Protection of Species at…

Numéro du REO

013-4143

Identifiant (ID) du commentaire

23609

Commentaire fait au nom

Individual

Statut du commentaire

Commentaire

Protection of Species at Risk (SAR) has and continues to be provided through the Crown Forest Sustainability Act (CFSA) which emphasizes providing enough habitat in a variety of forest types to account for the wide diversity of species present in our Crown Forests – not just those listed as endangered -. The Endangered Species Act (ESA) stresses a site-specific and individualized approach that does not recognize the benefits that habitat management provides through the CFSA. 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 permanent Section 55 Regulation. The Forestry industry MUST be present at the table when the species at risk legislation is evaluated and their input MUST be considered. Economic impact assessments of species at risk policy MUST be a priority as the review is carried out. Forestry operations approved in a Provincial Forest Management Plan pose little to no risk to species and their habitats.The COSSARO listing process for species is flawed as species with a lack of data are listed because there is a lack of data (precautionary principle). Furthermore, species may be at risk in some areas of the province but not all areas and therefore flexibility is needed. Current Area of Concern prescriptions must be re-evaluated and mechanisms for accountability on the Government side need to be created. If the forest industry loses their exemption, then the Government will have to list Forestry workers as endangered species.
Exempting forestry from the ESA would provide the best certainty for business.