heavily than the impact on residents and cottagers in the area who own land and provide the tax base for the area. At the very least the weightings for impact to residents and land owners should have been at least equal to the environmental and ecological weightings, however this is not the case and therefore weighting criteria is flawed, calculates an inaccurate, and in some cases, an illogical outcome.

The larger and most concerning issue is that the output of the draft environmental study re-confirms our concern relating to the lack of long term funding for the park operations, infrastructure and resources. The recommendation to utilize Beaver Lake Road and Anstruther Lake Road is clearly the least cost alternatives for the Ministry of Natural Resources and thereby Ontario Parks. While anyone can debate the environmental and ecological issues, the cost issue is fairly simple. If the Ministry of Natural Resources and thereby Parks Ontario are following the least cost alternative, the we can only assume that the park will never have the staff and infrastructure to properly manage a park covering this large of a land mass, and enforce the proper usage of the park given the number of campsites and projected park visitors. As a result, all constituents will lose, the public looking to enjoy the park, land owners, cottagers and residents who want to minimize traffic, garbage and noise, and environmentalist, who will see the area be impacted by additional visitors as the park moves towards operational status without adequate measures in place to protect the lands.

Further, we are also very concerned about the “Do nothing” alternative, which is not a viable option as the community has already been experiencing issues relating to park visitors and this trend will only continue with a “Do nothing” approach. In addition, the “Do nothing” alternative appears to have been presented to further justify the Beaver Lake Road alternative by presenting a less than satisfactory solution if the recommendation is not supported by the public. We do not feel that this action lives up to integrity of the “Charter” which is to work in conjunction with all local constituents.

In summary, our position is that while all constituents are concerned about protecting the ecological and environmental aspects both within and surrounding KHSS, we also have to have a realistic and logical balance between those concerns and those of the residents, private land owners, cottagers and for that fact, visitors to KHSS. In addition, there are other projects underway with the forest management plan and the mineral exploration activities that will create the very ecological and environmental impacts that your study suggests that we will create if a new access road to Bottle Lake is undertaken. In view of these factors, we believe the first priority should be securing a long term commitment for funding for park operations, infrastructure and staff. Once this is done, then the issue of access roads can be discussed with a greater level of certainty. As it stands today, regardless of which alternative is selected or approved, there is no guarantee that any of them could be brought to fruition as there is no funding currently available.

I want to thank you for your efforts in preparing this study. I understand the intent of the study and the premise under which your firm was selected. Unfortunately, you can only work with the information that you have, and unfortunately, there are many unanswered questions and information missing relating to park funding and operations over the long term.

If you would like to discuss any of our discussion points in more detail, please feel free to contact me at your convenience.

Sincerely,

 
   
Gary W. Jarosz
President, Cavendish Community Ratepayers Association
c/o 181 Fincham Avenue
Markham,  Ontario
L3P 4B4

c.    Mr. D. Coulas – Kawartha Highlands Signature Site Park
    Mr. T. Flynn – Township of Galway-Cavendish-Harvey
    Ms. I. Smith – Ontario Parks
    Mr. D. Ramsay – Ministry Of Natural Resources
   




October 22, 2007
Mr. Dave Coulas, Superintendent
Kawartha Highlands Signature Site
106 Monck Street
Bancroft, Ontario.
K0L 1C0

Dear Mr. Coulas:

Re: E.B.R. #PB05E6008 Kawartha Highlands Signature Site Plan Review
- 8.7.1 Access Roads

Further to the Stakeholder Groups of the Kawartha Highlands (SGKH) submission on the Preliminary Park Management Plan the SGKH would like to state its support for the comments made in the submissions of The Township of North Kawartha and The Township of Galway, Cavendish and Harvey.

Serious concerns are also being raised by many of our other members on the west side of the site that include property owners, cottage associations and road associations regarding the proposed use of the Beaver Lake Road as the primary western access road.

Some of the specific concerns regarding the Beaver Lake Road are its close proximity to
numerous private properties (within 100 m), the ambiguity of where funds come from for parking, road and bridge improvements and concern that the environmental assessment evaluation criteria does not accurately reflect an appropriate weighting factor to balance the issues, concerns and impacts to all constituents affected by the park.

The SGKH recommends that all of the above issues be clarified through direct dialogue with the Township of Galway, Cavendish and Harvey as well as representatives from local road and cottage associations prior to the approval of a main western access road.


Sincerely,


Len Bourne
Co-Chair SGKH


STAKEHOLDER GROUPS OF THE KAWARTHA HIGHLANDS
Box 219 Apsley Ont. KOL 1A0 705-656-4295
October 18, 2007
David Coulas, Superintendent
Kawartha Highlands Signature Site
Ministry of Natural Resources
106 Monck Street, Box 500
Bancroft Ontario
K0L 1C0

Re: EBR#: PB05E6008
K.H.S.S. Preliminary Park Management Plan

Dear Mr. Coulas,
The Stakeholder Groups of the Kawartha Highlands (SGKH) membership is comprised of localstakeholders who live, work and recreate in and around the Kawartha Highlands Signature Site.

The SGKH is an umbrella group whose members are generally other associations such as the OFAH, Township of North Kawartha, Bancroft Stewardship Council, Recreation Camps and of course virtually every active cottage association in the site. At a personal level many of the people we represent are themselves representative of multiple generations of local stewardship.

The SGKH is also one of the four signatories to the Kawartha Highlands Signature Site Charter Charter). The Charter was the basis of the Kawartha Highlands Signature Site Park Act, 2003 (KHSSP Act).

The Charter and the KHSSP Act were the culmination of years of public consultation and represent a unique, local, ‘made in the Kawarthas’, approach to planning, management and stewardship.

The Charter and KHSSP Act guaranteed on-going local participation, continuation of traditional, activities, protection of natural values, cultural values, and a scientific approach to the protection of ecological integrity. Our members doubted that such a unique approach would fit comfortably into an Ontario Parks planning template but we were assured by politicians, MNR planners and members of the Local Stakeholder Committee that it was both possible and guaranteed in law. With these assurances we signed the Charter.

After long and careful consideration of the Kawartha Highlands Signature Site Preliminary ParkManagement Plan (PPMP) we find it lacking and in many places in contravention of the Charter and KHSSP Act both in word and in spirit.
Our comments and recommendations are provided below.

1.3 Planning Context
This section states that the PPMP is consistent with the direction contained in a number of different documents. It does not mention either the Charter or the KHSSP Act. Given that the KHSSP Act has precedence over the Provincial Park Act and regulations under that Act this oversight should be corrected. (KHSSP Act: page 10, Section 20)

The Charter is the most complete expression of the background, goals and vision for the KHSS.

The SGKH strongly recommends that the Charter should be included in perpetuity as part of the KHSSP Management Plan.

3.3 Cultural Resources
The Charter specifically refers to cottaging as a traditional activity that will “continue to be an integral component of the area”. (Charter: page 5, Vision for the Kawartha Highlands Signature Site)

With 500 permanent cottages in the KHSSP and another 1500 adjacent to it cottaging is by far the most popular activity and its most obvious cultural influence in the KHSSP. Incredibly the one of the few references to cottages in the PPMP is a brief statement implying that the sole role of private cottages was to provide accommodation for American tourists in the “last couple of decades of the 1880s and into the 1900s…” (PPMP page 8, Section 3.3)

A section dedicated to cottaging should be developed in conjunction with local cottage associations and incorporated into the PPMP.

A cottaging section could include:
- A definition of cottaging
- Historic role of cottaging in the area
- The current presence of cottages in the KHSSP
- A list of typical, traditional cottage activities enjoyed on land and water
- An examination of potential stewardship roles for cottage associations.

We also find references to activities and culture of recreation camps to be lacking and would encourage a dedicated section be developed for this important cultural tradition.

Given that many transient users of the KHSSP will be surprised at the existence of cottages and recreation camps in the area we believe that the PPMP should embrace both cottagers and recreational camp users as partners and let potential visitors know of this unique aspect of the KHSSP.

The SGKH is willing to co-ordinate or assist with these endeavors.

3.4 Recreation
This section should include a more complete reference to cottage and recreation camp activities. Cottaging is by far the largest form of recreation in the KHSSP and hunting/fishing is probably the second. Potential visitors should be aware that these activities are taking place.

We are also concerned that certain traditional activities enjoyed by cottagers and/or LUP holders may be overlooked and therefore disallowed. Obvious examples are berry picking, canoeing, sailing, swimming, regattas, water skiing etc.

5.0 Boundary
This section should include a statement that there will be no expropriation of land for the purpose of increasing the area of the Park as per the KHSSP Act. (KHSSP Act: page 4, Section 4)

The PPMP states, “An ecosystem approach allows park management to consider the relationship between the park and the surrounding environment.” (PPMP: page 9, paragraph 5)

Since there has been a tendency towards implementing buffer zones around parks and imposing environmental constraints and since much of the area surrounding the KHSSP is private property a clear statement must be made as to the meaning and possible implications of this statement.

7.0 Overview of Goals Objectives and Desired Outcomes
The inclusion of tables in the PPMP is a good idea. It provides an easy to follow format, especially for those who might be new to the process.

We appreciate the provincial context provided at the beginning of each table. We strongly recommendadding a local context that can be easily taken from the Charter and KHSSP Act.

The SGKH is willing to assist with the drafting of an appropriate local contextual statement for each table.

Table 1. Protection
For years cottage associations have been actively testing water, promoting septic systems, naturalizing shorelines and taking other positive action to promote ecological integrity. Most cottage associations have naturalists and sometimes biologists as members.
We recommend promoting partnerships with interested local stakeholder groups and the inclusion of “citizen science” to supplement park initiatives.

Table 2. Recreation
We believe that “high-intensity day-use” activities promoted as an Ontario goal is inappropriate for the KHSSP and its low-density, semi-wilderness focus. It is even inconsistent with the PPMP that states,“No new day use areas or beach development is proposed in the park.” (PPMP: page 36, Section 8.7.4)

The Goal in Table 2 allows too broad and restrictive a reading as it pertains to traditional recreational activities. Specifically where the Goal states, “while allowing traditional recreational activities to continue in a controlled manner which has the least impact to ecological integrity” it could be interpreted as endorsing the ban of all traditional activities.

We are similarly concerned with the term “authorized traditional recreational activities” used in Objectives 2.1.1. What does “authorized” mean? This term does not appear in the Charter or KHSSP Act. What are the criteria for authorization? Once again this term appears to endorse the deauthorization of some or all traditional activities based on an unstated criteria or whim.

Within this table a positive statement should be made about the continuation of traditional activities including, but not limited to hunting, fishing and cottaging.

Table 3. Public and Stakeholder Interests
The word “allow” in Goal 3.2 should be “guarantee” so that it reads: To guarantee continued access to and enjoyment of private and tenured land.

The corresponding Objective 3.2.1 should not restrict landowners to their property but allow for the enjoyment of the land and water adjacent to their property.

We are encouraged to read, “The Management Advisory Board works with the public and stakeholder groups to assist with the development of partnerships intended to achieve the vision for the park”
(PPMP page 14, Desired Outcomes – last bullet point)

The SGKH believes this will be a positive step to engaging stakeholder groups to the betterment of the park and the fulfillment of the intent of the Charter and KHSSP Act.

The SGKH is willing to work actively and co-operatively with the Management Advisory Board to achieve these goals.

