Roadless Wilderness Areas
In February 2003, the Wildlands League and Sierra Legal Defence Fund submitted an EBR application focused on the planning and management of logging road networks in Ontario’s public forests, the need for access controls, and the preservation of roadless wilderness areas. The applicants requested that the Ministries of Natural Resources and Environment review all existing policies, Acts, regulations, and instruments, as well as consider the need to develop new legal mechanisms if necessary. Both ministries denied the application. (See pages 202-207 and 242-248 of the Supplement to this report.)
Logging roads provide access to the forest for many activities. Although some of these uses, like camping and canoeing, generally have a modest environmental impact, others, like mineral exploration and extraction, motorized hunting and fishing, have the potential to create significant negative impacts on ecosystems. In 2001, MNR estimated that approximately 80 per cent of the logging road network is open to public use in Ontario.
Condition 106 of the 1994 Timber Management Class Environmental Assessment Approval required MNR to develop a provincial policy on roadless wilderness areas within three years. The EA Board stated that “roadless wilderness areas are a matter of provincial interest comparable to timber management decisions that need to be made about landscape management and biological diversity.”
In 1997, MNR released Ontario’s Approach to Wilderness: A Policy. However, the ECO believes that this policy did not meet the terms and intent of the 1994 Timber Class EA. This policy does not address roadless wilderness areas in the Area of Undertaking for commercial forestry since it primarily deals with those already found in protected areas – areas already closed to forestry.
It is the position of MOE and MNR that this policy met the requirements of Condition 106. As such, MNR recommended to MOE in its review of the Timber Class EA that this condition be dropped from the revised EA approval issued in 2003, stating that the wilderness park class target had been achieved to the extent possible within the Ontario’s Living Legacy (OLL) planning area and that “by definition, wilderness parks and wilderness zones in other types of parks are roadless.”
The ECO observes that OLL did not in fact create any new wilderness class parks and, therefore, did not significantly affect the quantity of roadless wilderness areas in the province. The ECO also notes that MNR admitted that it was still trying to figure out how to address the commitment made in the policy to consider wilderness values on the “intervening landscapes …outside parks and protected areas,” such as in forest management units.
MOE received hundreds of comments on the proposed Declaration Order requesting a condition that would require MNR to develop a policy to maintain roadless wilderness areas outside of parks and protected areas. These comments came from disparate stakeholders such as environmental groups, tourism associations, and foresters, as well as from a letter-writing campaign.
Unfortunately, MOE chose not to include a condition for roadless wilderness areas. The ECO is concerned that the public interest is no longer buttressed by an active EA Board condition for MNR to plan for roadless wilderness areas in the area where commercial forestry is undertaken in Ontario.
The ECO believes that the recent revisions to the Timber Class EA and the Forest Management Planning Manual do not sufficiently address roadless wilderness areas within the Area of Undertaking. The ECO encourages MNR to consult on and develop a policy that explicitly addresses roadless wilderness areas, including forest road access and decommissioning roads, within the Area of Undertaking for forestry operations. The ministry should also ensure the provision of sufficient resources to enforce and monitor the field-based results of such a policy.
| This is an article from the 2003/04 Annual Report to the Legislature from the Environmental Commissioner of Ontario. |
Citing This Article
Environmental Commissioner of Ontario. 2004. "Environmental Assessment for Forest Management." Choosing our Legacy, ECO Annual Report, 2003-04. Toronto, ON : Environmental Commissioner of Ontario. 98.
