I am writing to you today to…

ERO number

019-1020

Comment ID

40201

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

I am writing to you today to express overwhelming support for proposal ERO# 019-1020. Given that the current regulation under the Endangered Species Act (ESA) expires this year, I ask that this proposal be approved and finalized as soon as possible. There can be no further delay on this item.

I strongly support a long-term solution for the forest sector which recognizes the Crown Forest Sustainability Act (CFSA) as an equivalent process to the Endangered Species Act (ESA). The CFSA is balanced legislation that allows multiple forest values, including endangered species, to be considered when developing and implementing forest management plans.

With a regional economic impact of nearly half a billion dollars, annually, Resolute is not only a major contributor to the socio-economic well-being of Northwestern Ontario, but also a large employer and driver of economic growth and prosperity in the Province. Their pulp and paper mill, three (3) sawmills, wood pellet plant, bio-refinery and woodlands operations make them by far the largest forest products company operating in Ontario. They produce approximately 600,000 Megawatt hours of power every year, the majority from renewable biomass. Their close to 900 employees have an annual payroll of $85 million, and 3,000 indirect jobs are associated with their operations.

My support for these changes is contingent on the finalized language containing no additional conditions, restrictions, or requirements, beyond what is already contained within the CFSA or O. Reg. 242/08 under the Endangered Species Act (ESA). While removing this duplication is a critical and essential first step, species at risk prescriptions contained within existing forest management guidance continues to limit access to a renewable and sustainable supply of timber.

The CFSA already provides landscape, stand, and site-level direction for managing, conserving, and protecting species at risk. Having two acts attempting to accomplish the same outcome represents the single greatest piece of red tape and duplication to this sector. While a permanent, legislative change to the CFSA is an essential and important first step, in order to unleash the full potential of the sector, improvements need to be made to forest management guidance (e.g. landscape guides and the Forest Management Guide for Conserving Biodiversity at the Stand and Site Scales) delivered under the CFSA

It is imperative that the government improves the effectiveness of species at risk policy and ensure a balanced approach between a healthy environment and vibrant economy. This change to the CFSA has the potential to significantly reduce administrative burden, costs, and business uncertainty, while ensuring a continued commitment to the highest standards of sustainable forest management