Dear Minister of Natural…

Dear Minister of Natural Resources and Forestry

I am writing today to share with you McRae Lumber’s comments regarding this EBR posting. As the fifth generation of my family to run and operate our forestry business, I like to think that I have a fairly high stake in the future of the forest industry in Ontario. Our survival and success in Ontario depends not only on good forestry and good management but also on good government. Your recent posting to the EBR is a reflection, that as a government you may be able to recognize the existence of the latter.

Make no mistake, I am not applauding the government for the way it has handled the implementation of the Endangered Species Act. I strongly believe the government has consistently failed its citizens of Northern and Rural Ontario. Poor or non-existent science coupled with a desire to appease special interest groups has made our working lives precarious and transformed us into second-class citizens of this province.

This proposal attempts to mitigate some of these issues but is, at best, a stop gap solution. However, under the circumstances I do support the proposal but I must ask for certain conditions. The creation of a panel to study the ESA and CFSA is a good idea, more work on socio-economic implications is badly needed. As is possible effects of climate change and cumulative effects of all the different species regulations. This work will require a tremendously dedicated panel and it is crucial that there are representatives on this panel who have a high stake in the future of forestry. These appointments must reflect the areas of the province where forestry is important. There needs to be a strong aboriginal, municipal and forestry focus.

Granting a section 55 regulation to the Forest Industry while this panel does its work is a very sensible action to take. However, it is difficult to imagine that the panel will be able to complete its mandate within 2 years. There are 27 listed species and so far it has taken 12 years to complete a modest socio-economic report on a single species. The logistics of what the panel is being charged with is beyond overwhelming especially when a large portion of the time will be lost to an election. Taking 5 years to examine the problem should result in a better solution, and will allow the panel to get it right the first time.

I believe it is also prudent to mention that I do not support the idea of integrating the ESA and the CFSA. There are a great many benefits to the Ontario Forest Industry, and to the province as a whole, to continue to operate under the CFSA. The first of this is that the CFSA can be described as a “landscape level” approach to management. It takes a macro view of the entire land base, and through the use of coarse filters attempts to manage the complex and interconnected ecosystem as a whole. The ESA in contrast, takes the exact opposite approach and seeks to singularly change habitat to benefit a single species only. There are a number of problems with this approach, including logistical questions such as what to do when the ESA calls for conflicting habitat management for two or more different species. As well as the more philosophical questions of not only which species to favour, but to what degree should certain species trump communities and the people that live in them.

My family has owned and operated sawmills in our area of Ontario since the early 1890’s. For generations our livelihood has come from the forest. We depend on those trees for our living and it is crucial that they grow back so our children can depend on them as well. Sustainability is not just a buzzword to us in the forest industry; we live and breathe it every day. We know that every forest management decision we make today directly influences our children and grandchildren. Which is why if we in Ontario still want to have a forest industry with locally sourced wood products, proudly made by your friends and neighbors right here in Ontario, then we really need to consider how legislation affects this industry.

It is vital that when we manage our forests we always consider the 3 pillars of sustainable forest management: environmental, economic and social. If we subscribe a greater importance to one area over the others we lose equilibrium and the model of sustainability breaks down. We cannot let this happen; there are too many communities and lives at risk. I firmly believe that the ESA will upset the equilibrium in the Northern and Rural areas of this province.

My final ask is that the government move quickly on this regulation and that we in the forest industry need a final decision before the end of March.

Sincerely,

Jamie McRae
McRae Lumber Company
Whitney, Ontario

[Original Comment ID: 212474]