March 21, 2022
To: Public Input Coordinator, Species at Risk Branch, Ministry of the Environment, Conservation and Parks; 435 James St South, Thunder Bay, ON P7E 6T1 Canada email@example.com
Strategic Priorities Directorate; Canadian Wildlife Service; Environment and Climate Change, Canada 15th Floor, Place Vincent Massey
Gatineau, QC K1A 0H3 firstname.lastname@example.org
From: Friends of Wabakimi, Vern Fish-President
Re: Proposed Conservation Agreement for Boreal Caribou in Ontario.
The Friends of Wabakimi is an Ontario Non-profit corporation based in Thunder Bay, Ontario with over 260 members. We advocate for canoe routes and habitat protection in the Greater Wabakimi area which includes numerous provincial parks, conservation reserves and five managed forests.
Our Mission Statement:
Through volunteer stewardship and collaboration with other stakeholders, the Friends of Wabakimi will participate in the planning processes to advocate for protection and preservation of the diverse natural, cultural, recreational and historical resources of the Wabakimi Area.
Friends of Wabakimi appreciate the opportunity to comment on the Conservation Agreement for Boreal Caribou in Ontario. https://ero.ontario.ca/notice/019-4995 Friends of Wabakimi and our precursor organization, The Wabakimi Project, have paddled and mapped canoe routes in this large area. We’ve seen the beauty of the boreal forest up close, and the occasional caribou as well.
While this proposed agreements states many important goals and plans; we’re not clear on the implementation steps to accomplish them. Our concern is that another agreement serves to “check off the box” with little actual progress to protect boreal woodland caribou as a keystone species; an indicator of the overall health of the ecosystem and the boreal forest.
We would be interested to know what concrete action steps have been taken in the Alberta/Canada agreement to date?
Currently, we’re deeply involved in the planning process for the Wabadowgang Noopming Forest 10-year plan. This prime caribou habitat is bordered on three sides by Wabakimi and Whitesands Provincial Parks. The planned timber harvest is certain to continue the fragmentation of this key forest.
Our forest plan comments (found here) support efforts to minimize the impact of forest harvest and promote restoration of the harvested units. What’s not at all certain though, is that once the boreal caribou leave the disturbed areas, will they ever actually return? Enhanced monitoring might answer that question, but by then it could be too late.
Friends of Wabakimi have proposed three areas for new Conservation Reserves in the Wabadowgang Noopming Forest, areas which are known for woodland caribou habitat. Further, Friends of Wabakimi has proposed new Conservation Reserve for the Misehkow Valley area, which is NW of Wabakimi Provincial Park, south the Albany River Provincial Park and bordered on the west by the Caribou Forest. And we’ve proposed the modest addition of Survey Creek adjacent to the Obonga-Ottertooth Provincial Park.
These modest areas of proposed protections would be an important, but by no means adequate, for the future of boreal woodland caribou. We urge both the respective Ontario and Canada ministries to consider our proposals and similar proposals, which would protect the forest from the fragmentation that threatens boreal woodland caribou.
However, the forest planners and Ontario’s MNRF say that new Conservation Reserves are beyond their mandate and scope. But clearly, this is within the scope of the Species at Risk Branch of the Ontario Ministry of the Environment, Conservation and Parks. Serious consideration of these proposed Conservation Reserves should be included in the implementation plans for this Ontario/Canada agreement.
In regards the proposed Ontario/Canada agreement:
WABADOWGANG NOOPMING FOREST PLANNING & PROPOSED CONSERVATION RESERVES -- FOW MAKES FORMAL COMMENTS FOR TEN-YEAR PLAN
The Friends of Wabakimi (FOW) has proposed four new Conservation Reserves and limitations on planned logging roads with our formal comments for the Wabadowgang Noopming (W.N.) Forest ten year plan (2023 to 2033). These four areas are closely proximate to Wabakimi Provincial Park and within the woodland caribou special area of concern. The FOW also clarified that Trail Lake (aka Tamarack Lake) Road should remain undeveloped so as to not cause increased pressure onsensitive caribou areas in Wabakimi Provincial Park’s SE corner.
