In Ontario, The ESA and the…

In Ontario, The ESA and the Crown Forest Sustainability Act (CFSA) do not align in a way which works for the people of Ontario nor is having both of these pieces of Legislation acting together on the same land base as it pertains to Forest Management in Ontario. The CFSA mandates Forest Management at two scales, the landscape level, and at a stand level. The well founded and strong science that drives this approach theoretically provides habitat across time for species at risk using both the coarse and fine scales. The ESA only manages at the fine scale for individual species, often time at the detriment to other species. The CFSA and the legislated guides that form Ontario's forest management policy framework are an effective tool that provides for the long term sustainability of a healthy landscape/ecosystem. The ESA's stipulation that one cannot "harm, harass etc..." creates area's that are effectively forever off limits to management, even though the forest cover is not static over time, this flies contrary to the paradigm of Landscape level course and fine filter management, which is not necessarily for an overall benefit to the species for which the restriction is being created for. The ESA as written would effectively halt Ontario's forest Sector if the CFSA would be replaced by the ESA, which I am vehemently against as the CFSA has proven to be world class piece of legislation. Alternatively, the idea of harmonization between the acts is also counter productive because the two paradigm's cannot coexist on the same landscape without both harm to landscape level integrity, and Ontario's economy. Thus; the forest sector in Ontario requires a permanent solution to the ESA, which can be accomplished through a permanent section 55 Regulatory Exemption. I do not support the Harmonization option as it does not effectively deal with the socio-economic and landscape level management risks associated with the ESA. The only path forward for a strong and resilient landscape in an era of fire suppression, and a strong and resilient Northern/rural Ontario economy and communities is to enact the CFSA as an equivalent process to the ESA.