As the provincial and…

As the provincial and federal caribou conservation strategies are different collaborations between Ontario and Canada needs to consistent.
Ne-daa-kii-me-nan Inc (Nedaak) (a First Nations forest management company) recognizes that there is a lack of Indigenous input in the provincial and federal strategy. This has created large issues with the current range line for caribou management and the disconnect to previous caribou herds and future establishment of caribou habitat.
The EBR stated that the goal of the conservation agreement for Ontario is to work collaboratively with partners to sustain or improve the environmental condition necessary for recovery of the boreal caribou a the range scale – however, the range needs to be developed with input from First Nations which is currently lacking.
During development of the 2021-31 Kenogami Forest Management Plan (FMP), there was disagreement from the First Nations regarding the caribou range that was presented and incorporated into the FMP. This was due to the lack of local Indigenous input into the ranges that were established and the promotion of caribou management in areas that were not historically caribou habitat (from local knowledge). The LTMD was challenged in this respect and although local First Nation members developed strategies within the area managed for caribou on the Kenogami, there is still the outstanding issue that was not addressed regarding alteration of the range line.
It is noted that one of the principles for inclusion in the conservation agreement is the “use of best available information including Indigenous Traditional Knowledge…” To this, Nedaak expects that, as the forest management provider on the Kenogami Forest, and a wholly First Nation owned company that is comprised of 7 First Nation Communities, will be specifically contacted to ensure they are involved in creating the conservation agreement in addition to providing traditional knowledge.
Nedaak expects that the 3 points listed under the Indigenous collaboration and engagement will be included in the conservation agreement, as it is currently stated that those items are only ‘proposed in the conservation agreement”
Stakeholders that are not directly affected by the conservation agreement should not have more clout or weight that those stakeholders that are living, working, and directly receiving economic benefits from the forest. It is very disappointing when those that live in southern Ontario where there is widespread urban sprawl covering productive land and land that once supported a variety of wildlife species are trying to impose restrictions on our way of life.
We acknowledge the attempt to protect confidential data Communities. The system to ensure confidentiality must be established and approved by the Indigenous communities.
To respond to the specific conservation sections:
1.1 – Indigenous communities or Indigenous led groups will be involved in the monitoring program
1.2 - During development of the approach to review boundaries with stakeholders and Indigenous communities etc, local Indigenous members or Indigenous led groups need to be part of the process and on the team.
1.3 Assessment of the effectiveness and efficiency of habitat restoration must include recognition of the current Ontario management through the establishment of the dynamic caribou habitat scheduling system that has been in place since 1995. Review of the original DCHS to the current DCHS and actual suitability of the area to become future caribou habitat must be considered in the effectiveness determination. (i.e. the original 1995 area was more pertinent to caribou and caribou habitat than the additional areas added to the DCHS over time – the range line was moved and forest within the new area is not suitable habitat and will never be based on the forest composition)
2.1 The areas that currently have caribou and those that have shown to have caribou in the past should be those areas where caribou management should occur. Covering 75% of the Kenogami (as an example) to bring back caribou habitat and subsequently caribou, does not make sense. Moose was an integral part of a large portion of this area and should be the priority species again.
4.4 Using evidence to develop approaches needs to consider all aspects (i.e past harvest history, silviculture techniques) and integrate that information.

Overall the development of caribou management needs to include Indigenous knowledge over desires of NGO’s, concentrate habitat recovery in those areas that support caribou currently and target specific areas that will support caribou without stand conversion, and not to the detriment of moose populations.
Nedaak is willing to participate in the task teams for the entire project to ensure that local Indigenous knowledge is obtained and used in the development of this conservation agreement.