P52 the park delivers the management plan - -
responses - - - - -last update Oct 17 07
return to the park index page
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pdf in this folder - - support is withdrawn!!!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 st