I am writing as an…

I am writing as an individual member of the public to comment on the proposed revisions to the Forest Management Planning Manual, the Forest Information Manual, and the Scaling Manual. I appreciate the opportunity to participate, and I have read the proposal and the supporting change tables.

I support efficient government and I understand the goal of reducing duplicated cost and effort in plan preparation. However, after reviewing the proposal, I believe the changes carry risks that are not adequately addressed in the regulatory impact analysis, and I am asking the Ministry to withdraw the proposal in its current form pending further work. My specific concerns are set out below.

1. Fewer consultation cycles. Each forest management plan currently triggers its own consultation process. Allowing one plan to cover multiple adjacent management units would reduce the number of separate plans, and with them the number of distinct opportunities for the public and affected communities to engage. The proposal states that participation rights are maintained, but consolidating plans inherently reduces the number of formal entry points, and that reduction is not analyzed.
2. Weaker footing for First Nation and Métis engagement. The existing process is built around customized, community-by-community consultation and the incorporation of Traditional Ecological Knowledge. A plan spanning several units and a far larger territory makes it harder for an individual community whose traditional territory covers only part of that area to have its specific concerns meaningfully reflected. The proposal frames consolidation as reducing duplication for communities, but it does not demonstrate that community-specific engagement is preserved at the same depth.
3. Cumulative effects and aggregated harvest limits. A multi-unit plan establishes a single planned harvest area across a much larger geography. The analysis does not show that sustainability limits calculated for each unit are preserved when aggregated, or that the larger scale will not obscure localized over-harvesting that would have been visible in a single-unit plan.
4. Plan author capacity. The plan author must be a single Registered Professional Forester. It is reasonable to question whether one author or a small team can meaningfully account for the ecological and social variation across an area that could span several million hectares, and the proposal offers no assurance on this point.
5. Reduced granularity of monitoring and accountability. Reporting and compliance tracking organized around a consolidated plan may make it harder for the public to scrutinize what is happening in any one specific area.
6. Open-ended discretion and risk of becoming the default. Approval of a multi-unit plan rests with the regional director against fairly open-ended proposal criteria. The proposal does not explain what guardrails prevent multi-unit planning from becoming the routine approach rather than a justified exception.
7. Linkage to Bill 56 and the Scaling Manual changes. The Scaling Manual revisions are tied to the elimination of the harvest approval requirement once provisions of the Building a More Competitive Economy Act, 2025 are in force. Tying manual changes to legislation that is not yet fully in effect makes it difficult for the public to assess the complete combined effect of what is being proposed here.
8. The “neutral” environmental finding rests on an unexamined assumption. The impact analysis concludes the environmental consequences are neutral because the overall planning process is unchanged. That conclusion depends on the assumption that consolidation does not change outcomes in practice, which is precisely the point in question and is not substantiated.

For these reasons I respectfully ask the Ministry to withdraw the proposal in its current form. If the Ministry chooses to proceed, I would ask at minimum that it publish a fuller analysis of the effects on consultation frequency and on community-specific Indigenous engagement, commit to clear limits on when multi-unit planning may be used, and demonstrate how aggregated harvest limits will preserve unit-level sustainability.

Thank you for considering these comments