RE: ERO Posting 019-4995,…

RE: ERO Posting 019-4995, Conservation Agreement for Boreal Caribou in Ontario

The Northwestern Ontario Municipal Association supports a workable agreement that ensures the best outcome for the citizens of Ontario. However, we ask that the forest industry, regulated professionals, directly impacted stakeholders, and Indigenous communities are consulted on the details of a finalized Conservation Agreement before signing to ensure no group or industry will be negatively impacted.

Prior to signing the agreement, it is important to address the following:
1) Prioritize caribou range boundary review before implementing other conservation actions.
2) Clearly define key legal terms, such as “recovery” and “self-sustaining” and provide indicators for what recovery will look like.
3) Recognition of management for all forest values, i.e., social, economic, and environmental. While an important consideration, we do not believe Ontario’s forests should be managed solely to support boreal caribou.
4) Clearly outline and demonstrate that the working forest landscape, wood supply to mills, and mining activities will not be impacted because of expanded parks or protected areas.
5) Incorporate the impacts of a changing climate on boreal caribou habitat.

Most importantly, the federal Species at Risk Act (SARA) needs to respect provincial species at risk frameworks, including Ontario’s Crown Forest Sustainability Act (CFSA) and Endangered Species Act (ESA). Ontario already has effective legislation to protect species at risk while balancing other forest values, there is no need for further action by the federal government. A weak agreement that does not update current caribou administrative boundaries and endorses the federal definition of “self-sustaining” has the potential to devastate northern Ontario.

Ultimately, we support the conservation agreement and the monitoring of the caribou ranges, but we stress that the CA must not impact forestry or mining activities specifically along the costal range.