Jennifer Chikoski, Senior Policy Advisor Ministry of Natural Resources, Policy Division - Species at Risk Branch c/o Centre for Northern Forest Ecosystem Research 955 Oliver Road - Thunder Bay, ON P7B 5E1 Fax: 807-343-4001 Re: A proposed approach for habitat protection for Woodland Caribou (Forest-dwelling boreal population) under the Endangered Species Act, 2007 - EBR Registry Number 011-2303 Dear Ms. Chikoski, I am deeply concerned about the Ministry of Natural Resources' recent proposal to exempt industry from meeting the requirements for woodland caribou protection under the Endangered Species Act. This approach will grant industries like forestry, mining and hydro, full access to most of Ontario's caribou habitat in the boreal forest. Habitat loss, including alteration and fragmentation, is the main threat to approximately two-thirds of the province's species at risk. The lack of sustainable forestry operations, coupled with the lack of contiguous land that is off limits to industrial development, is forcing more and more species closer to the brink of extirpation across Ontario. Woodland caribou are considered "threatened" both federally and provincially and have been facing a drastic, ongoing range recession - caribou have lost 50% of their historic habitat since 1880. Healthy, self-sustaining populations of woodland caribou require large, undisturbed areas of mature forest to survive. Current science indicates that the only way to ensure woodland caribou persist in a forest is by maintaining the area's intact remote character. There is no existing evidence to suggest that caribou will re-inhabit an area that has been subject to industrial activities, particularly logging. Although this proposal will provide a "protection zone" for woodland caribou, it will at the same time facilitate the loss of habitat on a piecemeal basis - proceeding with this approach will ultimately result in the continued decline of woodland caribou in the province. Caribou needs must be considered on a landscape scale to ensure their entire range is protected. The economy is an important concern during these difficult times however I believe protecting caribou is possible without compromising current mill requirements. Given that many mills have already closed and that there is still wood available from areas that have already been disturbed, it is unnecessary to further threaten woodland caribou for the sake of the economy. The fate of woodland caribou will in many ways determine the future of the boreal forest itself. As an indicator species, caribou reflect the overall health of the forest. If we protect woodland caribou, other wildlife that need intact mature boreal forest ecosystems to survive, will also benefit. With the passage of the Endangered Species Act, Ontario became a North American leader in species at risk protection and recovery. We must ensure this important piece of legislation is upheld for the future of woodland caribou - and the province's other threatened species as well. I urge you to withdraw the proposal to exempt forestry, mining and hydro from fully complying with the Endangered Species Act in caribou habitat. If approved, this exemption will drive caribou from the forest, further paving the way for their extirpation in Ontario. Thank you for taking my concerns into consideration. Sincerely,