I am writing in response to…

I am writing in response to the proposed minor revisions to the Forest Management Guide for Boreal Landscapes and the Forest Management Guide for Great Lakes-St. Lawrence Landscapes (ERO 025-0847).

The Ministry’s summary boldly asserts that these revisions will “continue to conserve biodiversity and the long-term health of public forests” with “no anticipated negative environmental implications.” This is not just disingenuous—it’s a blatant hypocrisy that insults the intelligence of Ontarians who rely on these Crown forests for clean water, wildlife, and cultural heritage. While you tinker with boundary tweaks and wording clarifications, the real existential threats to our forests—industrial chemical warfare and habitat-shredding energy projects—march on unchecked, rendering your “sustainable management” claims a cruel joke.

Consider the single most egregious ongoing assault: the aerial and ground spraying of glyphosate-based herbicides across hundreds of thousands of hectares of freshly clearcut Crown forest each year. This broad-spectrum toxin, deployed to wipe out “undesirable” hardwoods and shrubs in favor of monoculture conifer plantations, is a biodiversity killer masquerading as stewardship. Peer-reviewed science is unequivocal: glyphosate drifts into wetlands and streams, decimating amphibians, fish, and aquatic invertebrates (Edge et al., 2013; Relyea, 2005); it starves pollinators and ground-nesting birds of essential cover, fueling the collapse of aerial insectivores (Stanton et al., 2018; Spromberg et al., 2023); and it lingers in soils and runoff far beyond your outdated risk models (Battaglin et al., 2014; Health Canada re-evaluations, 2015–2023). Yet your 2024 guide review? Silent on this chemical apocalypse. You cannot preach “emulating natural disturbances” while chemically sterilizing the understory, creating barren tree farms that mock the diverse, resilient ecosystems the guides claim to protect. This isn’t science-based forestry; it’s corporate subsidy for pulp and paper giants, subsidized by taxpayers and the blood of Ontario’s wildlife.

And let’s not pretend your renewable energy fairy tale is any greener. The Ministry continues to greenlight the bulldozing of intact boreal and Great Lakes–St. Lawrence forests for wind turbines on Crown land, fragmenting habitats with roads, transmission lines, and turbine pads that scar the landscape for decades. Take the Bow Lake Wind Facility near Sault Ste. Marie: 36 turbines churning out 90 MW since 2012, predominantly on Crown land, celebrated as a “partnership” with Batchewana First Nation. But the reality? A bat monitoring technician, tasked with studying local populations, was forced to abandon the work mid-study due to the turbines’ “acoustic pollution.” As documented in noise complaints to the Ministry, the turbines were “generating unacceptably intrusive and potentially dangerous noise emissions into the natural environment,” drowning out the bats’ echolocation calls and rendering the site unusable for scientific assessment. This isn’t hypothetical harm—it’s proven acoustic sabotage of wildlife corridors, where bats, already reeling from white-nose syndrome, now face ultrasonic interference from gears, rotors, and blades that disrupts their hunting, migration, and mating (Long et al., 2011). Cumulative effects? Ignored. Landscape-scale biodiversity? Shredded for photo-ops and power contracts. How many more “silent springs” must we endure before you admit that these projects turn vibrant forests into industrial graveyards?

Your proposed revisions—reassigning the Spanish Forest, syncing assessment timelines, clarifying misalignments—do nothing to halt this hypocrisy. They polish the veneer while the core rot festers. If the Ministry truly honors “the best available science and knowledge” and the “long-term health of forest ecosystems,” then act like it:
1. Immediate glyphosate phase-out: Ban its use on Crown lands with a hard deadline (e.g., 2026), following Québec’s lead—Ontario’s forests demand no less.
2. Cumulative impact mandates: Fold industrial wind (and all energy infrastructure) into landscape-guide assessments, including acoustic and habitat fragmentation modeling, with veto power for high-risk sites like Bow Lake.
3. Independent oversight now: Launch the Ontario Forest and Lands Advisory Council—stocked with frontline ecologists, arborists, anglers, naturalists, and Indigenous guardians, not just bureaucrats and industry reps—to enforce binding rules on herbicides, old-growth protection, and restoration. No more self-policing charades.

Ontario’s public forests are not your playground for half-measures. They are irreplaceable life-support systems, and your inaction is complicity in their destruction. End the glyphosate scourge. Halt the acoustic and habitat carnage from turbines like Bow Lake. Or admit that “sustainability” is just code for business as usual.

The people—and the bats—deserve forests that sing, not ones silenced by your policies.

References: Wind Concerns Ontario, 2021 noise complaint documentation; Long, C. et al., 2011, Ultrasonic noise emissions from wind turbines: Potential effects on bat species