In this blog, we highlight some of the changes to habitat and land use management in Alberta in 2025. This is the second post in our ELC Year in Review Blog Series. The first looked at updates made by the Alberta Energy Regulator, which you can find here. In today’s post, we will highlight changes to habitat, land use, and species at risk management in Alberta, including links to previous work on these topics. Specifically, this post comments on the release of the Upper Smoky Sub-Regional Plan; the draft Plan for Parks; changes to the Wildlife Act and the All-Seasons Resort Act; the controversial decision to create harvest pastures or shoot farms on diversified livestock farms; and changes to the conservation easement program.
As well, we will describe some matters that arose over the past year, and which are expected to continue to develop in 2026.
Upper Smoky Sub-Regional Plan and Caribou Recovery
In November 2025, the provincial government released the final version of the Upper Smoky Sub-Regional Plan.[1] Initially, the work on this began as a way to address caribou range planning in accordance with the 2020 Agreement for the Conservation and Recovery of the Woodland Caribou in Alberta pursuant to section 11 of the federal Species at Risk Act [SARA].[2] In the section 11 agreement for caribou, the parties (Canada and Alberta) agreed to the goal of supporting the conservation and recovery of woodland caribou populations to naturally sustaining status, including the achievement of a minimum 65% undisturbed habitat in alignment with Environment and Climate Change Canada’s 2016 report Range Plan Guidance for Woodland Caribou, Boreal Population.[3]
In Alberta, the provincial government decided to pursue caribou range management through the creation of sub-regional plans, including the most recent Upper Smoky sub-regional plan. However, the Upper Smoky sub-regional plan is lacking in specific commitments geared towards caribou protection and recovery. The plan divides the sub-region into three zones: the ‘go zone’, the ‘slow go’ zone, and the ‘nature first’ zone. The two caribou ranges located in the region overlap with the slow go zone, an area which allows for industrial development and a ‘diversity of land uses’ rather than the more protected ‘nature first’ zone.[4] Some examples of the allowable land uses include petroleum and natural gas dispositions (with some focus on reducing the footprint of inactive or economically unproductive sites); coal development and exploration; and forestry (with certain restrictions).[5] The sub-regional plan is also missing any specific objective related to caribou habitat protection and does not include any reference to the goal of 65% undisturbed habitat set out in numerous caribou recovery documents. It does propose the creation of two new conservation areas in the ‘nature first’ zone, which will fall under the Provincial Parks Act; however, these areas will not encompass the identified caribou ranges.[6]
The release of this sub-regional plan coincided with the expiry of the Section 11 Agreement between the province and the federal government – the plan was set for a five-year term, which expired this fall.[7] In the event that caribou herds continue to decline despite the creation of these sub-regional plans we will have to watch to see if the federal government decides to step in to uphold their obligations under the SARA or if they are pushed to do so through litigation.[8]
The final step in the release and implementation of the Upper Smoky Sub-Regional Plan was an Order in Council (“OIC”) released on November 5, 2025.[9] This OIC amended the South Saskatchewan Regional Plan (SSRP) to adopt the Upper Smoky Subregional Plan. You may have noticed that the Upper Smoky region does not fall within the boundaries of the SSRP and so, in order to do this the OIC included a broad interpretation of section 8 of the Alberta Land Stewardship Act (ALSA).[10] Section 8(2)(i) states that a regional plan may “manage an activity, effect, cause of an effect or person outside a planning region until a regional plan comes into force with respect to the matter or person.”[11] The OIC interprets this section to include the adoption of a subregional plan, concluding that “the SSRP can authorize a subregional plan whose boundaries fall outside of the boundary of the South Saskatchewan planning region.”[12] The OIC does acknowledge that the “intent is for the Upper Smoky Subregional Plan and the Upper Smoky Subregional Plan Regulatory Details to be removed from the South Saskatchewan Regional Plan upon the coming into force of the Upper Peace Regional Plan.”[13] However, the Government of Alberta’s regional planning in the Upper Peace has not yet begun.[14]
The OIC also adds the Upper Smoky Subregional Plan Regulatory Details and specifies “[e]xcept as otherwise provided in the Upper Smoky Subregional Plan Regulatory Details, the Upper Smoky Subregional Plan is not intended to have binding legal effect and is a statement of policy to inform the Crown, decision-makers, local government bodies and all other persons.”[15] The Regulatory Details, the part of the plan with binding legal effects, are set out Schedule C of the OIC. These regulatory details are relatively short and include a few focus areas such as:[16]
- targets to reduce area of inactive well sites;
- limits on surface disturbances in conservation areas;
- allowable dispositions in conservation areas; and
- the establishment of watercourse management areas and riparian areas.
