Bringing Ecological Integrity to the Landscape: Ontario’s Protected Areas Planning Manual
Ontario’s protected area system includes 329 provincial parks and 294 conservation reserves. These protected areas vary in their size, geographic characteristics, biological diversity and accessibility.
Together, they contribute to Ontario’s overall biodiversity, economy, outdoor recreation and natural heritage appreciation opportunities. The framework within which the Ministry of Natural Resources (MNR) plans and manages protected areas has several levels, which produce increasingly detailed and site-specific decisions. These levels include legislation, strategic directions, MNR planning policies, protected area systems planning, land use planning and site-specific management directions.
At the level of the individual protected area, management directions can be: (1) a brief management statement that addresses a limited number of non-complex issues; or (2) a detailed management plan that addresses substantial and complex issues. While 613 of Ontario’s 623 protected areas are currently covered either by a management plan or statement, this does not necessarily mean that these management directions reflect up-to-date legislation and policies or were subject to adequate public involvement when they were developed. Of Ontario’s 294 conservation reserves, for example, fewer than 20 are covered by a management direction that involved public consultation through a posting on the Environmental Registry, as required by the Environmental Bill of Rights, 1993 (EBR).
With the passage of the Provincial Parks and Conservation Reserves Act, 2006 (PPCRA), MNR is required to “prepare a management direction that applies to each provincial park and conservation reserve” by September 2012, and annually examine management directions that have been in place for 10 years or more to determine whether they need to be amended or reviewed. To guide the preparation and amendment of management statements and plans, the PPCRA requires MNR to prepare a planning manual. In August 2009, MNR finalized its Protected Areas Planning Manual (the “manual”), replacing the Ontario Provincial Park Management Planning Manual (1994) and processes that were previously used for planning conservation reserves. MNR states that the manual “establishes a provincially consistent, transparent and predictable approach to protected areas planning.”
The Protected Areas Planning Manual
The manual outlines each step that MNR staff are to follow in developing management directions for protected areas, including:
- scoping the project;
- compiling background information;
- consulting the public;
- preparing preliminary management direction; and
- obtaining approval for the revised direction.
The manual recognizes, however, that planning processes are often iterative, multiple steps may occur simultaneously, and certain aspects may occur throughout the planning process. The manual provides minimum requirements for involving stakeholders, Aboriginal communities and the public in the planning process. MNR notes that sometimes a secondary management plan may be prepared for complex topics where management direction policy is required or needs elaboration.
The manual also provides guidance for the implementation of a management direction. This includes:
- communicating its status to affected parties and the public;
- using adaptive management; and
- implementing projects through the Class Environmental Assessment for Provincial Parks and Conservation Reserves (Class EA-PPCR).
The manual encourages monitoring both the implementation of the management direction and the effectiveness of its management actions. Finally, the manual provides guidance on updating, examining and amending management directions, and direction on monitoring the implementation, maintenance, and revision of the planning manual itself.
The PPCRA directs that the “maintenance of ecological integrity shall be the first priority” in all aspects of the planning and management of Ontario’s provincial parks and conservation reserves. Ecological integrity refers to a condition in which “biotic and abiotic components of ecosystems and the composition and abundance of native species and biological communities are characteristic of their natural regions and rates of change and ecosystem processes are unimpeded.” The planning manual acknowledges ecological integrity as the first priority in the planning and management of protected areas and instructs that this principle be considered throughout the planning process.
Public Participation & EBR Process
MNR appears to have thoughtfully reviewed the five comments submitted by the public and reconsidered aspects of the proposed manual. Notably, MNR revised the manual to remove references to “implementation plans,” which in the draft manual involved grouping related projects together and subjecting them to the requirements of the Class EA-PPCR rather than the consultation requirements of the EBR. Instead, the approved manual now references “secondary plans,” which may be prepared to address complex topics. MNR insists that these secondary plans will be treated as amendments to management direction and subject to posting on the Environmental Registry, as is clearly required by the EBR.
ECO Comment
The ECO is pleased with the clear and detailed guidance that the manual provides. The figures, tables and references to supplementary tools should provide an easy-to-follow path for MNR staff and the public.
