Dear Editor:
I am writing to you because of my grave concern with the application by the Town of South Bruce Peninsula (TSBP) for Permit for activities to achieve an overall benefit to a species. This is just another way to say that they want to “enhance” piping plover habitat by bulldozing.
I am part of a group that has been fighting to keep Sauble Beach as natural as possible for the piping plovers for many years. I am not against “cleaning” the beach, that means removing litter, large logs, etc. by hand, not by large mechanized means. Environmental Defence, Ontario Nature and Ecojustice are some of the groups fighting this environmental damage.
The Town of South Bruce Peninsula (TSBP) was finally charged (2 charges) by MNRF for damaging endangered species habitat and they lost on both counts. As part of the attachment is the court transcript.
I have attached a timeline from prior to the destruction right thru to this years high water damage. The beach sand has been completely washed out because of the deep bulldozing that was done.
Shortly after the judgement came down, they sprayed with 3 toxic herbicides and they are now requesting to spray and groom the beach again. There is no beach, so I am assuming they will spray and groom the dunes. They are using the idea that they are “enhancing the beach for plovers” with spraying and grooming but all expert testimony and research states that leaving the beach in its normal state is best.
This is the application. https://ero.ontario.ca/notice/019-1818 Comments due June 25, 2020.
I appreciate everything you have already posted about this issue and I hope that this background will assist you.
If you have any questions, please contact me.
Comments about ERO # 019-1818 June 16, 2020
Instrument type: Permit for activities to achieve an overall benefit to a species
ERO number: 019-1818
Ministry reference number: SW-C-003-20
The Town of South Bruce Peninsula (TSBP) was charged with two counts of “destruction of endangered species habitat” by the Ministry of Natural Resources and Forestry at Sauble Beach. The Town was found guilty on both counts. The Mayor on her Face Book (FB) page uses the argument that they were enhancing the plover habitat when they bulldozed into the old dunes and the beach and removed all the living and dead material. The Mayor believes that it is more important to have a “clean beach” than to protect habitat and states that on her FB page.
The Judge found that the Town did not even adhere to their own Bylaw 62-2015 about beach maintenance. This application is again the Town trying to "clean" the beach without any regard for animal habitat. Since the Town has already shown that they will not adhere to the conditions for maintenance. I do not believe that the Town will undertake minimal maintenance or adhere to the conditions of this permit as evidenced by their previous behaviour. In addition, the “Plover experts” stated that raking (enhancing) a beach does not encourage plovers, it discourages them.
In terms of economic factors, bird watching is a huge tourist industry that provides many dollars to the local economy. The Town would be smart to encourage more birdwatchers and fewer day trippers.
The Town claims that there are invasive plant species that need to be removed. I personally challenged the Mayor to prove the number, species and locations of these invasive plants. She has not responded. To the best of my knowledge, there are no invasive species as they were all sprayed by toxic herbicides last fall. The only vegetation remaining is in the dunes and spraying in sand dunes is generally not acceptable.
With the high water and the large waves, very little beach exists at Sauble now. Because of the previous raking, flattening of the beach and cuts into the old dunes, the wave action has removed most of the sand right up to the front edge and in some cases right into the old dunes.
In its attempt to protect a "human recreational habitat" it is my belief that the TSBP have contributed to and perhaps, even caused its destruction. The sand where grasses and willows were removed was naturally compacted by the elements and held in place by the roots of the vegetation.
Bulldozing loosened the sand and with nothing to hold it in place, it has been swept into the lake.
Obviously, the Town is not responsible for the rise in lake levels but they are responsible for the removal of vegetation which held the sand in place.
To add insult to injury, in the same week that the Town was found guilty in the ESA trial, they sprayed the remaining marram grass, willows and phragmites with Garlon RTU, Roundup and Arsenal.
In my opinion, this proposal should be denied and TSBP should be closely monitored for any and all work related to any beach in their jurisdiction. Granting this proposal would be completely opposite to the findings of His Worship Justice of the Peace C.W. Anderson on October 03, 2019, at Owen Sound, Ontario.
David H Lewis, B.Sc. M.E.S.
C (416) 804-6046