The FOW represents wilderness paddlers and recreational businesses with a current membership of over 250 who have an interest in the Greater Wabakimi Area. The FOW is the successor organization to The Wabakimi Project, which explored and mapped routes, portages and campsites over a fourteen year period. The maps for the W.N. Forest are contained in Wabakimi Canoe Routes Volume 5. FOW President Vern Fish is our representative on the W.P. Forest Local Citizens Committee (LCC). Previously, FOW met with the MNRF and their consultants.
Of significance is Ontario’s Crown Land Use Policy Atlas Policy (CLUPA) Report G2616: Caribou Lake / Wabakimi, adopted in 2006, which states, “The primary use for this area will be commercial tourism. Extractive activities such as timber harvesting, while growing in importance, will remain secondary. Road access will be managed to maintain commercial tourism and fish and wildlife habitat. Land use conflicts will be resolved recognizing the importance of commercial recreation in the area.”
Proposed Conservation Reserves While creation of new Conservation Reserves is outside the purview of the Ministry of Natural Resources Forestry’s (MNRF) forest planning process; it is within the broad responsibilities of the MNRF generally.
The D’Alton Block has an unusual high concentration of interconnected small lakes and rivers. It has been documented as historical caribou habitat and migration corridors. There are several valuable remote tourism outposts scattered across the “block”. This tangle of lakes has the potential to be enhanced for recreational canoeing and creates opportunities for canoe outfitting for the Whitesands community.
Currently, canoeing access to the D’Alton Block is limited to portaging in from Caribou Lake. If the existing Big Lake Road were opened to recreational use up to the stream crossing just south of Big Lake, another route would be available to paddlers. This limited access would still maintain the wilderness character of the outpost cabins. It would also help reduce canoeing pressure on caribou calving on Caribou Lake in May and June.
4. Doe-Fawn Lake Complex – This area is located north and northeast of Collins. It is bounded on the south by the CNR Line, on the west and north by Wabakimi Park and on the east by Fawn and Doe Lakes. This area features shallow soils and is important currently used year-round caribou habitat. This small but important area deserves status as a Conservation Reserve to protect this caribou habitat. Eliminating or limiting road access and designating the area west of Doe and Fawn Lakes as a Conservation Reserve will accomplish both of these goals.
Roads inside of CLUPA G2616.
We are recommending some areas within CLUPA G2616 for Conservation Reserve status. That designation lies outside of the scope of the forest management planning process (FMP). However, it does lie within the responsibilities of Ontario’s Ministry of Natural Resources and Forestry (MNRF), and this is a Crown FMU. The Crown Forest Sustainability Act (CFSA) makes it clear that the Minister shall not sign any FMP that is not sustainable for all forest values. So, this draft FMP can, and should:
Of particular importance for lowest possible grade, temporary (perhaps winter) roads are:
These roads should be winter roads… or left just in the current state to keep open the possibility of increased formal protection of the caribou habitat and remote recreational experience.
A Sense of Wilderness
According to Vern Fish, FOW President, “Our goal is to maintain a sense of wilderness in key parts of this forest… Wabakimi has important values to be preserved. Our FOW priorities and concerns are:
-- Ecological integrity and sustainability
-- Maintaining a healthy and sustainable woodland caribou population
-- Protect lakes that support Lake Trout
-- Protect exceptional recreation and tourism values adjacent to Wabakimi Park:
*Maintain existing and potential wilderness tourism business opportunities
*Preserve historical canoe routes that directly or indirectly connect to adjacent provincial parks.”
“We do understand the need for economic benefit to Whitesand First Nation, and Armstrong. We believe that the - above recommendations are consistent with long term sustainability for both the natural environment and local economy.”
Contact: Vern Fish, FOW President at email@example.com
The FOW will participate in the planning process to advocate for the protection and preservation of the diverse natural, cultural and historical resources of the Wabakimi Area.
Vern Fish and Shawn Bell represent the FOW on the Local Citizens Committee (LCC) that provides input to the forest management planning process for Wabadowgang Noopming Forest Management Plan. This is the Crown Land that separates the Wabakimi Provincial Park from the Community of Armstrong, Ontario. This area is over a million acres and it includes the Raymond River, Big River and Collins River canoe routes.
As part of the forest management process a Contingency Plan (CP), a two year plan, is written to provide direction for forest management activities until the ten year plan can be completed in 2023. The FOW submitted comments to Contingency Plan - Stage Three Review of Proposed Operations on November 22, 2020. See previous Conservation post. The CP is followed by a more intensive discussion to result in a 10 year forest plan.
