Protected Aresa Association
of Newfoundland and Labrador
St. John's, NL A1C 5M3 Canada
Phone: (709) 726 - 2603
Fax: (709) 726 - 2764
paa@nf.aibn.com
www.paanl.org

July 18^th, 2007

To: Hon. Clyde Jackman, Minister
Department of Environment and Conservation
Box 8700, St. John's, NL A1B 4J6

Re: EA Reg.1340 "Grande Meadows Golf Course Expansion"

Dear Minister Jackman,

Protected Areas Association (PAA) has a long history of monitoring the Grande Meadows Golf Course and is not surprised to see another registration document requesting an expansion of this golf course. Since the proponent is a volunteer group that is both persistent and community-based, we would like to see them find a compromise solution that would be both environmentally wise and protect the integrity of the Provincial Park Act. We wonder if your government could help them return to their 1999 expansion proposal that passed muster with flying colours: we and other conservation groups approved it, and government released it from EA without requiring further study. Yet they don't seem to have pursued it - "for commercial reasons."

Unfortunately, we find some serious problems with this registration document.

1. Lack of clarity in map boundaries. Grande Meadows Golf Course Association radically compromised the integrity of Frenchman's Cove Provincial Park in 1991. That was when the government of the day allowed a golf course to morph 23 hectares of the park into a golf course - to cut down forest stands with chainsaws, and destroy natural features with bulldozers and tractors. Partly in response to that event, the 1997 Provincial Parks Act was amended to set a cap of five hectares on any commercial licence, lease or development within a provincial park. But before the amendment's protection, 23 of Frenchman's Cove Provincial Park's 51 hectares already had been leased to Grande Meadows Golf Course.

So with 45% of the park already lost to a private golf club, PAA cannot support any more park land being sacrificed. Moreover, this map does not show the details and parameters of the new request, and in fact, the park will be impacted by this proposal, since the golf course is already entirely inside the provincial park. A wetland already inside the golf course is scheduled to be infilled to create another fairway. Another wetland used by migratory waterfowl each fall and spring (straight north of and alongside the park) will be infilled and turned into more fairways, and the natural shoreline at the end of the peninsula will be used for yet more infill. The maps supplied to the Department of Environment and Conservation are sketchy black and white photocopies and difficult to read, there are no specific measurements provided, the boundaries of the aquatic areas slated for infill are impossible to define clearly, and the current park boundaries are absent. It appears that the offshore island will be made part of the peninsula, using some of the 30,000 cubic meters of infill.

2. Lack of clarity in map on wetlands. We know that natural wetlands in this park - and in the wetland immediately NW of and adjacent to it - provide habitat to nesting wildlife and migrant birds. Pintail ducks and Wilson's snipes are only two of many bird species using these wetlands. However, these wetlands are not clearly defined in the maps, nor do the maps show which inshore areas are slated to be infilled. The little 8x10" black-and-white maps make it virtually impossible to assess the natural areas that will be impacted by the further destruction of this landscape. Will the one remaining wetland on the current course be infilled in an attempt to cram another fairway or two into that area? It appears so.

3. Absence of proper environment impact analyses on loss of wetlands. This document proposes an increased intensity of use of the part of the park containing the nine-hole golf course, combined with the probable removal of the remaining wetland still present on that course. In addition, the proposed in-filling of the southern end of the peninsula will decrease the natural shoreline and appears to eliminate the nearby island by joining it to the peninsula with infill: both of these have traditionally provided valuable waterfowl staging habitat-but the document does not include any comment from ornithologists. It does not even give estimates of how much infill will be used in what locations; the document raises far more questions than it answers, and this should raise red flags for government.

4. Absence of proper environmental impact analysis on marine life. This document proposes dumping 30,000 cubic metres of infill into the wetlands, the barasway, and the barachoix. This infill will impact marine life, bird habitat and water levels, and has the potential to cause flooding. The details and cost of these impacts should be fully explained and justified in this document, but is not even touched upon.

5. Absence of analysis of the increased use and seepage of pesticides on the land. With the predicted increased intensity of use of the current golf course and the addition of fairways on the other side of the barachoix, there needs to be a proper analysis of the amount of pesticides that will be used, and their effect on a barachoix that is currently brackish.

6. Lack of clarity in the map showing the flow of the golf course. Since the map doesn't clearly delineate and number the fairways (thereby indicating direction of the game), it is difficult to assess the effect of the game on the park. PAA wants to know if golfers will need to travel on natural areas in the course of their game. Will golf balls or staff retrieving golf balls disturb natural areas and bird habitat? One thing seems certain: there will have to be significant crowding of fairways in the current southern-most area, as the attempt is made to cram two more fairways into the space holding the current nine holes.