8.3.1.1 Private Recreation Camps
One of the criteria listed for granting a yearly LUP or enhanced tenure is, “an assessment of the effect of the camp on the natural heritage values and/or conflict with other users”. (PPMP: page19, Section 8.3.1.1)

It is our hope that all users who share the KHSSP show respect for each other and their recreational activities. We are also aware that hunting can bring out sincere and even emotional responses on both sides of the issue. With these statements in mind it is important to remember that the KHSSP is a child of Lands for Life and later Ontario’s Living Legacy and that both of these initiatives guaranteed and actually promoted hunting as a living example of our cultural heritage.

8.3.1.3 Boat Caches
Boat caching is a traditional activity that has occurred in the KHSSP for generations. It is used for accessing private property, accessing hunt watches, removal of game, fishing and other recreational purposes. In recent years boats cached by cottagers have aided in search and rescue and fire fighting.

Boat caching does not harm the ecological integrity of the KHSSP and is a traditional activity guaranteed by the Charter and KHSSP Act. The PPMP must be modified to allow boat caching to continue.

The SGKH recommends a free permit system with specific locations and limits to the number of cached boats at any given spot appropriate to the location.

The SGKH is willing to assist park staff in identifying the owners of cached boats, removal of derelict boats and, where needed, the construction of boat racks.

8.3.2 Water Management
Many cottage associations have conducted water testing and have records dating back years. We are confident that they would share the historical information and aid park staff in monitoring water quality on an on-going basis.

8.3.8 Vegetation Management
The PPMP statement regarding a conditional ban on chainsaws in the KHSSP is too vague. It states,“Ontario Parks proposes to prohibit chainsaws in the park except as authorized by authority of the park superintendent.” (PPMP page 24, Section 8.3.8, 6th bullet point)

We have been told this is intended to restrict campers from bringing chainsaws into the park and the park superintendent will authorize other uses. You can appreciate that a chainsaw is an essential tool used by cottagers and LUP holders for fuelwood harvesting as well as road and trail maintenance.

It is the observation of our members that backcountry campers seldom use chainsaws although it is more prevalent with motorboat campers.

The SGKH recommends a ban on cutting live trees. It further recommends a positive statement as to the authorized uses of chainsaws for harvesting fuelwood, road and trail maintenance and for the purposes of search and rescue as well as other circumstances where safety is the concern.

The restriction on harvesting fuelwood within 100 m of private property and within .5 ha of an LUP are short sighted and counter productive to allowing some dead wood to remain as habitat.

The SGKH recommends that fuelwood permits should restrict the amount of fuelwood that can be harvested, not the location of the harvesting. With cooperation between permit holders and the park superintendent it is even possible that harvesting could be targeted, on an ad hoc basis, to blow downs on roads, trails, campsites and other locations identified by the park superintendent.

8.3.10 Fisheries Management
The PPMP allows the harvesting of bait-fish while proposing to disallow the use of bait-fish by anglers. While acknowledging the objectives of reducing the chance of spreading disease and invasive species into the KHSSP we find that the MNR already have restrictions in place that should meet these objectives.

The SGKH recommends allowing the use of bait-fish harvested within the KHSSP for the purposes of angling.

8.3.13 Research
The PPMP states, “Removal of natural materials or artifacts is strictly prohibited, unless authorized by the Park Superintendent, and any materials removed remain the property of Ontario Parks.”(PPMP: page 27, Section 8.3.13, 9th bullet point)

This statement would appear to ban berry picking a traditional activity enjoyed by generations of cottagers. It would also ban the collection of fallen leaves, pinecones, acorns and twigs – the very things small children collect to make a table centerpiece for a Thanksgiving dinner at the cottage.

The SGKH recommends that this point be reworded in such a way as to prohibit the removal of artifacts and natural materials of a significant cultural or natural value.

8.3.14 Inventory and Monitoring
The Charter, KHSSP Act and PPMP all speak to the importance of adaptive management, inventories and monitoring to protect the ecological integrity of the KHSSP.

At the same time the best-case scenario is that the KHSSP might have one staff Biologist and share the resources of district staff with all the other Provincial Parks. The resources available to the park do not appear to be adequate for the job at hand.

The SGKH recommends that partnerships with local stakeholder groups be formed to guide, encourage and avail the park of the resources of the “citizen scientists”. In a time of inadequate staffing and budgets we believe this would be a great asset to the park.

8.4 Recreation Management Policies
This section is silent on the recreational activities of cottagers and those who belong to recreational camps.

The SGKH recommends that the PPMP include a positive statement on the continuation of traditional recreational activities enjoyed by cottagers and recreational camp members.

8.4.1 Services for Visitors
The first bullet point in this section describes the services that may be provided to visitors including, “firewood, camping and grocery supplies, camping equipment rentals, canoe rentals, fishing equipment rentals and souvenirs”. (PPMP: page 28, Section 8.4.1, 1st bullet point)

These services are also provided by local businesses.

As one of its desired outcomes the PPMP lists, “The park’s current contribution to the local and regional economy continues.” (PPMP: page 13, Table 2 Recreation, Desired Outcomes 9th bullet point)

The SGKH recommends proceeding cautiously and consulting with local businesses with any plans to offer services that compete with local businesses.

The KHSSP Act states “No facility that is intended to be used by the public shall be erected or constructed by the Ministry at a location that is within 100 meters of private property that is surrounded by Park lands or abuts Park lands on or after the day this section comes into force.”
(KHSSP Act: page 5, Section 9)

The SGKH recommends including this wording in section 8.4.1.

8.4.3 Hunting
The KHSSP Act clearly states: “11. (1) For greater certainty, a person may hunt, fish and trap in the park in accordance with the Fish and Wildlife Conservation Act, 1997. (2) Section 4 of the Provincial Parks Act does not apply to the Park.” (KHSSP Act: page 12, Section 11 points 1 and 2)

By “mistake” the KHSSP was regulated with a group of other parks under Regulation 665/98 of the Fish and Wildlife Conservation Act. This action contravenes the Charter and KHSSP Act.

The PPMP states, “M.N.R. is considering a change to the regulation to broaden the scope of hunting in the Kawartha Highlands to increase the number of species that can be hunted throughout the entire year.” (PPMP: page 28, Section 8.4.3, 1st bullet point)

This statement is both incorrect and misleading to the general public. It has caused unnecessary confusion and conflict as well as placing hunters in a position of unknowingly breaking the law.

The KHSSP Act states, “If there is a conflict between a provision in this Act and a provision in the Provincial Parks Act or a regulation made under that act, the provision in this Act prevails.” (KHSSP Act: page 10 Section 20)

The SGKH strongly recommends that this regulatory “mistake” be corrected in the most expedient manner possible.

8.4.4 Recreational Fishing
The KHSSP Act clearly states, “Subject to Subsection (2), nothing in this act shall limit or in any way diminish a right of access to or through land that is part of the park where that right was granted under the Public Lands Act or other provincial legislation on or before March 29, 1999.”(KHSSP Act: page 10, Section 17.1)

Yet the second bullet point in this section states, “No person is permitted to use an ATV to access lakes in the park for fishing purposes.” This statement contravenes the Charter and the KHSSP Act.

Stakeholders have been using ATVs to access lakes for the purposes of fishing for many years. With an aging population a restriction of this traditional activity will put a premature end to the enjoyment of fishing to our seniors and handicapped anglers.

The SGKH strongly recommends the removal of the second bullet point.

The PPMP allows the harvesting of bait-fish while proposing to disallow the use of bait-fish by anglers. While acknowledging the objectives of reducing the chance of spreading disease and invasive species into the KHSSP we find that the MNR already have restrictions in place that should meet these objectives.

The SGKH recommends allowing the use of bait-fish harvested within the KHSSP for the purposes of angling.

8.4.6 Mechanized Travel
Motorboats
The Charter clearly states; “Ontario Parks does not intend to apply for any federal restrictions on boating where there is private property.” (Charter: page 10)

Yet the PPMP’s first bullet point under Motorboats proposes to amend existing regulations and place restrictions on motorboat use.

The SGKH strongly recommends that all proposed motorboat restrictions that are in conflict with the Charter be withdrawn from the PPMP.

Snowmobiles
The KHSSP Act clearly states, “A person may operate a motorized snow vehicle in the park if the motorized snow vehicle is operated on a preexisting road or trail, or on a road constructed under subsection 10 (2).” (KHSSP Act: page 9, Section 15.5)

Yet the PPMP’s first bullet point under Snowmobiles limits snowmobile use to preexisting roads or trails for the “sole purpose of” gaining access to private or tenured property, or for recreational purposes on an Ontario Federation of Snowmobile Club (O.F.S.C.) trail.

The SGKH strongly recommends that this unwarranted and unnecessary restriction that is also in conflict with the Charter and KHSSP Act be withdrawn from the PPMP.

The PPMP’s second bullet point under Snowmobiles states, “For the purposes of gaining access to winter fisheries, motorized snow vehicles are restricted to traveling over frozen lakes.” This statement is obviously nonsensical. A snowmobile must travel over approved roads and trails in order to reach the frozen lake as per the Charter.

The SGKH recommends this bullet point be removed and that lakes (frozen or otherwise) are included as part of the approved trail network.

All-Terrain Vehicles (ATVs)
ATVs appear to have become the scapegoat for environmental abuse. While Jeep and ATV rallies are threats to the ecological integrity of the KHSSP and should not be allowed these activities have been limited to a few areas on the west side of the site. On the east side of the site ATVs often come and go without a trace.

Neither the Charter nor the KHSSP Act single out ATVs for specific comment – they are included as “motor vehicles”. See Charter page 16 Definitions.

The SGKH strongly recommends that, consistent with the Charter and KHSSP Act, ATVs should be managed along with all motor vehicles (not separately) and that Jeep and ATV rallies should not be permitted.

8.4.8 Other Recreational Uses
This section is rather limited in its scope on what can and can’t be done in the KHSSP. It does not address traditional activities at all. Cottaging and hunting are two categories of activities that should be included.

The SGKH recommends that the PPMP include a positive statement on the continuation of traditional recreational activities enjoyed by cottagers and recreational camp members.

The SGKH recommends that if a list of approved and unapproved activities is going to be made that a criteria be stated and that the actual list be an appendix that can be updated as required.

8.5.1 Natural Heritage Education
This section discusses both natural and cultural heritage but the title omits cultural.

The KHSSP is a unique park within the Ontario Parks system. The Charter and KHSSP Act celebrate, protect and define that uniqueness – the KHSSP is a “Made in the Kawartha’s” park.

The SGKH recommends that with some minor adjustments the natural and cultural heritage education theme could be made to reflect that uniqueness. For example the history of the area and the historic and on-going role of the diverse stakeholders/partners could easily be woven into the proposed initiative and make it MUCH MORE relevant to and reflective of the KHSSP.

8.5.2 Partnerships
This section is rather weak especially in light of the incredible history of stakeholder participation from the Lands For Life initiative through Ontario’s Living Legacy, the Local Stakeholder Committee, the Charter and the KHSSP Act.

While discussing the role of the Municipalities in the “park management plan and the “ongoing management of the park” the Charter clearly states: “The park will also seek to develop a range of other types of partnerships in order to ensure effective management and involvement of the stakeholders.” (Charter: page 10)

The SGKH strongly recommends that this section be made more positive in the park’s commitment to partnerships with stakeholders as an ongoing component of management planning, monitoring, “citizen Science” and other roles beneficial to the KHSSP.

8.6.1 Marketing
The marketing of the KHSSP should make clear the large number of cottages and recreational camps in and adjacent to the site. Marketing as a traditional park will lead to inappropriate expectations of some members of the public who are seeking a traditional park experience.

Marketing and signage should present the area as the “Kawartha Highlands Signature Site” with the Ontario Parks logo present as is done on the cover of the preliminary plan.