The Plan Author, Jeffery Cameron of NorthWinds Environmental Services, provided a detailed response to our comments and offered to set up a virtual meeting with representatives of the Ministry of Natural Resources & Forestry and members of the writing team to answer our questions. This meeting was conducted on January 25, 2021. The following FOW board members participated in this call: Dave McTeague, Randy Trudeau, Ian Curran, Victoria Steeves, Ray Tallent and Vern Fish. MNRF staff included Robin Kuzyk and Steve Young.
The following topics were discussed:
1) Caribou Management
Caribou are an endangered species in Ontario. Their management is guided by the Dynamic Caribou Habitat Schedule (DCHS). For more details on DCHS go to
The CP provides for logging operations in the Dalton Block which is an area between Caribou Lake and the D’Alton Lake. This area is recognized as a calving area for caribou and is also noted for remote tourism values. The Big River canoe route flows through this region. (See Volume 5 of the FOW canoe route booklets). The logging is designed to create more caribou habitat but could have a short term impact on caribou and recreational Areas of Concern (AOC). The FOW have pointed their concern for both impacts. The staff pointed out that these concerns have been taken into account by creating AOC’s which require buffers for the logging operations. The logging will also only be done during the winter months to further reduce the impacts.
2) Placement of Primary Roads
The logging road leading up the Dalton Block is currently scheduled for winter access only and is defined as a secondary road. It has been proposed that this road be upgraded to a primary road which would make it permanent and allow summer use. This decision will be finalized in the Forest Management Plan which is scheduled to be completed in 2023. The FOW noted their concern about the impacts of a permanent road.
3) Crown Land Use Policy Atlas Policy, Report G2616: Caribou Lake / Wabakimi
This policy states that the area around the Dalton Block should be managed primarily for recreational and wildlife purposes. The staff pointed out that this policy does not prevent logging and is only one policy impacting the forest management plan for this area.
4) Road Access for Recreational Canoers
The FOW does not want to break up the wilderness with roads. However, if a road is going to be built for other purposes can this road also be used for canoeing access? The Big Lake Road provides access to the Dalton Block. We would like to see access to the Big River canoe route off of the Big Lake Road if possible.
Road access to Crown Land is covered by other aspects of Ontario law. Thus, this becomes a complicated administrative question for the MNRF to answer. We did not get a definite answer to this question at this time.
5) Canoe Route Maintenance
We asked if we could explore the possibility of working with the MNRF to help maintain canoe routes within the Wabadowgang Noopming Forest. These routes include the Raymond, Big River, Collins River and parts of other routes. The staff recommended that we talk to Emily Hawkins, Resource Operations Supervisor, about work permits and other details.
6) Process for creating consensus on primary roads
A big controversy brewing in the LCC has been the placement of primary roads to provide access to logging units near the border with Wabakimi Provincial Park. The FOW has recommended that a facilitator be used to build a consensus on this issue. This issue will be discussed further at a future LCC meeting.
(for a really deep dive into these forest management issues here's a recent summary!)
NEW! The FOW is strongly advocating for buffers and protections for Armstrong Forest Canoe routes. These new comments are for the tw0-year forest plan, which is to be followed by a ten-year plan. We know the MNRF is considering our detailed points. Your Conservation Committee and especially FOW President Vern Fish have spent hours pouring over the proposed road building and harvest plans.
The proposed roads and harvest are pushing deep into the corners of this forest, which are bounded on three or more sides by Wabakimi and other Provincial Parks. Read full comments and see photos here! A few key points we made:
The FOW Conservation Committee has contributed comments to the current Forest Management Plan (effectively, for 2021 to 2033) and, more recently, to the document known as the LTMD (Long Term Management Direction) Summary, which describes main aspects and impacts of the plan. Our full comments can be seen here: FOW COMMENTS ON ARMSTRONG FOREST LTMD.
One of our main concerns is with road-building associated with timber harvest. In particular, a primary road extension is planned to allow harvest of a block (AB-3) on the Wabakimi Provincial Park boundary south of Whitewater Lake. The road option that seems to be preferred by the Armstrong Forest Local Citizens Committee (LCC) is an extension of Dalton Road running generally north, to the east of Caribou Lake, then to the west, over the top of Kellar Bay of Caribou Lake. Such a route would cross four canoe routes that are mapped to the east and north out of Caribou Lake (See FOW Map Volume 5).
