re: ERO #019-0880 Ontario’s…

re: ERO #019-0880 Ontario’s Forest Sector Strategy

Joe Maure
Forest Sector Strategy - Ministry of Natural Resources and Forestry

Dear Mr. Maure,

Thank you for receiving my comments on the proposed draft Forest Sector Strategy (ERO: 019-0880)

Please do not implement Ontario’s Forest Sector Strategy and enabling proposals as presented.

On December 4, 2019, the government posted Ontario’s Forest Sector Strategy draft (the Strategy), on the Environmental Registry of Ontario - a detail-free document that claims to reduce “red tape”, create “prosperity” and signal that “Ontario is open for business”. Without waiting to receive all the public comments on this proposal before making decisions MNRF posted five additional proposals on the Friday before the holidays. These include proposed permanent exemptions for the industry from both the Endangered Species Act and the Environmental Assessment Act, changes to independent forest audits, forest management planning and pest management.

Together these additional proposals begin implementing the vision laid out in the Strategy, while the Strategy itself is supposedly still undergoing public consultation. That they were snuck in before a major holiday adds to my concern that this is not sincere public consultation.

One of the main thrusts of the draft Strategy is the claim that Ontario has an extra 15 million cubic metres of wood volume (representing about 15 million ha of forest) that is not being utilized that could be used to expand the forest industry. There is no convincing evidence that this wood is actually available or that it could be used without impacting forest biodiversity, long term industry prospects or the stability of our climate.

Indeed, the subsequent proposals seem to pave the way for increased logging no matter the consequences by removing safeguards under the Endangered Species Act and the Environmental Assessment Act. This appears to be an attempt to make sure that these laws and the values that they are meant to protect do not stand in the way of accelerated logging.

It strikes me as a grossly irresponsible course of action during a time of climate and biodiversity crises and counter to sustainability.

It also runs counter to the goal to “meet current and future environmentally-conscious consumer choices” as mentioned in the Strategy. I do not want to purchase products produced under a regime that removes environmental safeguards to accelerate logging.

Please do not go ahead with the draft Strategy in its current form or its enabling proposals as planned. Please have meaningful consultation opportunities with the public similar to what you offered select forest companies.