Critical Plant Species

ALTO HSR · Flora & Fauna · Plant Species at Risk

The Southern Route Threatens Some of Canada’s Rarest Plants

The Frontenac Arch is the most biodiverse terrestrial region in Canada. The southern ALTO corridor runs through the middle of it.

Research by Rena Upitis and Lindsay Davidson February 2026

Route Decision in 2026 — Before Environmental Assessment. The route selection will be made in 2026, before the formal environmental assessment is complete. Biodiversity concerns must be raised now — in the consultation phase — when they can still influence which corridor is chosen.
The Short Version. The southern ALTO route would cut through the Frontenac Arch Biosphere Reserve — a UNESCO-designated region where five major forest ecosystems converge. This area is home to plant species that exist nowhere else in Canada, including Deerberry, which has only five surviving wild populations in the entire country. A high-speed rail line through this corridor would permanently destroy habitat, sever the ecological connections these species depend on, and likely violate federal law. The northern corridor avoids these conflicts entirely.
Why It Matters
A corridor that can’t be replaced

The Frontenac Arch is an ancient granite bridge connecting the Canadian Shield to the Adirondack Mountains. It’s the only continuous north-south forest corridor in eastern North America — the Nature Conservancy of Canada calls it one of the most important forest corridors east of the Rocky Mountains. Five separate forest regions meet here — boreal, Great Lakes–St. Lawrence, Carolinian, Appalachian, and Atlantic. That convergence is why you find plants at the very edge of their range, living in habitats that exist nowhere else in Canada. Destroying this corridor doesn’t just harm the plants living there today. It shuts down the pathway species need to move northward as the climate changes.

The ecological significance of this landscape has been further confirmed through Canada’s Key Biodiversity Areas (KBA) programme. Three KBAs have been formally identified within the Frontenac Arch Biosphere — Thousand Islands, Charleston Lake, and Frontenac Forests — with a fourth, Napanee Limestone Plain, in the process of being proposed. Parks Canada has described the area as a “continentally significant wildlife movement corridor.” Any federal decision to route permanent infrastructure through a landscape containing multiple KBAs would be difficult to reconcile with Canada’s commitments under the Kunming-Montreal Global Biodiversity Framework. WCS Canada

What a high-speed rail line actually does to the landscape. A high-speed rail corridor is a fully fenced, grade-separated linear barrier — up to 60 metres wide, with security fencing on both sides and no level crossings. For plants and the animals that disperse their seeds, a permanently fenced HSR line is functionally impassable. Populations on either side become genetically isolated. For species already reduced to a handful of sites, that isolation accelerates the path to extinction.
Species at Stake
Three things the southern route would put at risk

These aren’t hypothetical concerns. Each of these species is protected under federal law, and each has confirmed or likely habitat in the southern corridor study area.

SARA Status: Threatened
Deerberry
Vaccinium stamineum
Deerberry (Vaccinium stamineum)
Photo: Ontario Ministry of the Environment, Conservation and Parks · ontario.ca

This is the most critical case. Deerberry is a shrub that grows in open woodland on shallow granite soils — exactly the landscape the southern corridor crosses. Less than 1% of its global range is in Canada.

Only 5 populations left in Canada 6 more already extirpated No natural seedling establishment ever recorded

That last point is what makes Deerberry so precarious. The plants set fruit, but no one has ever documented a wild seedling successfully establishing in Canada. Restoration attempts at Thousand Islands National Park have had only limited success. The federal Recovery Strategy says survival depends on maintaining habitat at all currently known sites with no loss of populations. COSEWIC 2020

The southern corridor runs through the fire-dependent Pitch Pine and Red Oak woodland on granite that Deerberry requires. Building a rail line here would destroy habitat directly, fragment the surviving populations, and alter the hydrology these communities depend on. The January 2025 identification of Thousand Islands as a Key Biodiversity Area — the region where nearly all of Canada’s Deerberry populations occur — adds a further layer of formal conservation recognition to the habitat the southern corridor threatens.

SARA Status: Endangered
Butternut
Juglans cinerea
Butternut (Juglans cinerea) fruit
Photo: Ontario Ministry of Natural Resources and Forestry · ontario.ca

Butternut is a native tree found throughout the southern corridor, particularly at forest edges and along waterways. It has lost most of its range to Butternut Canker, a non-native fungal disease. Only about 13,000 trees remain in Ontario.

Endangered under SARA ~13,000 remaining in Ontario Declining due to canker disease

Any construction that removes a Butternut tree or damages habitat within a prescribed area around confirmed individuals directly engages SARA protections. A significant risk exists that pre-construction surveys have not yet been conducted in the corridor, meaning Butternut populations will only be discovered when the environmental assessment is formally triggered — at which point delays and costs escalate. COSEWIC 2017

Irreplaceable Habitat Type
Granite Barren Communities
Pitch Pine, Bear Oak, Deerberry & associated species

The granite barrens of the Frontenac Arch are rocky hilltops and ridgelines with exposed Precambrian bedrock and thin, nutrient-poor soils. They support fire-adapted plants including Pitch Pine, Bear Oak, and Deerberry that exist at their northern limits.

