The Government of Ontario’s new Forest Sector Strategy has been portrayed as a gift to the people of northern and rural Ontario. It claims to herald a “better quality of life”, secure “a prosperous future”, and of course, “end unnecessary duplication”.
Instead, it’s another bulldozer for the Premier to pave the way for sweeping changes to the laws and policies that govern and protect public forests. Intricately tied to the Forest Sector Strategy are substantive cuts and amendments to the Crown Forest Sustainability Act, the Environmental Assessment Act, and the Independent Forest Audit system, among others. These changes are being pushed through with little genuine public input.
The government seems to believe that consultation need only happen with the “right” people and conveniently, the “right” people have been determined by the government. This should not sit well with most Ontarians.
The almost nonexistent public consultation on the strategy and the proposed weakening of laws, planning and oversight of our shared forests has been shocking. For starters, when the government announced it would be hosting seven roundtables across the province in 2018, it prevented participation through an invite-only process. Now, spring boarding off the changes already tucked into last year’s omnibus bill, multiple new postings were quietly released on the Environmental Registry in late December.
There are currently four additional postings on the registry (the proposal to permanently exempt industrial logging from the Endangered Species Act has now closed), each of them associated with the new Forest Sector Strategy. Heavy on rhetoric and scant on details, these postings are nowhere near the standard of public consultation established through Ontario’s Environmental Bill of Rights.
The recent Auditor General’s Report on the Environment exposed the government’s disregard for the legal requirements to consult the public on decisions with potential impacts on our environment. She reported that half of the proposal notices posted by the Natural Resources, Municipal Affairs, and Energy and Mines ministries in 2018/19 “did not adequately describe important aspects of the proposal, such as the environmental implications” (page 34). The government is ignoring its obligation to properly inform and consult Ontarians prior to decision making.
The consequences of a grossly inadequate public consultation are significant. It takes away the public’s ability to see the big picture. There are several interconnected proposals that accompany the Forest Sector Strategy, including:
Forestry activities in Ontario will no longer be required to meet the conditions outlined Declaration Order MNR-75 (the current environmental assessments process that must be followed when planning forestry on Crown lands to ensure that potential environmental effects and public and aboriginal input are considered before forestry operations). The Province has unilaterally stated that all conditions are now met. Further, without Declaration Order MNR-75, individuals will no longer be able to request an Individual Environmental Assessment (also known as a “bump up request”) with MECP if negotiations with forest license holders and/or MNRF fail. Environmental Assessment Act ERO 019-0961
The Minister will be allowed to extend the time between Independent Forest Audits from the current five-year cycle to ten years. The current five-year audit period is consistent with the adaptive management cycle identified in the Forest Management Planning Manual designed to ensure compliance with provincial forestry requirements. Waiting 10 years to find that a forest is not being sustainably managed is too long, and leaving this to the discretion of the Minister of the day is absurd. At least nine Ministers have moved through the Minister of Natural Resources and Forestry in the last decade alone; one only lasted 129 days. Independent Forest Audit process ERO 019-1006
Industrial forestry activities will be permanently exempted from Ontario’s Endangered Species Act (ESA). In 2019, the Province already pushed through significant changes to weaken the recovery requirements of the ESA, including allowing activities approved under other laws to be carried out without additional authorizations that provide overall benefit for at-risk species, even if those activities will result in harm. The recent proposal was nails in the coffin. Crown Forest Sustainability Act ERO 019-1020
The government’s excessive use of the word “modernize” in their proposed strategy is ironic. Rather than modernize the system, it is boldly going where we’ve gone before. While its public messaging does continue to support the laudable goals of the previous government, such as championing innovation, diversification, fair trade and education, and assures us (repeatedly) that changes to “cut red tape” will have no consequences to sustainability and the health of our forests, climate, and biodiversity. Yet, many environmental values are being put at a much greater risk.
Right now, most of the unharvested but available wood in Ontario is “committed” to license holders who pay nothing to retain the commitment and have no obligation to make wood available to newcomers or alternative uses. Most of the license holders are not even close to fully using the available wood – on many forests less than 50% of the planned harvest is cut within a plan period. We could be sharing that wood supply surplus between investment in forestry dependent communities and conservation of forests for other users. Keeping in mind, a large part of the allowable cut is of low quality, distant and uneconomic to harvest, and a glossy strategy can’t fix that.
Meanwhile, the legal and policy frameworks to safeguard the range of interests on our forests are being dismantled with very little public engagement. Who among us wants to cheerlead for that?
Julee Boan is Ontario Nature’s Boreal Program Manager. Based in our Thunder Bay office, she works collaboratively with local conservation groups, First Nations, and industry to seek environmentally responsible approaches to economic development in northern Ontario. She completed a Ph.D. in forest sciences with research focused on mitigating the impact of industrial logging on woodland caribou.