Hello, I submit this comment…

Hello,
I submit this comment from the perspective of approx 50 000 hours experience: owning and running a Forest Management Company who has employed up to 30 people; being a shareholder and president of a small land development company; sitting on the Board of Westwind Forest Stewardship, the French/Severn SFL, in the Independent Logging seat for 8 years; having been a director of the Near North Chapter of the Central Almaguin Chamber of Commerce; sitting as the secretary-treasurer for the Ontario Woodlot Assoc. Near North Chapter for nearly 10 years; and lastly as the newly elected Mayor of Joly Township who sits on joint municipal committee's such as the Central Almaguin Planning Board, the Sundridge Medical Center Committee, and the Central Almaguin Economic Development Association.

Note to context,
A) the Parry Sound-Muskoka District's that I serve is made up of mostly small villages nestled within vast undisturbed natural areas of predominantly rugged hardwood and mixed forests, and have been categorized as a jurisdiction in a population crisis and in economic disparity. I am confident that these issues are synonymous to other Southern Region Districts such as Bancroft/Minden, Lanark/Mazinaw, Kawartha Lakes, the Ottawa Valley and numerous others (Kenora, Dryden, Fort Frances area), and and I would argue that these areas are suffering among the worst in Ontario from nearly 2 decades of the past governments reign of political tyranny on rural Ontario.

B) Small rural villages, dispersed in nature and away from supply routes, do not attract large business like one horse towns or urban centers do.

C) These are not extremely economically diverse areas, nor are they "one horse towns". Cottaging, recreation, retirement, forestry or farming (depending if the land is forests or fields) and the public sector are the main industries, and almost exclusively driven by small business. That is relevant, because in the north in "one horse towns" lead by large corporations, they have one autonomous voice, compromises can be made and socio-economic crisis can be more easily managed. In extremely economically diverse areas, as are a high proportion of large urban centers, one one sector fails creative-destruction occurs, and other sectors see a benefit from a failing sector. In places such as the ours, where autonomy is all but stripped from municipalities by southern-urban influence, mostly by (often radically) left leaning professions (such as the legal, municipal planning profession, engineering, biology and to a lesser (but some) degree foresters ect. who originate, at least in education, from urban centers where universities exist), and whereas conflicting land uses strongly exist, communities are failing.

While recreation is important and does support local economies, its success is highly dependent on weather, and as we have seen steadily over the past few years fails constantly on account of varying degrees of: bugs and rain in the early cottaging season; (last year with) fire during the mid-end cottaging season; the existence (or lack thereof) of snow during the snowmobile season; lack of large game tags during the hunting season, ect. ect. ect.. Regardless, even if the recreation industry boomed all the time, these jobs (gas stations, recreation tour guides, giftshop employee's) are seasonal at best and don't support housing, nor would they if housing was remotely affordable in the area.

Our retirement industry, again an important contributer to local economies, has limitations as well, and I am following this closely on certain committee's. A lack of ability to develop retirement housing is one limiting factor, but not the only. We have a difficult time attracting to the area health care providers from home care professions all the way up to doctors. Partly, its that these are one spouse jobs, and there is no other well paying jobs in the area. But also, in the absence of new home starts, if we had retirement housing developments this would free up single family units for working families. Neither is happening fast enough. Lastly, urban culture is who is retiring here excepting a small proportion of people who have moved away for their working lives and are returning to their home towns to retire. Urban culture does not understand, nor do they make efforts to understand, rural industries. They are blinded by the decimation of natural areas (such as the Carolinian forest) in the south, and have an unfounded fear that it could happen to our areas, what they don't realize is that north of Orillia they enter the Canadian Shield which is a vast and largely impossible-to-develop area in the swamps and on the rock of the Canadian Shield.

The cottagers, with the same urban culture views, want their playground and nothing else to happen there. Again, the jobs associated with cottaging, with the exception of construction and building professionals, are low paying. All jobs are seasonal and overlap and/or are similar to the recreation industry i.e. cottage maintenance, food service, grocery store, hardware store's, walmart ect.. Again, these jobs don't support housing.