The ECO applauds MNR for unambiguously recognizing the priority of ecological integrity in protected areas planning and incorporating this consideration throughout the manual’s planning steps. In particular, the ECO appreciates the manual’s instructions to identify monitoring methods and indicators to measure the effectiveness of management directions in maintaining ecological integrity. Effective monitoring should guide the future management of each protected area and provide the information needed to inform MNR’s State of the Protected Areas Report.
Nevertheless, the ECO strongly disagrees with MNR’s decision to put important details regarding protected areas planning in separate guidelines that seemingly will be unavailable for public comment. Despite MNR’s legal obligation to adhere to the EBR, the manual states that MNR will manage the supplementary tools and guidelines independently of the manual and they “may be changed, created or deleted at MNR’s discretion without external involvement.” Several of these guidelines will likely be environmentally significant, including guidelines that direct: how to determine planning and management priorities in the context of ecological integrity; how to consult with public and Aboriginal communities; and how to monitor the effectiveness of management directions.
Although the manual refers to an MNR website for the “most current list of planning tools and guidelines,” as of August 2010, this website listed no such documents. According to MNR, they were still being developed. Given their likely environmental significance, the ECO urges MNR to comply with the EBR and post the draft guidelines on the Environmental Registry for public comment once completed.
While the previous parks planning manual contained detailed policy directions for provincial parks (e.g., on the phase-out of commercial trapping in protected areas), the new manual provides only general planning guidance and relegates detailed direction to undrafted guidelines (e.g., the Protected Areas Compatibility Test). As a result, until the supplementary guidelines are developed, protected areas planning seemingly lacks detailed guidance on important details, such as the appropriateness of specific activities in protected areas. To ensure that activities in protected areas do not jeopardize ecological integrity, planning staff need a policy that clearly articulates MNR’s position on the appropriateness of specific activities in protected areas. In addition, MNR needs a guideline to screen the compatibility of unforeseen activities with the maintenance of a protected area’s ecological integrity. The ECO encourages MNR to fill these policy gaps as promptly as possible and, as required by the EBR, post these policies on the Environmental Registry for public comment.
The ECO reiterates the observation made in our 2006/2007 Annual Report that protected areas must be managed on a greater ecosystem basis to fulfill their mandate of protecting biodiversity. Management directions for protected areas should consider ways to identify and address threats that originate from outside their borders. Likewise the planning manual should instruct that this consideration be included in management plans and statements. Also, given that MNR’s SEV includes a commitment to encourage energy and resource conservation in the ministry’s operations, the ECO is disappointed that the planning manual does not instruct MNR staff to consider ways to incorporate greening opportunities into management directions.
The ECO has expressed frustration before that there is no requirement that MNR adhere to policies and plans created under the PPCRA. Because policies under the PPCRA have no regulatory weight, no matter how sound the guidance in the planning manual or how protective a management plan, there is nothing that requires MNR staff follow them. To give management directions the authority they need to ensure environmental protection, the ECO encourages the government to amend the PPCRA to require that a decision made by a Minister of the Crown be consistent with park management statements and plans.
While the PPCRA and the planning manual clearly prioritize the consideration of ecological integrity, the Class EA process for projects in protected areas, which predates the PPCRA, does not. As the ECO has noted before, this inconsistency poses serious problems, which, unless fixed, will be exacerbated in the years to come. The ECO is disappointed that MNR is late in completing its required review of the Class EA-PPCR, but hopes the delay is due to a substantial overhaul of this document to prioritize the consideration of ecological integrity.
| This is an article from the 2009/10 Annual Report to the Legislature from the Environmental Commissioner of Ontario. |
Citing This Article:
Environmental Commissioner of Ontario. 2010. "Bringing Ecological Integrity to the Landscape: Ontario’s Protected Areas Planning Manual." Redefining Conservation, ECO Annual Report, 2009/10. Toronto, ON : Environmental Commissioner of Ontario. 75-8.
| Recommendation 5:
The ECO recommends that the Ministry of Natural Resources amend the Provincial Parks and Conservation Reserves Act, 2006 to make management direction for protected areas binding on the Crown. |