These communities depend on conditions — exposed bedrock, thin soils, periodic fire — that cannot be recreated. Research published in Applied Vegetation Science found that many Frontenac granite barrens are already disappearing due to woody plant encroachment, meaning these populations are already vulnerable before any infrastructure impact. Cohen 2023

Physical destruction through construction is irreversible. You cannot blast and grade bedrock terrain and then restore it to a functioning granite barren.

The Legal Framework
What the law requires — and why Alto has no choice about it

Alto is a federal Crown corporation. The federal Species at Risk Act (SARA) applies to it without exception. These aren’t optional guidelines — they are binding legal obligations.

SARA Section 79 — Must notify, must assess

When a federal project is likely to affect a SARA-listed species, the proponent must notify the competent minister and take all feasible measures to minimize impacts. For Deerberry — five populations, no natural reproduction — the bar to prove a rail corridor won’t jeopardize recovery is extremely high. SARA s.79

SARA Section 61 — Critical habitat destruction is prohibited

It is illegal to destroy any part of identified critical habitat for a listed species. For Deerberry and Butternut, critical habitat is defined in their Recovery Strategies. This prohibition is absolute — it applies regardless of the proponent’s identity or the project’s public benefit. SARA full text

What about Ontario’s Bill 5? Ontario weakened its provincial species-at-risk legislation in June 2025. But this actually increases federal SARA’s importance. SARA explicitly applies on non-federal lands when provincial law doesn’t provide equivalent protection. Ontario’s reforms opened exactly that gap. The weaker the province gets, the stronger the federal obligation becomes.
Key Biodiversity Areas add further weight. Three KBAs have been formally identified within the Frontenac Arch Biosphere — Thousand Islands, Charleston Lake, and Frontenac Forests — with a fourth pending. Any federal decision to route permanent infrastructure through a landscape containing multiple KBAs would be difficult to reconcile with Canada’s commitments under the Kunming-Montreal Global Biodiversity Framework, which explicitly calls for the identification and conservation of Key Biodiversity Areas.
What We’re Asking For
Seven things Alto should do
1

Conduct a full flora survey before choosing a route

A complete baseline plant survey of the southern corridor — particularly for Deerberry, Butternut, and granite barren communities — must happen before any route recommendation is made, not after.

2

Notify the ministers under SARA Section 79 — now

The obligation to notify is triggered by current knowledge, not by the formal start of the environmental assessment. The species identified in this research make notification necessary immediately.

3

Assess whether any southern alignment can pass the Deerberry test

With only five populations in Canada and no natural reproduction, can any route through this corridor genuinely avoid jeopardizing Deerberry’s survival? Commission an independent assessment.

4

Engage Parks Canada, ECCC, and conservation groups

Thousand Islands National Park, Environment and Climate Change Canada, and the Frontenac Arch Biosphere Network must be consultation partners — not afterthoughts.

5

Seriously consider eliminating the southern corridor

Based on current knowledge, the southern corridor likely cannot meet SARA requirements. Concentrate assessment resources on the northern corridor, which crosses different terrain with less confirmed critical habitat.

6

Don’t treat Ontario’s weaker rules as reducing federal exposure

Bill 5 increases the weight carried by SARA, not decreases it. Alto should plan on the federal obligations being the binding floor.

7

Extend the consultation if the flora survey isn’t done

If pre-construction surveys haven’t been conducted, the public can’t meaningfully comment. Extend the consultation to allow community-sourced species data to be reviewed.

Bottom Line
The southern corridor puts irreplaceable species and habitats at risk. A route exists that doesn’t.
  • The Frontenac Arch is the most biodiverse terrestrial region in Canada — five forest ecosystems converge here and nowhere else.
  • Deerberry has five populations left in this country. No wild seedling has ever been recorded. The margin for error is zero.
  • A permanently fenced HSR corridor would sever the Arch’s north-south connectivity — the pathway species need to survive climate change.
  • Three Key Biodiversity Areas have been formally identified within the Biosphere, with a fourth pending. Routing permanent infrastructure through multiple KBAs conflicts with Canada’s Kunming-Montreal commitments.
  • Federal law requires Alto to assess these impacts before choosing a route. That assessment hasn’t happened yet.

The route decision will be made in 2026. If these concerns aren’t raised now — during the consultation — they become legal disputes and mitigation negotiations, not design choices.

Sources
2Nature Conservancy of Canada — Frontenac Arch Natural Area
5Cohen, M. (2023). Woody plant encroachment in granite barrens. Applied Vegetation Science. DOI: 10.1111/avsc.12733
6Government of Canada — SARA Section 79 Guide
7Government of Canada — Species at Risk Act (full text)
9Frontenac Arch Biosphere Network — Conservation
10WCS Canada (Jan 2025) — Thousand Islands KBA designation

Research by Rena Upitis and Lindsay Davidson. Facilitated with AI tools with human review and revision. Current as of February 2026.