8.7.6 Backcountry Camping
The final bullet point in this section discusses an evaluation of the “backcountry campsites” in the KHSSP and a subsequent evaluation of the carrying capacity of the area.

The PPMP defines “backcountry” as, “A term applied to areas where there are no permanent access roads, developments or settlements. Camping facilities are generally primitive [fire pit, tent pads, pit privy] and a few other facilities exist.” (PPMP: page 41)

Closing campsites on access lakes is consistent with the semi-wilderness recreational vision and goals of the KHSSP.

Closing campsites on access lakes will improve safety when combined with a ban on launching a canoe at dusk and the provision of one or two overnight campsites at major access points for late arrivals. Local commercial operators could also provide overnight accommodations.

Closing campsites on access lakes will also reduce potential conflicts between campers and cottagers.

The SGKH strongly recommends that all non-backcountry campsites be closed.



Upon consideration of the PPMP the SGKH has come to the conclusion that at the root of most of our concerns is the obvious straying from the direction provided by the Charter and KHSSP Act by Ontario Parks in the preparation of this document.

While ecological integrity is the overriding goal it is not the only goal and it is not the goal for which all other goals are sacrificed. It does not justify banning traditional activities protected by the Charter and KHSSP Act. In fact the restriction or banning of any activity must be justified by inventory, monitoring and adaptive management – that is deductive science – not an opinion or a political point of view.

Perhaps the realization that the KHSSP will be under funded has led Ontario Parks to punitively restrict and ban certain activities rather than commit the resources to manage them.

Despite assurances to the contrary perhaps Ontario Parks had trouble fitting this unique area into its park template.

Regardless of the reasons the PPMP has strayed from the vision and direction of the Charter and KHSSP Act to the extent that the SGKH can not support it at this time.

It is in everyone’s interest to create a Management Plan that will reflect the vision, goals and direction provided in the Charter and KHSSP Act.

The SGKH strongly recommends that PPMP planners meet with active, interested Charter Signatories to resolve the issues outlined in this submission.

The SGKH looks forward to working positively and productively to resolve the conflicts between the PPMP and the Charter and KHSSP Act in order to achieve a Management Plan worthy of the history and uniqueness of the Kawartha Highlands.

Sincerely,
Len Bourne
Co-Chair SGKH
cc: Laurie Scott MPP Haliburton-Kawartha Lakes-Brock
Jeff Leal MPP Peterborough
Adair Ireland-Smith, Managing Director Ontario Parks
SGKH Members




FOCA
Federation of Ontario Cottagers' Associations
18-156 Duncan Mill Rd
Toronto, ON M3B 3N2

Mr. Dave Coulas,
Superintendent Kawartha Highlands Signature Site
106 Monk Street
Bancroft, Ontario KOL 1C0
Re: FOCA Response to Kawartha Highlands Signature Site Preliminary Park Management Plan, E.B.R. #PB05E6008

Dear Mr. Coulas,

On behalf of the Federation of Ontario Cottagers' Associations we wish to register the following comments/ concerns in relation to the Kawartha Highlands Signature Site [KHSS] Preliminary Park Management Plan [PPMP]:

1] The Charter Signatories of the KHSS agreed to a park designation, to protect the KHSS, based on the commitment that it would receive "substantial funding~ [Charter page 17] for planning, operating and maintenance costs. For the past three years the KHSS budget has been significantly cut back and the PPMP does not guarantee "substantial funding~ to provide for the resources to fully manage the KHSS. FOCA has great concern, that without proper funding, the ecological integrity of the area may be threatened.

2] The KHSS is a very unique park in that it is superimposed on an area that has been settled, under crown land purchasing policies, by over 500 waterfront property owners. Another 1500 cottages are located on the boundaries of the park. These landowners have enjoyed many traditional activities both on the surrounding lakes and the vast crown land adjacent to their properties. In order to protect these traditional activities a Charter was signed by all stakeholders.

It is of serious concern to FOCA, that the PPMP significantly restricts and/or removes many of these traditional cottage activities, which were to be protected under Bill 100, 2007 and the KHSS Charter.

We trust that the MNR will address these concerns in the next stage of developing a final management plan for the KHSS.

Regards,



Terry Rees
Federation of Ontario Cottagers' Associations, Inc.










STAKEHOLDER GROUPS OF THE KAWARTHA HIGHLANDS
Box 219 Apsley Ont.
KOL lA0 705-656-4295
Subject: E.B.R. # PBO5E6008 Kawartha Highlands Signature Site Prelimina~ Park Management Plan

Dear Ms. Ireland Smith:

On behalf of the Stakeholder Groups of the Kawartha Highlands [S.G.K.H.] and the Ontario Federation of Anglers and Hunters [O.F.A.H.], we request a meeting between representatives of our organizations and you and/or appropriate staff to discuss our mutual concerns in regard to the Preliminary Park Management Plan [P.P.M.P.] and the future process for revisions.

It is the expectation of all stakeholders that the K.H.S.S. Management Plan will be a legitimately derived document based on the Kawartha Highlands Signature Site Act, 2003 [Act] and the Kawartha Highlands Signature Site Charter [Charter].

Stakeholders were promised a "Made in the Kawarthas" plan based on the Charter and Act. In many instances the P.P.M.P. either contravenes the Charter and Act or omits items outlined in the two documents. These discrepancies must be rectified before the publishing of the final Management Plan.

A careful review of the P.P.M.P. combined with discussions with the main author of the P.P.M.P. at the open houses clearly displays a lack of understanding of the detailed negotiations that led to the development of the Charter and Act.

Another great concern, as stated at the open houses, is that there will be no further consultation in the development of the final plan.

We request consideration be given to implementing a similar consultative process as was employed in the development of the Charter. Senior park staff, responsible for approving the plan, meeting with representatives of the two remaining signatories of the Charter, who are also directly connected to the K.H.S.S., would be a positive first step in restoring confidence that a management plan, that truly reflects the spirit of the Charter and Act, can be achieved.

Members of the S.G.K.H and the O.F.A.H. have served as the main stewards of the K.H.S.S. for many decades and will most likely be called upon to continue this important stewardship role in the future. It is our goal to work with the Park staff to implement the vision, goals and guarantees contained in the Charter and Act to ensure the protection of the K.H.S.S. for future generations. Addressing the concerns outlined above would serve as a laudable first step in developing a strong partnership to achieve this goal.

Yours in Partnership

S.G K.H.    O.F.A H.






October 16, 2007 David Coulas,
Park Superintendent Kawartha Highlands Signature Site Park
106 Monck Street, P.O. Box 500
Bancroft, Ontario KOL lC0

Dear Mr. Coulas:

RE: KAWARTHA HIGHLANDS SIGNATURE SITE PARK

The Township of Galway Cavendish and Harvey would like to go on record as stating that any changes to the Charter are unacceptable. The Charter is a formal agreement with the Province developed to assist with the management of the Kawartha Highlands Signature Site.

The Township of Galway Cavendish and Harvey is concerned with the following issues:

1.    The lack of provincial funding to create park infrastructure.
2.    The usage of a Township road without financial support instead of creating a new

access as stated in the Charter.

3.    The lack of funding for Emergency Services.
4.    Policing of the Park
5.    Garbage

Issues of Concern:

• Lack of Provincial Funding

The Township of Galway Cavendish and Harvey is concerned with the lack of provincial funding for the Kawartha Highlands Signature Site. Once again this appears to be another case of provincial downloading. The Township of Galway Cavendish and Harvey will not receive any financial benefit from the Kawartha Highlands Signature Site, however it appears that there will be significant costs. The Ratepayers of GCH have paid for the existing roads and bridges.

If upgrades are needed, it will not be "users" of the park that pay; it will be the Township taxpayers.

• Parking

Where will parking be located? The park is not officially opened and there are already problems with parking. The Township of Galway Cavendish and Harvey in co-operation with the Ministry of Natural Resources constructed a temporary parking lot. The parking off of Beaver Lake Road is at capacity now; if the Park becomes officially open the problem will significantly increase.

• Roads

The existing roads were paid for by the tax ratepayers of the Township of Galway Cavendish and Harvey. If the existing road cannot accommodate the traffic then the Township does not think it is fair that our ratepayers must contribute to upgrades. Currently the Beaver Lake Road is the main access road for the following lakes -Catchacoma, Beaver, Gold, Mississauga and Bottle. We estimate that Beaver Lake Road services approximately 1,000 cottages. We also have ratepayers from North Kawartha using our roads for access as it is closer to their property.

• Traffic problems for our ratepayers

As previously mentioned the Beaver Lake Road services approximately 1,000 cottages and is at capacity now. It is not feasible to add additional traffic to this road.

• Garbage

The proposed plan is to have campers take their garbage with them when they leave the park. Who is going to police this? We are having problems now with garbage being left behind and again the park is not yet officially opened. Who is going to police the situation and how can you be sure that there are no bottles or cans taken into the park? In an ideal world the garbage would not be left behind but we realize that this is not the case. The issue of garbage disposal needs to be addressed.

• Bridges

We know that the existing bridges cannot hold any additional traffic. Who will be responsible for widening the bridges? The County of Peterborough is in the process of replacing a bridge over the Mississauga River at a cost of over $1 million dollars. Who does the Ministry think will pay for any upgrades or repairs? Surely you can't expect our ratepayers to pick up the tab?

• Land Use - ATV versus Horseback Riding and Mountain Bike Riding

We question the logic of allowing ATVs on existing trails but not allowing horseback riding or mountain bike riding. It would seem that these activities would be less intrusive on the environment than ATVs that burn gas. The horseback riders and mountain bike riders must be on a trail so we do not see how permitting these activities would be detrimental to the environment.


• Emergency Services

Who will pick up the tab for Emergency Services? The Township of Galway Cavendish and Harvey pay the Ontario Provincial Police $763,000.00 per year for policing. This is based on our number of occurrences. If there are an increased number of occurrences as the result of the Kawartha Highlands Signature Site, who is going to pay for the extra costs? You cannot expect our ratepayers to pick up the tab.

If campers get lost in the Kawartha Highlands Signature Site, it will be the Township of Galway Cavendish and Harvey's Fire and Rescue Department that will be called in. Again, we question who will pay for this service?

• Monitoring the Site

Who will monitor who goes in and who comes out of the site, especially with day trippers? If the Park had its own entrance then all visitors to the park would have to check in and check out.

Summary:

The Township of Galway Cavendish and Harvey is very concerned with the cost of the Kawartha Highlands Signature Site for local tax payers. It does not seem equitable that people who benefit from the Site do not pay for it.

If the Provincial Government wants an Ontario Park then it should provide adequate funding to support such a venture.

Respectfully submitted,
Pat Kemp, A.M.C.T., C.M.C. CAO/Deputy Clerk

p.c.    Minister of Natural Resources

Laurie Scott,
MPP Elect Jeff Leal,
MPP Elect Barry Devolin,
MP Township of North Kawartha Council






To All LLCA Cottagers,

Re: Preliminary Park Management Plan

Please find attached some documents with background information and
resources related to the Preliminary Park Management Plan. Copies of the
attached documents have also been sent to all members by mail.

The deadline to respond is October 22nd.

You can respond by email, letter or on-line at the EBR Registry. Details
are provided in the attached documents.

Please take a few minutes to read the documents. If you are not familiar
with the Charter or the Preliminary Park Management Plan take the time to
understand them.

Did you know that the Preliminary Park Management Plan will ban such
simple pleasures as picking blueberries and riding a mountain bike? Did
you know that caching a boat to use for fishing on a back lake will also
be banned? Are you aware of the restrictions being placed on ATV and
snowmobile use?

It is essential that we all comment on the issues that are important to
us.

It's up to you.



