I would like to suggest that…

I would like to suggest that what the government is proposing here is a conflict-of-interest situation. Although the declaration order is likely outdated, as mentioned, that does not mean that logging should not be subject to environmental assessment under the EAA. How will section 26 of the order be replaced? Logging and forest management generally have widespread and negative impacts on ecosystems in proportion to the number of people they employ; if anything should be assessed for impacts it should be this industry. By removing the EAA procedures available to the public and overseen independently by a different ministry, the MNRF puts itself in a position to be both the CFSA administrator, policy proponent and judge in situations where people may request further investigation into environmental impacts.

You note that, "The planning conditions in this declaration order have all been met and incorporated into MNRF’s existing manuals, policies, procedures or guidelines.MNRF’s implementation of conditions with respecting monitoring and reporting have also contributed to the development of its forest management policy framework. Accordingly, the conditions would no longer be imposed under the EA Act.", but what you don't note is that the MNRF currently has a number of proposals that would modify the conditions to further reduce oversight of the forest industry.

Please reconsider your proposal to remove forestry from the oversight of the EAA and the opportunity for recourse Ontarians have under the EAA under section 26 of the declaration order.