This memo is written from…

This memo is written from the perspective of the forest industry in attempts to address the limitations of the current Endangered Species Act framework.

While the protection of endangered species is a crucial component in natural resource management, the implementation of policy and regulations stemming from the Endangered Species Act are disconnected from the realities on the ground. The integration of policy with other forest values and considerations is an intricate task that involves a great deal of consultation with both forestry stakeholders and First Nation communities. It seems as though this facet of endangered species protection and habitat conservation has been overlooked, which has led to numerous social and economic repercussions. If implemented, the ripple effect of unprecedented habitat conservation strategies will further restrict the ability to carry out sustainable forest management.

The clearest and most pertinent example of the issues stated above is the caribou policies being forced onto forest management entities without any regard for the social and economic ramifications. The extent to which caribou management has evolved has the potential to cripple the forest industry by restricting the ability to properly conduct forest management. Large deferral areas and timing restrictions only decrease the amount of timber available for harvest, which forestry companies at all levels rely on, and also has a number of ecological consequences (i.e. over-matured stands, loss of merchantable species and increased fire risk).

It was alarming to learn that the governing bodies for endangered species items do not actively include Registered Professional Foresters (RPF’s). RPF’s are the only provincially recognized professionals in natural resource management and also the individuals directly affected by the decisions made by organizations comprised of biologists and specialists.

The extent of First Nations involvement needs to be emphasized moving forward. The incorporation of traditional ecological knowledge is consistently mentioned throughout the various MNRF guides that govern forestry activities in Ontario, however, it seems like the groups affected by these decisions are not well informed or educated. During the Jan. 24th webinar it was stated that there is a “measured approach” for including First Nations who are affected by the implementation of ES regulations, however, when these regulations are raised at various stakeholders’ meetings I’ve attended, none of the communities are aware of the rationale, impacts, etc. of decisions.

Opening Ontario for business is an emerging theme. Therefore, decisions should be made to benefit the province as a whole instead of solely focusing on single species. The disconnect noted above results in sloppy mixing of endangered species regulations and forestry objectives.

In summary I am proposing the following revisions to the Endangered Species Act:

1) Improved notification and implementation processes for new endangered species protection
regulations (i.e. specific detail on timing, potential impacts on forestry, etc.)
2) Enhanced industry and FN engagement on decision making
3) Inclusion of RPF knowledge

Thank you for your consideration,
Ryan