Dear Premier / Minister …….
I am writing to provide my support for the proposal posted on the Environmental Registry on January 26, 2018 to extend the Endangered Species Act (ESA) Section 55 Regulation for Forestry.
For the past decade, the implementation of the ESA for forestry has been a difficult issue for Ontario. The act presents a serious risk of unintended consequences if implemented without proper regard for the impacts on communities, First Nations, Forest Industry and the many workers who depend on this sector for their livelihood.
For me, this act could mean (loss of my job, closure of my mill, loss of my contract, economic consequences to my town etc etc).
The posting also proposes to form an expert panel which includes representatives from Northern Communities, First Nations, Forest Practitioners, and Scientists. This panel is critical to ensure that real science and the views of the people who live and work in the forest regions of Ontario are appropriately incorporated into any implementation plan for the ESA. The panel also need to consider how to appropriately integrate the ESA with the world-class Crown Forest Sustainability Act (CFSA), which governs forest management activities in Ontario. The CFSA seeks balance in providing for social, economic, and environmental objectives, and has served the province will over the past 25 years.
The recognition that government needs to take more time to ‘get it right’ is a welcome development. However, we would urge the government to allow for more time than the currently proposed two year extension to deal with the very complex issues associated with the ESA. A five year extension would be a more realistic time frame for this panel to be able to fully assess the options available and to provide appropriate implementation advice.
Finally, time will be of the essence in finalizing this proposal. With the deadline for the expiry of the current Section 55 Regulation fast approaching, this extension should be put into place immediately following the end of the 45 day review period.
Thank you for recognizing the critical issues at stake with respect to the ESA, and for taking positive action to ensure that the hard-working people of Northern Ontario are properly involved in a workable solution for this act.
Submitted March 4, 2018 7:55 PM