ALTO HSR · Environment · Biodiversity & Species at Risk
Canada’s Most Biodiverse Region Is Directly in the Southern Corridor’s Path
The southern corridor would run through the Frontenac Arch — one of only 19 UNESCO Biosphere Reserves in Canada, home to more species at risk than anywhere else in Eastern Ontario. Federal law does not allow this to be waved away.
ALTO HSR Citizen Research InitiativeMarch 2026
What is at stake. The southern corridor would pass through the heart of the Frontenac Arch Biosphere Reserve and through confirmed habitat for more than 25 federally protected species — including Endangered turtles, snakes, birds, bats, and fish. Federal law makes it a criminal offence to harm these species or destroy their habitat without a permit — and those permits cannot be granted if the project would jeopardize a species’ survival.
ALTO has not published a species at risk inventory for either corridor. The public consultation deadline is April 24, 2026.
Key Finding. Choosing the southern corridor would trigger a cascade of federal legal obligations that cannot be overridden by fast-tracking legislation. It would also put Canada’s UNESCO Biosphere Reserve designation for the Frontenac Arch at risk — jeopardizing $1.8 billion in annual regional tourism, internationally recognized conservation status, and Canada’s credibility under the global biodiversity framework it helped negotiate.
Six municipalities have already passed formal council motions opposing the southern corridor — five unanimously, and one calling for alignment with Highway 401. The legal obligations are binding today. The UNESCO periodic review is coming. None of this has been addressed in ALTO’s consultation materials.
The Frontenac Arch
Canada’s most biodiverse region — and one of its most protected
The Frontenac Arch is an ancient granite ridge that runs from the Canadian Shield down to the St. Lawrence River, where it creates the Thousand Islands. Where five separate forest regions converge, it has become the most biologically diverse area in Canada — a continental crossroads for plants, animals, and entire ecosystems. First Nations call it the backbone of the mother.
In 2002, UNESCO recognized the Frontenac Arch as a Biosphere Reserve — one of only 19 in all of Canada. The reserve spans 2,700 km² from Brockville to Kingston, north to Perth and Verona. It is part of a global network of over 700 protected sites in 130 countries, recognized as internationally significant for their ecological integrity and their connection between people and nature.
19 UNESCO sites in Canada
Frontenac Arch is one of only 19
The southern corridor runs directly through it.
2,700 km² reserve area
Brockville to Kingston
North to Perth and Verona — a living landscape connecting nature and human activity.
25+ protected species
Federally listed Endangered or Threatened
In confirmed habitat within the southern corridor study area.
$1.8B tourism spending
South Eastern Ontario
In the first 9 months of 2024 — directly dependent on the region’s ecological and heritage assets.
What a Biosphere Reserve actually is. A UNESCO Biosphere Reserve is not a fence around wilderness. It is a living landscape — a zone where nature and human activity are managed together. The Frontenac Arch reserve has three layers: a core area (5,073 ha) with strictly protected ecosystems; buffer zones (15,900 ha) used only for activities compatible with conservation; and a transition area (200,000 ha) of communities, farms, and sustainable stewardship. A high-speed rail line — permanent fencing, cleared safety corridors, 300 km/h trains — is not compatible with any of these zones.
On the public recordCBC Ottawa Morning · Mar 25, 2026
ALTO’s CEO confirms the corridor’s absolute barrier character — one day before consultation closed
On CBC Ottawa Morning on March 25, 2026, ALTO CEO Martin Imbleau stated: “Nothing can cross it. If at 330 kilometres you cross a deer, it’s a huge incident… overpass and underpass will have to be strategically positioned.” He also acknowledged wildlife concerns remain uncharacterised: “We need to look at and to have some sampling in dangerous species. Are there any concerns on the wildlife that we’re not aware of?” He confirmed environmental field surveys were commencing “this week.”
At the Frontenac Arch — the location where biodiversity loss would be most irreversible — ALTO’s CEO was still asking whether species concerns exist one month before the consultation closed. The species-at-risk inventory required before any lawful determination under SARA s.79 had not been completed by the time public input closed.
More than 25 federally protected species live in the southern corridor
Canada’s Species at Risk Act (SARA) creates legal protections for species listed as Extirpated, Endangered, or Threatened. These protections are automatic — they do not require a separate environmental review to activate. Any construction that harms these species or their critical habitat is a federal offence. The southern corridor passes through confirmed habitat for all of the following.
Endangered — Federal & Provincial
Spotted Turtle
Lives in bogs, fens, and shallow wetlands throughout Eastern Ontario. Found in only 6% of its global range within Canada, with population declining significantly. Critical habitat identified in the southern corridor.
Threatened — Federal & Provincial
Blanding’s Turtle
Makes the largest overland movements of any Ontario turtle — up to several kilometres between wetlands. A fenced rail line is a deadly barrier. Only 10% of the population reproduces at any given time, so losing even a few adults devastates recovery.
