A species at risk that is of great concern to Ontario Nature and our members is boreal caribou. For over a decade we have appealed to the Government of Ontario to address the increasing fragmentation of caribou habitat, and to implement recovery plans that protect caribou’s critical habitat, as required by the 2012 Federal Recovery Strategy.  

The best available science calls for a risk-based approach that ensures habitat disturbance does not exceed thresholds outlined in the 2012 Federal Recovery Strategy. However, Ontario has failed to implement these limits to disturbance in forests managed for industrial logging.  

Ontario and Canada recently drafted a Conservation Agreement (CA), which is defined under the federal Species at Risk Act as a voluntary agreement “to benefit a species at risk or enhance its survival in the wild.” Instead of instituting protections for caribou critical habitat in Ontario, the draft CA contemplates vague processes for reviewing policy, and identifying lands that may or may not receive protection and that may or may not be critical habitat. The agreement is best described as a “plan to make plans” through more assessments and reviews. It is far from the needed mandatory prohibition on critical habitat destruction.  

Further, the agreement fails to reflect the dire situation for caribou habitat in Ontario, including:  

1. Boreal caribou populations continue to decline. The 2019 Federal Recovery Strategy Progress Report states that 8 of the 9 caribou populations in Ontario are declining.   
2. The Ontario Auditor General says the Province of Ontario is failing. The November 2021 Auditor General report shows that many current decisions from the Government of Ontario have been more harmful than helpful for species at risk.  
3. Ontario law doesn’t require the forestry industry to recover caribou. The forestry industry received a permanent exemption from Ontario’s Endangered Species Act, 2007 (ESA), and is no longer legally required, under provincial law, to recover caribou.  
4. The Province of Ontario refuses to implement its own caribou insurance plan. Ontario’s Caribou Conservation Plan (2014) sets out an “insurance plan” requiring that new areas not be opened up to industrial logging unless caribou populations are shown to be self-sustaining. It has never been implemented. Habitat fragmentation continues, despite evidence that this will increasingly endanger boreal caribou. 
5. The Province of Ontario wants to double industrial logging. One of the Ontario’s Forest Sector Strategy’s goals is to almost double industrial logging by 2030. This strategy was published without any consideration of how forests could be shared to support the recovery of boreal caribou. 

Despite the evidence, the federal government is contemplating an agreement with Ontario that will undermine caribou recovery. In fact, lawyers at Ecojustice have stated that the agreement, as currently proposed, would be the weakest conservation agreement in Canada, and it will leave the federal government in breach of its legal obligations under the Species at Risk Act, SC 2002, c 29. 

The federal government has committed to work to halt and reverse nature loss by 2030 in Canada. The CA must align with and uphold this commitment. 

Please join Ontario Nature in urging the federal government to revise the CA so that it includes mandatory and immediate interim protection for critical caribou habitat. The deadline is March 21, 2022.