Rick Meridew
Attachments A"The Backgrounder"  ,B Letter to Laurie Scott, and C are below

a)-------------
    URGENT!

Deadline for Response to the
KHSS Preliminary Park Management Plan:
October 22, 2007
October 12, 2007                    EBR Registry Number: PB05E6008

To All Members,

This is your final opportunity to comment on the Kawartha Highlands Signature Site Preliminary Park Management Plan (PPMP)  – the document that will determine what your cottage experience will be like in the future.

You may be thinking, “Why should I care?” 

The PPMP will dictate what you can and can’t do off your property. The land surrounding our cottages is no longer Crown Land it is a Park and Park rules will apply – and Park fines of up to $25,000.00 can be charged to those who don’t follow Park rules. The PPMP is the guideline for the Park rules.

This package provides background information, links to resources and documents to assist with your submission.

General Areas of Concern

Our members, the Stakeholder Groups of the Kawartha Highlands (SGKH) and the Ontario Federation of Anglers & Hunters (OFAH) have concerns with the PPMP. The SGKH and OFAH (Charter Signatories) believe the PPMP contravenes the Charter and KHSSP Act (Bill 100) in many places.

1. Retain the Charter: There has been talk that the Charter will cease once the PPMP is finalized. The Charter is the most complete statement of the agreement of the Signatories and must be retained for the protection of our rights. The Charter contains background information and direction not included in the KHSSP Act.

2. Respect the Charter: Stakeholders were promised a “Made in the Kawarthas” plan based on the Charter, but much of the PPMP is a template commonly used for all parks with minimal direction from the Charter. 

3. Include Cottaging: The KHSS is a unique Park superimposed on over 500 cottages and 50 recreation camps. An additional 1500 homes and cottages are adjacent to the Park. The Charter and the KHSS Park Act were developed, in part, to protect our traditional activities and rights. There is nothing in the PPMP to define “cottaging” or the traditional cottage activities that are being protected – only what is banned and restricted. Cottaging is not just what we do on our private land, it includes the traditional activities we do off the dock and on the land around us. PPMP silence on cottaging combined with various bans and restrictions in the PPMP and Provincial parks Act will diminish the enjoyment of our cottage life and traditional activities.

4. Acknowledge Local Stakeholders: We have been stewards of the land for over 100 years during which time there has been significant improvement in the environmental and ecological integrity. Major ecological threats to the Park today are abusive camping, Jeep and ATV rallies. There is no scientific evidence that our traditional activities have a negative affect. In fact we have had a positive influence.

5. Improve Funding: The Charter Signatories agreed to a Park based on “substantial funding”. (Charter page 17) Every year the park budget has been cut back and it looks like under funding will continue.

6. Protect Traditional Activities: Under funding and staff shortages may require cottagers, anglers, hunters, and trappers to continue to act as stewards. Our stewardship including assisting with search and rescue, reporting abusive users, assisting with threats of fire etc. will be marginalized by PPMP restrictions and/or bans on cached boats, use of small motors on back lakes, ATVs and snowmobiles. Further more these should be protected as traditional activities.
Specific Examples

1. Snowmobile & ATV Use: The PPMP states: “Private and tenured landowners are able to access their properties and enjoy activities on these lands as they had prior to the establishment of the park.” (p. 14) Traditionally we have also used snowmobiles and ATVs to visit back lakes and other cottagers. Both activities could be banned with the current wording.
- We recommend continuing these traditional activities with a free permit on approved trails.

2. Boat Caches: Boat caches have been enjoyed for generations for the pursuit of fishing on back lakes. Previous discussions and the Management Options document suggest boat caching continue but be regulated by permit. The PPMP restricts boat caching to trappers, bait-fish harvesters, commercial out-post operators and those who require it to access private property or tenured land.
- We recommend continuing this traditional activity via a free permit system, for the purpose of angling, hunting, safety and stewardship. Our association offers to assist with: establishing appropriate caching locations, identifying active cached boats, removing old boats, reducing the number of cached boats and the construction of storage racks.

3. Hunting: The charter clearly states: “11[1] For greater certainty, a person may hunt, fish and trap in the park in accordance with the Fish and Wildlife Conservation Act, 1997. [2] Section 4 of the Provincial Parks Act does not apply to the Park.” (p. 12) By mistake the KHSS was grouped with a number of parks at regulation and hunting was mistakenly put under the Provincial Parks Act. This has lead to significant restrictions.
- We recommend that this mistake be corrected immediately as it places the park in contravention of the Charter and KHSSP Act.

4. Outboard Motor Restrictions: The Charter clearly states; “Ontario Parks does not intend to apply for any federal restrictions on boating where there is private property.” (p. 10) [i.e. Buzzard Lake].
- We recommend that the tradition of using small motors on back lakes continue for accessing private and tenured land, fishing, search and rescue and fire assistance purposes.

5. Camping: The PPMP defines backcountry as “A term applied to areas where there are no permanent access roads, developments or settlements. Camping facilities are generally primitive [fire pit, tent pads, pit privy] and a few other facilities exist.” (p. 41) By definition backcountry camping should not take place on access lakes or lakes with private property. At our AGM there was unanimous support for Trudy’s recommendation to close all campsites on Long and Loucks Lakes (to break the history of motorboat camping) and then review this in the future.
- We recommend closing all campsites on access lakes and provide some overnight campsites at major access points for those who arrive too late to ensure arrival at their campsite in daylight.

6. Cottaging: In the Vision Statement for the KHSS in the Charter clearly states: “Traditional activities including cottaging will continue to be an integral component of the area and diverse low-density recreational opportunities will continue to be available.” (p. 5) Yet the Plan is virtually silent on the topic of cottaging and every reference to access limits the use of ATVs, snowmobiles and motorboats to going to the cottage – with no guarantee of the enjoyment of those recreational vehicles on the surrounding trails and lakes. The use of your motorboat, canoe or kayak may or may not be subject to a permit. Berry picking and mountain biking are banned. Obviously cottaging has not been included as an “integral component” of the KHSS.
- We recommend working with cottage associations to develop a definition of “cottaging” and a sampling of typical “traditional cottage activities” that can be acknowledged in the PPMP.

7. Partnerships: The Charter clearly states: “The park will also seek to develop a range of other types of partnerships in order to ensure effective management and involvement of the stakeholders.” (p. 10) Yet the PPMP provides no firm guidance on partnerships.
- We recommend the PPMP includes partnerships with local stakeholder groups such as the SGKH and cottage associations and include them in future stewardship and management planning.
To further assist your response to the Plan we have enclosed:

∑ Blank Kawartha Highlands Signature Site Preliminary Park Management Plan response sheet. 
∑ Minutes of the LL&LLCA Information & Discussion Meeting held on Sept. 9, 2007.

Additional resources are available online: http://www.ontarioparks.com/english/kawa_planning.html

∑ KHSS Charter is the 1st link on the left.
∑ Link to the EBR Site is the 2nd link on the left.
∑ The Preliminary Park Management Plan is the 4th link from the bottom on the left.

You can respond via letter, response sheet, email or online at the EBR web site. Encourage your family and/or friends who visit the cottage to respond.

You MUST put the EBR# on all responses: PB05E6008.

Direct your responses to:

David Coulas, Park Superintendent
Kawartha Highlands Signature Site Park
Ministry of Natural Resources
106 Monck Street, Box 500
Bancroft Ontario K0L 1C0
EBR#: PB05E6008
Phone: (613) 332-3940 Ext. 255       
Fax: (613) 332-1800       
eMail: kawartha.highlands@mnr.gov.on.ca

You may wish to tell MPP Laurie Scott what you think.

Laurie Scott       
14 Lindsay St. N.
Lindsay ON
K9V 1T4
eMail: laurie_scott@ontla.ola.org

At the SGKH meeting held Monday October 1st Dave Coulas, Park Superintendent mentioned that he had received 200+ email comments over the weekend. My guess is that the majority of those emails came from people with no ties to the area and that most of them called for more restrictions on traditional activities – their opinions are being heard and taken into consideration. Are yours?

The SGKH, OFAH, LLCA Executive and Township of North Kawartha have all gone to bat to protect cottager’s rights in the new park but numbers do matter and if you don’t comment Ontario Parks will assume you agree with the Preliminary Park Management Plan as it stands.

Cottagers; your silence on the PPMP will be construed by Ontario Parks as consent.

The future is up to you.

 

Rick Meridew
President, LLCA




B)-------
    PRELIMINARY PARK MANAGEMENT PLAN

    INFORMATION & DISCUSSION MEETING

            September 9, 2007

The meeting was called to order at 10:30 am with 22 cottagers in attendance.

President Rick Meridew stated that the purpose of the meeting was to discuss the KHSS Preliminary Management Plan (PMP) and share our thoughts and reactions.

Important things to consider:
1. How would the implementation of the PMP impact our cottage activities?
2. How would the implementation of the PMP impact our other traditional activities?
3. Does the PMP reflect the terms of the charter?
4. Does the PMP reflect the spirit of the charter?
5. Are there general issues that the PMP does not identify?
6. What specific activities do you participate in ‘off the dock’ and ‘behind the cottage’ and how would the implementation of the PMP impact them?

By the end of the meeting we had come to consensus on all issues we discussed. The main discussion points are included below with a reference to where they correspond to the PMP.

Based on the points contained here and after the open houses and further email input we will create a response from the association.  Individual responses are strongly encouraged as well.

Note: The term “semi-wilderness” is used to describe the KHSS due to the fact that there are 500 private cottage properties within the KHSS and approximately 1650 lakefront properties adjacent to the site. The term “wilderness” would imply that there was no private property within the park.

Concerns with the document:

Goals 1.1 – Ecological Integrity
∑ Doesn’t talk to the traditional activities coexisting with cottagers.
∑  Needs to enshrine the existing values of cottagers and other traditional users.
∑ The definition of traditional activities needs to be more specific. What does ‘authorized traditional activities’ mean?
∑  It needs more balance.
∑  They have already begun delisting traditional activities i.e. ATVs, snowmobiles. Traditional use should be allowed unless proven, through science, that there is ecological damage caused.
∑  Does lack of funds sometimes lead to drastic measures? i.e. ban ATVs and bait fish because they can’t afford to monitor them.
∑ They need to redefine “cottaging” to include activities which we do off the dock and on the surrounding land, not just on our own property. We should get support through FOCA for this.

Park Values 3.3 – Cultural Resources
∑ While there is some discussion of post contact history and culture in this section it is really never mentioned again in any of the policies. Only Aboriginal heritage is mentioned. Why? This park was supposed to reflect the cottage community as well as the traditions of logging, hunting and trapping.
∑ Further reference to traditional activities within the Policies portion of the PMP is to limit or ban them. This is not in keeping with the goals of the Charter.

Park Policies 8.3.1.3 – Boat Caches
∑ Boat caches are a traditional aspect of hunting and fishing as both a tool and access method and as such should be protected under the Charter
∑ The numbers in the response to the questionnaire don’t justify the severe restrictions.
∑ The whole aspect of stewardship lost i.e. assistance with fires, rescue etc. Need to empathize use of cached boats for emergency response.
∑ Limiting travel by cached boats forces hunters to have watches closer together and to cottages. This is a safety issue.
∑ SGKH may offer to assist in facilitating permits, policing sites, erecting racks, in cooperation with the park.
∑ We do support no cost permits and the need to have reasonable numbers of cached boats.

Park Policies 8.3.8 – Vegetation Management – no chainsaws
∑ “Ontario proposes to prohibit chainsaws” should be changed to clarify chainsaws being a permitted use for property owners, recreation camp permit holders and fuelwood permit holders.
∑ There can be no restrictions on private property.
∑ Again the incidents of stewardship not taken into account i.e. cutting trees on trails etc. for the purpose of safety.

