Public Input Coordinator…

Public Input Coordinator
Species Conservation Policy Branch
300 Water Street
Floor 5N
Peterborough ON K9J 3C7
Canada

RE: Forest Sector Requires Permanent Regulation Followed by Workable Species at Risk Policy after 10th Year Review of the Endangered Species Act

To Minister Phillips and Staff

I would like to thank the government for the opportunity to provide input on the future of the Endangered Species Act. The outcome from this review will prove to be critical for the future health and viability of the Ontario Forestry Industry.
McRae Lumber Company was started in 1885 and I am currently the 5th generation of my family to operate the business. We currently employ 65 people in the mills and have another 40 contractors in the forest operations. A high percentage of our employees identify as first nations, and our employees form the backbone of our small community.
Our company has been a proud part of Ontario’s Forest Industry for the past 134 years. We have survived depressions and recessions, world wars and fires. Throughout, we have maintained our commitment to sustainable forestry and our community. We have long since learned that proper forest management can provide a balance between environmental, social and economic interests. With a holistic broad-based approach to forest management, we can have a forest with high levels of ecological integrity that is still able to provide recreational opportunities, wood products for the forest industry and jobs for the local communities.
The Crown Forest Sustainability Act (CFSA) is a fantastic example of legislation that looks at the forest as a whole and manages on a macro scale. The ESA works in the opposite fashion; it manages on a micro scale and in my opinion has a hard time seeing the forest for the trees.
Once again I would like to thank you for the opportunity to comment on the 10th Year Review of Ontario’s Endangered Species Act: Discussion Paper, ERO number 013-4143. We look forward to working with your government to improve the effectiveness of the Endangered Species Act (ESA) and ensure a balanced approach between a healthy environment and a healthy economy.

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). This can be accomplished through a permanent 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, we 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

It is our understanding that the Ministry of Natural Resources and Forestry (MNRF) is responsible for species at risk prescriptions currently being delivered under the CFSA. It is our expectation that unworkable prescriptions will be addressed and improved regardless of any future changes made to the ESA.

Further, we remain extremely concerned about role of the Federal Government and potential negotiations with Ontario on Conservation Agreements. For example, a MNRF socio-economic analysis determined that up to 2800 jobs could be lost and 8 mills could close as a result of the province meeting the federal disturbance thresholds for caribou. It is our expectation that Ontario will consult with us well in advance of any draft and will not enter into a Conservation Agreement with the Federal Government that will result in lost jobs and lost opportunity. It is also important to note, that this socio-economic analysis was only completed on one species and there are currently 100+ species on the listing.
The government must decide: how important are the over 57,000 direct jobs to the province, how important are Northern and Rural Ontario, how important are sustainable and locally produced wood products?
When answering these questions it is also equally important to remember that none of these questions has to come at the expense of our forests, our wildlife or our species at risk. The CFSA manages for all wildlife, including species at risk, and has been doing so for over 25 years.
In order to avoid serious socio-economic impacts, we need 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.

I would like to thank you very much again for the opportunity to comment on an issue that is of critical importance to not only my company but the entire forestry sector. The ESA is the one issue that can truly make or break Ontario’s Forest Industry.

Sincerely,

Jamie McRae
McRae Lumber Company
Whitney, Ontario