To Whom it may c with…

Comment

To Whom it may c with reasonable, workable, or balanced prescriptions.

First Nations have become exponentially more involved in forest management from year to year. They want to be a big part of this solution. The First Nation representative at the most recent PFTC meeting offered his thoughts on how such a process could work. After his comments, I think all attending PFTC members realized that anything less than what he proposed would be merely meeting for the sake of meeting. True First Nation consultation, incorporating local indigenous knowledge, will take a lot more than 2 years and many more resources than what is being considered. This proposed extension is a great opportunity to really do this right, advance reconciliation, and do a better job of managing the forest for species-at-risk and all other species. A great opportunity for AAM here. Socio-economic impacts of proposed prescriptions are impossible to calculate without good population data. In fact, many of the species-at-risk that the forest industry is most concerned with, e.g. whip-poor will, blandings turtle, are only concerning because we are finding so many individuals of those species as we continue to do more surveys to look for them, which in turn makes you wonder if those species are at risk to begin with. If they were rare it would not be onerous. More time is needed to collect population data and hopefully get some of these species off the list – a good thing obviously. The entire COSSARO listing, de-listing process needs to be looked at. COSSARO needs to reach out to local practitioners, First Nations and district biologists to get better data on species populations, well in advance of the decision to list the species. It’s impossible to stay ahead of the process as it works now. First Nations and practicing foresters need to be on COSSARO to help the committee reach out and get local knowledge, and keep them grounded. Without this extension and the eventual permanent CFSA solution, implementing the ESA in our working crown forests will lead to endless permits and red tape, and expensive and frequent court challenges. It may work in areas of dense human population, where wildlife habitat is in short supply and deforestation and conversion to non-forest is a real threat. But the ESA’s single-species, protectionist approach, does not fit well in the vast, diverse, constantly-changing crown forests in the Area of the Undertaking in Ontario. We are also worried that the upcoming provincial election may delay approval of this regulation, and impact our ability to operate after June 2018, so this needs to be approved by the end of March 2018.

[Original Comment ID: 213277]