https://www.nrdc.org/bio/julee-boan/canadas-caribou-protection-delays-bring-more-forest-degradation​

Ontario fails, Canada hesitates and caribou lose. 
It’s been this way for over a decade since the Government of Canada told Ontario to comply with the federal recovery strategy for boreal caribou. Two months ago, the federal minister of Environment and Climate Change Canada (ECCC) declared that critical caribou habitat is not being effectively protected in Ontario, creating an opportunity for the federal government to compel Ontario to halt and reverse caribou decline. (In fact, the federal government previously made this assessment in 2021, but cabinet failed to act.)

This week, Canada once again wavered and, instead of stepping into provincial jurisdiction to protect caribou habitat from further degradation, granted Ontario yet another extension to show compliance with federal protection standards. We expect that over this next year Ontario will once again fail in its mandate to take meaningful action to recover caribou. It’s likely that instead of protecting critical caribou habitat, it will call upon its industry partners to tap former industry scientists, who will once again declare that what caribou need most is more logging. It’s time their longstanding assertion—that logging vast tracts of remaining critical habitat will lead to caribou recovery—should, as they say, “go the way of the dodo.”
The legal and policy frameworks that apply to boreal caribou in Canada are complex, and this complexity is used by industry and provincial governments to justify the continued lack of effective habitat protection. In Canada, provincial and territorial governments have constitutional rights to manage forestry resources. However, while each province has made the commitment to establish legislation and programs that provide for protection and recovery of species at risk, the federal government has the power to intervene in provincial jurisdiction if at-risk habitat is not effectively protected.

Over decades, industrial logging has steadily eroded the older conifer forests boreal caribou rely on for survival. The meta-analysis conducted by caribou researchers for the federal boreal caribou recovery strategy showed a significant relationship between levels of cumulative disturbance in a caribou range and calf survival, a relationship that multiple regional studies have reaffirmed (e.g., COSEWIC, 2014; Hervieux et al., 2013; Rudolph et al., 2017). Research in 2020 concluded that, based on a nationwide analysis representing the full spectrum of regional variation in environmental conditions, “anthropogenic disturbances are the primary agent contributing to boreal caribou declines across Canada.” Of the 51 existing caribou populations, only 15 are considered self-sustaining; that is, likely to persist without human intervention to restore their degraded habitat (and a halt to new degradation).

To give caribou a chance at long-term survival, the recovery strategy directs provinces to reduce disturbance levels—the combination of roads, clearcuts, seismic lines and other developments—in caribou ranges.

Since provincial and territorial governments also receive taxes from industrial activities, this can and often does lead to, at best, contradictory mandates: to recover declining wildlife and expand industrial activity. Today, six of Canada’s 13 provinces and territories still have no specific laws devoted to species at risk conservation. Laws that do exist, such as in Ontario, have been poorly implemented and often rolled back. For example, despite the lack of evidence that forest management is supporting caribou recovery, in 2020, after years of aggressive lobbying, the Government of Ontario granted the forest industry a permanent exemption from having to comply with the province’s Endangered Species Act—essentially removing any regulatory requirement for the industry to prioritize recovery. In addition, when Ontario released its Forest Sector Strategy in the same year, it announced that it would endeavor to almost double industrial logging in the province by 2030.

Why is protection being delayed?Despite broad agreement among caribou experts about how forest management should be undertaken to sustain boreal caribou and advance their recovery (e.g., through limiting cumulative disturbance within caribou population ranges), significant barriers exist to implementing these strategies.

Ideologies of development and growth without limitsCanada uses natural resources faster than the environment can regenerate them. In North America (and elsewhere), the benefits of continual economic growth are accepted as self‐evident and are for the most part unexamined in mainstream discourse. Industry has co-opted the term “sustainable” to focus primarily on job creation and retention, the so-called “third pillar” in the sustainability stool, while environmental and social needs are often simplified, considered secondary or disregarded altogether. Frequently, significant public resistance arises when actions are taken to establish limits to industrial or other development expansions, even when scientific evidence has shown that much of our consumption is wasteful, unnecessary and does not meaningfully contribute to our quality of life. This sense of the limitless bounty of nature can be traced back to the frontier mindset of colonialists in Canada. The country was established on the false belief that the land was terra nullius, “nobody’s land,” wide open for exploitation. Its large size, with an abundance of water and vast tracts of forest, has given rise to the perspective that significant negative ecological impacts are unlikely and can always be mitigated. 

