Dear Premier Ford, Minister…

Dear Premier Ford, Minister Phillips, and Minister Yakabuski,

In response to EBR Posting 013-4143, 10th Year Review of Ontario’s Endangered Species Act Discussion Paper, I ask you consider the following comments.

For over 17 years I have worked in silviculture, forest management planning support, and forest certification programs. As a forest sector worker, I have witnessed, over this time, the proven effectiveness of the Crown Forest Sustainability Act (CFSA) to provide balanced landscape scale as well as stand and site scale management of Ontario’s Crown Forests. The CFSA enables a management framework to consider and address social, economic and environmental values across the landscape.

A balanced ecosystem management approach that addresses multiple objectives is only possible on Ontario’s Crown Forests by continued implementation of the CFSA as an equivalent legal tool for implementing SAR protection through a permanent ESA Section 55 regulatory exemption. This Section 55 ‘exemption’ does not ‘exempt’ forest workers from protecting SAR, it binds us to achieving these protections through a different, more efficient, practical and balanced way through the CFSA. Authorization provided under the CFSA, rather than the ESA, would enable better economic development while providing positive outcomes for all species, not just species at risk.

Landscape scale management addresses all species, including those at risk and is the only scale appropriate for Ontario’s Crown Forests to address habitat for many species, including the many at risk. Case-by-case and species-specific approaches do not work across landscapes. Landscape management that regulates a range of natural variation of landcape classes is a strategic approach providing the best chance of positive outcomes for all species, not just those at risk (refer to the Forest Management Guide for Boreal Landscapes MNRF 2014). This landscape approach is best implemented through the existing tool, the CFSA for Ontario’s Crown Forests. Forest Management Plans, manage at landscape scale but also provide for stand and site level management for conserving and protecting biodiversity, including species at risk: refer to the Forest Management Guide for Conserving Biodiversity at the Stand and Site Scales (MNRF 2010).

In Southern Ontario, where landscape approaches are limited due to urbanization, land ownership, infrastructure needs, land use variety, and other factors, the ESA permitting system, and habitat regulation is best implemented.

Positive outcomes for species at risk are possible only through policy that balances the three pillars of sustainability: social, economic and environmental. Please include complete socio-economic impact analysis before releasing SAR policy; and then effectively consult, and listen to, impacted stakeholders, including forest workers, Metis and First Nations prior to any SAR policy being implemented. This economic analysis is not only needed for changes to the framework and content of the Act and Regulations as proposed in this 10 Yr review, but is required before listing species, developing recovery strategies, defining general habitat descriptions and regulating habitat. To include these items, it would be appropriate to extend timelines for development of government materials, such as response statements etc.

The best available science is only useful when a wide range of input from forest workers, affected stakeholders, Metis and First Nations are consulted on 1) the interpretation of the science and 2) the resulting habitat prescriptions. Such consultation will ensure protection prescriptions are workable (socially, economically and environmentally).

Finally, it should be noted, that forest management does not ‘destroy’ or ‘damage’ habitat. The environment is always changing, whether those changes are managed or left to random change of the fire cycle. There is no static environment. The ESA has been ‘now’ focused to the detriment of long-term provision of habitat. A managed forest that creates through harvest and renewal, a wide range of landscape classes, provides habitat over time for all species, not just those at risk; and, does this through the CFSA that enables a management framework to consider and address social, economic and environmental values across the landscape. References to forest operations, done in compliance to the CFSA, should be noted in government documentation as having long-term benefit to habitat.