Comments on the …

Comments on the “Conservation Agreement for Boreal Caribou in Ontario”
Environmental Registry of Ontario Number: 019-4995
General
• While I applaud efforts to preserve boreal caribou populations, I feel that there is a need to bring in a more realistic approach to population maintenance and recovery actions. Trying to recover boreal caribou populations in the southern portion of their range is impractical given the level of development. Your document indicates that human land use activities are a major factor in the decline of caribou populations. The communities, railways, highways, roads, mines, forestry operations in the southern portion of caribou range are not going away and development will in fact be increasing (e.g. proposed mining developments, new roads to First Nations Communities). Therefore, the probability of successfully recovering caribou in this part of their range is very low. This means that there will be no value gained for the expenditure of public funds in this part of caribou range!
• I realize that the argument then becomes one of are we then just pushing the caribou northward. For me it is a question of where can we effectively achieve the purpose of the conservation agreement. I feel that the focus should be on areas where development is currently limited and where we can develop and implement mitigation measures that will be effective.
• The proposed conservation agreement indicates that “boreal caribou protection and recovery will consider biological, social and economic factors…”. Thus, I respectfully request that the positive and negative impacts of caribou protection and recovery actions on other species (e.g. furbearers, moose, birds etc.), and on trapping and hunting be fully evaluated, documented and presented to the public.
o Where I live, I am abundantly aware that current management actions focused on re-establishing caribou populations have had an adverse impact on furbearer, moose and bird populations as habitat for these species has been destroyed or fragmented.
o Please don’t dismiss these observations. These are observations made by myself and other individuals who are out on the land almost every day. Citizen science/observation is widely recognized as valuable in wildlife management circles (See Wildlife Society publications, Birds Canada publications).
o Trapping has never been recognized as a business activity or as having much of an economic impact at the local, provincial and national level. Trapping is the longest standing sustainable business activity in Canada and contributes, in a significant manner, to local, provincial and national economies. Furbearer harvests have declined substantially on traplines where habitat management for boreal caribou has occurred and this has significantly affected revenue. If Canada and Ontario believe that it is important to ensure the survival of caribou while guaranteeing our continued prosperity (page 4) then trapping needs to be considered an important economic factor in discussions related to management efforts for caribou.
o Similarly, I have seen a radical decline in moose populations in those forest management units where habitat management for boreal caribou has occurred. This has had an adverse effect on moose hunting opportunities both as a social activity and as an economic activity.
o Forest management has long been recognized as having an adverse impact on bird populations. Cutovers established for caribou habitat management are extremely large in size and are often located one beside the other so there is the cumulative disturbance effect.
• I understand that boreal caribou require large undisturbed areas of old conifer upland and lowlands. If this is the case then why are forest product companies allowed to cut large tracts of old conifer forest each year? It is also important to note that stands well under rotation age are being cut and wood is being wasted in many forest management units. So, if you are cutting old age stands and stands under rotation age how will you achieve or maintain large areas of old conifer stands?
• Stakeholder Involvement- There is a lot of mention of stakeholder involvement in this proposed agreement and I support this. This is one aspect of the agreement that must be taken seriously and acted on in a practical and sincere manner.
• Cumulative Disturbances – I have never seen a comprehensive analysis of cumulative disturbances within any of the caribou ranges. A very cursory analysis would suggest that the 65% undisturbed habitat benchmark is not being achieved in some ranges. I would like to see an analysis of cumulative disturbances conducted on an annual basis and provided to the general public so that “adaptive management” adjustments can be made.
• Building on existing actions – I am concerned with the statement that the agreement will build on “existing actions”. This assumes that existing actions are effective when perhaps they aren’t. I would challenge the notion that a landscape management approach in its current form is working. We have been playing around with habitat management for caribou since the early 90’s and the reports on caribou population status are clear that things are not improving. These reports are consistent with what trappers and hunters are seeing on the ground. I would also suggest that there is no way that you can prove that ecosystem form and function are being maintained in areas managed for boreal caribou.
• Adaptive Management – This is a very important management concept that must be better addressed in this agreement as it doesn’t appear to have been given much
credence to date. For adaptive management to work we need a consistent monitoring effort along with transparency in what those monitoring efforts identify. The public needs to know if management efforts are working and the money that they are spending has value.
• Mitigation of Socioeconomic Impacts – I want to ensure that trapping and hunting are part of discussions to mitigate socioeconomic impacts. I would also like to see a description of the methodology that will be used to assess and mitigate socioeconomic impacts.
Principles
• All of the principles proposed for inclusion in the agreement are appropriate but I feel that they need some elaboration.
o Use of best information – The on-the-ground observations of trappers and hunters need to be part of efforts to collect and use the best information for management. MNRF, Birds Canada, The Wildlife Society are organizations that recognize the value of citizen science/observations.
o Transparency – This has been lacking to date. When information is provided it is often heavily “sanitized” and lacking in detail. Monitoring results and all other data/information related to the management of boreal caribou must be readily available for public scrutiny. As part of this transparency principle I would like to see a line by line summary of how much money is spent and how it is spend on an annual basis since public funds are being used.
o Risk based approach – This is important but not just for caribou. I would like to see a risk assessment conducted to show how proposed caribou management efforts positively or adversely affect other species.