Fear of job lossFor local communities that have historically depended on natural resource extraction, a significant level of precariousness is associated with a reliance on global commodity markets. Job loss can be cyclical, and when large industrial facilities such as mills or mines close, the impacts can be devastating to small, resource-dependent communities that aren’t buffered by much economic diversity. Globalization, shifting demand and automation have impacted these industries significantly. 

“...the substitution of routine tasks by machines has been happening steadily in the logging and forestry sector. The advent of skidders, mechanical harvesting, and remote chipping has modernized bush operations. GIS, telemetry, and satellite imagery have also optimized harvest planning and access development. Remote sensing of harvesters can grade, sort, and scale product in one operation. These technologies have led to a significant reduction in employment in the logging and forestry industry.” 
Northern Policy Institute (2019)

Ineffective systems to address cumulative disturbanceThe combination of human activities on a forest results in cumulative disturbance. Yet, the separation of government ministries, and lack of regional planning, mean that the overall impact of development is often not coordinated or adequately addressed. Unless landscape-level planning, including regional and strategic impact assessments, is prioritized to put limits on how disturbance accumulates, we will continue to see caribou decline. Recently, cumulative disturbance has been further exacerbated by wildfires, about half of which are directly human-caused or appear to be part of climate change trends toward drier summers in many parts of the boreal forest.

Wildlife populations in Canada are under stress from many factors, including climate change, pollution, invasive species and overexploitation, among others. Yet habitat loss and degradation continue to be key drivers of decline for most species at risk in Canada. Caribou conservation efforts can also help achieve other biodiversity and environmental goals. Setting aside large tracts of boreal forests from industrial development to achieve caribou conservation can help to deliver on Canada’s international protected areas commitments (e.g., Global Biodiversity Framework) and potentially on its climate obligations.

Nearly 800 wildlife species are at risk of extirpation (local extinction) or extinction in Canada. Research has shown that boreal caribou can serve as a focal or “umbrella” species, as the key driver of caribou decline, habitat fragmentation, also negatively affects many other species. 
“Protection of the Boreal Caribou’s critical habitat is expected to improve outcomes for 80 other listed species at risk, benefit 90 percent of the bird and mammal species that live in the boreal forest, and provide protection of soil carbon storage hotspots.” 

Environment and Climate Change Canada (June 15, 2023)
This means that, if provinces and territories can manage the boreal forest (the vast majority of which is public/Indigenous homelands) for caribou survival and recovery, these decisions should benefit other wildlife that rely on unfragmented older, conifer forests, too. 
Instead, loss and degradation of habitat continues. This most recent delay will enable thousands more hectares of caribou habitat to be logged, in addition to forests that burn. It also puts Canada further behind in addressing the biodiversity and climate crises.

Julee Boan and Rachel Plotkin have published a chapter explaining the drivers of delays in protecting critical caribou habitat in the book, Transformative Politics of Nature: Overcoming Barriers to Conservation in Canada. Pre-orders for the book are available at University of Toronto Press and Amazon.

​www.snnewswatch.com/local-news/feds-pressure-ontario-on-boreal-caribou-conservation-7164564?utm_source=SNNewsWatch&utm_campaign=2cbf7bfe52-DailySN&utm_medium=email&utm_term=0_85a78531ab-2cbf7bfe52-45811288

OTTAWA — The federal government has established a timeline for Ontario to take additional steps to protect the boreal caribou and its habitat.
The species was declared to be threatened since 2003.
Stephen Guilbeault, minister of environment and climate change, announced last week that Ottawa is giving the province until April 2024 "to demonstrate equivalency of approach between provincial measures and the federal framework."
According to Guilbeault, that timeline was previously agreed upon mutually.
The minister said that after determining earlier this year that some portions of the boreal caribou's critical habitat on non-federal land in Ontario is not adequately protected, he has recommended that a critical habitat protection order be issued as required under the Species at Risk Act.

Click on the link above for the rest of the article.....



​

​More analysis from Julee Boan, with the NRDC! 

​his blog was coauthored with Rachel Plotkin, Boreal project manager with the David Suzuki Foundation in Canada.

Whenever a conservation agreement — a recovery tool under Canada's Species at Risk Act — is announced, it is hailed as a breakthrough. Conservation agreements are intended to signal that the federal government and a partner (e.g., provincial or Indigenous government) are committed to undertaking joint actions that benefit species at risk and enhance their chances of survival.