The sub regional plan came into force at the beginning of January 2026 and impacts will be seen throughout the coming year.
Plan for Parks: Conservation or Recreation First?
In summer 2025, the Government of Alberta released the draft Plan for Parks, a policy document intended to provide “strategic direction for recreation and conservation of sites managed under the Provincial Parks Act.”[17] The final version has not yet been released. The ELC provided comments on the draft policy document, which you can read in full here. We divided our comments into four main topics: the stated purpose of parks; the balance of conservation goals versus recreation and access; the importance of clear Indigenous co-management; and the need for more focus on climate change mitigation and adaptation. Throughout these topics one of the consistent themes was that the Plan placed a reoccurring emphasis on recreation ahead of conservation. In our comments, we argued that while recreation is important, the core of parks management must be ecosystem management and the protection of wildlife and species at risk. Similarly, the plan included a very limited discussion of climate change despite the need to be prepared for new and varied impacts on parks from extreme weather and other impacts of climate change.
Throughout this plan the focus on conservation was secondary. We hope that in the final version the Plan reflects what the land and ecosystems need to thrive in these areas.
Jake Weirick on unslpashed.com
Land Use Shifts Under the All-Seasons Resort Act
Land management was also impacted this year through changes to the All-Seasons Resort Act. This is a 2024 Act which was designed to “streamline the process for approval of all-season resorts throughout the province.”[18] We provide an overview of the Act in our blog post here, but to put it simply, this Act enables officials designated by the Minister to issue statutory authorizations under specified provisions of the Environmental Protection and Enhancement Act, the Public Lands Act and associated regulations, and the Water Act in relation to all-season resort developments.[19] The provincial cabinet can designate public lands as an all-season resort so long as it abides by ALSA, the Act itself and any subsequent regulations and 2025 amendments extend this program to private lands connected to otherwise applicable public lands.[20]
There are a few specific issues to watch for in these amendments. The first is that if a protected area designation is rescinded for an area, those lands may be designated as all-season resort areas, perhaps suggesting that the Minister could recommend an area be delisted to accommodate a proposed all-season resort development. As Heelan Powell points out in our blog post describing these changes, “[i]t is also noteworthy that once public lands are designated as all-season resort area, any previously applicable land use plans, policies or programs cease to apply unless the director deems otherwise” potentially including any land use restrictions for sensitive landscapes.[21] Further, this Act moves the consideration of all-season resort areas out of the purview of the Natural Resources Conservation Board, an established regulator.
Regulations specific to the All-Seasons Resort Act are promised for 2026 and we will follow up to see if any of these issues are addressed.
Wildlife Act Amendments and Provincial Priorities
2025 also saw updates to the Wildlife Act, Alberta’s primary legislation dealing with the management of wildlife and hunting regulation. Most of the amendments were technical changes primarily concerned with access to hunting. These included expanded opportunities for minors to hunt, expanded use of dogs during hunting, new technologies, and the allowance for bears and mountain lions to be hunted for food and for parts of the animal to be discarded.[22] While none of these changes will likely have a significant direct impact on species at risk, they do serve to demonstrate the province’s priorities with regard to wildlife management. Overall, expansion of hunting may have negative impacts on species in the province but there are far more risks associated with habitat destruction, pollution, and climate change – none of which have been addressed in any recent changes to these laws. To read more about these changes, you can find our blog post on the topic here.
Harvest Preserves, CWD, and Risks to Cervids
This fall, a controversial change was included in the Red Tape Reduction Statutes Amendment Act or Bill 10, specifically the legalization of canned hunts. These are areas where hunted animals are confined by a fence. Until now, this has been illegal and carries with it both ethical concerns and risks around the spread of chronic wasting disease (CWD) which is fatal to cervids like deer, elk, moose, and caribou. You can read a full account of the concerns associated with this change in our blog post here.
In summary, Bill 10 makes significant changes to the Livestock Industry Diversification Act, allowing for the creation of harvest preserves or farms where cervids can be hunted in an enclosed area. This is a controversial type of hunting which is decried by numerous hunting and angling associations across North America. Beyond these ethical issues, there are also significant risks to wild cervid populations due to the potential spread of CWD. The risk of CWD is increased when cervid populations are found in close quarters and once transmission has begun it is very difficult to stop as this type of disease can live in soil for numerous years. One of our focuses is the fact that there is evidence that CWD can be passed from farmed cervids to caribou. As we have already indicated in this roundup, caribou are at-risk across the province, and the combination of decreased caribou range due to habitat destruction and the potential for CWD transmission could be catastrophic. Thus far, the changes to the Livestock Industry Diversification Act are not sufficient to mitigate the increased risks associated with CWD and the ethical concerns can only be addressed with a reversal of this entire policy.