Stakeholder Engagement
• Collaboration – Collaboration with organizations or individuals is emphasized yet trapper and hunter input date has not been given much weight in the management of boreal caribou to. I want a commitment that trappers and hunters will be full partners in all discussions on management actions that will form part of this agreement. I suggest that collaboration at the trapper’s council level would be appropriate.
Conservation Measures
• Caribou Monitoring Program – I support a monitoring program that will improve our understanding of the status of boreal caribou in relation to the management actions that are taken to maintain or recover populations. However, I also want to see monitoring of other key species (furbearers, moose, birds) in the boreal forest. We have been told that a landscape management approach for caribou is also good for other wildlife species that live in the boreal forest. Well let’s see if that is true. This information will better help the public to understand the effect of management actions that are focused on caribou.
o I need to understand what is meant by “the need to adjust existing policies, where appropriate, (e.g. prioritization of species…)”. I will not support a restriction in the ability of trappers to harvest furbearers or actions to limit hunting opportunities for moose. Access restrictions are one of the things that I will not accept without a lot of supporting rationale.
• Caribou Range Boundary Review and Updating – I support a process that will involve stakeholders and provide for a periodic and transparent review of caribou range boundaries. I have indicated in previous comments that while caribou may have existed in certain areas in the past, the current level of human land use activities in certain ranges and climate change makes recovery very improbable and a waste of limited taxpayer dollars. In these areas the management for furbearers and moose should be the focus. I will continue to promote a more realistic approach to the management of boreal caribou.
• Habitat Restoration Assessment Initiative – I fully support the assessment of the effectiveness and efficiency of habitat restoration approaches. Of particular interest is the documentation of the cumulative disturbances at a range level because I feel that this is not being well monitored and therefore is not being incorporated into an adaptive management approach.
o Stakeholders must be involved in this assessment initiative because it is these groups/individuals who are on the land almost every day and see the direct effects of habitat management efforts.
• Science Plan – I support the development of a science plan as this is one of the ways that you support an evidence-based approach to the management of boreal caribou, support an adaptive management approach and, spend taxpayer dollars in an effective manner. Once again stakeholders need to be engaged in the development of a science plan.
• Data Sharing – I support data sharing between the federal and provincial governments. I would also like to see a provision that allows stakeholder groups to access data.
• Habitat Restoration – While it appears reasonable to “Develop a prioritized list of Crown land locations for all boreal caribou ranges and implement habitat restoration activities in select locations.” I need more information on what this means in practical on-the-ground terms. I support decreasing fragmentation and cumulative disturbance but I want to see how this might be done given the influence of forest products companies and mining interests.
o I want to see an “evidence based” approach used to establish the prioritized list and I want to see this evidence provided to stakeholders and the general public in a transparent manner.
• Protected Areas Initiative – I would not support the expansion of protected areas if it means that trappers will have further restrictions on their ability to harvest furbearers or access their trapline areas. I want to see a listing and map description of the Living Legacy Sites that you are looking at before any decisions are made to incorporate these into an expansion of protected areas.
• Forest Management – I have significant concerns around the forest management planning process, as it relates to caribou habitat management, because the impacts on furbearer habitat, trapper harvests and, trapper access to their traplines are significant! I would support a review of the effectiveness of the BLG and how forest management activities are used to manage caribou habitat. The following are my main concerns:
o Cumulative disturbances don’t appear to be well managed. The cutovers that have developed are often adjacent to each other and these cutovers are excessively large. This results in large portions of traplines being cut.
o Forest products companies are harvesting large tracts of old conifer stands even when we know caribou, American marten and wolverine require this type of habitat.
o There is no evidence of an effective “adaptive management approach” in forest management plans.
o A paper published in Wildlife Bulletin 38(1) by Dr. David Euler highlights the problem with forest management activities. This paper indicates that there seems to be little reason to believe that certified forests are more likely to protect and conserve habitat for bird species. Bird species are often used to gauge the health of forest ecosystems.
• Mining Exploration and Development – Best management practices for mining activities are referenced but my understanding is that such practices are not a requirement like they are in the forest management planning process. Significant habitat impacts can occur on the landscape due to mining activities so a review of the effectiveness of these best management practices is warranted.
• Lake Superior Coast Range – Development and implementation of a management approach for the Lake Superior Coast Range would appear to a waste of time and taxpayer money. It is highly unlikely that the population of caribou in this range will survive given the level of human land use activities that are in and adjacent to the range and given the effects of climate change. Would it not be better to focus efforts on those areas where there is a higher probability of a successful outcome?
• Evidence Based Approach – An evidence-based approach is necessary in order to enable an adaptive management framework. If you want to refine an evidence based approach then involve stakeholders in the collection of information.