Threatened — Federal & Provincial
Gray Ratsnake
Canada’s largest snake — found in only two locations in all of Ontario, one being the Frontenac Arch. Returns to the same trees year after year. Travels up to 4 km between winter and summer habitat. A fenced rail line would permanently sever its movement corridors.
Threatened — Federal
Western Chorus Frog
One of the first frogs heard in spring. Extremely low mobility means it cannot simply move around a rail barrier. Habitat loss and linear features are its biggest threats.
Species at Risk — Birds
Endangered — Federal & Provincial
Cerulean Warbler
Requires large, unbroken tracts of mature deciduous forest — exactly what the Frontenac Arch provides. The southern corridor would fragment this habitat permanently.
Endangered — Federal & Provincial
Red-headed Woodpecker
Among its greatest threats: collisions with vehicles, utility towers, and power lines — all features that accompany a rail corridor.
Endangered — Federal & Provincial
Loggerhead Shrike
A rare predatory songbird that has nearly disappeared from Ontario. Requires open habitat free from major disturbance for nesting. The Napanee Plain holds one of only two remaining breeding areas in Canada.
Threatened — Federal & Provincial
Least Bittern
Canada’s smallest heron. A wetland specialist that will abandon marsh habitat if human activity or loud noise becomes too great. A 300 km/h train running through its habitat is not a manageable disturbance.
Threatened — Federal
Bobolink & Eastern Meadowlark
Two grassland birds whose populations have collapsed across Ontario. Both nest in agricultural fields — the same fields the southern corridor would permanently sever. Bobolink was downlisted provincially in 2021 but retains Threatened status under federal SARA.
Threatened — Federal & Provincial
Eastern Whip-poor-will
A nocturnal bird of semi-open Shield forest. Sensitive to habitat fragmentation and light pollution from infrastructure.
Species at Risk — Fish, Bats & Plants
Endangered — Federal
American Eel & Channel Darter
Two federally Endangered fish species in the waterways crossed by the southern corridor. In-stream construction would disturb spawning habitat.
Endangered — 4 of 8 Ontario species
Bats — Four Endangered Species
Little Brown Myotis, Northern Myotis, Tri-colored Bat, and Eastern Small-footed Myotis. All four use the Frontenac Arch’s forests and waterways as foraging and commuting habitat. Rail corridor lighting, ground vibration, and infrastructure compound losses from White-nose Syndrome, which has reduced Ontario populations by 85–99% since 2010.
Threatened / Endangered
Protected Plants
Eastern Prairie-fringed Orchid, Small White Lady’s Slipper, American Ginseng, Butternut, Black Ash, and others — all federally listed, all present in the southern corridor. Ground disturbance during construction could eliminate populations entirely.
ALTO has not published a species inventory. A comprehensive SARA species inventory for either corridor — identifying exactly where these species live and where their critical habitat has been legally identified — has not been published by ALTO. The consultation deadline was April 24, 2026, and the inventory did not exist in the public record.
Federal Law
What the Species at Risk Act actually requires — and why it can’t be bypassed
The federal Species at Risk Act is not like a municipal permit that can be waived for a big project. It creates automatic criminal prohibitions the moment a species is listed. These obligations do not disappear because the federal government has decided that high-speed rail is a national priority. Bill C-15 does not and cannot override SARA.
Step 1
Automatic prohibitions — in force right now
Under Sections 32 and 33 of SARA, it is a federal offence to kill, harm, harass, capture, or take any individual of a listed Endangered or Threatened species. Any construction activity that disturbs these animals or destroys their habitat is a crime unless a permit is obtained first.
Step 2
Critical habitat cannot be destroyed — even on private land
Section 58 prohibits destruction of critical habitat for listed species. SARA’s “safety net” provision means that even on private farmland, federal critical habitat protection can be triggered — overriding provincial land use law if necessary.
Step 3
A permit requires proving the project won’t jeopardize recovery
To build in critical habitat, ALTO would need a federal permit. That permit can only be issued if: all reasonable alternatives have been considered; all feasible measures to minimize harm will be taken; and the activity will not jeopardize the survival or recovery of the species.
Step 4
For species like the Spotted Turtle — the permit test may be impossible to pass
The Gray Ratsnake’s Frontenac Arch population is one of only two in all of Canada. The Spotted Turtle is found in only 6% of its global range here. Demonstrating that a permanently fenced 300 km/h rail line through their habitat will not jeopardize their survival or recovery would be extraordinarily difficult to argue in court.
Step 5
The “alternatives” test creates a direct obligation to consider the northern corridor
SARA’s permitting framework requires that all reasonable alternatives that would reduce impact on the species have been considered. A northern corridor that avoids the Frontenac Arch entirely is a reasonable alternative. ALTO must demonstrate why it was rejected on grounds other than simply being less convenient — and it must do this before any permit can be issued.