We expressed our concern that best practices be followed, so as not to obliterate the portages, which are also entered on the Values map that forest planners utilize. We also requested that, should such a road go in, access for canoers be allowed (that is not a given on those primary roads, which may be open only to logging operations and First Nation persons). If there is possible lemonade to be made from this, it could be for allowing access to the Crown Land canoe routes in that area, some of which connect into Wabakimi Provincial Park. For more detail, please refer to the above link.
While timber harvesting is key economic driver for the area economy, we posit that recreational canoeing, wilderness exploration, fishing and appreciation of these natural values also has economic and social value to the area economy that’s not adequately recognized in the proposed Long Term Management Direction Summary.
These comments were developed by the Conservation Committee and approved by the Board of Directors and submitted prior to the July 30, 2020 deadline.
Conservation Committee: An Overview and Recent Activities
The Conservation Committee of FOW consists, at present, of Ray Tallent (chair, firstname.lastname@example.org) Shawn Bell, Doug Blount, Mark Dandrea, Vern Fish, Amy Funk, Dave McTeague, Randy Trudeau and Terry Isert. Any FOW member who is interested can participate on the Conservation Committee (you can express your interest at https://www.wabakimi.org/membership-interactive-site.html ) or email email@example.com. Our focus is on gathering and sharing information on environmental issues in the Wabakimi Area, and in communicating our concerns and positions to the ministries that oversee activities in the area. For FOW, this most closely relates to the value of the area in its wilderness features and as a canoeing destination, and our involvement reflects these priorities. The ministries also take into consideration the views of stakeholders who have different priorities.
The Wabakimi Area, as circumscribed by Phil Cotton and delineated in every volume of Canoe Route Maps, includes Provincial Parks, Conservation Reserves, and other Crown Lands under management as Forest Management Units. Management of the Parks and Conservation Reserves falls to the Ministry of Environment, Conservation and Parks (MECP), whereas the Forest Management Units are managed by the Ontario Ministry of Natural Resources and Forestry (MNRF). So, the Conservation Committee is involved with two different ministries, depending on the area of concern. A main contact person for the parks and conservation reserves is Shannon Lawr, the Park Superintendant for Wabakimi Provincial Park. FOW President Vern Fish has had a number of conversations with him, and we intend to stay actively involved as the Park Plan for Wabakimi progresses.
There are about five Forest Management Units in the Wabakimi Area. The MNRF develops and oversees management plans for these units, following guidelines set up by the Crown Forest Sustainability Act (CFSA) and – in the case of areas like this with ‘continuous’ woodland caribou distribution – the Dynamic Caribou Habitat Schedule (DCHS; please note: there will be a mandatory quiz over acronymns at the end of this article :<). Each management plan covers about one decade, and there are subsequent plans scheduled out to well over one century.
Part of this longer term perspective is to plan any harvesting in such a way as to mimic fire cycles (at about a 100-year rotation in any one place) on the area and to maintain enough mature forest at any one time to support the woodland caribou. In the plan discussed below, for instance, about 9% of the forest unit area is slated for harvest over a 12-year plant period. It should be noted that the plans for Crown Forest lands attempt to balance “biological, social, and economic objectives” (LTMD – Long Term Management Direction --Summary). These lands tend to see more extractive activities and more human-related disturbance on the landscape than do the parks and preserves.
One way for stakeholders to participate in the Crown Forest management plan process is via a Local Citizens Committee (LCC) that offers input and comments to the planners. Shawn Bell and Vern Fish are FOW’s LCC participants on the Armstrong Forest (Wabadowgang Noopming) that surrounds Armstrong and the Whitesand First Nation and forms much of the eastern border of Wabakimi Provincial Park. This particular forest unit is well over 600, 000 hectares (over one million acres) in size and forms much of the eastern border to Wabakimi Provincial Park.
Submitted by Ray Tallent, FOW Conservation Chair
FOW engages with Armstrong Forest Planning
Recently FOW President Vern Fish was accepted as our representative to the Armstrong Forest Local Citizen Committee (LCC). Board member and Thunder Bay resident Shawn Bell was accepted as our Alternate. They replace Phil Cotton who was appointed shortly before he passed.
