Re: Road decommissioning (A…

Re: Road decommissioning (A.1.2.7.10) - Has MNRF fully considered the implications of allowing conditions on road decommissioning? Many may be sound, such as ensuring protection of fish habitat, taking base measures to ensure public safety (signage, berms, etc.) However, others may not be and MNRF may lack the legal authority to impose them (CFSA doesn't even mention the word 'road' and the PLA doesn't appear to grant authority to the Minister to force a party to keep a structure on Crown land). Road decommissioning should not become a matter of public consultation nor should an administrative protocol to guide decommissionings be used to limit the SFL-holders right to absolve themselves of responsibility for a water crossing structure. If SFL-holders bear all responsibility for a water crossing structure, then they also in many cases own the structure. No party should be able to compel an SFL-holder to carry an ongoing risk associated with a water crossing or unreasonably impede an SFL-holder from collecting their private property from Crown land. Critically, the FMPM cannot allow for district- and regional-level MNRF staff to deny road decommissioning because of concerns over how it may affect the general public - not only may this ostensibly grant MNRF staff greater power than the Minister possesses in law, but the public doesn't generally have any right to drivable access on Crown land. If MNRF desires the option to deny, delay, or impose extraordinary conditions on road decommissioning, they should at least be willing to assume immediate responsibility of water crossing structures so that they can then be managed in the public interest.