It has now been a year since Canada entered into such an agreement with Ontario for boreal caribou, on Earth Day, 2022. At the time, environmental lawyers and watchdogs expressed deep concern that the agreement would likely do more harm than good. The “caribou in the room” was that, more than a decade after the federal boreal caribou recovery strategy and accompanying guidance were published, Ontario continued to willfully ignore the fundamentals of critical caribou habitat protection, which are predicated on enforcing limits to cumulative disturbance. The conservation agreement risks the possibility of providing green cover for the province.

So, have caribou’s chances of survival been enhanced under the agreement?

Regrettably, the last time Ontario released any information on the condition of caribou populations was almost a decade ago. The province conducted “Integrated Range Assessment Surveys” between 2010 and 2013 to calculate caribou population size, recruitment rates, survival, population trend and probability of occupancy. The final reports were released in 2014 and survival rates showed disturbing trends of decline.
Despite the lack of evidence that forest management is supporting caribou recovery, in 2020, the Government of Ontario, after years of aggressive lobbying, granted the forestry industry a permanent exemption from having to comply with the province’s Endangered Species Act – the only tool with the capacity to prioritize species recovery.
It is well documented that industrial disturbance in the mature, unfragmented forests on which caribou depend is most likely driving their decline. As such, to understand how caribou are faring under the agreement in the absence of population trend data, we must turn to the province’s management of caribou habitat as the best proxy. In other words, we can look at how disturbance levels have or are likely to change under the conservation agreement in forests where logging and mining occur. According to recent research, “the 65% undisturbed critical habitat designation in Canada's boreal caribou Recovery Strategy may serve as a reasonable proxy for achieving self-sustaining populations of boreal caribou in landscapes dominated by human disturbances”, while acknowledging that some populations may be more or less vulnerable.

In most ranges, the cumulative disturbance has increased; Ontario’s forest management policies continue to lead to more fragmentation of caribou habitat. (Although Ontario hasn’t publicly reported this range disturbance data since 2018.) On the ground, a number of new forestry cutblocks and roads in undisturbed caribou habitat are planned in current Forest Management Plans, as illustrated in our map below.

Map of northern Ontario, Canada. (See Above) Dots show approximate location of new roads and logging planned in undisturbed caribou habitat by 2030. Remaining caribou range is shown in green and existing main roads are shown in red. Data Source: Ontario GeoHub (April 2023) and Ontario Forest Management Plans (Natural Resources Information Portal, April 2023, https://nrip.mnr.gov.on.ca/s/fmp-online?language=en_US).
​
Ontario’s failure to take the necessary steps to recover caribou and protect existing habitat has not gone unnoticed by the federal government, which has assessed that the province is failing to effectively protect critical habitat. The assessment triggers a mandatory recommendation to Cabinet for federal intervention (called a critical habitat protection order), so we can assume that such an order is either being pulled together or has already been presented.

On the heels of the federal environment minister’s assessment, Ontario committed $29 million to put toward caribou research, monitoring and protection. However, how those funds will be spent remains ambiguous. Resources are necessary to finance caribou recovery, but what Ontario has put on the table lacks a plan and targets for habitat protection and cumulative effects management.

In the absence of the effective protection of critical habitat in Ontario, the federal government must stop the ongoing loss. Despite the predictable fear-mongering by forest industry lobbyists, if Cabinet issues a protection order, it lasts only five years, providing time for the province to put its funding to good use. Since Ontario has declared it could sustainably double the amount of logging in the province, industry’s bemoaning that protecting more caribou habitat will “devastate” northern economies has been met with considerable skepticism. 

Federally, the government has committed to halt and reverse nature loss, an essential measure to forestall an imminent sixth extinction crisis. It has the authority under the Species at Risk Act to intervene, and a recent Commissioner on the Environment and Sustainable Development report has critiqued the ministry’s failure to issue these orders. Further, despite the growing use of conservation agreements to advance caribou protection across Canada (eleven conservation agreements have been signed for boreal and southern mountain caribou since 2019), none of these agreements have met the important criteria to protect critical habitat in alignment with the Species at Risk Act.

A pause on new roads and logging in undisturbed areas until critical caribou habitat is effectively protected, while third-party monitoring is conducted to update our understanding of the condition of caribou populations, could slow declines and provide the needed pivot toward recovery.

It’s time for the Ontario government to share how the $29 million will be spent to protect caribou habitat and monitor populations and for Canada to show leadership by implementing a protection order. 

