Submission to the…

Submission to the Environmental Registry of Ontario ERO #019-0880
Comments on Draft Forest Sector Strategy

The Wilderness Committee is a registered charity that works for people-powered protection for wilderness, wildlife and climate. Our thousands of supporters in Ontario are concerned with maintaining and enhancing the hard-earned legislations that are meant to protect clean water, wildlife and woodlands to sustain healthy communities and democratic rights under the Environmental Bill of Rights. We respectfully submit the following comments with regards to the draft Forest Sector Strategy.

Comments/Suggestion

1. The draft Forest Sector Strategy’s plan to double logging in the boreal forest is unacceptable without a clearly articulated strategy to set aside forests for: biodiversity and old-growth, woodland caribou and other species-at-risk, maximum carbon storage, education and research (to compare silviculture practices to growth in unmanaged forests), the social needs of local communities and as Indigenous Protected Areas. The Forest Sector Strategy must identify and commit to areas for protection. The commitment to sustainability must specifically address all the points above throughout the development of the final strategy.

2. In order to prevent extinction, forestry must not be exempt from the Endangered Species Act. Without limits to logging and dedicated areas protected from industrial expansion; boreal caribou are on a path to extinction. Ontario has missed the 2017 deadline to create mandatory plans to protect at least 65% of caribou habitat. The forestry strategy must address how it will meet this goal.

3. Businesses whose operations drive boreal caribou to extinction are bad for Ontario business. Forestry is not sustainable if it causes extinction. In 2018, 17 U.S companies wrote a letter to Premier Ford (see attached) urging Ontario to “protect critical boreal caribou habitat from degradation”. If Ontario wants to maintain a reputation for sustainable forestry, it needs to heed this call.

4. Any plan to reduce so-called red tape needs to specifically chart the pros and cons of the existing and proposed changes to legislation - if the Class EA for Forestry is to be replaced in whole or part - how will the new rules ensure the public has the same opportunities to affect change as in the current assessment approach? Transparency is critical. If there is an intention to change the 'area of the undertaking' this must be clearly articulated in any proposal and needs public scrutiny.

5. The pros and cons of changing from the current FRI based inventory approach need to be documented in a scientific and professional document for the public, including the provision of clear information on the new remote sensing technology that is proposed and the manner in which it is verified on the ground.

6. The province must consult with Indigenous communities, traditional ecological knowledge holders, environmental organizations and scientific experts and be transparent about the results of that consultation.

7. The draft states that 77% of the Crown forests managed in Ontario are certified for sustainability. The goal needs to be 100%.

8. The proposed Forest Sector Advisory Committee must include NGO's that represent the interests of the non-timber industry for any strategy to be implemented properly