I am deeply concerned about…

I am deeply concerned about the proposal re: Ontario's Forest Sector Strategy that would amend General Regulation 334 (Environmental Assessment Act) to remove the Regulatory Duplication of Forest Management requirements in Ontario.

The Strategy, posted on the Registry on December 4, 2019 - a document without details - purports to reduce "red tape", create "prosperity" and signal that "Ontario is open for business". Five additional proposals were then posted -- on the Friday before the Christmas holidays -- before all of the public comments on the December 4 proposal were received. It seems, then, that decisions have been made, undermining the value of public "consultation" or comment.

The five additional proposals include permanent exemptions for the forest industry from both the Endangered Species Act and the Environmental Assessment Act, changes to independent forest audits, forest management planning and pest management. The lack of full and meaningful public consultation is irresponsible and disrespectful, making a mockery of the public consultation process.

The draft Strategy claims Ontario has an extra 15 million cubic metres of wood volume (representing about 15 million ha of forest), currently unused, but that could be used to expand the forest industry. This ignores the role of this "surplus wood" in supporting biodiversity and carbon capture. The government also fails to provide any specific evidence that this wood is actually available - and also fails to address the impact the use of this wood would have on forest biodiversity, climate stability and the long term prospects of the forest industry.

Indeed, the draft Strategy seems to promote increased logging regardless of the consequences as it removes the safeguards provided by the Environmental Assessment Act (EAA) and its regulations.

I support the position of CPAWS and other organizations that Ontario should be reviewing its environmental assessment program to regain public trust and increase the capacity to administer potential new logging streams, and a next generation forest sector. I agree that the EAA does not provide unnecessary duplication, e.g., the loss of a “bump-up” request for an individual environmental assessment is a specific example of removing distinct and unreplicated functions.

The existing EAA Declaration Order regime includes a 30-day period for any individual to make a written request to the Minister of the Environment for an individual environmental assessment of specific proposed forest management activities in the plan. This provides a final oversight provision to Ontarians - and this would be removed under this proposal. This is unacceptable from a public interest perspective -- but also, no evidence is provided for the claim that the full 61 conditions of Declaration Order-75 are being met and incorporated into MNRF’s existing requirement.

The proposal minimizes the role of the public and those who care about the public interest, and at best minimizes concerns about climate change and the increasing threats to biodiversity. Given the global concerns about climate change, the government (including MECP) should be assessing the environmental impact of forest operations. This substantial gap in Ontario’s forest management during what scientists generally agree is a climate / carbon emergency should speak to the need of ongoing environmental assessment and against exemptions from this process.

I am opposed to the proposed draft Strategy in its current form and to the specific proposal to exempt forest operations from the Environmental Assessment Act. Ontarians deserve more meaningful consultation opportunties on these issues.

Thank you for your consideration.