April 22nd EARTH DAY Action Request
 
To: FOW members and supporters
Fr:  FOW Conservation Committee  
Re: Contact:            Federal Environment Minister Steven Guilbeault
       Copy to:            Ontario Environment Minister David Piccini
 
 
Suggested Message:
 
Dear Minister Guilbeault,
 
I am writing to request that you issue a federal protection order for a 5 year moratorium on new woodland caribou habitat degradation/roads on forests like Ontario’s Wabadowgang Noopming WHILE the province of Ontario conducts population surveys with their recently announced $29 million in funding.
 
(Include any key points as per our backgrounder below)

Steven.Guilbeault@parl.gc.ca   Or mail to: House of Commons, Ottawa, Ontario, Canada  K1A 0A6 
Please send a copy to:
David Piccini, david.Piccini@pc.ola.org;  Or mail to:  Ministry of Environment, Conservation and Parks, 5th Floor, 777 Bay St., Toronto, Ontario  M5B 2H7
 
         Please consider a Letter to the Editor of your local newspaper.

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FOW CONSERVATION UPDATE – April 2023
 
Friends of Wabakimi are deeply concerned about the continued loss of essential habitat for woodland caribou and associated wildlife species. Boreal caribou are listed as a threatened species under Canada’s Endangered Species Act as well as by Ontario and other provinces.  
 
Ontario defines threatened as “….likely to become endangered if steps are not taken to address factors threatening it.”
 
The recently adopted 10-year forest plan for the Wabadowgang Noopming forest continues new roads, clearcutting and habitat destruction immediately adjacent to Wabakimi Provincial Park and other surrounding parks & conservation reserves. Two MNRF maps show the areas planned for road building and clearcuts in the near term. (Map 1, Map 2)
 
FOW actively participated in this forest planning process. The FOW supports challenges to this forest plan as unsustainable for wildlife, habitat and recreational values.   The loss of boreal forest habitat is concerning others as well.  Here’s a summary of what we know.
 
Canada’s Federal environment minister Steven Guilbeault has told Ontario they are not effectively protecting the habitat of boreal caribou. Currently Mr. Guilbeault is pressuring Quebec to protect caribou. An Environment Canada five-year federal protective order is one possibility which raises the issue to high prominence; but the practical effect is unclear.  (The minister recommends and the federal cabinet decides…a process that’s not public.)
 
This is after Ontario signed a Boreal Caribou agreement with the federal government with lofty goals of collaboration, monitoring and protection.  Immediately, this was criticized by the Wildland League (CPAWS chapter), as lacking actual habitat protections.   
 
On March 15, 2022, Ontario’s minister of environment, conservation and parks David Piccini pledged $29 million over four years to support habitat restoration and protection and research.  Lakehead University in Thunder Bay is slated to receive significant funding. Which department will receive the funds and how will this be spent?  While monitoring of woodland caribou populations is clearly needed; will it make any difference if habitat loss continues?   FOW is reaching out to Lakehead to learn more.
 
Julee Boan, now with the Natural Resources Defense Council (NRDE), and previously with Ontario Nature addressed these issues recently and noted Ontario’s weakened Endangered Species Act and the intense push-back from the timber industry.  

Our understanding now is that the federal government is still looking for ways to work with Ontario in some sort of cooperative sense.
 
FOW’s (and others’) position is that there should be a moratorium on new caribou habitat degradation/roads (through the protection order for 5 years) WHILE the province conducts population and habitat surveys with their $29 million in funding.
 
Ontario Nature Protected Places campaign.  FOW has previously proposed areas near Wabakimi Provincial Park further protection, i.e. conservation reserves. These are now indicated on Ontario Nature’s story map.
 
 
Protection and Preserving the Boreal Forest
 
The bigger issue is the boreal forest and ongoing threats.  As noted by Environment America, the boreal forest is the Amazon of the North, essential for global climate health.  Trees that have grown for decades in the boreal forest (the largest intact forest on Earth, stretching from Newfoundland to Alaska) are chopped down to make tissue products that are used for mere seconds.
 
Canada is one of 105 signatories to The Glasgow Declaration on Forests, announced in 2021 at the United Nations Framework Convention on Climate Change Conference (COP 26). It calls for halting and reversing forest loss and land degradation by 2030, and that achieving our global climate targets requires protecting and restoring forests.
 
The European Union (EU) issued a new regulation last December to not allow products coming from areas of deforestation as well as “degradation.”  The EU is a consumer of wood pellets from Ontario and Canadian forests.
 
Natural Resources Canada (NRCAN) has given the industry’s FPAC $750,000 of public money to promote that Canadian forests are not degraded. (NRCAN is the federal ministry that promotes Canadian forest products. NRCAN lobbied against the EU regulation.)
 
