Ontario’s proposal to expand…

Numéro du REO

026-0109

Identifiant (ID) du commentaire

185672

Commentaire fait au nom

Individual

Statut du commentaire

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Commentaire

Ontario’s proposal to expand multi-unit forest planning and streamline approvals is presented as an efficiency measure with no change to environmental outcomes. This assumes forests will continue to balance carbon released through harvesting over time. In reality, that balance depends on strong monitoring, transparency, and accountability.

Data from Environment and Climate Change Canada shows managed forests can shift from a carbon sink to a net source depending on harvest levels and wildfire activity. Carbon is released immediately through harvesting and fire, while regrowth takes decades to recover it. This creates a persistent gap that must be actively measured and managed.

Larger planning areas and reduced reporting risk masking local losses of older, high carbon forests and weakening the ability to track cumulative impacts. Without clear, accessible data, communities, Indigenous governments, and the public cannot assess whether forests are gaining or losing carbon over time.

Scientific guidance, including from the Intergovernmental Panel on Climate Change, underscores that accurate tracking of emissions and removals is essential. Older forests store significantly more carbon, and shifts toward younger forests reduce storage for extended periods. These changes are not visible without consistent monitoring.

The issue is not whether forests regrow, but whether Ontario can demonstrate that they are keeping pace with emissions. Without strong guardrails, it becomes unclear whether policy decisions are reducing emissions or increasing them.

Recommendations

Require cumulative carbon assessment across multi-unit planning areas

Maintain explicit carbon impact reporting, including recovery timelines

Integrate wildfire emissions into forest sector reporting

Strengthen protection of mature and high carbon forests

Maintain transparent, accessible data and meaningful public and Indigenous participation

Ensure efficiency measures do not reduce monitoring detail or accountability