Comment
As a life-long resident of Northwestern Ontario, I have had the privilege of being able to grow up, be educated, work, raise a family, and very soon retire in this very special part of Ontario. The forest has a special meaning to me - not only is it the place that I and my family most enjoy for its beauty and for recreation, it is also the reason that I have been able to work and support my family here for four decades. It has provided a very balanced and meaningful life for myself and the many other dedicated Northerners who also chose to live and work here. The most desirable aspect of this region is it's ability to provide a balance between social, economic and environmental values. There are not many places where all of these things can exist in harmony, but they do here. That is why I have become increasingly concerned about the unbalanced nature of Ontario's Endangered Species Act and the near impossibility of implementing this act for Forestry in Ontario without significantly impacting other important forest objectives, most notable socio-economic values. As a forester and a manager of woodland operations, I have witnessed the ever evolving science that drives continuous improvement in forestry. I have also witnessed the evolution of the current legal framework for managing forestry in the province under the Crown Forest Sustainability Act (CFSA). This Act is extremely effective in requiring forest management to consider and deliver on many forest objectives from socio-economic to environmental. The CFSA is also very effective in delivering species protection plans through the Forest Management Planning process required under the Act. This planning process also provides significant opportunities for involvement from a range of interests including communities, First Nations, trappers, cottagers, other industries and the general public. Input from those who live and work in this region is critical to ensure the right balance is struck in forest management plans. By contrast, the Endangered Species Act is not balanced. It provides for protection of individual species at risk, but it does not allow for species objectives to be balanced with other very important forest objectives or even other species. This is not good forestry, and has a high potential to permanently disrupt the balance that the CFSA has been so effective at creating. That is why I am supporting the proposal to extend the current Section 55 Regulation for Forestry and to form an expert panel to provide input and advice to government. This is an appropriate next step to finding a solution to the damaging aspects of the ESA. In addition, I would suggest the following:
- A two year Section 55 extension is not enough time to deal with a complex issue such as the ESA and forestry. I would suggest a much longer time horizon of at least 5 years, to allow for proper involvement of First Nations, Communities, other stakeholders and experts in finding a solution - The extension of the Section 55 should be implemented very quickly in order to be in place before the expiry of the current regulation in July. - The panel should be provided with the best science and information pertaining to Ontario, including traditional ecological knowledge and experience of local residents in order to be fully equipped to make recommendations - The impacts of climate change on habitat needs to be factored in to any decision on species recovery in Ontario in order to have plans that will be achievable and effective - The Crown Forest Sustainability Act must be considered as an equivalent or superior legal tool to the Endangered Species Act for implementing species protection plans to ensure that forest management objectives and outcomes are balanced. Thank you.
[Original Comment ID: 212740]
Submitted March 6, 2018 2:21 PM
Comment on
Amendments of Ontario Regulation 242/08 (General Regulation - Endangered Species Act, 2007) relating to forest operations in managed Crown forests, incorporating species recently listed to the Species at Risk in Ontario List, and safe harbour
ERO number
013-1669
Comment ID
3244
Commenting on behalf of
Comment status