I am writing to provide my…

I am writing to provide my support for the proposal posted on the Environmental Registry on January 26, 2018 to extend the Endangered Species Act (ESA) Section 55 Regulation for Forestry.

I am a Registered Professional Forester working in Ontario. For the past decade, the implementation of the ESA for forestry has been a difficult issue for Ontario. The act presents a serious risk of unintended consequences if implemented without proper regard for the impacts on communities, First Nations, Forest Industry and the many workers who depend on this sector for their livelihood. I have seen first hand the devastation to communities, workers and families when industry is forced to shut down.

One legislated responsibility of every Professional Forester is to serve and protect the public interest, rather than the special interests of any one person or group. Socio-economic studies completed by the MNRF, verified by Ontario's Ministry of Finance, as well as independent wood supply studies completed by industry foresters, have all concluded that thousands of jobs and hundreds of millions of dollars of tax revenue will be lost if proposed policy direction were to be enacted.

We need the opportunity to get this right for the sake of all Ontarians, the Forests and the Species at Risk.

The posting proposes to form an expert panel which includes representatives from Northern Communities, First Nations, Forest Practitioners, and Scientists. This panel is critical to ensure that real science and the views of the people who live and work in the forest regions of Ontario are appropriately incorporated into any implementation plan for the ESA. The panel also need to consider how to appropriately integrate the ESA with the world-class Crown Forest Sustainability Act (CFSA), which governs forest management activities in Ontario. The CFSA seeks balance in providing for social, economic, and environmental objectives, and has served the province will over the past 25 years.

Ontario's Professional Foresters must also be part of the expert panel.

The recognition that government needs to take more time to ‘get it right’ is a welcome development. However, I would urge the government to allow for more time than the currently proposed two year extension to deal with the very complex issues associated with the ESA. A five year extension would be a more realistic time frame for this panel to be able to fully assess the options available and to provide appropriate implementation advice.

Finally, time will be of the essence in finalizing this proposal. With the deadline for the expiry of the current Section 55 Regulation fast approaching, this extension should be put into place immediately following the end of the 45 day review period.

Thank you for recognizing the critical issues at stake with respect to the ESA, and for taking positive action to ensure that the hard-working people of Northern Ontario are properly involved in a workable solution for this act.

[Original Comment ID: 212715]