Ontario continues slashing forestry environmental rules

The Ontario Government has a plan for the forest industry consistent with the stated priorities of the Ford government to ‘reduce red tape’, ‘create prosperity and ‘ensure Ontario is open for business’.

What we see, however, is the gutting of environmental laws and rules that would steamroll the sustainability of public forests and trample Ontario’s reputation in the marketplace. Ontario has already proposed exempting forestry operations from the Endangered Species Act (ESA) and Environmental Assessment Act. It is also proposing to give away up to 15 million m³ of wood supply without a clear plan that also includes communities, protecting at risk species and ensuring a safe climate.

And to make matters worse, Ontario has already begun implementing the draft strategy without waiting for and responding to comments. It makes a mockery of the public consultation process.

Please send the letter below to the Ontario Government telling them to hit the brakes on its radical proposals that would only benefit the forest industry.

UPDATE: Read our Wildlands League submission on the Proposed Draft Forest Sector Strategy

Read the Wildlands League submission on endangered species and forestry.

Read what scientists are saying on endangered species and forestry.

Deadline for submission is February 18^th. Please help us get in as many comments as possible to respond to these troubling proposals created behind closed doors for a select few forestry companies.

Jennie

Weller

Environmental Assessment and Permissions Branch

re: ERO #019-0961 Proposed amendments to General Regulation 334 under the Environmental Assessment Act to remove Regulatory Duplication of Forest Management requirements in Ontario

Jennie Weller
Environmental Assessment and Permissions Branch

Dear Ms. Weller,

Thank you for receiving my comments on the proposed amendments to General Regulation 334 under the Environmental Assessment Act to remove Regulatory Duplication of Forest Management requirements in Ontario  (ERO: 019-0961)

Please do not implement Ontario’s Forest Sector Strategy and this enabling proposal as presented.

On December 4, 2019, the government posted Ontario’s Forest Sector Strategy draft (the Strategy), on the Environmental Registry of Ontario - a detail-free document that claims to reduce ‘red tape’, create ‘prosperity’ and signal that ‘Ontario is open for business’.  Without waiting to receive all the public comments on this proposal before making decisions MNRF and MECP posted five additional proposals on the Friday before the holidays.  These include proposed permanent exemptions for the industry from both the Endangered Species Act and the Environmental Assessment Act, changes to independent forest audits, forest management planning and pest management.

Together these additional proposals begin implementing the vision laid out in the Strategy, while the Strategy itself is supposedly still undergoing public consultation. That they were snuck in before a major holiday adds to my concern that this is not sincere public consultation.

One of the main thrusts of the draft Strategy is the claim that Ontario has an extra 15 million cubic metres of wood volume (representing about 15 million ha of forest) that is not being utilized that could be used to expand the forest industry.  There is no convincing evidence that this wood is actually available or that it could be used without impacting forest biodiversity, long term industry prospects or the stability of our climate.

Indeed, this proposal seems to pave the way for increased logging no matter the consequences by removing safeguards under the Environmental Assessment Act (EAA).

Instead of removing EAA assessment oversight, Ontario should be reviewing the environmental assessment program to regain public trust and increase the capacity to administer potential new logging streams, and a next generation forest sector.  The EAA does not provide unnecessary duplication.  The loss of a “bump-up” request, for example, for an individual environmental assessment is a specific example of removing distinct and un- replicated functions. Under the existing EAA Declaration Order regime, there is a 30-day period for any person to make a written request to the Minister of the Environment for an individual environmental assessment of specific proposed forest management activities in the plan. This provision allows an existing final oversight provision to Ontarians, and an inter-ministry check-point that would be removed under this proposal. Both of these roles are important, and cannot, and will not be replaced under this proposal. 
The proposal also asserts that the full 61 conditions of Declaration Order-75 have been met and incorporated into MNRF’s existing requirement but no specific evidence of this claim is provided.

Climate change is an increasingly important societal concern and value, that was not assessed at the time of the original Timber Class EA Hearings, nor at any stage of the Declaration Order history that followed. MECP should not be backing away from its obligations to assess environmental impacts such as climate change which has never been assessed for forest operations. This substantial gap in Ontario’s management of its forests in a carbon emergency demonstrates the dangers of exemption from ongoing assessment of environmental risks and values.

Please do not go ahead with the draft Strategy in its current form or this specific proposal to exempt forest operations from the Environmental Assessment Act.  Please have meaningful consultation opportunities with the public similar to what you offered select forest companies.

Sincerely,

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