Thank you for the…

Thank you for the opportunity to comment on the proposed amendments to General Regulation 334 under the Environmental Assessment Act as described on the Environmental Registry of Ontario posting number 019-0961.

Our Company supports initiatives put in place to find efficiencies and reduce unnecessary duplication in Forest Management Planning and modernizing approval processes. As such, we support the government’s intention to modernize the Environmental Assessment (EA) process which aims to remove duplication between the EA Act requirements and the Ministry of Natural Resources and Forestry’s (MNRF) policies, regulations and guidelines.

Specifically, we support the elimination of the Individual Environmental Assessment (IEA or bump up – T&C 26) process currently entrenched within the Forest Management Planning (FMP) process. The current issue resolution process that precedes the IEA bump-up process is rigorous enough to ensure that stakeholder disputes are appropriately addressed within the FMP process. The current IEA bump-up process causes major delays for FMP approvals (in some cases over 2 years) and results in an unnecessary administrative burden for both the MNRF and forest industry.

Our Company also supports the streamlining of the process for MNRF to be able to make amendments to the Declaration Order MNR-75 (T&C 58). The current process seems overly onerous and unwieldy for both the MNRF and MECP and discourages timely changes to the Dec Order.

We do however have concerns that some of the requirements included in the current Declaration Order MNR-75 may or may not be adequately addressed by MNRF’s proposed changes to the forest policy framework, regulated forest manuals or supporting forest policy, programs and procedures. Specifically, we have concerns that a number of the Dec Orders as noted in our attached letter may not yet be adequately addressed.

Thank-you for providing the opportunity to comment on the proposed amendments to regulation 338. We support the governments efforts to streamline approvals and to remove duplication. In so doing, we continue to seek assurances that the government will maintain important requirements that support forest stewardship and sustainability in Ontario.