Park Policies 8.3.8 – Fuel wood permits
∑ The restrictions of “within a 100 m. of the harvester’s own property” and “restricted to within 5 m. on either side of the approved motorized vehicle access road and trail system” or within the area of an LUP are not feasible in many cases.
∑ There should be no restrictions on distance as there is already a restriction on quantity within the fuelwood permit.
∑ Bringing  wood in from outside could present risk of decease.
∑ If the park can sell wood, where is it coming from?

Park Policies 8.3.10 – Fisheries – live bait
∑ There are already zones determining live bait use that take into consideration protection from invasive species and disease.
∑ There are 14 commercial bait fisheries licenses within the KHSS which are allowed to continue yet anglers are not allowed to use the bait fish they harvest.

Park Policies 8.4 – Recreation Management policies
∑ Traditional recreational activities for cottagers should be built in. We need to add all activities which we as cottagers associate with cottaging off the property as well as on.

Park Policies 8.4.1 – Services For Visitors
∑ To conform to the Charter it should include that no new facilities will be built within 100 m. of private property.

Park Policies 8.4.3 – Hunting
∑ Doesn’t adhere to the Charter.
∑ Need to be strong about preserving the status quo as is stated in the Charter.
∑ Some trails are not on the M.A.B.’s maps. There may be two sets of maps, one for the public and one for the hunters, trappers etc. It was promised that hunting and trapping trails would be excluded from the public trails for reasons of safety.

Park Policies 8.4.6  - Mechanized Travel
∑ The Charter says they can’t restrict motors on lakes with private property. The Management Plan restricts. It can’t be allowed to happen!
∑ It would be illegal to restrict motors to property owners on certain lakes without 100 % agreement by property owners on the lakes.
∑ Again the issue of use of motors for rescue, fire etc. is ignored.
∑ Motorboat camping definitely needs to be addressed however.
∑ “Overnight mooring” refers to houseboats.
∑ “Travel on frozen lakes” needs to be corrected to “travel on frozen lakes and trails”. Property owners and LUP holders are being stranded on their own property once they arrive.
∑ The restriction on ATVs for the purpose of ice fishing is contrary to the Charter.

Park Policies 8.4.7 – Shore Lunch Sites
∑ It is best to be sure you have purchased your shoreline so that visitors can’t picnic or even camp there.

Park Policies 8.4.8 – Other Recreational Uses
∑ Again they need to list cottage type activities i.e. mountain biking should be allowed for landowners and LUP holders, on existing trails for the purpose of exercise and travel. One cottager has been a member of the Ontario Mountain Biking Team and practiced from the cottage.
∑ Day use should be minimized in areas of heavy cottage traffic and activity.

Park Policies 8.6.1 – Marketing
∑ There should be minimal marketing as there are minimal facilities. To date it has been restricted to the web site.
∑ Signage should not be “Park” but rather the Park logo and the title “Kawartha Highlands Signature Site”.

Park Policies 8.7.6 – Backcountry Campsites
∑ Both the KHSS Recommendations Report and the KHSS Charter define camping as backcountry. The PMP defines backcountry “a term applied to areas where there are no permanent access roads, developments or settlements”. One of the major threats to the protection of the ecological integrity of the area is the increasing abusive motorboat campers on lakes that have permanent access roads. They are often large groups exceeding 9. Strategies should be developed to accommodate large groups.
∑ It should read, “There be no campsites located on lakes in the KHSS that have permanent access roads”.
∑ Beaver Lake Road and Anstruther Lake Road are proposed to be the ‘primary access roads’ for the KHSS but not the only access roads. The Long Lake Road will continue to be a busy access point.

OTHER ISSUES:
LLCA Access
∑ Need to be negotiations with park staff, the association and the lodge owners to discuss future management of the access point.
∑ Concerns include garbage, night launches parking, camp site reservations etc.
∑ Concern that the park may go into competition with the lodge for canoe rentals etc.

Buzzard Lake Portage & Area
∑ The private docks are part of the traditional uses. They need signage as private docks.
∑ The public dock is in bad repair.
∑ Negotiations need to take place with landowners and LUP holders to address issues.
∑ The small island across from Brown’s needs a “no camping” sign.

Made in the Kawarthas?
∑ This park was supposed to be unique and reflect the traditional uses by local groups and individuals. This is poorly reflected in the PMP and it must be put back or we will lose it.
∑ No recognition of the stewardship role of local stakeholders – although it is becoming apparent that the park won’t have the funding to do the job on their own.

WHAT YOU CAN DO:
∑ Attend the open houses on Saturday, September 15 at Wilson Park Community Centre or Sunday, September 16, at Cavandish Community Centre and voice your concerns.
∑ Write to your MPP re your concerns. You can use the response from the LLCA as a model if you wish. The LLCA draft response will be circulated in a couple of weeks.
∑ E-mail your list of cottage activities on and off your property to Peter or Rick, for inclusion in the response.
∑ Respond individually before October 23 to:
    David Coulas, Park Superintendent,
    Kawartha Highlands Signature Park,
    P.O. Box 500,     106 Monck Street,
    Bancroft, Ontario, K0L 1C0
    Quote the EBR Registry Number: PB05E6008



C)----
ED note   --- This was a photo copy of the Preliminary park management plan comment sheet passed out at the open houses. WE can not import the format but any reader can go directly to the link    PB05E6008 and page wherein you can submit directly your comments by pressing the comment button.








 
The following is a list, ---, of some of the major concerns identified at our Sept., 9th meeting  of the Stakeholder Groups of the Kawartha Highlands. You may want to comment on those that are important to you and/or you know are important to your neighbour. The important thing is to comment!!!

General Comments
The designation to make it a Park was based on the assurance that it was to be a fully funded and fully organized Park. This is a promise that appears to be broken.
This is a very unique Park that was superimposed on over 500 cottagers and over 50 hunt camps. The Charter and the KHSS Park Act were developed to protect our             traditional rights. The Preliminary Park Management Plan [PPMP] does not honour these documents in that it restricts many of these traditional rights.
This was to have a made in Kawarthas management plan, but the preliminary plan appears to be cut from a template that is commonly used for all parks without much             regard for the Charter.
We have been the stewards of the land for over 100 years. We have witnessed significant environmental advancement [improved ecological integrity] during this period. Except for abusive camping and outsiders intruding with jeep and ATV rallies there is no scientific evidence that our traditional activities have had any negative affect on the     area. In fact we have had a very positive influence.
Due to the shortage of money to fully manage the Park, the future protection of the area will most likely depend heavily on cottagers, anglers, hunters, and trappers etc as the     stewards of the Park. Our continued support including; assisting with search and rescue, reporting abusive users, assisting with threats of fire etc will obviously be needed. Our cached boats, use of small motors on back lakes, ATVs on official trails and snow machines are essential for this type of assistance.
Cottaging is not just what we do on our private land, but it is about the many activities we do off the dock and on the crown land behind. To restrict many of our traditional     activities will not only limit the amount of stewardship support we can provide, but it will change our cottage life, as we have known it in the past.

Specific Comments related to the Preliminary Park Management Plan
 The PPMP states [page 14] “Private and tenured landowners are able to access their properties and enjoy activities on these lands as they had prior to the establishment of         the park.” The major restrictions in the PPMP affecting traditional activities such as: snowmobiling, cached boats, motor restrictions on back lakes, ATVs on official trails     etc basically removes/restricts these activities and isolates one on their own property after accessing the property.
 The Charter suggest boat caching be regulated by permit- not be restricted as in the PPMP. This would mean that cottagers/hunters could not have any cached boats on             back lakes except to access a property. We recommend this traditional activity, for the purpose of angling, hunting, safety and stewardship, be continued and regulated by     a free permit. Our association is offering to assist the park superintendent in: identifying active boats cached in the KHSS, appropriate caching locations, streamlining and     amalgamating the number of boats cached and where appropriate assisting with the construction of storage racks.
 The charter clearly sates; “11[1] For greater certainty, a person may hunt, fish and trap in the park in accordance with the Fish and Wildlife Conservation Act, 1997” By         mistake the KHSS was grouped with a number of parks and hunting was mistakenly put under the park act which could lead to significant restrictions. This mistake             should be corrected immediately.
 The charter clearly states, “Ontario Parks does not intend to apply for any federal  restrictions on boating where there is private property.” [i.e. Buzzard Lake]. The only         indication of motorboat controls stated in the Charter is, “including horsepower limits on lakes that are entirely surrounded by park land.” We recommend that this                 tradition of using small motors on back lakes continue for recreation, search and rescue and fire assistance purposes.
 Camping-The PPMP defines backcountry as “A term applied to areas where there are no permanent access roads, developments or settlements. Camping facilities are             generally primitive [ fire pit, tent pads, pit privy] and a few other facilities exist. At our AGM there was unanimous support for Trudy’s  recommendation to close all             campsites on Long and Loucks Lakes to break the history of motorboat camping. In future consideration might be given to opening a few family campsites if and when a     reservation system is in place, proper tools of enforcement are developed and sufficient enforcement officers are provided. At the Sat. open house it was suggested that the Park might provide a few campsites for late arrivers. From our experience this would encourage launches after dark, which is a major safety issue. For safety reasons a better     recommendation would be to provide emergency campsites at the access point [the lodge already does this] and/or directions to the nearest drive in commercial                     campground or motel.

 

 







RESPONSE TO
KAWARTHA HIGHLANDS SIGNATURE SITE PARK
PRELIMINARY PARK MANAGEMENT PLAN


October 9, 2007
To whom it may concern:

Thank you for the opportunity to respond to this document.  I and my family are a members of The Catchacoma Cottagers Association, The Cavendish Ratepayers Association, The Stakeholder Group of the Kawartha Highlands, (SGKH), and the Federation of Cottagers Association, (FOCA).  We will be copying these groups with our response.

We have been in attendance at all your open forums and have followed the development of the Signature Site with considerable interest.  Our cottage is located at the end of the Beaver Lake Road on Catchacoma Lake, south of the Bottle Creek Dam.  We have reviewed your plan in as much detail as current timeframes afford us and we would like to make the following comments:

1. Precedence Statement Needed:

As outlined in the Signature Park Access Road Study, it would be our understanding that this plan is subservient to the Kawartha Highlands Signature Site Park Act KHSSP of 2003, and the KHSSP Charter, both of which take precedence over the Provincial Park Act.  As is common in these kind of documents, a precedence statement needs to be made in order that there be no confusion. 

The paragraph found in Section 2, page 5 (ie. “Kawartha Highlands…use policy atlas”), is not sufficiently clear.

We also remind you of the Kawartha Highlands Signature Site Charter which states on page 3 – Purpose of Charter …to...  “Provide interim direction for the management of the recommended park until such time as the area can be protected under legislation and a management plan is provided.”

2. Partnership Denied:

With regard to Section 1.4 pages 2-3, the methods chosen by the Management Board and Mr. Coulas do not meet the requirements of public consultation.  The meetings are not chaired and without public record which facilitates the loss of many valid comments and suggestions and erodes the integrity of the Ministry commitment to Stakeholder consultation.  We attended those meetings and heard many comments by the public and many promises by Mr. Coulas and staff, which if publicly recorded, would present a very different view to what is presented in this report. 

In summary, the Signature Site process was to be a new joint partnership approach to management.  Mr. Coulis and staff have not honoured the MNR initial and on-going statements of joint management. There has been no effective public consultation and Mr. Coulas has put forth an agenda of promises that while calming the public clearly contradict the Ministry’s public statements regarding the unavailability of resources. This essentially negates most the stakeholder concerns brought forward. 