Ontario’s Bill 5 makes this worse, not better. Ontario’s 2025 Bill 5 reformed the provincial Endangered Species Act, significantly narrowing habitat definitions and stepping back from protecting aquatic species and migratory birds already covered by federal SARA. This means SARA becomes the primary layer of protection for species like the Cerulean Warbler and Red-headed Woodpecker — not a backstop. ALTO now faces the full weight of federal SARA directly.
UNESCO Designation at Risk
Canada could lose its UNESCO Biosphere Reserve designation for the Frontenac Arch
UNESCO Biosphere Reserves are reviewed every ten years. If Canada cannot demonstrate that the Frontenac Arch still meets the criteria for designation — including functioning as an intact ecological corridor — UNESCO can recommend corrective action or withdrawal.
This is not a theoretical risk. 61 sites have been withdrawn from the World Network by 14 countries. In 2017 alone, the United States withdrew 17 sites at once.
Why a rail line would threaten the designation
The Frontenac Arch is designated specifically because it is an intact land bridge. A permanently fenced rail line cuts it in two, violates the zone system, contradicts all three UNESCO functions, and overrides community participation — four of the core requirements for continued designation.
What’s at risk economically
$1.8 billion in tourism spending in South Eastern Ontario in the first 9 months of 2024. 2.6 million visitors spent $512 million in Kingston alone. Canada’s protected areas return $3.62 for every $1 invested. Losing the UNESCO designation would signal that the ecological values that make this region worth visiting are being degraded.
Municipal Opposition — on the record
Seven municipalities have formally opposed the southern corridor
UNESCO’s framework requires meaningful local participation in biosphere reserve governance. The following municipalities have passed formal council motions opposing the southern corridor: South Frontenac Township (unanimous), Rideau Lakes Township (unanimous — ALTO subsequently withdrew a planned delegation), City of Belleville (unanimous), Tyendinaga Township, Stone Mills Township, City of Kingston (called for a route more closely aligned with Highway 401), and Drummond/North Elmsley Township (March 10, 2026).
At the political level: MP Shelby Kramp-Neuman (Hastings–Lennox & Addington–Tyendinaga) has formally opposed both routes. MPP Steve Clark (Leeds-Grenville-Thousand Islands and Rideau Lakes) has publicly opposed the southern route.
The Carbon Paradox
ALTO is promoted as “green” infrastructure — the southern corridor contradicts that claim
The Fundamental Contradiction. ALTO’s entire environmental case rests on replacing car and air travel with electrified rail — reducing transportation carbon emissions. That case collapses if the rail line is built through one of the most ecologically significant carbon-storing landscapes in Eastern Canada.
The Frontenac Arch’s intact peatlands, wetlands, and forests function as active carbon storage systems. Fragmenting these systems doesn’t just destroy habitat. It converts carbon storage into carbon release, while simultaneously destroying the biodiversity Canada has committed to protect under the Kunming-Montreal Global Biodiversity Framework it helped negotiate. A project cannot credibly claim to be green infrastructure while destroying irreplaceable ecological infrastructure to build it.
Corridor Comparison
How the two corridors compare on legal and environmental risk
Risk Factor
Northern Corridor
Southern Corridor
UNESCO Biosphere Reserve
Not affected
Directly bisected — designation at risk
SARA-listed species
Fewer — mostly upper watershed
25+ species including several Endangered
Gray Ratsnake critical habitat
Not affected
Direct overlap — one of only 2 populations in Canada
SARA permit difficulty
Moderate
Extremely high — “no jeopardy” test very difficult to meet
Ecological corridor integrity
Does not affect Frontenac Arch
Permanently severs a continental-scale land bridge
Tourism and UNESCO brand
Not affected
$1.8B regional tourism economy at risk
Litigation risk
Moderate
High — favourable conditions for SARA judicial review
Four Things That Need to Happen
Before any route is approved
1
Publish a full SARA species inventory for both corridors
Identifying all listed species and all identified critical habitat. This should have been done before the consultation opened. It has not been done.
2
Conduct an independent assessment of the southern corridor’s impact on the Frontenac Arch Biosphere Reserve
In consultation with the Frontenac Arch Biosphere Network and with UNESCO’s MAB Secretariat directly.
3
Confirm that SARA obligations will be fully met
The federal government must explain how it intends to comply with SARA’s automatic prohibitions and permitting requirements. SARA cannot be overridden by the Minister of Transport or by Bill C-15.
4
Publish a full comparative risk assessment across all corridor options
Accounting for the legal, ecological, diplomatic, and economic costs — not only construction costs. The Frontenac Arch concentration of risk has not been disclosed or assessed in the consultation materials.