1 October 11, 2011 by COURIER the Honourable Peter Kent, P.C., M.P
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October 11, 2011 BY COURIER The Honourable Peter Kent, P.C., M.P. Minister of the Environment Les Terrasses de la Chaudière 10 Wellington Street, 28th Floor Gatineau, Quebec K1A 0H3 Dear Minister Kent: Re: Recovery Strategy for the Woodland Caribou (Rangifer tarandus caribou), Boreal Population, in Canada – Saskatchewan Mining Association. The Saskatchewan Mining Association (SMA) represents mining and exploration companies operating and investing in Saskatchewan. This initial letter to you is to express the sincere and deep disappointment of our members in the proposed Recovery Strategy of the Woodland Caribou (Rangifer tarandus caribou), Boreal Population, in Canada (the Proposed Recovery Strategy) that was released on August 26, 2011. The SMA has been actively involved in consultation sessions with Environment Canada (EC) over the past two years that were to have informed this Proposed Recovery Strategy. These efforts included direct correspondence to senior EC officials on August 6, 2009, January 25, 2010, September 13, 2010, and June 30, 2011, as well as direct involvement in a consultation meeting in Saskatoon on August 31, 2010 (correspondence is attached). In each of these instances, we provided Environment Canada officials with our concerns regarding the Scientific Review for the Identification of Critical habitat for Boreal Caribou report, as well as information to help inform development of the Recovery Strategy. Unfortunately, this input was not used or was ignored in the development of the Proposed Recovery Strategy. This document contains the same unanswered, critical shortcomings as did the earlier review, and we have not been provided with an explanation as to why the information we had provided was disregarded. In this proposal, Saskatchewan unfairly bears the consequences of a flawed model that was not developed in a transparent manner. As written, the Proposed Recovery Strategy will not only impose severe restrictions on the development of any resource or infrastructure project in the entire northern half of Saskatchewan, but will also restrict economic and social development for the residents of this region, already one of the most economically disadvantaged areas in all of Canada. Even worse, it is far from certain that implementing such severe restrictions on human and industrial activity in the north would have any impact whatsoever on the sustainability of the province’s woodland caribou populations. As this report indicates, natural fires are the most significant 1 factor affecting caribou habitat in northern Saskatchewan (exceeding 60% disturbance in some units), while anthropogenic activities have very little impact (2-4%) in any of the local population regions identified. Minister, I would ask that you reflect upon the serious repercussions that this report will have on the social and economic fabric of the people of Saskatchewan, particularly the province’s north, on its mineral industry, on the investment climate in Canada and strategically on the global supply of uranium – especially given that anthropogenic activities are recognized as having a minimal impact on the boreal caribou populations in northern Saskatchewan. A more detailed letter from the SMA that specifically addresses what we have identified as the scientific, technical and administrative errors and inconsistencies will be forthcoming. We would be pleased to discuss our concerns with you or your staff at any time as we look to find a solution to ensure healthy boreal caribou populations, a healthy quality of life for residents of northern Saskatchewan, and a healthy mining sector that can continue to contribute to the province’s economic growth and to global clan energy security. Yours sincerely, Pam Schwann, P. Geo, M.Sc. Executive Director cc. Right Honourable Stephen Harper, Prime Minister of Canada Honourable Brad Wall, Premier of Saskatchewan Honourable Joe Oliver, Minister of Natural Resources Canada Honourable Jim Flaherty, Minister of Finance Honourable John Duncan, Minister of Aboriginal and Northern Affairs Honourable Ed Fast, Minister of International Trade and Minister for the Asia-Pacific Gateway Hon. Diane Finley, Minister of Human Resources and Skills Development Canada Honourable Gerry Ritz, Minister of Agriculture, MP Battlefords - Lloydminster Honourable Lynne Yelich, Minister of Western Economic Development, MP Blackstrap Honourable Andrew Scheer, Speaker, House of Commons, MP Regina – Qu’Appelle Mr. David Anderson, Parliamentary Secretary to the Minister of NRCan, MP Cypress Hills – Grasslands Mr. Ed Komarnicki, Parliamentary Secretary to the Minister of Human Resources & Skills Development and to the Minister of Labour, MP Souris-Moose Mountain Mr. Tom Lukiwski, Parliamentary Secretary to the Leader of the Government in the House of Commons, MP Regina – Lumsden - Lake Centre Mrs. Kelly Block, Chair Saskatchewan Caucus, MP Saskatoon – Rosetown – Biggar Mr. Rob Clarke, MP Desenthé – Missinippi – Churchill River Mr. Randy Hoback, MP Prince Albert Mr. Ray Boughen, MP Palliser Mr. Garry Breitkreuz, MP Yorkton – Melville Mr. Bradley Trost, MP Saskatoon – Humboldt 2 Mr. Maurice Vellacott, MP Saskatoon – Wanuskewin Mr. Wayne Wouters, Clerk of the Privy Council and Secretary to the Cabinet Honourable Bill Boyd, Saskatchewan Minister of Energy and Resources Honourable Dustin Duncan, Saskatchewan Minister of Environment Honourable Ken Krawetz, Saskatchewan Minister of Finance Honourable Jeremy Harrison, Minister of Enterprise Saskatchewan Honourable Ken Cheveldayoff, Saskatchewan Minister of First Nation and Métis Relations Honourable June Draude, Saskatchewan Minister of Social Services Saskatchewan Mining Association Executive 3 .