3. Boundaries:

In section 5 page 9 last paragraph, the report states “Ontario Parks will support in principle…to sell their property”.  It is our understanding that there were to be no expansions of the Park under any circumstances and that was the purpose of the NO Expropriation statement in Charter on page 8.  We pointed this out to members of the Management Board, who denied any expansion plans and suggest this is only with regard to takeover of long abandoned properties (eg. Quarries).  If such is the case, than it should be clearly stated in the Management Plan that there be no expansions of the Park Boundaries and no acquisitions of private property either now or in the future. Also, that the buffer zones that have been established around other Provincial Parks and that are a defacto expansion of those parks will not occur.  In fact, if any buffer is required, that those buffers will be taken from within the existing Park.  Further, that no projections of ideals, hard philosophies, etc. will be placed on Crown Land beyond the Park. 

In simple terms, these two Townships have paid the Ecology mandate in full already.  The goverence of any land outside the Park and the private land within the Park are the pervue of the Township and no other governing bodies.  The sale and development of Crown Land in and around the Park will be allowed to resume.

Therefore, item 3.2 page 14, (Table I --- Goals), be changed from “to allow continued access…” to “to guarantee access and enjoyment of private and tenured...”

Further, in the desired outcomes paragraph of this section, the activities of cottagers are undefined at this time. It is our position that those activities should not arbitrarily be decided on by MNR or Management Board.  We recommend that those activities be defined by such organizations as FOCA to a provincial standard in conjunction with MNR. 

4. Access Roads:

The direction of the Charter is very clear on this subject as it relates to the western access.
See Page 11 Limit on location of roads that says: -
”The western public access road will follow a corridor that ensures the minimum length of construction within the boundaries approximately defined by lots 16 to 29 in concession VIII, IX, X and IX in Cavendish township.

We do not agree with the position of this report or the conclusion of the Environmental Assessment Report and questioned Ms. Wall in regard to her recommendation on the Eastern side.  We confine our comments to the road north of Catchacoma vs. the Beaver Lake Road.

 Question 1
Were there any clear and insurmountable obstacles, environmental or physical to the road north of Catchacoma? 
Answer 
“Yes, read the environmental report”.
After reading this report, there are no such environmental or physical impediments.
Question 2
 Had Ms. Wall read the Meteek report and did she have a copy?
Answer
 “No”.
    We suggested that we would undertake to provide a copy.
Question 3
 Some 25 years ago the Townships undertook construction of a road east from Beaver Lake to Anstruther Lake.  That road was in the same location as the current trail and proposed parking lot (yellow area).  It is our understanding that MNR, in a response to environmental studies at that time, halted that road and cottage construction on Beaver Lake as the area was deemed to be ecologically sensitive. Was Ms. Wall aware of and had she reviewed these reports?
Answer
 “No”.
Question 4
Was Ms. Wall aware of the lake level on Bottle Lake and Beaver Lake and was she aware of the height of land that separated the two?
Answer
 “No”.
Question 5
 Was Ms. Wall aware that any activity on this narrow and low ridge could reverse the flow of Bottle Creek thus resulting in further disruption to the Beaver Lake supply of water?
Answer
 “No there was no such review”.
Question 6
 How many and who from amongst the local residents, either seasonal or permanent, were involved in your study?
Answer
 “None”.
Question 7
 Was Ms. Wall aware of the threatening and aggressive interaction (especially toward single female residents) of Park seeking individuals who used the local Beaver Lake Road?
Answer
 “We believe that managing people can easily be done whereas the environment takes precedence”.
Question 8
 Was Ms. Wall aware of the incidences of private property usage and damage caused by Park-seeking individuals along the Beaver Lake Road?
Answer
 “People will continue to use the road anyway and it is up to the Town to manage the people who come to the Park”.

The current Beaver Lake Road and its’ privately built and maintained extensions service a community of approximately 2000 tax-paying citizens.  Considerable numbers of these people are permanent year long residents.  The road is enjoyed and used by walkers, hikers, bicyclists, horseback riders, etc.  Many parents are seen walking, especially on weekends, with small children, babies, and pets.  The road is already at capacity and motorists currently place many of these residents at risk.  It is a country road and in many places is a single lane only.  Any increased use, especially by those unfamiliar with local use, places the residents and the enjoyment of their privately owned homes at an unacceptable level of risk. 

Beaver Lake has one single source of water from a low-lying marsh area beyond its eastern boundary.  Ms. Wall’s study contradicts previous studies on the sensitivity of that area and she does not address the issues.  Inherent in a valid Environmental Assessment, there needs to be some review of existing material/studies of the area.  Ms. Wall disavowed any knowledge or review of these studies.  Further, she had no understanding of the historical development of the area through its longstanding citizens and families who have resided in the area for generations.

The major lake chain Catchacoma/Mississauga etc. drains through the Mississauga Dam. The Trent Severn Waterway System controls that dam. As such, the lake levels vary approximately 6 ft. causing navigation issues and ecological stress to shorelines. Bottle Lake and Anstruther Lake dams control the water levels in those respective lakes and also have abnormal fluctuation levels.  Both dams are controlled by the Trent Severn system. (Bottle dam by MNR for the TS  see page 62 KHSS Management Plan Background Information) All are reservoir lakes. Any comments as to Environmental issues on these lakes must be tempered by this knowledge.

This year was the first year that MNR has not reduced the water level in Bottle Lake in order to increase the supply downstream.  If Trent Severn/MNR is to stop opening these dams the problems downstream will be further exacerbated.  There needs to be a commitment by MNR that this will not happen.  Any ecological discussions in the area would necessitate this understanding. Ms Wall does not appear to consider this point.

Our overall impression to Ms. Wall’s study can best be characterized by our response to two paragraphs in section 3.2.1 page 4 --- Remoteness and Semi Wilderness Characteristics.  Herein she discusses a helicopter survey and uses the term “in tact wilderness area”.  Ms. Wall should know that the north end of Bottle lake, (the area she was looking at), is a site of a large former sawmill.  Its’ remains are still visible.

The access route that Ms. Wall studies and comments on are not the route/road proposed in the charter.  Our expectation is and always has been that such a road would be eastbound from Hwy 507 crossing Pencil Creek at the bridge and proceed east to the Park boundary crossing barren high ground. In accordance with the Charter that says “will follow a corridor that ensures the minimum length of construction within the boundaries approximately defined by lots 16 to 29 in concession VIII, IX, X and IX in Cavendish township” Such a road would be significantly north and away (>100 m) from any private property.  In general it follows that above mentioned sawmill’s original supply road. That Pencil Creek Bridge is noteworthy as the oldest existing bridge facility in the area and predates either of the two Beaver Lake bridges. Beyond the Pencil Lake Bridge and eastward to the Park, is an area that has been approved recently by MNR for logging operations.  There are numerous existing bush roads in the area, ie. The Rathburn Trail, wide enough for car passage, and approved by MNR for the Jeep Jamboree use every year .

We find it incomprehensible, that Ms. Wall should have any ecological issues along this existing road or within an area approved for logging etc. BY MNR.

In assessing the routes on the Eastern vs. the Western side of the Park, it is important to understand that the Eastern routes are almost wholly within the Park.  The Western routes are almost wholly outside the Park. 

Ms Wall tries hard. Concern is expressed for three animals from the “Ontario Species At Risk List”.  They are the Eastern Hognose Snake and Blanding’s Turtle, from the “Threatened” list and the Five Lined Skink from the “Special Concern” list. Of these only the snake was actually observed all-be-it in an area outside the park (See page 14 of the Access road study report). Ms Wall’s concerns were only for habitat that MIGHT support these species. Concern for flora and fauna  - in a logged over, burned over, hi land area –can only be seen as superfluous, when viewed against her distain for the single source supply bog area east of Beaver Lake.

This document's “Project Objectives” state that there will be no new facility development within 100 M. of private property (section 1.3 page 2). Tuckers road was rejected in this report by MNR as not satisfying this criteria  (section 2.2 page 5). There is no place along the Beaver lake road that meets this requirement and yet the road is being proposed!  Two new interim parking lots for 20-25 vehicles were built adjacent to the Beaver Lake road as access points to Bottle Lake. (See page 65 Beaver lake road update.) They were paid for in part by MNR through Mr. Coulas.  Both lots are within 30 ft. of private property and contravene the basic objectives of this Environmental Plan. (Page 2)

This study contravenes the clear direction of the Charter and is incomplete.  It makes recommendations that contravene its own “Project directives.  It is inconsistent in its application of Project directives and Environmental concerns.

We believe the Management board and MNR should reject this Access road study report and proceed with construction of the road to the north of Catchacoma Lake as agreed in the Charter
   
5. No Management Plan.
We are presented with a Management Plan.  It is neither management nor planning.
Google :  Management Plan. The first hit says the following:
“How do you convince someone that you will be able to effectively manage their project? Writing a proposal involves more than telling the customer what you are going to do and how much it will cost.  Your customer wants to know how you are going to make sure the work is done properly and how you are going to staff the project.”

The document delivered is a Land Use Policy Statement made by the government for land that they own.
It is absolutely clear that the motivation and driving force behind this report is a lack of funds. Mr. Coulas is adept at these “open houses”.  He appeases the many concerns raised, with promises (read plans) of action that require these funds --- funds he clearly does not have and may never have.  To “operationalize” with no assessment of resources needed to realize the plan is a complete waste of time.
This “Plan” is completely silent on the issue. We make the following comments:

1) The roll out announcements spoke of the sum of 6 million dollars.  That was shortly reduced to 6 hundred thousand and again reduced to some 3 hundred thousand.  Mr. Coulas therefore has a budget, although reduced, and we would like to see, what it has used, and an action to date addendum.
2) MNR Crown land use policy to date for the last 70 years (see MMR web sites) has been the sale of property for “cottaging” as a means of funding the local infrastructure and education budgets.  This “Management plan” changes that dynamic because:
    A) No further properties within this large geographic area will be sold.  The government’s general revenue fund is depleted.
    B) The supply side of lakefront properties is reduced.  Cottage costs increase and evaluations rise.  With market value assessments Property Taxes rise disproportionately for those remaining.
    C) A way of life, significant and unique to Ontario, begins to change.  What was available to the average working person is no longer.
    D) Revenue sources for the local townships are frozen.
    E)  The normal improvements related to roads and privately funded infrastructure is frozen.  Cost to local owners rise.
3) Costs further rise. This park brings people. People, who do not pay local taxes and who use local services (i.e. roads, garbage dumps etc.)  This Management plan loads itself (piggybacks) on the local infrastructure.  Mr. Coulas and the LSC have for 5 years been asked the question  “What plans are there for replacement of funds (to the townships) removed by your actions”  Mr. Coulas has on two separate occasions stated that grants will be forthcoming “in accordance with policy”  No such funds have been received. Why?
This document neither plans nor manages.  In order to be a realistic and credible Management Plan, it must address these issues as future objectives.  Current empty promises by Mr. Coulas with regard to these future plans/objectives must cease until fully clarified and agreed upon.

This Preliminary Park plan demonstrates a disturbing inability to follow through with agreements and directions.  The Charter was a document negotiated by a senior government minister of the day.  It is our view that it is certainly “beyond the mandated scope of Mr. Coulas and the management board to change that document or quibble it’s meaning.  They are to take direction from the Charter and this document needs to follow that direction, item by item, projecting how each of the issues therein will be dealt with i.e. managed (as in the above noted quote).  We suggest that when practical realities are deemed by the management board to conflict with the Charter, they should be highlighted with options suggested, taking into account the Charters intent, and brought forward to the signatories of the Charter for discussion and resolution.

