Thank you, Mr. Chair.

Thank you to the members of the committee.

The Forest Products Association of Canada, or FPAC, is pleased to have the opportunity to appear before you on this important topic.

Just to provide a little context, when it comes to forestry and the activities that we do across Canada, particularly when it comes to fish and to fish habitat, the vast majority of forestry-related activities include building and deactivating roads to access operations. This requires the installation, maintenance—and, in the case of temporary roads, removal—of culverts and bridges. That's really what we're here to talk to you about today.

Prior to the act changing in 2012, we were under the HADD provisions, which we're back to now. DFO had been working quite diligently with natural resource sectors to develop compliance support tools, particularly for routine activities that were considered low risk to fish and to fish habitat. These tools included operational statements, and they were developed back in the 2000s. They were focused on avoiding harmful alteration, disruption or destruction of fish habitat, otherwise known as HADD.

In 2012, as you know, the federal government made revisions to the Fisheries Act, and despite allegations to the contrary, the 2012 version of the legislation did not reduce the operating standards employed by our sector—the forestry sector. Instead, forestry companies continued to implement a high degree of rigour in activities in and around water, in large part due to provincial standards, which did not change, and due to independent certification systems and company-specific operating procedures.

When the act was subsequently revised again in 2019, it was done under the premise of restoring lost protections. What this resulted in was essentially a return to the previous version of section 35 HADD provisions. However, unfortunately, we lost all of the compliance support tools for routine activities that were developed prior to 2012. We had raised concerns that there would be delays in developing all of these new compliance tools, which unfortunately has been our experience in the last five years. This has resulted in a lack of predictability for our industry, costly delays and an unforeseen administrative burden. These delays are not resulting in better outcomes for fish and for fish habitat.

I raise these concerns to emphasize a key point. The lack of progress on behalf of DFO in implementing the 2019 Fisheries Act is really not acceptable, and it falls short of commitments made by the government when the new act came into force. We believe that the department has the institutional knowledge and experience to develop these codes and regulations. We appreciate that DFO has been engaged quite broadly, for five years, in talking to people through its Let's Talk Fish Habitat platform, but it's time to move from talking about it to taking action on tools to support fish habitat.

I will allocate the remainder of our time to my colleague, Scott Jackson, who can elaborate.

Thank you.

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