7. Lack of clarity in the map showing parking and driving range needs. Since a driving range is normally a standard part of a golf course, how does the club intend to do without one? If the proponent is right and the enlarged course attracts more golfers, how will the current parking lot accommodate them? Will golfers start parking on park roads and camping areas? What are possible congestion areas? None of this is analyzed. The proponent states that fund-raising events have been held, but doesn't indicate any allocation for overflow parking. The proponent states that there is no need of additional parking space or a driving range, but if this document is released will there be a future one containing a request of park lands for additional parking?

8. Lack of indication of edge effects on the park. If the golf course is expanded to the borders of the natural areas with no buffer zones, the natural areas are going to be compromised. There is no comment on the effect of a golf course contiguous to bird habitat. There is no comment on birds at all, actually, beyond denying that the golfing area is important to geese.

9. Lack of justification of how golfing enhances the mandate of the Provincial Park. The mandate of the Provincial Parks is to protect habitat and provide environmental education and recreation in a natural setting. Conservationists and parks planners see a direct conflict between golfing and parks. Golf courses cope with birds as a "problem" by shooing them away and discouraging nesting. They are also fairly infamous for pesticide run-off and harmful alteration of natural habitats into man-made ones. Frenchman's Cove Provincial Park encourages the visits of over 20 species of terrestrial birds including "stray and vagrant species" - meaning unusual and rare birds. The document does not explain how birders who enjoy the park's exceptional offerings will have their recreation "enhanced" by a more intense use of the golf course.

10. Lack of explanation of the effect of loss of wetlands to wildlife. The proposal will remove (infill) valuable wetlands - a small one on the current course but much larger ones next to the park. Ornithologists can explain if this loss may force birds to abandon traditional nesting areas and create over-crowding in the park's small remaining wetland, or lead them to abandon the area altogether.

11. Lack of a long-term proposal of park management. Currently the nine holes are leased to a community golf association with volunteer management. What will happen when the lease with Parks expires? Who will pay the costs of restoring the natural environment and returning to compliance with the Provincial Parks Act?

12. Lack of a long-term economic plan. What is the market-growth in golfing in the Burin Peninsula? The proponents give no facts, no indication of the numbers of active golfers on the Burin. What is the golfing tourist growth potential? How many of the current golfers at Grande Meadows are tourists? Is golfing a better investment for this park than ecotourism? Grande Meadows golf course is inconvenient to major transportation hubs and far from major population bases. Any tourist coming from St. John's or Corner Brook would pass several fine 18-hole golf courses before turning down onto the Burin Peninsula. Though these economic expectations have no direct connection with the environment, it is important that we weigh predictable economic benefits and possible conflicting uses before proceeding with an expansion plan.

Protected Areas Association is disappointed to be warning the minister about the flaws in this registration document. Of all the proposals that the Grand Meadows Golf Association has brought forward over the years, we still find the least objection to 1999's EA Reg. 828, which proposed placing an additional nine holes inland beyond the barachoix, away from the park and in private lands. To date, this is the least invasive plan for the immediate environment of this park. Obviously, we were not the only people to approve it, since it was released from environmental assessment by government. The equally obvious question is, in light of approval all around, why was this proposal not developed?

We strongly recommend that this document, Reg. 1340, be subject to rigorous environmental analyses and an Environmental Impact Statement.

Protected Areas Association would also recommend, if this proposal is turned down, that the government purchase the private wetland immediately adjacent to Frenchman's Cove Provincial Park on its West, to protect this public park from any further encroachments into its natural areas. This would certainly be heralded by park supporters around the province as some compensation for the loss of so many of the park's natural features when the Wells government turned the park's southern half over to development of the current golf course, 16 years ago.

Thank-you.

Sincerely,


Laura Jackson                Jennifer Morgan
Executive Director          Associate Director

Protected Areas Association of Newfoundland and Labrador
Box 1027, Stn. C, St. John's, NL A1C 5M3 Phone: (709) 726-2603 Fax: (709) 726 - 2764 paa@nf.aibn.com
Under the Distinguished Patronage of
His Honour the Honourable Edward Roberts, QC, ONL, Lieutenant Governor of Newfoundland and Labrador,
and Christopher Pratt, C.C.

It is horrifying that we have to fight our own government to save the environment.
~Ansel Adams