There are many additional areas of concern and we endorse the issues raised by the Long and Loucks Lake and area cottagers associations.  We note as well the concerns raised by John Kerr in the Thursday Sept 13 2007 issue of the Toronto Sun.

The issue of the road north of Catchacoma, apart from all other issues, provides a signal the government is serious, a commitment for action and an obligation to fund --- This is planning, implementation and management!  Without these there can be no park, no plan, and no future.

This report lacks prudent insight into the management needs of a large land mass, validity in its process and integrity in its failure to negotiate with relevant Stakeholders.  As it stands, it should be withdrawn in order that the Stakeholders not face the distasteful inevitability of withdrawing from the Charter agreement.

Respectfully submitted.









DRAFT POTENTIAL RESPONSE

Revised DRAFT POTENTIAL RESPONSE

LONG LAKE AND LOUCKS LAKE AND AREA COTTAGERS' ASSOCIATION and a possible bases for SGKH or individual responses

RESPONSE to the KAWARTHA HIGHLSNDS SIGNATURE SITE PRELIMINARY PARK MANAGEMENT PLAN (PPMP)

The Long Lake and Loucks Lake and Area Cottagers' Association (LL&LL&ACA) are pleased to respond to the "Preliminary Park Management Plan". Our association, similar to the Stakeholder Groups of the Kawartha Highlands (SGKH), represents a cross section of the majority of stakeholders directly connected to the Kawartha Highlands signature site (KHSS) including cottagers, permanent residents, land use permit holders, hunters, anglers, motorized snow vehicle operators, ATV operators, bear hunting license holders, commercial property owners and most importantly the two local municipalities.

For over the past 75 years our members have been the stewards of this unique area, often picking up the responsibility of the MNR especially during periods of budget cutbacks, which have been ongoing for the past forty years. These responsibilities include:

• Accepting responsibility for the Long Lake access point

• Acting as the eyes and ears for the MNR to report abusive use

• Putting out campfires, collecting garbage and reporting occurrences

• Offering backcountry assistance for the North Kawartha Fire Department, the Peterborough County Ambulance Service and the MNR in emergency response by utilizing backcountry motorboats cached boats, ATV's and motorized snow vehicles.

It is of serious concern for the "vision of the KHSS goal of the legacy of protection and stewardship ensuring that the semi-wilderness characteristics are preserved" and "longterm protection of both natural and cultural heritage values is required for the preservation of this unique area" that the PPMP propose extreme restrictions on the very stakeholders who have been and will potentially continue to be the major protectors of the KHSS.

It must be remembered that this new park is not at all similar to Algonquin Park. Algonquin was primaTily an uninhabited area made into parkland whereas the KHSS was a widely inhabited area selected to be a park even though it had a significant established population of permanent residents, recreational hunting camps, seasonal residents, commercial operations, etc. Further it was selected in spite of the fact that the Meteek Report clearly stated that the KHSS was already at or near its ca~ing capacity. The amazing thing is that the site experienced two major forest fires in the early nineteen hundreds and has made tremendous recovery while being supported by the local stewards practicing the host of traditional activities which are now been threatened.

Page 4 states that "Policies that govern the park will protect the park's natural and cultural values, maintain its traditional uses and provide the opportunity for recreational activities that are compatible with the natural values and semi-wilderness character of the park. The semi-wilderness character has supported these same traditional uses by the local stewards' yet the PPMP recommends removing many of these traditional rights even before "the initial task of the recreation management program will be to evaluate and quantify the carrying capacity of the Kawartha Highlands for recreation." is carried out, [page 28]. To date there is no scientific evidence to indicate these traditional activities have any significant effect on the parks natural and cultural values.

Under desired outcomes, [page 14] "Private and tenured landholders are able to access their properties and enjoy activities on these lands as they had prior to the establishment of the park" The major restrictions in the PPMP affecting snowmobiling, boat caching, motor restrictions basically removes these activities and isolates one on their own property after accessing the property.

It is obvious from the recent cutbacks to the MNR and the 10.0 statement ofthe Implementation Priorities of the PPMP that the KHSS will not be funded to the level of a fully managed park.'  Park development, operations and resource management will be contingent upon the availability of funding and unforeseeable changes in priorities or policy". Such funding is and will be a serious restriction to the recommendation of the original KHSS Recommendation Report (2001))"An operating Provincial Park with a commitment to provide adequate funding to support IMS and management planning and implementation". The reality is that the ultimate protection of the KHSS will depend on a strong partnership between the Local Stakeholders and the limited Park Staff. A fully organized, fi'lly funded provincial park was and is a dream. A paramount question arises as to why the preliminary park management plan places the significant restrictions on the actual stakeholders who have been and will potentially continue to be the major stewards ofthis unique area. One questions how that relates to the desired outcome,[ page 14], "Good relations are maintained with adjacent landowners, surrounding communities, and private and public groups that affect, or are affected by, the park"

One can only speculate that many of the recommendations may be the result of the author or authors of this preliminary plan were not aware of the actual spirit and or the understanding of: the KHSS Recommendations Report, the KHSS Charter, the cultural heritage values and public input by the local stakeholders directly connected to the KHSS. One also questions whether many of these restrictions are simply the result of severe budget restrictions that will not provide for the proper management of the park therefore the easiest way out is to simply ban the majority of traditional activities.

The majority of the local stakeholders, directly connected to the KHSS, strongly recommended that the KHSS should not be designated a Provincial Park. It is obvious that a fully funded, organized Provincial Park is not being proposed. That being said, we
would make the following comments and recommendations:    i

• Park Name: the title of the Preliminary Park Management Plan utilizes the heading: Kawartha Highlands Signature Site with the park logo. This is in keeping with the discussions surrounding the Charter

• 8.3.1.3. BOAT CACHES: Boat caching has been a traditional activity for over the past 70 years. Not only is it a necessity for stakeholders for hunting and fishing as a traditional use, it also provides for supportive access to assist with safety emergencies such as fire and accidents as well as stakeholders observing and reporting abusive situations. Recent fire and rescue assistance to the North Kawartha Fire Department, Peterborough county ambulance service, OPP and the MNR are exceptional examples of the assistance of cached boats, motors on back
country lakes and accommodating rescue and fire personell. With limited budget for management staff it provides for excellent stewardship assistance in the backcountry throughout the year. The Kawartha Highlands signature Site Recommendations Report (KHSSRP) states, "We further recommend that boat caching be regulated by permit". With such a vast area to protect, the continued stewardship by these stakeholders is of significant importance for safety and park watch.

Recommendation: Boat caching, for the purpose of angling, hunting, safety and stewardship, should continue as a traditional activity being regulated by permit. The SGKH and the cottage associations assist the park superintendent in: identifying active boats cached in the KHSS, appropriate caching locations, streamlining and amalgamating the number of boats and where appropriate, boat caching racks for
storage.
Further a complete inventory of active cached boats be shared with all fire and recreational services to assist in fire and rescue.    i

• 8.3.8. CHAINSAWS AND FUEL WOOD PERMITS:

The wording "Ontario proposes to prohibit chainsaws" changed to clarify chainsaws being a permitted use by landowners and recreation camp permit holders. The restriction of"within a 100m ofthe harvester's own properly'' is not feasible in many cases. Nor is the statement "restricted to the LUP area ( - Sha) or within 5m on either side of the approved motorized vehicle access road and trail system" feasible.
In some cases these specified areas may already be cleared of dead trees, close to being cleared or not appropriate. This could result in the need to import rewoowhich may have environmental concerns
A fuel wood permit is self controlling in that it restricts the quantity allowed per year.

• 8.4.3. HUNIING: 'MNR" is considering a change to the regulation to broaden the scope of hunting in the KH to increase the number of species throughout the entire year". If consultation on this proposal is not part of the management plan process, the management plan should clearly indicate that preserving the status quo is guaranteed in the Charter.

• 8.4.4. RECREATIONAL FISHING: "Ontario proposes a ban on the use and possession of live bait fish". Existing commercial bait fishing may continue in KHSS yet, anglers are not allowed to put them on the hook.
Recommendation: The wording be changed to the use and possession of live baitfish must be locally caught baitfish only.

• 8.4.5. BACK COUNTRY TRAVEL/BACK COUNTRY CAMP1NG: "back country camping will be permitted on designated campsites only" Both the KHSS Recommendations Report and the KHSS Charter define camping as backcountry. The KHSS PPMP defines backcountry "a term applied to areas where there are no permanent access roads, developments or settlements". Presently, one of the major threats to the protection of the ecological integrity of the area is the    increasing abusive motorboat campers on lakes that have permanent access roads. Historically, a significant number of large group camper/users utilize the KHSS camping loops. These groups often exceed 9 in size. The environmental educational factor for these young campers is quite significant. Attention should be focused on notifying these groups re the resommendation of a maximum of  9 campers per site and suggestions as to where other opportunities for larger group camping opportunities exist. Recommendation: There be no campsites located on lakes in the KHSS that have permanent access roads.

• 8.4.6. MECHANICAL TRAVELJMOTOR BOATS/SNOWMOBILES: "Ontario Parks proposes to amend existing regulations to restrict motor boats to any lake which has private property. Motor boats will not be permitted on any other lake, other than for park management or emergency response purposes". "In addition, Ontario Parks proposes that only owners of private property on Crab, Bottle, Buzzard, Cox and Cold Lakes will be permitted to operate motor boats on these lakes"
The KHSS Charter clearly states, "Ontario Parks does not intend to apply for any federal restrictions on boating on lakes where there is private property. Not only is the proposal to lirnit motors to landowners on certain populated lakes contrary to the Charter, it would be illegal to make such a proposal without the unanimous consent of the property owners on these lakes. The only indication of motorboat controls stated in the Charter is "including possible horsepower limits on lakes that are entirely surrounded by park land" Small motor used by anglers and hunters has been a traditional use for over 75 years. It is imperative that this continue in order to access lakes for fishing and trolling for lake trout, for transportation for hunters and game retrieval. Further, it is important to recognize the importance of motorized boats on back lakes for assisting with emergencies and for the ongoing stewardship of the backcountry.
Recommendations: Small motors be a permitted use on all backcountry lakes in the KHSS for the purpose of angling, hunting, fire and rescue and to assist in stewadship.

SNOWMOBILES: Snowmobiling has been a traditional activity for over 50 years in the KHSS. This includes snowmobiling from lake to lake, mainly on existing portage trails for the purpose of ice fishing, gaining access to Ontario Federation of Snowmobile Clubs, visiting neighbours on nearby lakes and for recreation. The wording in the present PPMP would suggest that numerous landowners and LUP holders would by stranded on their own property after access.
Recommendation: Motorized snow vehicles may be operated by landowners and LUP holders on pre-existing roads, frozen Lakes connecting trails throughout the KHSS. A vehicle permit must be obtained free of charge.

 ALL-TERRAIN VEHICLES (ATV'S):

 MOUNTAIN BIKING With the Provincial Government's thrust to encourage fitness, it is surprising to find this low level informal traditional activity, by local stakeholders, being banned. Many landowners and LUP holders use mountain biking for both fitness and transportation including one biker who is a member of the provincial mountain biking team. It would appear that there may be some confusion with the difference between organized adventure group mountain biking and informal individuals utilizing this activity for fitness and transportation. Recommendation: Mountain biking be a permitted activity for individuals for the purpose of transportation and fitness on approved trails and roads. Large group adventure mountain biking is not permitted in the KHSS.