Conservation Easements, Wetlands, and What’s Ahead in 2026
As we move forward into 2026, there are several areas of habitat management to keep an eye on. Several of these legal amendments were not implemented until late in 2025 or early 2026 and as such the implications of these legal changes, along with any regulatory or policy updates remains to be seen. Additionally, other program changes that began in 2025 may start to be fully implemented. For example, changes to the conservation easement program with the Private Land Conservation Program. This program newly limits conservation easement funding to 50 years with program applications opening in spring 2026. The provincial government also announced changes to the wetland policy in December 2025 enabling “low-impact” activities on certain temporary and seasonal wetlands on private farmland, which holds significant implications for species at risk and habitat in those areas. We will have to watch and see how these policy reforms are set out and the consequences of these changes.
While we are still waiting on several announcements, it is clear through both the changes that have been implemented over the past year and the programs coming in 2026 that ecosystem management and habitat protection has not been a focus of the past year. Instead, changes have been focused on increasing industry access, hunting opportunities, and economic development. Without any accompanying habitat protection, there is a risk that these changes result in detrimental impacts to both our species at risk populations as well as general habitat health across the province.
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[1] Government of Alberta, “Upper Smoky Sub-Regional Plan” (November 2025) online: https://www.alberta.ca/system/files/epa-sub-regional-plan-upper-smoky-plan-november-4-2025-with-appendix-v2.pdf [Upper Smoky Sub-Regional Plan].
[2] Agreement for the Conservation and Recovery of the Woodland Caribou in Alberta, (19 October 2020) between Her Majesty the Queen in Right of Canada and Her Majesty the Queen in Right of the Province of Alberta pursuant to Section 11 of the Species at Risk Act and Sections 10 & 11 of the Government Organization Act online: https://open.alberta.ca/dataset/40a40950-f210-4a37-b2a1- e274a9c75a48/resource/9d5326f4-0f3a-4aef-b0a2-d6fabc8439b4/download/aep-agreement-for-theconservation-and-recovery-of-the-woodland-caribou-in-alberta-2020.pdf [Section 11 Agreement].
[3] Section 11 Agreement at 5.
[4] Upper Smoky Sub-Regional Plan at pg 11.
[5] Upper Smoky Sub-Regional Plan at pages 14 & 28; You can find some of our recent coal blogs here, here, and here.
[6] Upper Smoky Sub-Regional Plan at 37.
[7] Section 11 Agreement at 14.
[8] Environment Canada, “Recovery Strategy for the Woodland Caribou (Rangifer tarandus caribou), Boreal Population, in Canada” (2012) Species at Risk Act Recovery Strategy Series online: https://www.registrelep-sararegistry.gc.ca/virtual_sara/files/plans/rs_caribou_boreal_caribou_0912_e1.pdf.
[9] Amendments to the South Saskatchewan Regional Plan, OIC 339/2025 online: https://kings-printer.alberta.ca/Documents/Orders/Orders_in_Council/2025/2025_339.pdf [OIC 339].
[10] Alberta Land Stewardship Act, SA 2009, c A-26.8 [ALSA].
[11] ALSA, s 8(2)(i).
[12] OIC 339, Appendix A, s 3.
[13] OIC 339, Appendix A, s 3.
[14] Government of Alberta, “Upper Peace Region” online: https://landuse.alberta.ca/RegionalPlans/UpperPeaceRegion/Pages/default.aspx.
[15] OIC 339, Appendix A, s 4.
[16] OIC 339, Schedule C, s 67-75.
[17] Government of Alberta, “Plan for Parks Engagement” online: https://www.alberta.ca/plan-for-parks-engagement.
[18] Brenda Heelan Powell, “Environmental Protection, Transparency and Accountability are not Red Tape” (28 Nov 2025) Environmental Law Centre online: https://elc.ab.ca/post-library/environmental-protection-transparency-and-accountability-are-not-red-tape/ [Heelan Powell].
[19] All-Season Resorts Act, SA 2024, c A-38.5, s 5 [ASRA].
[20] Bill 10: Red Tape Reduction Statutes Amendment Act, 2025 (No.2), s 3(3).
[21] Heelan Powell & ASRA, s 8.
[22] Bill 41.