Thank you for the…

Thank you for the opportunity to comment on the draft Forest Sector Strategy.

I understand the priorities of the proposed strategy, as outlined in the proposal summary, and the four pillars of the proposed strategy.

As a resident of Northern Ontario, I have seen the social and economic devastation of small communities across the region after forestry activities declined, and mills have been shut down and demolished. Since the survival of many northern communities depends upon a vibrant forestry industry, I support the development and implementation of a strategy that will help sustain the sector.

The comments below relate to individual portions of the proposed new document.

• With regard to the first pillar of action, “Putting more wood to work”, the first action “Invest in advanced remote sensing technologies” may have implications for other sectors in Ontario. LiDAR (Light Detection and Ranging) is cited elsewhere in the strategy as a technology that might be used.
 If and when remote sensing is done, the results should be made available to other government ministries (e.g., Ministry of Environment, Conservation and Parks, and Ministry of Energy, Northern Development and Mines) as a potential cost-saving measure for their programs. They should also be made available free of charge to other sectors (e.g., hydroelectric, and mineral exploration and development) to promote economic development.

• With regard to the second pillar of action, “Improving our Cost Competitiveness”, the third action “Make strategic investments in critical infrastructure” may also have implications for other sectors, and for Ontario.
 In past years, many Ministry of Natural Resources district offices and/or Forest Management Plans have had rigid rules about third-parties using forest access roads. They have used policies and/or physical barriers to limit or prohibit third parties from using forest access roads, and blocked or scarified roads after forestry operations ended.
 Investments in infrastructure (e.g., access roads, culverts, bridges, etc.) would support the forest sector and make it more competitive. Less stringent restrictions on the use of the access roads by mineral sector workers would concurrently make Ontario more attractive for investments in mineral exploration and development.

• With regard to the fourth pillar of action “Promoting Stewardship and Sustainability”, the penultimate action “respond to a changing climate” has links to endangered species recovery plans.
 In places, the Province has established recovery plans for species that are at the limits of their natural habitats. As climate change continues, some areas may no longer provide suitable habitats for those species. There must be a process for reviewing and modifying the recovery plans if and when such changes occur, so that forestry workers – and others who depend upon access to Crown land – do not have to comply with restrictions that are irrelevant to their locations.

• With regard to Sustainable Forest Management under the proposed strategy’s (page 12), it would seem relevant to include a reference to the Province’s Wildland Fire Management Strategy (2014) with the list of seven other actions that Ontario has taken to achieve sustainable forest management.

• With regard to the goals cited in the draft strategy for improving the cost competitiveness of the provincial forestry sector, it appears that one action – mentioned under “Addressing Barriers to Trade” on page 26 – is missing. That action relates to the phrase “we will need to work with…the federal government…”
 Given that the provincial website www.investinontario.com notes that over 96% of the province’s total wood product exports are shipped to the United States, it is in Ontario’s best interests to work with the federal government to ensure that new softwood lumber disputes do not arise under the provisions of the new Canada–US–Mexico trade agreement. A successful outcome, whether by 2022 or by 2030, with regard to the international trade agreement should be included in the goals on page 21.

• As mentioned previously with regard to the second pillar of action, infrastructure is important to the mineral sector. The wording under “Making Strategic Investments in Forest Access Roads” should be changed, however, to better represent the mineral sector.
 At present, the phrase “…other industries like rail, energy utilities, mining as well as emergency first responders” is used. The mineral sector includes two distinct – and distinctly different – parts. The first is mineral exploration (and development), while the second is mining. This is amply demonstrated by the fact that the parts are represented by completely different professional organizations, both provincially and nationally. Both parts should be recognized in this section of the strategy.

• Environmental groups may refer the Ministry of Natural Resources and Forestry to the Ontario Forest Accord in feedback with regard to the proposed Forest Sector Strategy. The Accord was signed in 1999 as an adjunct to the Ontario’s Living Legacy Land Use Strategy. Article 7 of the accord states “Develop a process for sharing permanent increases in wood supply between additional protected areas and increased forest supply.”
 It is worth noting that – as stated in the proposed strategy itself – the volume of timber harvested is currently less than 60% of what it was in 2000. Any argument for creating additional protected areas due to the article 7 must be considered in the context of the 1999 wood supply, not the 2020 wood supply.