First of all, this document…

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019-0880

Comment ID

42990

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Comment

First of all, this document is sorely lacking in details. How is the public meant to be able to comment on the kind of text that one would usually find in a corporate brochure? The fact that the term "species at risk" only shows up once as an afterthought between parenthesis shows that this is not a strategy that can make any comprehensive claim towards sustainability. (Also, the fact that fruit, nuts, and maple syrup are listed as "common foods that have a component of wood" is downright embarrassing. Food that can only be harvested from living trees does not count as a "use for wood".)

Commenting on what little information is provided - while I very much support the role of sustainable forestry in the future of Ontario, that is not what this strategy proposes:

- a sustainable harvest can not be calculated based on cubic metres of growth. A forest is a complex ecosystem and mature trees play a role that is distinct from those of seedlings, saplings, or young trees. On paper, the new trees "help" the math by growing faster, but it will be decades before they provide the same wildlife habitat, water capture and respiration, shade, and soil stabilization. A forest needs trees of all ages and stages, everywhere.

- the draft makes numerous mention of new access roads but in no way suggests an understanding of or intent to mitigate the harms these roads can cause: increased introduction of invasive plant species and fungal spores brought in on muddy truck tires, water pollution from runoff and sediment, habitat fragmentation that reduces mating opportunities and thus diversity within a species (especially for non-flying insects and burrowing invertebrates that can no longer move under the compacted soil of the roads), and wildlife strikes and increased noise that disrupts natural behaviours including feeding patterns and mating calls

- while the draft talks about the climate emergency (inaccurately referred to as climate change) it seems to focus on this as an economic opportunity without acknowledging the ever-increasing stresses that will be put on existing habitats. This is an era that calls for rapidly increasing protections for intact, pristine habitats, not increased commodification.

- Including "decaying" forests on a graphic alongside industrial carbon emitters completely overlooks the role that standing dead trees and decomposing logs play in complete forest ecosystems

There is a lot of good in this. Maximizing the use of mill by-products, promoting product innovation, training for youth and indigenous communities are all good things. Afforestation of unproductive agricultural land may be a good thing (unless a wetland or other habitat creation would be more appropriate). However red tape and regulations are not bad words, especially when it comes to preserving the national treasure that is the boreal and Ontario's southern forests. Both the government and the forestry industry must demonstrate a more comprehensive understanding of the forest as a complex and vital ecosystem before proceeding with a new sector strategy.