FOW supports petitioning the Canadian Council of Forest Ministers, (a consortium of federal and provincial officials), for a clearer definition of “forest degradation,” which should state, “Forest degradation is evidenced by widespread decline in bird habitats and populations, significant habitat fragmentation and shifts in age structure in forests managed for timber extraction,  and the fact that only 15 of Canada’s 51 boreal caribou herds have sufficient habitat remaining to survive long-term.”
 
Environmental and NGO organizations advocating for woodland (boreal) caribou and their habitats include:
David Suzuki Foundation
(https://davidsuzuki.org/action/protect-canadas-forests-from-degradation/)
Ontario Nature (protected places)
Environment North (based in Thunder Bay, ON)
Natural Resources Defense Council (NRDC)
The Narwhal (independent environmental journalists)
PEW Memorial Trust
World Wildlife Fund Canada
Canadian Parks and Wilderness Society
Canada Geographic
Alberta Wilderness Association
 
As if these challenges are enough, the province of Ontario is encouraging a mining boom in the boreal forest.   Several large projects are proposed in areas both immediate east and west of Wabakimi Provincial Park. Research is needed to understand the environmental risks and economic alternatives. 

 
Summary of Public Comments - NEW 

 (Paddlers!  Have you seen woodland caribou or signs, in SE Wabakimi P.P., Tamarack Lake, Lookout River &  Boiling Sands Rive;, Crown land routes- Collins, Fawn, Doe, Tunnel Lake, Rushbay, Vale Creek, D’Alton, Caribou and Little Caribou, Linklater, Raymond River, Big Lake, Big River, Pawshowconks etc.  We have do citizen monitoring! We need photographs, video and anecdotal evidence of caribou in these areas.  Please let us know!    Send to info@wabakimi.org)
 
The Friends of Wabakimi participated in this 10 year forest planning process administered by the Ministry of Natural Resources and Forestry (MNRF) as detailed on our Conservation Page.   The Wabadowgang Noopming Forest  (W.N.) is immediately adjacent to Wabakimi Provincial Park; just north and SE of Armstrong, Ontario.   It was split off the larger Nipigon Forest and has operated under a two-year contingency plan since.
 
MNRF has now issued their near  final determinations. (See their determination here) This is after FOW participated in the Dec. 6th in-person Issues Resolution Meeting with MNRF staff and many other interested parties. 

(Update:  Logging/road map 1;  Logging Road Map 2)
 
We achieved some modest goals: 1) A primary logging road was rerouted to lessen the long-term impact on the D’Alton Lake area, currently subject to ongoing harvest.  2) Small increases in buffers around known canoe routes. 3) Made known to MNRF and all parties that there’s a growing constituency that supports canoe routes and essential habitat protection.
 
But the overall end result promotes forest harvest activities and road building into virgin forest with little regard for the long-term impacts on woodland caribou.  
 
One distressing feature of the MNRF’s decision is the lack of any established monitoring.   Referring to the area SE of Tamarack Lake, the decision says, “As there is no known and verified caribou values present in this area at this time there is no area of concern prescription applied for caribou in this location of the forest.”  How would they know?  No monitoring has been done in recent history.  Essentially, MNRF is flying blind when it comes to the long-term impact on essential woodland caribou habitat.   They’ve made it clear it may be up to us to provide knowledge of caribou presence.
 
The FOW Board reviewed these issues at their last meeting and determined, after some strenuous discussion, to support Bruce Hyer and other advocates in efforts to question and potentially challenge this plan insofar as the plan is not sustainable for caribou, park values, ecological values, general recreation, and remote tourism.  That could entail being a “Friend of the Court” for an injunction proceeding or filing a petition under the Federal Endangered Species Act.    
 
Regardless, FOW has strived to build good relations with local communities, First Nations, and land managers such as the MNRF.  We will continue to do that in the hope that better understandings and collaborative solutions are possible.   
 
What else can we do now or in the future??

1. Provide our own monitoring; and share sightings with MNRF, our experts &  INaturalist.   This is an immediate need! 
2. Aspects of the MNRF W.N. plan are left vague and undefined; subject to future determinations and iterations of this planning process.  We can monitor and comment.
3. Research and determine if  the Canada/Ontario Boreal Agreement has any affect on this or other  forest plans.
4. Promote recreational canoe & outdoors economic benefits to local communities.
5. Involve more FOW  members with our Conservation & Forestry Committee.
6. Research other Forest Units (i.e. Caribou Forest), for future conservation/canoe route efforts

Fr:                   Vern Fish, Friends of Wabakimi - President,
                        Dave McTeague, Friends of Wabakimi - Board Chair
                        Maurice Poulin, Board of Directors
To:                  Mitch Legros, Ministry of Natural Resources & Forest
                        Jeff Cameron, Wabadowgang Noopming Forest Plan Author
Re:                  Request for Issue Resolution
Date:               November 6, 2022
 
Dear Sirs:
 
As you will recall, we have been long concerned about, and commented upon, proposed roads and logging in and near three areas adjacent to Wabakimi Provincial Park and inside the special land use zone of CLUPA 2616.

1. What is now called Kellar Road.
2. D’Alton Road between the D’Alton Block and the north end of Caribou Lake 
3. The area of the proposed Rocky Road near Tamarack and Bath and Gneiss lakes, the Boiling Sand River (all in the far southeastern corner of Wabakimi Park).

These areas are all highly sensitive and contain important values, some of which area threatened by all-weather roads (construction and use) and summer timber harvesting. We believe that these areas and these values are threatened by the proposed 2023-2033 draft plan. We believe that the draft plan is not adequately sustainable for the following values:

• Woodland caribou inside and outside of the park (Calving areas especially on Caribou Lake and Hollingsworth Lake, travel corridors, and year-round habitats)
• Park values. In the absence of any park plan, what occurs outside of the park will have significant de-facto effects upon the park and park values
• Remote tourism, both current and potential
• Important walleye spawning beds at the mouth of Campbell Creek
• Prime lake trout lakes (Caribou and Campbell lakes)
• Wilderness canoeing: both General Recreation, and Commercial canoe outfitters. The concerns include:

1. Loss of remoteness
2. Adverse effects upon woodland caribou, which are a threatened species and key value not only for their own inherent biodiversity, but also a big draw for wilderness paddlers for a chance to see them.
3. The north end of Caribou Lake is the most important access point for the park, both in qualitative and quantitative terms. It really should have been included in the park as an access zone. That may happen someday. While we do understand that is a land use planning decision and lies outside of FMPs, the FMP must recognize its effects upon those values. There are also established canoe routes and connections to the north and east of Caribou Lake, connected to Caribou Lake.
4. There are extremely important canoe routes closely adjacent to the proposed Rocky Road (including Tamarack Lake and Boiling Sand River, Gneiss, Bath, Gnome, and Collins Lake). Paradoxically Tamarack and the Boiling Sand are both high quality routes and access points, while also having a severely limited capacity for increased access and use. Through both future FMP’s and park planning, these important but fragile canoe routes must be protected from logging disturbances from May-September, and overuse threatening park values (including caribou and lake trout) caused by undue disturbance and access.

At an earlier stage in the FMP we identified all these values, and urged that these three areas be established as Conservation Reserves. We were informed that such a land use planning decision lies outside of the aegis of the FMP. We do understand that. However, those values and their sustainability must be protected, and the options must be kept open. Therefore, we are requesting that we engage with the Regional Director in the Issue Resolution process outlined in the FMP manuals. We feel strongly that:

1. The D’Alton block and the northern end of Caribou Lake be protected from the noise and disturbance of roads (construction and use, and enhanced access). We are requesting that any and all roads and harvesting be done during the winter, occurring only between mid-September and April. All roads must be winter only and very temporary.
2. The Kellar Road and harvesting should only be winter/temporary. It should never be a primary road. 
3. Rocky Road and the associated harvest within at least 2 km of the park boundary should either be:

1. Only winter roads, without gravel, and with winter harvesting. This would be a large compromise, given that what we feel is really needed is:
2. Harvesting or roads within 2-3 km of the Wabakimi Boundary be deferred until the 2033-43 plan. This will:

• Allow the completion of the Wabakimi Park plan. Hopefully by then there will be an approved plan that ensures only winter roads and harvest within 3 km of Wabakimi Park, over the shortest possible time frame to protect both tourism and caribou values. Wabakimi is beginning to boom, and the tourism business potential is very significant.
• Maintain the option of future harvesting and associated employment, without reducing the Annual Harvest Allowance on the forest.
• Protect existing (presently three) commercial canoe outfitters and foster additional potential future local outfitters, including indigenous businesses owned by Whitesand and Collins members.
• Protect the high-quality experience on the canoe routes for canoeists in general. In short, ensure the sustainability of the high-quality recreational canoe trip wilderness experience, with the lowest possible adverse effects on the boreal ecosystems there.
• Protect caribou habitat currently used year-round for the upcoming decade, and allow better caribou monitoring and planning, helping to ensure long term sustainability. This is crucially important at the southern limit of the line of continuous caribou distribution… far, far north of the original southern limit in Wisconsin and Minnesota. Recently the Federal Government committed many millions of dollars to caribou monitoring by Ontario, which would be useful here there is little or no recent caribou monitoring.
• Maintain the existing level and means of access for local and traditional users.

In the late 1990’s, all three of these areas were included in CLUPA 2616, part of a long, monumental, expensive provincial land use planning decision. This special land use designation puts caribou, wildlife, and remote tourism values as a higher priority than forestry. While it does not ban forestry, it does state firmly and clearly that in matters of conflict with logging, that matters will be resolved in favour of the protected values. So far, many planning team members have not seemed to take that mandate seriously. MNRF policy staff have repeatedly reasserted in this process that provincial land use decisions come before logging decisions. There are province-wide implications as to whether MNRF does indeed support the land use decisions from Lands for Life/Ontario’s Living Legacy. It seems clear to us that our proposals above are a reasonable compromise between forestry and clear CLUPA 2616 directives. In addition to direct input from us to the FMP, we have participated in the LCC meetings, and we also voiced our concerns to the LCC planning team representative.

The Crown Forest Sustainability Act directs the Minister to not approve plans which cannot be shown to be sustainable for all forest values. We believe that our suggestions above will result in an FMP that is more sustainable than the proposed draft plan.  What are the next steps? What other information do you require?
Respectfully,
  
Vern Fish                    Dave McTeague                      Maurice Poulin
President                     Board Chair                            Board Member

​To: Jeffrey Cameron RPF,                              Date: July 31, 2022
WN Forest Plan Author

Fr: Vern Fish, President
Friends of Wabakimi
 
Re: Stage Four Comments
Wabadowgang Noopming Forest (WNF)
2023-2033 Management Plan
 
Dear Mr. Cameron,

As you know, I represent the Friends of Wabakimi (FOW) on the Wabadowgang Noopming Forest LCC. The Friends of Wabakimi is a non-profit organization registered in the Province of Ontario. Our mission is to “advocate for the protection and preservation of the diverse natural, cultural and historical resources of the Wabakimi Area”. The FOW define the Wabakimi Area as a 2,572,734 hectare virtually roadless tract that includes Wabakimi Provincial Park and a host of surrounding provincial parks, Conservation Reserves and Crown land. The Wabadowgang Noopming Forest (WNF) is part of the Wabakimi Area.
A Sense of Wilderness

I attempt to keep the Board of Directors up to speed on the progress of the forest management plan for the WNF. They feel that maintaining a sense of wilderness in the WNF is an important value to be preserved. FOW’s priorities and concerns fall under the following topics:

1) Ecological integrity and sustainability
2) Protect critical habitat for species at risk
3) Maintaining a healthy and sustainable woodland caribou population
4) 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
*Allow limited access to historical canoe routes across the WNF
Crown Land Use Policy Atlas (CLUPA)*

The policies of CLUPA 2616 covers the WNF north of the Big River. “Road access will be managed to maintain commercial tourism and fish and wildlife habitat. Operating and annual plans will contain specific guidelines for the protection of tourism values and fish and wildlife habitat.”

We understand that forest management and logging are allowed in CLUPA 2616. We appreciate the effort that has gone into using the McKinley Road to access Block AB-3 to avoid building a road between Caribou Lake and D’Alton Lake. We note the effort to prevent road access to the Michell Lake and creation of buffers to insulate historic canoe routes. We also note the effort to decommission secondary roads once they are abandoned.
We also note that even though the Big Lake Road is signed "Road closed to unauthorized vehicles. Access prohibited under PLA. This gate is currently open, and the intent is to keep it open.” (Page 179). We assume this means that recreational paddlers can still use the Big Lake Road to access the Big Lake and the Big River. As noted, the FOW encourage limited access to historical canoe routes.
*Please note that on page 73 of the Management Plan it appears that CLUPA 2616 has been mislabeled as CLUPA 2619.

Species at Risk
CLUPA 2616 does focus attention on maintaining fish and wildlife habitat. Page 198 of the draft forest management plan notes that “known nests will not be destroyed”. Page 47 provides a list of birds identified as Species at Risk. This list includes: Canada Warbler, Olive Sided Flycatcher, Common Nighthawk and the Bald Eagle. All of these bird species and many more have been identified along Big River canoe route which includes the Reef Lake Peninsula. Evidence of caribou was also found along the Big River. The attached memo, Reef Lake Peninsula Harvest Area, provides details and supporting documentation.
As a result of this documentation, the following motion was approved by the Board of Directors of the Friends of Wabakimi at their June 26, 2022 meeting.

“To maintain the habitat and the wilderness values of this potential conservation reserve, the Friends of Wabakimi strongly recommend that the Reef Lake Peninsula NOT be considered for logging.”

Herbicides & Rocky Road
In the Summary of the Wabadowgang Noopming 2033-2033 Forest Management Plan on page 10, herbicide use was identified as a major issue. At this time it is unclear as to whether herbicide use would be acceptable to all stakeholders particularly in the areas that the Rocky Road would make accessible. If herbicides are not acceptable and cannot be used as silviculture strategy to regenerate the forest after the cut, will this block still be logged? If not, will the Rocky Road still be needed?

Wabadowgang Noopming Draft Forest Management Plan 2023-2033
Forest Management Plan Timetable

                                  www.wabakimi.org; info@wabakimi.org
 
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   borealcaribouconservation@ontario.ca
 
Strategic Priorities Directorate;  Canadian Wildlife Service; Environment and Climate Change, Canada   15th Floor, Place Vincent Massey
Gatineau, QC     K1A 0H3  ec.eccc-caribou.ec@canada.ca

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:

• We support the proposed investment in monitoring and science (Conservation Measure 1.1), and the review and collation of existing science and Traditional Ecological Knowledge over the next 1 – 5 years (Conservation Measure 1.2, 1.4). We are also pleased to see acknowledgement of the need to engage thoughtfully with Indigenous communities from year 1 and to continue to assess this approach (Conservation Measure 1.3).
• We are particularly pleased to see mention given to prioritization of Crown land locations for habitat restoration (Conservation Measure 2.1). We hope this will be initiated in Year 1 as stated, and implemented in Year 2. We recommend that this be extended to include establishing protected status for these priority areas as well.
• We support Conservation measure 2.2, to expand and create new protected areas. In conjunction with 2.1, these are the key things which are needed to improve the status of Boreal Caribou in Ontario.
• We applaud the consideration of funding to support Boreal Caribou conservation initiatives, and recommend that these include tangible actions including habitat restoration and protection (Conservation measure 5.1).

 
                                                       

 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.    

1. Caribou Lake (the northern half). The northern shore, with its dozens of islands, has been documented as critical calving habitat and an east-west migration corridor. Caribou need to be protected from adverse influences that will reduce their movement and their calving success. These impacts include roads, adjacent logging and excessive recreational use in May and June. These impacts could be well achieved through status as a Conservation Reserve, with appropriate management prescriptions under the Public Lands Act. Aside from concerns about affecting caribou calving, the northern half of Caribou Lake has a relatively high intensive use recreational capability. It acts as a “filter/buffer” to reduce overuse of the more sensitive sites inside the park.
2. Caribou – Campbell - Hollingsworth Triangle – This area is bounded by the park on the west and lies north of Caribou Lake and south of Campbell and Hollingsworth Lake including Campbell Creek, which is an important walleye spawning area. Campbell Lake is a valuable and remote lake trout lake. Hollingsworth Lake has been well documented by MNRF as critical caribou calving area, historically and presently.
3. The “D’Alton Block” (aka Big River Canoe Route)  – This area includes most of the Big River drainage stretching from Linklater Lake on the north, to Lower Pawshowconk on the east, the Big Lake to the south and northeastern arm of Caribou Lake. The D’Alton Block would include D’Alton, Reef, Moonshine, Cosmo, Amra, Michell, Cumaway, Rhodes, Ruxton, Pawshowconk and the Linklater Creek chain. It also includes all the Big River as far east as the McKinley Road.

 
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:

1. Defer roads and harvesting wherever possible within those areas recommended for Conservation Reserve status.
2. Wherever possible, any harvesting within these sensitive, valuable, and contentious areas should utilize access that is:

• As temporary as possible
• Winter roads/harvesting where possible
• As short-term harvest as is feasible, preferably in winter.
• Fully decommissioned and revegetated to remove linear features

Of particular importance for lowest possible grade, temporary (perhaps winter) roads are:

• Kellar Road, and any proposed road near the north end of Caribou Lake.
• Roads in or near the D’Alton Block
• Roads near Hollingsworth or Campbell Lake
• The Trail Lake Road anywhere west of Fawn/Doe Lakes.

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 info@wabakimi.org