Protected Areas Planning

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In 2012, the Government of Ontario made a firm commitment to expand the province’s system of protected areas as a way to conserve biodiversity. Setting aside lands for protection, however, is only the first step. The benefits that Ontario’s protected areas provide in conserving biodiversity, and all their other ancillary values, are directly related to how effectively these areas are cared for through proper planning and management.

Covering nine per cent of the province, Ontario’s system of protected areas comprises 334 provincial parks and 295 conservation reserves. The Provincial Parks and Conservation Reserves Act, 2006 (PPCRA) governs this system of protected areas, and the Ministry of Natural Resources (MNR) is responsible for its planning and management. The Act directs MNR to make the maintenance of ecological integrity the first priority and to consider the restoration of ecological integrity in all aspects of protected areas planning and management. According to MNR, “ecosystems have integrity when their lands, waters, native species and natural processes are intact.” This includes healthy and viable populations of species at risk in their natural habitat.

The PPCRA further directs that protected areas should be managed to permanently protect biodiversity, to provide opportunities for ecologically sustainable outdoor recreation, and for appreciation of Ontario’s natural and cultural heritage. Protected areas should also be managed to facilitate scientific research in support of monitoring for ecological change. As such, the ministry is required to prepare management direction for each provincial park and conservation reserve.

Management direction, which consists of either a management statement or a management plan, provides protected areas with a site-specific policy and resource management framework. Non-complex issues are addressed through brief management statements, while more substantial and complex issues are covered in management plans. Management direction sets out policies for permitted activities within protected areas, such as identifying the types of activities (e.g., recreation, development, resource management, etc.) that are allowed in protected areas and establishing rules for when, where and to what extent these activities should take place. Management direction provides assurance that these activities are compatible with environmental protection and are responsive to the public interest. Plans and statements also provide a record of public consultation and input into the planning process.

Both internal pressures (such as hiking, fishing and other recreational activities within protected areas) and external pressures (such as mining and logging just outside park boundaries) can present challenges to managing the ecological integrity of protected areas. Collectively, these pressures can have significant and cumulative impacts on the lands, waters and species of a protected area if they are not thoroughly understood and carefully managed.

Additionally, past human activities have fundamentally altered the ecology of many ecosystems, so that plans for protected areas must include direction to restore important ecological features (i.e., species) and functions (i.e., fire, connectivity, etc.) that have been historically modified or even eliminated. Thus, management direction must address the full complement of pressures and issues facing protected areas with the overall priority of maintaining and restoring ecological integrity.

Changes to Protected Areas Legislation

The Ontario government’s 2012 omnibus budget bill – Bill 55, Strong Action for Ontario Act (Budget Measures), 2012 – amended the PPCRA by removing time limits for the preparation, serving the public: Annual Report 2012/2013 113 duration and periodic review of management direction for provincial parks and conservation reserves. These changes are part of the government’s strategy to manage natural resources over broader landscapes, with an overall objective of reducing MNR’s budget (for more information on MNR’s transformation, see Part 2.1 of this Annual Report).

Formerly, MNR was required to prepare management direction for existing parks and conservation reserves within five years of their creation, with a deadline to prepare management direction for all existing protected areas by September 2012. However, with the passing of Bill 55, these deadlines no longer exist. Furthermore, the amended PPCRA now requires MNR to examine management direction that has been in place for 20 years or more, instead of the previous requirement to examine 10-year-old management direction.

Request for Review of the Provincial Parks and Conservation Reserves Act, 2006

In December 2012, the ECO received an application for review under the Environmental Bill of Rights, 1993 (EBR) requesting that MNR review the PPCRA and reverse the amendments included in the omnibus budget bill (Table 4.6.1). The applicants argued that the removal of legal planning deadlines could cause environmentally significant impacts as management direction will become, and remain, outdated for some protected areas while others may not have any management direction at all. In February 2013, MNR denied the applicants’ request, concluding that a review of the PPCRA was not in the public interest (for a detailed review of this application, see Section 2.4.2 of the Supplement to this Annual Report).

Table 4.6.1. Summary of Bill 55 Changes to the Provincial Parks and Conservation Reserves Act, 2006.

Management Activities Original Timelines Current Timelines
Prepare management direction for existing protected areas By September 2012 Not specified
Prepare management direction for new protected areas Within 5 years Not specified
Planning horizon for management direction 20 years Not specified
Age of management direction to be considered for review 10 years 20 years
State of Ontario's Protected Areas Report due Every 5 years Every 10 years

Implications of Bill 55 Changes to the PPCRA

In our 2006/2007 Annual Report, the ECO warned that without proper planning and conscientious management, Ontario’s protected areas would be nothing more than lines on a map. Turning a blind eye to protected areas will not ensure the conservation of those values and amenities they are meant to protect. The ECO also warned that MNR would face considerable challenges in implementing the PPCRA unless the ministry’s budget was significantly increased. Yet, MNR continues to rely on a cost-recovery model for protected areas management.