Issues specific to Long Lake, Loucks Lake and Area (Buzzard Lake) Cottage Owners' Association:

BUZZARD LAKE AND BUZZARD LAKE PORTAGE: The landowners and LUP holders require docks, garages, vehicles and a self-maintained trail to access their properties. Three private docks are located on Long Lake at the Buzzard Lake portage. Signage should be considered to indicate they are private docks. The dock on Buzzard Lake is in very poor condition. Discussion needs to take place with all Buzzard Lake landowners and LUP holders in order to address this issue.

Buzzard Lake has become an overly utilized and abused area by campers often resulting in camping on non-designated sites, with garbage strewn on campsites and the portage, human waste, campfires left burning etc. Discussions should take place to explore the continued stewardship by Buzzard Lake landowners and LUP holders to ensure the protection of Buzzard Lake The small island opposite Browns island should be signed "No Camping" immediately. It is not presently a designated campsite nor can it sustain one, but it is constantly being abused with overcamping.
 
LONG LAKE ACCESS POINT: Although Long Lake road is not considered one of the two primary access roads into the KHSS, it is estimated that over 50% of the backcountry users entering the KHSS utilize this access point as well as a significant number of day
users.
The LL&LL&ACA has served as the administrators of this privatized public access point for the past 22 years. The current and previous Long Lake Lodge owners have operated the access point for this period of time.

This experience has revealed the need for:
• Daily supervision of parking. On weekends this is required from dawn to dusk.
• Daily availability for information and assistance, etc
• Daily/weekly maintenance of garbage, recycling, washrooms, grass cutting and litter control, etc.

Discussions need to take place with the LL&LL&ACA and the present lodge owners to discuss the future management of the Long Lake access point..








OFAH FILE: 430 KHSS/794
September 24, 2007                       
Fax # (613) 332-1800



Mr. Dave Coulas, Superintendent
Kawartha Highlands Signature Site
106 Monck Street
Bancroft, Ontario
K0L 1C0

Dear Mr. Coulas:

Subject: E.B.R. # PB05E6008 Kawartha Highlands Signature Site (K.H.S.S.) Preliminary Plan Review

On behalf of our 81,000 members and 655 member clubs province wide, we have reviewed the Kawartha Highlands Signature Site Preliminary Management Plan.

The Ontario Federation of Anglers and Hunters (O.F.A.H.) is one of the four signatories of the Kawartha Highlands Signature Site Charter, and we signed with the clear understanding and commitment from the Ontario government, the M.N.R., and Ontario Parks, that angling and hunting and other traditional activities would continue in the K.H.S.S. as they have in the past.

As a result of our review of the preliminary management plan, and in particular with respect to the proposed policies regarding hunting, boating, snowmobiling and fishing, we DO NOT SUPPORT the preliminary management plan for the K.H.S.S.

First and foremost, the final management plan must be consistent with the spirit and direction of the Kawartha Highlands Signature Site Charter in all respects. The preliminary plan is not.

A detailed description of our concerns is as follows:

Section 8.3.1.3 Boat Caches
Boat caching has occurred in the Kawartha Highlands Signature Site for many years for many reasons. The proposed policies completely overlook the use of boat caches for recreational uses. Essentially, it is proposed that boat caches be only approved to access property. No provision is made for continued recreational use, and this is contrary to the Charter. Boat caching has occurred in the past to access hunt watches, access lakes for fishing purposes, or simply for recreational purposes. The continuation of all traditional uses is guaranteed in the Charter; the proposed policies must be modified to reflect this continued existing use. We would support the administration of boat caches through a free permit system administered by the park to ensure unregulated or unauthorized boat caching does not occur and to address abandoned boat caches, if that is a documented problem.

8.3.8 Vegetation Management
The policy proposal to prohibit chainsaws in the park is unwarranted. Chainsaws are necessary tools in a variety of circumstances, including the collection of fuel wood, and trail and road maintenance. Possession of, or ready access to, a chainsaw may also be a safety issue, should a road or trail be blocked that is required for emergency purposes. A ban on the cutting of live vegetation should more than adequately address the ecological concern that this unnecessary chainsaw ban is intended to address.





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Furthermore, we expect that identified preexisting roads and trails will be maintained. The Charter is clear that the approved road and trail network consists of those roads and trails existing prior to 1999; therefore, we expect this network to continue in perpetuity. The closure or abandonment of any portion of this network would be in contravention of the Charter.

With respect to fuel wood permits, limiting the scope of the fuel wood permit alters the terms of the permit and, in our opinion, is contrary to the Charter. Specifically, limiting the collection of fuel wood to dead wood only within 0.5 ha of a recreational Land Use Permit is inappropriate, and has the potential to result in the increased legal or illegal transportation of wood into the park, which could be a vector for the spread of invasive species and counter to the maintenance of ecological integrity.

8.4.3 Hunting
The plan reads, “M.N.R. is considering a change to the regulation to broaden the scope of hunting in the Kawartha Highlands to increase the number of species that can be hunted throughout the entire year.” This statement is blatantly incorrect and misleading, and has already created unnecessary conflict. No one is seeking to broaden the scope of hunting in the Kawartha Highlands to increase the number of species that can be hunted, but rather the maintenance of traditional activities as was guaranteed in the Charter. The Kawartha Highlands under Regulation 665/98, caused a conflict with the Charter document, and this must be corrected prior to the development of the final management plan, or the plan will be contrary with the Charter in this regard.

In fact, this error has resulted in consequences for hunters this year. Unbeknownst to hunters and bear management area operators, Regulation 665/98 came into effect this year for the K.H.S.S.  The M.N.R. has supplied no information to this effect to the general public or stakeholders; so persons are effectively breaking the law should they hunt in a manner that had been lawful last year, including hunting before September 15 during a regular open season, or harvesting species that were lawfully hunted last year, including for example, wolves, coyotes, raccoons, groundhogs or crows. 

Failure to amend the regulation, and thus, not correcting the error made, is contrary to the Charter. At this time, we are requesting that an amendment to the regulation be drafted immediately, with O.F.A.H. consultation, and that any necessary public consultation take place by early 2008.

8.4.4 Recreational Fishing
The O.F.A.H. does not support the ban of live baitfish in the K.H.S.S., which is a traditional use, and submit that locally caught and baitfish from the baitfish licensees in the K.H.S.S. be permitted for sale and use within the K.H.S.S.

8.4.6 Mechanized Travel
Motorboats
Similar to boat caching, motorboat use has occurred in the area of the Kawartha Highlands Signature Site for many years for many reasons, only part of which are addressed by the proposed policies.

This section is clearly and blatantly contrary to the spirit, intent, and direction found in the Charter. Again, the proposed policies overlook the use of motorboats for traditional recreational uses. Essentially, it is proposed that motorboats be only approved to access property. No provision is made for continued recreational use, and this is contrary to the Charter.

Nowhere in the Charter does it say that any motorboat ban on any lake will be considered. The Charter clearly states that, “Ontario Parks does not intend to apply for any federal restrictions on boating on lakes where there is private property;” and the only indication of motorboat controls stated in the Charter is “including possible horsepower limits on lakes that are entirely surrounded by park land.” In accordance with the Charter, the final plan must reflect the continued traditional use of motorboats in the K.H.S.S. for traditional recreational activities. The proposed policies must be modified to reflect this continued existing use.


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Snowmobiles
The Charter is clear in saying, “Section 15 (5) A person may operate a motorized snow vehicle in the park if the motorized snow vehicle is operated on a preexisting road or trail, or on a road constructed under subsection 10 (2).”

However, the preliminary plan limits snowmobile use to preexisting roads or trails for the “sole purpose of” gaining access to private or tenured property, or for recreational purposes on an Ontario Federation of Snowmobile Club (O.F.S.C.) trail. Limiting recreational use of snowmobiles to O.F.S.C. trails is contrary to the Charter. Recreational use of snowmobiles must be permitted on preexisting roads and trails as per the Charter direction, and for fishing purposes, frozen lakes and water bodies must be included as part of that approved network.

All-Terrain Vehicles
The Charter describes “motor vehicle” use, not just All-Terrain Vehicle (A.T.V.) use. In the Charter “motor vehicle means any vehicle propelled or driven otherwise than by muscular power, including an automobile, bus, all-terrain vehicle, motorcycle, or motor-assisted bicycle, but does not include a motorized snow vehicle.” Sections 13 and 15 of the Charter are clear when “motor vehicles” may be used. The preliminary plan narrowly defines A.T.V.’s and limits discussions of permitted use only to A.T.V.’s, and is contrary to the Charter. For example, use of Off-Road Vehicles, as defined in the Off-Road Vehicles Act and as found in the Glossary of the preliminary plan, would be permitted to be used in accordance with Sections 13 and 15 of the Charter to access private property, to go hunting, or other authorized uses, but the preliminary plan would prohibit this right, and therefore, is contrary to the Charter.

Motorcycles, Motorized Bikes and Scooters
This policy needs to recognize all motor vehicle use as defined in the Charter and Section 15 of the Kawartha Highlands Signature Site Park Act, in addition to Section 13 (2) as described.


8.4.8 Other Recreational Uses
This section proposes that mountain biking be “prohibited within the Kawartha Highlands.” Property owners and recreationalists regularly use mountain bikes within the signature site, and we have been shown no evidence by Ontario Parks that net negative ecological effects occur in the K.H.S.S. as a result of the use of mountain bikes on preexisting roads and trails. We recommend that mountain bikes continue to be used on the preexisting road and trail system, as they have been in the past.


8.7.2 Internal Roads and Trails
The proposed policy reads, “Abandoned roads and/or trails will be left to regenerate, and vehicular travel is not permitted on them.” As mentioned previously, we would expect that identified preexisting roads and trails be maintained. The Charter is clear that the approved road and trail network consists of those roads and trails existing prior to 1999; therefore, we would expect this network to continue in perpetuity.  The closure or abandonment of any portion of this network would also be in contravention of the Charter. Whether the road or trail is used once every few years or frequently does not give Ontario Parks the ability to abandon these preexisting roads or trails. Furthermore, given the right of access to the K.H.S.S. as provided in Section 17 of the Charter, restricting access to land holders or recreational users at any of the preexisting entry points to the K.H.S.S. (for example, via a gate just north of Buckhorn), is in contravention of the Charter. These entry points must remain open for authorized use.

We continue to support the presentation of the area as the “Kawartha Highlands Signature Site” with the Ontario Parks logo present, as agreed to during Charter negotiations and as is presented on the cover of the preliminary plan. Referring to the area as a “park” by name, given the uniqueness of the area, land use direction, and interspersion of private property, may provide an inappropriate connotation for those seeking a traditional park experience.


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Given the above serious concerns and inconsistencies with the Charter, the Ontario Federation of Anglers and Hunters does not support the preliminary management plan for the Kawartha Highlands Signature Site.

These inconsistencies with the Charter must be rectified before the final plan is approved. If you have any questions on this submission, please feel free to contact me.

Yours in Conservation,




Robert Pineo
Forestry and Wildlife Specialist/Biologist

RP/jb

cc:    Kevin Wilson, A.D.M., Natural Resource Management Division
    Cam Mack, Ministry of Natural Resources
Adair Ireland Smith, Ontario Parks
    Barton Fielders, Ontario Parks
    Stakeholder Groups of the Kawartha Highlands
    Jim Whelan, Township of North Kawartha
    Tom Flynn, Township of Galway-Cavendish-Harvey
Phil Morlock, Canadian Sportfishing Industry Association
    Howard Noseworthy, Ontario Fur Managers Federation
    Guy Winterton, Bait Association of Ontario
O.F.A.H. Area Member Clubs
O.F.A.H. Zone E Executive
Mike Reader
Terry Quinney
Greg Farrant
Andy Houser