ERO Proposal - Changes to Crown Forest Sustainability Act

Wednesday Dec 11, 2019

Author: NOTO

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ERO Proposal Triggers Concerns

A recent posting to the ERO focused on amendments to Three Statutes administered by MNRF to support the proposed Better for People, Smarter for Business Act, 2019. The only information that was given in regards to changes to the Crown Forest Sustainability Act, 1994 was the following:

The proposed amendments would support changes to the forest management policy framework to reduce burdens to industry and streamline delivery by government. The proposed amendments would, if passed:

    • enable the issuance of a “permit” to allow a person to remove forest resources from a Crown forest for non-forestry purposes (e.g., roads, mining, utility corridors).
    • modernize the requirements for annual work schedules by removing the requirement for MNRF approvals.
    • enable the Minister to extend a Forest Management Plan.

The lack of information and supporting documents had NOTO staff and members concerned about the future direction of forestry and what it could mean to tourism. In response, NOTO looked into the Better for People, Smarter for Business Act and found a little more information on these proposed changes, however, it did leave several questions unanswered. As a result, NOTO has made a formal submission on behalf of the tourism industry listing the following concerns:

1. Enable the issuance of a “permit” to allow a person to remove forest resources from a Crown forest for non-forestry purposes (e.g. roads, mining, utility corridors)

  • What are the parameters to qualify for these permits?

  • Can anyone apply for one of these permits to build a permanent road or is this only for utility corridors?
  • Will there be any form of notice to other user groups in the area where the permit is issued?

2. Modernize the requirements for annual work schedules by removing the requirement for MNRF approvals.

This change is of great concern to the tourism industry. Often work schedules are changed during the lifetime of an FMP. Requiring the approval of MNRF provides a chance to review the work and ensure that proposed changes are classified properly as either minor or major amendments that require a more fulsome and important process to obtain approval.

Since both tourism and forestry industries have boots on the ground in our forests, it is vital that communication remain open between these businesses. The process of seeking approval on changes to annual work schedules allows for that communication to take place.

In addition, if a change to a work schedule includes moving roads or harvest blocks in a particular forest, what process is there to ensure that moose habitat, or endangered species will be protected if present? In many instances, MNRF and the other user groups have the knowledge of the forests. If there is no approval process, then how can we ensure that wildlife habitat is considered before changes take place?

Our MNRF plays a crucial role in managing our Crown land, wildlife and fisheries. Removing that ability to check in and ensure industries are using these Ontario assets accordingly is a serious issue of concern to the tourism industry.

Overall, it is our opinion that too much of the land use planning on our crown land is being left to the forestry industry. It is an extremely one-sided method of planning what activities will be able to take place on our landbase for generations to come. We understand that the reduction of red tape is a focus of this Government, however, our concern lies in the long term impacts on the environment, wildlife, fisheries and to the user groups of the landbase if approvals for changes to annual work schedules are not required. 

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