Bats Biodiversity Boreal Caribou Conservation planning Natural resource development Peatlands

WCS Canada Comments: Draft South Athabasca Sub-Regional Plan

Ray, J.

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Key points

These comments focus on the Government of Alberta’s draft South Athabasca Sub-Regional Plan (SASRP), a planning instrument that Alberta has positioned as central to caribou range planning and cumulative effects management in one of the most heavily industrialized landscapes in Canada.

Specifically, we highlight that:

• The draft SASRP does not deliver the several boreal caribou range plans that sub-regional planning was supposed to operationalize. It provides no range-specific recovery pathway, does not reference the 65% undisturbed habitat benchmark, and contains no enforceable limits on new footprint tied to habitat recovery objectives.
• The plan does not establish a functional cumulative effects management framework. It lacks an integrated ecological baseline, thresholds, enforceable limits, decision triggers, and any adaptive management structure capable of constraining development in response to ecological decline. Instead, it invokes cumulative effects rhetorically while organizing the landscape into sectoral silos that do not account for combined impacts.
• The draft plan’s treatment of biodiversity beyond caribou is inadequate. Although Outcome 2 of the draft plan refers to naturally self-sustaining plant and wildlife populations with a focus on species at risk, it does not operationalize that commitment. Peatlands are treated primarily as resources rather than core ecological infrastructure, key hydrological pathways of peatland degradation from in situ development are ignored, and the plan lacks meaningful safeguards for other species at risk, including bats and the habitat features on which they depend.
• These deficiencies are especially serious in a sub-region where 82% of land is already under industrial tenure, where oil and gas activity from in situ bitumen production represents about 79% of Alberta’s in situ bitumen, and where the plan is explicit that it is intended to support Alberta’s goal to double oil and gas production.
• These are not deficiencies that can be corrected through incremental revision. Alberta should withdraw the current draft and restart the planning process with a clear mandate to deliver credible caribou range planning, a functional cumulative effects management framework, and meaningful biodiversity protection.

Recommended citation

Ray, J. (2026). WCS Canada Comments: Draft South Athabasca Sub-Regional Plan. Wildlife Conservation Society Canada [WCS Canada]. https://wcscanada.org/resources/wcs-canada-comments-draft-south-athabasca-sub-regional-plan/