The Grand Council of the Crees

Opinion on Woodland Caribou

Posted: 2010-06-21

Ms. Madeleine Paulin, Deputy Minister
Ministère du Développement durable,
de l’Environnement et des Parcs
Provincial Administrator, Section 22
assessment and review procedure (JBNQA)

Mr. Peter Sylvester, President
Canadian Environmental Assessment Agency
Federal Administrator, Section 22
assessment and review procedure (JBNQA)

Subject: Application of the precautionary principle in environmental assessment: Opinion regarding suspension of the review of forest road projects given their impact on w oodland caribou habitat

Dear Ms. Paulin and Mr. Sylvester:

The James Bay Advisory Committee on the Environment (JBACE) is extremely concerned about the impacts of planned forest roads on the habitat of woodland caribou (boreal population), a species designated “threatened” since 2003.

Several months ago, we recommended to the Québec minister for natural resources and wildlife as well as to the federal environment minister that a regional approach to impact assessment of road infrastructure be adopted. In the Committee’s opinion, reviewing roads on an individual basis does not enable adequate assessment of their cumulative impacts. Unfortunately, no steps have been taken in this regard. Consequently, the Committee is forced to call for application of the precautionary principle and ask you to immediately suspend the review of road infrastructure.

Even though the woodland caribou recovery plan contains measures to be implemented during environmental assessment of forest roads, we find that such measures are impossible under current conditions. More specifically, identifying critical habitat is considered by scientists to be a crucial element of the recovery plan. Yet, it appears that proponents of forest road projects still do not have these essential maps and, consequently, cannot determine the exact impacts of their projects on woodland caribou. We would point out that this is a minimum requirement for ensuring that the habitat of this threatened species is taken into account. Moreover, protection of critical habitat is also an obligation under Canada’s Species at Risk Act.

Thus, as overseer of the administration of the Section 22 (JBNQA) assessment and review procedure, the JBACE is calling on you, as administrators of this procedure, to order the Review Committee and the Review Panel to stop reviewing forest road
projects until the criticalhabitat maps have been submitted and can be taken into consideration during impact studies for these projects. These habitats are critical to the woodland caribou’s survival and in the absence of this knowledge, it is impossible to assess the soundness of planned forest roads and formulate solid mitigation measures.

Yours truly,


Josée Brazeau
Vice Chairperson

cc: Matthew Coon Come, Grand Chief, Grand Council of the Crees and Chairman,
Cree Regional Authority
Isaac Voyageur, Cree Regional Administrator
Nathalie Camden, Associate Deputy Minister of Wildlife, MRNF
Damon Rourke, Director General, Implementation Branch, Indian and
Northern Affairs Canada
Richard Nadeau, Regional Director General, Fisheries and Oceans Canada
André Lapointe, Regional Director General, Transport Canada
Philippe Morel, Regional Director General, Environment Canada
Louis Lesage, Chairperson, HFTCC
Gauthier, Chairperson, CQFB
Gaudet, Chairperson, COMEV
Pierre Mercier, Chairperson, COMEX
Benoît Taillon, Chairperson, COFEXSouth