First I would like to…

   First I would like to commend you on what I perceive to be the strengths of this draft management plan:

  It is noteworthy that you have identified the protection of the woodland caribou population on the Slates, which you call the “park’s most notable natural feature” (Page 1), as the reason why “the replacement of the [previous] management plan was required” (1).

  Given this context for the creation of the new plan, it is not surprising that woodland caribou are also given a specific mention in the “vision” for the park: to “provide a refuge for the forest-dwelling woodland caribou and other wildlife species of the park” (5).

  Since 2007 the plight of the woodland caribou across Ontario, and Canada, has gained more attention, leading to 2009 provincial and 2012 federal plans for their protection. Also since that time, the Lake Superior herd (ON6) has been significantly weakened; the caribou have disappeared from Pukaskwa National Park, and predators have reached both the Slate Islands and Michipicoten Island (the other ON6 refugium).

  The draft management plan seems to acknowledge the change in context, recognizing that the park plays a central role in meeting the Ontario Government’s commitment “to managing Lake Superior coastal caribou for population security and persistence” (7). However, the language in the 2009 provincial document is exclusively about managing habitat in order to protect the ON6 herd. Unfortunately, the situation on the Slates Islands is such that the current threat to the persistence of woodland caribou in the park (i.e. predation by wolves), cannot be managed for by managing habitat.

  Rather, it is apparent that in order to meet the objectives and vision of the park, and to ensure a future for the ON6 herd you will need to actively manage for predators. Such intervention is permitted by the draft plan in at least two places:

  - “Wildlife population(s) may be controlled when human health or safety risks arise, or when the values for which the park has been established are in jeopardy” (19).

  - “Active wildlife management, if necessary, through the most appropriate means is permitted to protect existing wildlife populations” (19).

  In spite of this language, and the change in context brought about by the loss of ON6 caribou on the mainland and the arrival of wolves on both the Slate Islands and Michipicoten Island, woodland caribou make only a marginal appearance in your section on Implementation Priorities. There it is stated that “inventory and assessment of use of smaller islands by nesting waterfowl as well as use as caribou calving and nursery habitat” will be carried out in the “medium term” (30). Though one would expect to see there some mention of woodland caribou population decline from wolves, there is nothing. In fact, this current management problem is so absent from the draft management plan that if someone unaware of the current existential threat to ON6 read it, he or she would have no inkling of the dire situation of the park’s population (let alone the whole ON6 herd).

  Consequently, though I find the wording of your draft management plan relatively strong (as I detailed above), it does not currently provide any concrete assurance that the most “notable natural feature” of the park will actually be protected. As such, at this point I could not support the new management plan unless it was edited to include one of the following:

  - A note in the short term section of the implementation plan detailing what predator management for the preservation of woodland caribou in the park is to be undertaken.

  - A note in the short term section of the implementation plan detailing how the woodland caribou populations are currently (or will be) monitored, plus an explicit mention somewhere in the management plan of the minimum recruitment threshold, below which active predator management will begin.

  Absent one of these additions, the draft management plan does not offer the people of Ontario the assurance that the park’s staff is ready to act to protect the remnants of the Lake Superior herd, even though the management plan in its current state leaves room for such action. If such protection is not ensured by the new plan, then the ten year process of replacing the previous management plan in order to protect woodland caribou has been for naught, and the province will once again have failed to act in accordance with its own policies.

[Original Comment ID: 210009]