As a practicing R.P.F. in…

As a practicing R.P.F. in Ontario, thank you for the opportunity to comment on the 10th Year Review of Ontario’s Endangered Species Act: Discussion Paper, ERO number 013-4143.

The most important action the government must take is a permanent recognition of the Crown Forest Sustainability Act (CFSA) as an equivalent process to the Endangered Species Act (ESA); either through a perpetual Section 55 Regulation. The CFSA already provides landscape, stand, and site-level direction for managing, conserving, and protecting species at risk. Having two acts attempting to accomplish the same outcome represents the single greatest piece of red tape and duplication to this sector.

Once this essential first step has been accomplished, it must also ensure the following requirements be embedded in a new, modernized ESA:
1. Consideration of climate change on habitat in all species at risk policy
2. Cumulative impact of all species at risk policy on a healthy economy
3. Socio-economic impact analysis must be completed and shared with impacted stakeholders and
First Nations prior to any species at risk policy being implemented

The sector will continue to operate under the CFSA which, by law, requires, forestry operations to follow an approved forest management plan. Guides delivered under the CFSA include operational prescriptions and conditions, which may include reserves, modified operations, or specific conditions on road use and construction in the area near a species at risk and their habitat.

Once a permanent Section 55 Regulation has been passed, or other legislative change made to the ESA recognizing equivalency between the two acts, more work must be done on species at risk policy currently being delivered under the CFSA. Overly precautious timing restrictions on forest operations for wood or Blanding’s turtle, for example, is currently putting people out of work for weeks to months at a time; this is while the sector operates under an existing regulation and through the CFSA.

It is my understanding that the Ministry of Natural Resources and Forestry (MNRF) is responsible for species at risk prescriptions currently being delivered under the CFSA. I would like to see that unworkable prescriptions, such as the turtle example provided above, will be addressed and improved regardless of any future changes made to the ESA.

In order to avoid catastrophic socio-economic impacts, there should be a permanent recognition that the CFSA is an equivalent process to the ESA, while developing workable species at risk policy, and sending a strong message to the Federal government that Ontario will manage our own resources.