CRI CONSULTATION SUBMISSION
Environmental Protection
Environmental Submission — Formal Requests
14 formal requests on the Frontenac Arch Biosphere Reserve, the A2A wildlife corridor, and the Eastern Loggerhead Shrike on the Napanee Plain.
Environmental Protection
The formal requests below address ALTO’s Environmental Protection criterion. They span two related areas: the Frontenac Arch Biosphere Reserve and the A2A wildlife corridor; and the Eastern Loggerhead Shrike and alvar ecosystem of the Napanee Plain.
Core Finding — Frontenac Arch
The Frontenac Arch Biosphere Reserve’s northern boundary lies well south of ALTO’s northern corridor study area. Only the southern corridor crosses the designated UNESCO Biosphere Reserve, and it does so at the Frontenac Neck, the Reserve’s most geographically constrained point. There is no technically credible mitigation strategy capable of restoring Algonquin-to-Adirondacks corridor function through the Frontenac Neck once HSR infrastructure is built. The constraint is not engineering but geography: the bottleneck is the landscape itself.
Frontenac Arch & A2A Wildlife Corridor
1
Commission an independent wildlife connectivity assessment
Using species-level corridor modelling for Grey Ratsnake, Blanding’s Turtle, Cerulean Warbler, Eastern Whip-poor-will, and large mammals. This modelling must explicitly address the Frontenac Neck bottleneck geometry and include a formal feasibility assessment of wildlife crossing structures capable of maintaining A2A connectivity through a fenced HSR right-of-way.
2
Publish SARA critical habitat mapping at corridor resolution
For all listed species, with legal analysis of s. 32 and s. 58 implications before corridor selection. If no credible s. 73 permit pathway exists, the alignment must be rejected.
3
Conduct a formal UNESCO MAB compatibility assessment
Before any corridor selection decision, transmit findings to the Canadian National Commission for UNESCO and the International MAB Secretariat. This is not discretionary — it is required by Canada’s MAB commitments.
4
Conduct Parks Canada and UNESCO World Heritage impact assessment
For the Cataraqui Trail alignment’s crossing of the Rideau Canal at Chaffeys Lock, including analysis of alternatives to the 1912 heritage trestle — a federally recognised heritage structure within the Rideau Canal UNESCO World Heritage Site corridor.
5
Publish a Trans Canada Trail impact assessment
Addressing the permanent loss of 78.2 km of Trans Canada Trail designation across Leeds and Grenville, Frontenac, and Lennox & Addington Counties, including analysis of alternative corridor options and the feasibility of replacement.
6
Commission independent karst hydrogeological mapping
For the Cataraqui Trail’s Napanee Plain section, including dye-trace testing establishing flow connectivity between the corridor and municipal water supply springs.
7
Conduct population viability analysis for herpetofauna
For Grey Ratsnake (Frontenac Axis population) and Blanding’s Turtle, modelling cumulative mortality under a Frontenac Neck crossing added to the existing road barrier matrix.
8
Engage all relevant technical and community partners
Including Cataraqui Conservation, Friends of the Cataraqui Trail, the Frontenac Arch Biosphere Network (FABN), A2A Collaborative, Nature Conservancy of Canada, Rideau Waterway Land Trust, Parks Canada, and the Mohawks of the Bay of Quinte.
Eastern Loggerhead Shrike & Napanee Plain
9
Release ELOSH-specific habitat mapping overlaid on the southern corridor footprint
Has ALTO conducted Eastern Loggerhead Shrike (ELOSH)-specific habitat mapping? If so, the results must be publicly released as part of the consultation record before April 24, 2026. Total wild Canadian population: approximately 40 individuals; 22 confirmed Ontario breeding pairs (2022), below the federal Recovery Strategy’s own short-term Ontario target of 35 pairs.
10
Confirm designated ELOSH critical habitat has been mapped against corridor boundaries
The 2015 SARA Recovery Strategy identified critical habitat on the Napanee Limestone Plain. ALTO must confirm this has been mapped against the corridor footprint and make the results public.
11
File and disclose the SARA Section 79 notification
Confirm whether the mandatory notification to the competent minister has been filed. If not, state when it will be filed.
12
Formally consult Wildlife Preservation Canada’s Eastern Loggerhead Shrike Recovery Team
Confirm that the ELOSH Recovery Team has been formally consulted and that their comments will be publicly released as part of the consultation record.
13
Demonstrate SARA Section 58 compliance approach for the southern corridor
Specifically: what evidence of ‘no feasible alternative’ will be produced, and how will the ‘no jeopardy’ standard be met for a population of approximately 40 individuals?
14
Disclose MBCA compliance approach for multi-year construction across the Napanee Plain breeding season
The ELOSH breeding season runs April–August. What is ALTO’s approach to Migratory Birds Convention Act compliance during multi-year construction on the Napanee Plain?
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April 2026