"Adam v. Canada (Environment)", 2011 FC 962

In this decision, three First Nations and two environmental non-governmental organizations asked the Federal Court to, among other things, compel the minister of the environment (Minister) to recommend to the Governor in Council that it issue an emergency order under section 80 of the Species at Risk Act, S.C. 2002, c. 29 (SARA) for the protection of the boreal caribou herds in northern Alberta, which are part of a population of caribou listed as threatened under SARA.

Pursuant to section 80(2) of SARA, the Minister was required to make such a recommendation "if he or she is of the opinion that the species faces imminent threats to its survival or recovery." After reviewing the request, the Minister concluded that there were no imminent threats to the national survival or recovery of boreal caribou in Canada, and declined to make the recommendation.