The ministry primarily relies on revenues from operating parks to fund the management of all parks; however, 66 per cent of Ontario's parks are nonoperating and, therefore, generate no revenue. While operating parks contributed $68 million to the special purpose account in fiscal year 2011- 2012, MNR allocated only an additional $10 million for planning and managing the provincial parks system. This level of funding is totally insufficient to the task. But rather than increase its own funding, the government appears to have simply dropped some of its legal responsibilities for protected areas planning. Furthermore, the ministry admits that it does not directly track expenditures related to the management of conservation reserves.

Now, without legal deadlines, existing plans will become outdated and new protected areas could spend an indefinite amount of time with no management direction whatsoever. While the law still requires MNR to prepare and review management direction, the ministry will now be able to postpone these responsibilities. The ministry seems to be moving towards a reactive approach to protected areas planning in which it only addresses what it judges to be “priority” areas. This is unacceptable. Attention must not only be given to acute problems, but also to those that are chronic.

Protected areas exist to conserve biodiversity, not to generate revenue for the government. Ontario is arguably the only jurisdiction in North America that tries to fully finance its parks system from gate revenues. If nothing changes, then, over time, fewer and fewer resources will be devoted to ensuring that management direction effectively maintains and restores ecological integrity across the entire protected areas system. However, if the government were to increase funding by even a small margin, MNR could make a measurable, substantive difference in safeguarding Ontario’s protected areas.

Planning for Provincial Parks and Conservation Reserves

Updated management direction includes the most recent scientific information about the status of a protected area’s ecological integrity. While management direction is currently in place for 617 out of 629 protected areas, many plans and statements are not up to date. Almost half of Ontario’s 295 conservation reserves have management statements that are over 10 years old, and virtually none of them ever received the benefit of public consultation. In addition, most provincial parks are covered by management plans with an average age of 17 years. Killarney, Rondeau and Sandbanks are among the 145 provincial parks with management direction that is over 20 years old. Furthermore, the plans for some provincial parks have been in place for more than 30 years, including Petroglyphs (1977) and Polar Bear (1980). Outdated management direction lacks the information required to accurately assess threats, which impairs the development of effective strategies to maintain ecological integrity.

Nevertheless, the ministry considers all existing plans and statements to be “current,” despite the fact that management direction for only 89 out of 629 protected areas has been either approved or amended since the PPCRA came into force in 2006. Plans and statements that were prepared prior to 2006 were not required to ensure that the maintenance of ecological integrity was the first priority of planning and management. Thus, less than 15 per cent of management direction explicitly addresses the legal mandate of the PPCRA. This problem extends to some of Ontario’s most popular parks, including Algonquin and Wasaga Beach (see Table 4.6.2).

Table 4.6.2. Select Statistics for Provincial Parks (Note: information regarding visitors is not collected for non-operating parks).

Park Name Park Size (ha) Year established Year of most recently approved
management direction
Management direction explicity adopts
ecological integrity as the first priority?
2011 Visitors Number of species at risk 2011/12 Revenues 2011/12 Expenditures
Presqu'ile 982 1922 2000 No 207,685 11 $1,661,093 $1,308,889
Kesagami 55,977 1983 1998 No Unknown Unknown n/a $0
Algonquin 772,300 1893 1998 No 818,696 31 $10,611,490 $9,140,875
Cabot Head 4,514 1985 1996 No Unknown 17 n/a $0
Quetico 471,878 1913 1995 No 80,634 3 $1,131,537 $1,454,161
Lake Superior 160,810 1944 1995 No 112,113 2 $588,290 $878,735
Springwater 193 1958 1994 No 31,062 7 $202,510 $248,910
Sandbanks 1,550 1970 1992 No 605,538 11 $3,382,637 $1,424,938
Polar Bear 2,355,200 1970 1980 No Unknown 6 n/a $0
Wasaga Beach 1,844 1959 1978 No 1,497,228 24 $1,149,958 $1,268,128

Moreover, the longer a protected area waits for management direction, the greater the risk to ecological integrity. During this time, both the public and MNR remain in the dark as to how these ecologically significant places should be safeguarded. And yet, provincial parks wait an average of 15 years for management direction to be developed. In total, 108 parks went without management direction for more than 20 years. For example, Turtle River – White Otter Lake Provincial Park was created in 1989, but a management plan was not approved until 23 years later (see Turtle River – White Otter Lake Provincial Park Management Plan). Currently, seven conservation reserves and five provincial parks do not have any management direction. The amended PPCRA will allow protected areas to wait an indefinite amount of time for management direction.

