I am providing feedback to…

I am providing feedback to the discussion questions outlined in the Discussion Paper from a Forest Industry perspective. Many additional points were raised during the information sessions held across Ontario.
Strengthen Collective Responsibility for Wildland Fire Management
1) I support strengthening collective responsibility for wildland fire management in Ontario.
a. Entering into agreements with First Nations, Municipalities and Industry would provide greater clarity and elicit dialog towards a collaborative approach to wildland fire prevention, preparedness, response, and awareness.
2) I don’t think a one size fits all model will work given the diverse nature of First Nation Communities, Municipalities and even Industry. Rather identify the key objectives and desired results and have First Nations, Communities and Industry groups along with Fire experts develop a base model that could be customized for local circumstances.
Caution that not all First Nations, Communities or Industries have the resources or ability to commit to participating at the same level. Many competing priorities can make this difficult to achieve at widespread consistent level.
Improve Ontario’s awareness of wildland fire risk
3) I think there needs to be a broad approach to communicating wildland fire risk and the communications need to escalate as the wildland fire risk increases.
a. Educate children in school to give them a basic understanding of dangers of wildland fire as well as structural fires at home.
b. Continue with the use of fire danger signs but they must be maintained to be believed.
c. Radio and television news spots along with the weather
d. Digital signs along highways
e. Wiland Fire specific messaging (perhaps a Canadian version of Smoky Bear)
f. Use of Social Media
4) There are a few key points that I would suggest for improving the approach to preventing and preparing for wildland fires caused by industry. I would also note that Forest Industry reports and responds to fires in thier operating areas be it lightning or other human caused.
a. Modifying Industrial Operations Protocol MIOP has proven to be a good model for the prevention of large forest industry fires. There are some things that could be done to improve:
i. Update the weather station network across the province. MIOP relies on forecasts. Increasing the number and quality of weather stations will provide better/more accurate site-specific information to guide the implementation of MIOP. Better information will also elevate the accuracy of information used to determine fire risk and behavior. Combining with lightning strike mapping with an increased understanding of receptivity to lightning starts should provide the ability for rapid response to keep lightning fires small. This is particularly important near remote communities.
ii. Consider the inclusion of a compliant industrial onsite weather stations into the weather station system.
iii. Consider developing an app for evaluating fuel groups. Possibly even an AI generated model where you could take a picture of the forest site and answer a few basic questions to arrive at the fuel group.
b. Consider re-starting the Industry Fire Boss training to elevate awareness and provide additional capacity to support industry initial attack and response. Industry fire fighters can play a supportive role but are not professional firefighters and caution that their training level, fitness, and lack of proper equipment can leave them vulnerable.
c. Create a base of qualified wildland fire trainers to deliver S102 training in several languages.

Expand prevention and mitigation of wildland fire
5) Wildfire management planning should be part of the Forest Management Planning process to a greater degree. Currently considered as part of the natural disturbance pattern that is being planned but not really considered in terms of mitigating fire risk across the landscape and to the communities within and adjacent to the managed forest. This is a missed opportunity to have these important discussions with First Nations, Communities, and stakeholders.
Salvage should be included as an approved activity in the Forest Management Plans to allow for rapid response to recover damaged fibre and mitigate fire risk associated with Blowdown and insect damage. Current approval processes are far to long often taking over a year to be approved. This results in a loss of timber value, reduced interest in salvaging and a higher risk on the landscape.

6) The Forest Industry stands out in taking proactive measures to prevent wildland fires thru prevention, training, preparedness communications and response. The industry commits significant resources and investments annually toward this end.
Forest Industry employees are community members and are often part of volunteer fire departments.
Industry works closely with Municipalities and First Nations discussing and implementing plans to recognize and address wildland fire risk.
The local citizen committees associated with forest management planning includes stakeholders, First Nations, Industry and MNR. The existing committees could be consulted on aspects of Wildand Fire Prevention and Mitigation in the Forest Management Plans for the areas of managed Forests.
7) Some of the prevention and mitigation activities could be included in Forest Management planning.
Possibly direct some of the stumpage, land use fees, etc from general coffers to this effort.
Federal and Provincial Dollars should be used. Further costs should not be imposed on Industry, communities or First Nations.
Enhance Preparedness and Response to Wildland Fire
8) Increase MNR firefighting capacity to required levels in numbers, expertise and equipment. Become a net exporter of talent to be called upon by other jurisdictions.
As the majority of fires are lightning caused there needs to be a focus on early detection and rapid response to those lightning fire starts that need to be suppressed given their location and proximity to communities. Many are observed but there should be a capacity and a priority to respond with initial attack and keep the fires small whenever possible.
9) Increased training and capacity building. Perhaps supported partnering with forest industry. Involve and train local First Nations Community member to be part of the fire suppression capacity. These skill can be transferable to responding to other emergency situations.
10) Fostering improved relationships around the common goal of mitigating Wildland fire risks. Gather those groups together annually.
Address the Insurance and Liability concerns thru Provincial Equipment insurance and include language in regulations to speak to liability.
Look at standardizing equipment rental rates and simplify the billing process.
Evaluate the procurement process to enable a simplified approach to hiring heavy equipment for firefighting.
Indemnify people helping on fires.
Strengthen rules and consequences for non-compliance with forest fire laws
11) I question whether adding additional administrative penalties will be effective as many of the penalties currently on the books are not enforced. MNR lacks the resources to monitor in many cases and only appears to enforce after an event.
12) Authorities must wave cost recovery in cases where the Forest Industry has complied with the Act and Regulations and there is a fire start that results in fire suppression costs.
This should be written into regulations to encourage compliance with the Act and Regulations so that there is a clear understanding that if you comply you will not be subject to cost recovery.
13) Further consequences for those who fail to comply could include publishing the contravention like a hunting or fishing infraction. Most companies are under a form of certification and those infractions could impact the ability of a company to maintain certification.
Thank you for the opportunity to provide comment. I hope the comments provided during the open houses along with the written comments will help guide decisions. Please reach out if you have any questions or if I can provide further information.

Edward Frisby R.P.F.
Woodlands Operations Manager
Resolute Forest Products
Co-chair Fire Solutions Forum
Cell: (807) 633-7432
ted.frisby@resolutefp.com