Looking superficially at the public sector (and crown corporation) compensation packages - including municipalities, at first glance it would seem to suggest that these jobs are good for our particularly areas i.e. jobs that support families/housing, however, if these jobs are regulator type jobs, these areas end up with an abundance of people with nothing but time to regulate business. This condition drives business away. The less business activity, the more time regulators have, the more time they have the more frivolously they can be with regulating. They are good jobs, so subconsciously if not consciously, they tend to justify their jobs by interpreting regulations in a way that ensures they are needed. Regulation, including species at risk, bodes well for these regulator type jobs as well as professions such as the Municipal Planning profession who have legislated through the Planning Act and in the PPS assurance that they will succeed.

The above industries, while affected slightly negative, or in the public sector's case positively, are much less affected by Species at Risk then farming, forestry and land development. Legislation such as Species at Risk is often used for other ideological based purposes, such as gentrification. And its happening. Our towns and small villages are overwhelmed in the summer months, and practically ghost towns in the winter. While it may somewhat work for retiree's, cottagers, and recreationalists who come to the area, and as well for certain for people working in the public sector, this does not bode well for local hard working Ontarian's or ultimately the Province. The past provincial government created a welfare state in the North, then look up with disdain and call the North a cost center.

Especially forestry is failing, and in the small business portion of it. The only real year-round well paying in-house jobs that could exist (in the absence of the few factories who could afford to be away from shipping routes) have been made into seasonal, mostly winter, jobs by species at risk. Timing restrictions caused by load restrictions and cottaging seasons on forestry related activities are difficult enough for the industry, but exacerbated to the point of extremely damaging by Species at Risk. Species at Risk is the 'straw that broke the camels back'. Timing restrictions on road building, hauling, and harvesting have made it so difficult that the forest industry is at the point of giving up at all times of the year except winter. In the spring, timing restrictions on cutting trees due to bird migration, bats, and nesting seasons lead into the summer with restrictions due to turtles leading into the fall when any stream remotely resembling somewhere speckle trout spawning could occur stymie the best attempts are managing forestry operations.

But the dynamic of how Species at Risk legislation goes much further then its direct affects on forestry. Forestry currently has an exemption through the Crown Forest Sustainability Act, otherwise it would not exist, for other local economic activities such as land development the Species at Risk legislation does not manifest itself so relatively kindly.

While Municipal Planners are certainly not, quarries, farmers, and proponents of land development and the general public are paying the cost, and dearly in some instances. Page 22, the Provincial Policy Statement for Municipal Planning speaks to 2.1 Natural Heritage, and particularly 2.1.5 "Development and site alteration shall not be permitted in e) significant wildlife habitat". Municipal planners are arbitrarily recommending, almost by default, Environmental Impact Studies (EIS) for nearly all land development applications i.e. consent for severances and sub-divisions, re-zoning. They are interpreting the PPS to mean that it is not exclusive to known significant wildlife habitat or species at risk sightings, but that the PPS direction is to search all properties for significant wildlife habitat or species at risk thus requiring an EIS. Blandings turtles nest under cottagers decks, snapping turtles on new gravel roads, peregrine falcons on sky-rise buildings, rare owls in barns ect. ect. ect. So if species at risk and their habitat could occur anywhere including developed areas, every application must endure a a very costly and time consuming environmental impact study, and at a great risk. A proponent must spend what could be a great deal of money to get an EIS that might be in many cases the demise of their proposed development. This is keeping the price of land down, which intuitively seems like a good thing to attract people to the area, but the Building Code has made building un-affordable to working families*. Even if the Building Code was made reasonable, without the ability to severe or subdivide, the price of land would skyrocket because demand would surpass available building lots.

Every economic development association in these regions have identified lack of jobs and lack of housing as primary causes of disparity in their communities. You can't have housing without good jobs that will support the cost, you can't have jobs without affordable housing. Species at Risk is impacting both.

In closing, the species at risk legislation is by and far the most corrosive legislation that exists in terms of the sustaining our local economies, development, and subsequently population in rural Southern Region areas. An entire book could be written on the subject and how it pertains to Southern Region. Farming also faces its challenges, as do quarries, but I do not have the experience in those sectors to comment.

For more information, or just to chat please contact me.