The ministry’s track record shows that the rate of drafting, amending and approving management direction for protected areas over the last seven years was alarmingly slow even when legislated deadlines were in place. Clearly, MNR is not providing sufficient resources for protected areas planning. Furthermore, it is evident that the ministry’s reliance on the cost-recovery model has resulted in a substantial backlog of planning and subsequent management action. The failure of this model is further evidenced by the fact that management direction is older for operating parks than for non-operating parks and conservation reserves. There is no excuse for this. Operating parks face substantial pressures from human activities, which are unlikely to be adequately addressed in outdated management direction. Since resources are usually directed to operating parks, there should be enough funding to ensure that these areas, at least, have updated management plans.

Read: What Happens When Parks Stop Making Enough Money?

Reporting on the State of Ontario’s Protected Areas

The Minister of Natural Resources has a legal obligation to publicly report on the state of the protected areas system. The government’s 2012 omnibus budget bill altered this self-reporting requirement – from once every 5 years to once every 10 years. These reports provide a broad assessment of whether MNR is meeting its objectives for protected areas planning. They are also intended to identify socio-economic benefits, as well as threats to ecological integrity. MNR released its first and only State of the Protected Areas Report in 2011. Now, the next report is not required until 2021.

The ECO has previously stated that it is extremely important for such reports to provide a frank assessment that will enable MNR to focus its resources on key systemic issues, be they common threats to ecological integrity or the need to strengthen government policy (see Part 4.4 of the ECO’s 2008/2009 Annual Report). The 2011 State of the Protected Areas Report noted:

  • Recreational activities, such as all-terrain vehicles, boating and snowmobiling, were identified as ecological stresses. However, MNR noted an “absence of quantitative studies that measure the impacts of recreational use.”
  • Hunting is permissible in 423 protected areas for game mammals, game birds and migratory birds. MNR noted that “it is not possible to determine the extent of hunting in protected areas” as the ministry does not specifically collect this information.
  • Sport fishing is permissible in all protected areas, except where fish sanctuaries have been established. MNR noted that it “does not have estimates of harvest levels,” although concern regarding the impact of fishing pressure on fish populations” was identified in 37 per cent of protected areas according to a survey of ministry staff in 106 parks.
  • Trapping is permissible in 532 protected areas. MNR notes “the numbers and varieties of species harvested in protected areas are unknown.”
  • Invasive species were identified as a concern in 50 of 214 provincial parks in a ministry survey, but details are unknown.
  • Operational expenditures (i.e., planning, management, enforcement, monitoring, etc.) are “directly related to visitation.”

It is not possible for MNR to accurately identify threats to ecological integrity without this kind of information. Yet, it is unlikely that this situation will improve over the next reporting cycle unless the ministry commits sufficient resources to this issue. To date, there has been no indication that MNR is working to address the problems identified in its 2011 State of the Protected Areas Report.

ECO Comment

A chronic lack of funding is the single greatest barrier to the effective planning, management and operation of the provincial system of protected areas. While the ECO believes it is acceptable for MNR to use gate revenues from operating parks to offset costs associated with recreational facilities and activities, it is illogical to apply the cost-recovery model to all aspects of running Ontario’s system of protected areas. The ECO strongly disagrees with the ministry’s reliance on the cost-recovery model because this approach provides no assurance that the maintenance of ecological integrity – the conservation of nature – will occur for the vast majority of protected areas that do not pay for themselves (see pp.41-47 in the ECO's 2003/2004 Annual Report and pp. 99-106 in the ECO's 2006/2007 Annual Report). The government should consider the costs of planning, management, enforcement and science in protected areas as investments in the health of our province, which will reap benefits for all Ontarians.

The ECO believes that protected areas are an invaluable public resource, and management should not be prioritized based on their ability to generate revenues. The value of parks and conservation reserves should not be measured in dollars and cents, but rather by the ultimate role they play in conserving Ontario’s biodiversity.

The Ministry of Natural Resources manages protected areas on behalf of all Ontarians for a very special purpose: to maintain and restore ecological integrity. To fulfil this important responsibility, the government must provide sufficient funding for protected areas planning. Management direction for parks and conservation reserves must reflect the best available scientific information, planning practices, public input and current government policies in order to implement an adaptive ecosystem management approach that is both defensible and of practical value. Plans for protected areas are the roadmap to conserving Ontario’s biodiversity, but without proper direction, our way is lost.

Recommendation 7:

The ECO recommends that MNR discontinue its user-fee cost-recovery approach for all aspects of the management of Ontario’s protected areas, except for recreational activities.

This is an article from the 2012/13 Annual Report to the Legislature from the Environmental Commissioner of Ontario.

Citing This Article:
Environmental Commissioner of Ontario. 2013. "Protected Areas Planning." Serving the Public, ECO Annual Report, 2012/13. Toronto: The Queen's Printer for Ontario. 112-118.