I wish to comment on…

ERO number

019-0774

Comment ID

37028

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

I wish to comment on proposed changes to the Crown Forest Sustainability Act and related legislation and regulation associated with the CFSA. I served as Chair of the Environmental Assessment Board Committee that approved the Class Environmental Assessment of Timber Management on Crown Lands in Ontario, which remains the most extensive public examination of forest management in any jurisdiction. Our work influenced the development of the CFSA and has allowed forestry to be carried out in Ontario for the last 25 years with considerable public support and confidence in the environmental protections contained in the legislation and regulation. I also serve as a member of the Ontario Forest Policy Committee.

In my opinion, improvements can always be made over time to administrative and operational functions and I rely on the experience of professional foresters and people working in the field to determine which efficiency improvements can be made in these proposed changes that aim to satisfy the government's objectives to reduce red tape and to make Ontario more open to business.

My concern is that the protection of sustainability not be damaged by these proposed changes. Unlike other legislation and regulation, the primary focus of the CFSA is not to regulate the forest industry, its purpose is to keep forests on the ground forever in Ontario. After all, without the healthy forests that have been managed under the CFSA, there would be no wood supply for industry and fewer environmental benefits for everyone across the province. In order for there to be confidence that forest sustainability is not significantly negatively impacted by the proposed changes, there needs to be analysis that we can continue to rely on forest sustainability. I recommend that the Ontario Ministry of Natural Resources and Forestry document the evidence that the proposed changes do not threaten forest sustainability.