Volume 5 Canoe Routes. There are many canoe routes in the Armstrong Forest which The Wabakimi Project improved and documented in FOW Maps Volume 5 as well as several major points of entry into Wabakimi Provincial Park. Logging and road development in this Crown land forest will impact the area’s habitat and canoe routes.
Vern attended his first meeting on May 27th. This was the LCC’s first online meeting, a change which greatly helps our involvement. The Armstrong Forest is currently revising the next ten-year Forest Management Plan (FMP). Vern reported:
New Logging road. The dominant issue was the location of a road to haul logs out of the northwest corner of the Armstrong Forest. (See the Dalton Road Extension map. The logging company refers to the road as the Dalton Road Extension but the locals refer to it as the Big Lake Road.) Here's the full report in our June newsletter. We'll report further soon our questions to MNRF staff and their responses.
Armstrong Forest Planning Process
Going forward, the Armstrong Forest is going to be managed separately from the current Nipigon Forest unit. At stake is a ten year plus management plan for forest harvesting, associated roads, habitat and wildlife conservation and addressing the needs of the area communities and recreational interests.
The FOW recently responded to the Armstrong Forest Desired Benefit Survey. Protecting historic canoe routes, and essential wildlife and habitat is the essence of our response. We don’t want more roads into the wilderness, but access to canoe routes is desirable if there are developed roads. (FOW Survey Response & Letter)
The Conservation Committee recommended this response after reviewing critical documents, such as:
the “Forest Management Guide for Boreal Landscapes”
the “Stand and Site Guide” for Conserving Biodiversity at the Stand and Site Scales.
Another important guide is the Woodland Caribou Recovery and Conservation Policy: https://www.ontario.ca/page/range-management-policy-support-woodland-caribou-conservation-and-recovery.
See also the recent article by Wabakimi Park biologist Shannon Walshe: http://www.ontarioparks.com/parksblog/wabakimi-caribou/
Raymond River Route Letter
Recently, we let MNRF know about concerns specific to the Raymond River route (including Hollingsworth, Raymond and Scallop Lakes) in the NW section of Armstrong Forest. This route was mapped and cleared in 2018. A proposed road could impact this route. (View Letter )
Forest Plans and Maps
In the current forest plans there are different maps with lots of detail and maps about tourism (canoe routes, outposts), cultural resources, and forestry operations. There are significant forest harvest management areas in all five forest units to the east, west and south of the provincial park. These can be found by going to ontario.ca/forestplans.
Protecting Crown Land Canoe routes and surrounding habitat was an important reason Phil Cotton started the The Wabakimi Project.
“Wabakimi is quickly becoming an island of wilderness, despite being over 890,000-hectares-huge. Our wanton destruction of the boreal forest for lumber, pulp and minerals is partially to blame. Crown land usage outside of Wabakimi is further confounded by the fact that four separate Ministry of Natural Resources (MNR) districts manage the land according to a non-uniform series of regulations. One of my objectives in identifying old canoe routes has been to convince MNR and park managers that the wilderness values of the Crown land outside of Wabakimi’s boundaries should be preserved – for the sake of both canoeists and wildlife. I hope that in making MNR aware that these historic waterways still exist they will be protected and continue to act as corridors to and from Wabakimi’s interior.”
“Uncle” Phil Cotton, as told to Ontario Nature in 2009
Phil’s 2014 treatise on ONTARIO CROWN LAND CANOE ROUTES is essential reading for his deep understanding of the issues facing the unprotected area around the Wabakimi area provincial parks. Phil also made a strong call for linking up with a broad range of public interest organizations to advocate for the Crown Land forests, “There is an urgent need for a single, unified voice to represent recreationalists who value and enjoy the province’s wilderness canoeing opportunities and to speak for the protection and preservation of all existing Crown land canoe routes.”
FOW Conservation Committee
We’ve had several meetings on Sundays at 7:00 p.m. CST, (8:00 p.m. EST), by Skype. If you’re interested in participating or learning more; drop us an email at firstname.lastname@example.org
Ray Tallent is our FOW Conservation Director. (See Ray’s article on Feather Mosses in our Dec. 2019 newsletter).
Other issues we’d like to explore in the future are: