FOW Requests Issues Resolution Meeting with MNRF Regional Director -- advocates for road building restrictions & protecting caribou habitat

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