To Whom It May Concern:…

 To Whom It May Concern:

  Thank you for the opportunity to comment on Policy Proposal Notice EBR: 012-8249, Building a Wildlife Management Strategy for Ontario: Discussion Paper. The Ontario Forest Industries Association (OFIA) has reviewed the document and would like to provide the following comments.

  As outlined in the discussion paper, wildlife management has evolved over the decades from managing for game and individual species, to understanding and managing ecosystems. An ecosystem approach to managing for a multitude of values across the landscape is what made the Crown Forest Sustainability Act (CFSA), the act our industry operates under, such a landmark piece of legislation.

  OFIA supports the principles of the CFSA and views this act as potentially providing a solution to managing for all species, including species at risk. The CFSA’s two principles are the following: 1.Large, healthy, diverse and productive Crown forests and their associated ecological processes and biological diversity should be conserved.

  2.The long term health and vigour of Crown forests should be provided for by using forest

 practices that, within the limits of silvicultural requirements, emulate natural disturbances and landscape patterns while minimizing adverse effects on plant life, animal life, water, soil, air and social and economic values, including recreational values and heritage values.

  We believe that these principles are in alignment with the principles and vision of the proposed discussion paper, and as a result is something that OFIA and our member companies generally support.

 An important component of managing wildlife in Ontario is managing for species at risk (SAR). Ontario’s forest sector has a long history of providing for SAR and we are currently evaluating the linkages between the CFSA and the Endangered Species Act (ESA) in co-operation with the Ministry of Natural Resources and Forestry (MNRF).

  It has become clear through this process that there will be significant implementation challenges due to the differing approaches of these two acts.  While the CFSA reflects the modern ecosystem approach mentioned in the discussion paper, the ESA focuses primarily on the protection and recovery of individual species. A central question to this challenge is what will happen when two or more species, with different habitat requirements, occupy the same area?

  Accordingly, we were pleased to see the following statement made in the discussion paper: “Ontario’s species at risk and their habitat are protected under the Endangered Species Act, 2007. Landscape species like the boreal population of caribou, which is listed as Threatened in Ontario, interact directly and indirectly with many other northern species such as moose, white-tailed deer, black bear and wolf. For this reason, it is important that wildlife population and habitat management activities consider the status and potential interactions of all species on the landscape.”

  Furthermore, OFIA was pleased to see an acknowledgement of the human-wildlife connection and consideration of socio-economic values within the discussion paper.  However, we ask that a more explicit statement that a socio-economic analysis will be undertaken during policy development be included in the paper.

  As a sector, we remained entirely committed to working with the MNRF in order to find workable solutions for managing Ontario’s wildlife and species at risk.  We ask that we continue to be involved in this discussion moving forward

[Original Comment ID: 196338]