To: MNRF I attended the open…

To: MNRF
I attended the open house in April here in Thunder Bay. I was disappointed to hear the MNRF has undertaken a separate planning process that is outside of the Forest Management Planning (FMP) process. The CLUPA process seems to have no review period or accountability – like an independent forest audit would per the FMP process. The FMP process would have outside auditors assess whether the management actions are meeting the intended purpose over time per the legislated planning manual. The CLUPA process should be denied and the issue sent back to the FMP planning process.

My understanding of natural resources management policy in the province is based on the principle of adaptive management. Creating a park is a short sighted ‘protective’ idea that leaves management of this area to nature’s whims- meaning forest fire. With the risk of fire ever increasing over time. This type of management that caters to only one species and provides a private park for a few cottages, is not sustainable forest management.

I want this proposal to be fully denied. I expect the Province to choose to implement its own policy of adaptive management rather defining a private park. The area should be managed for the long term health of the entire forest area, not one species. Direction in the MNRF Stand and Site Guide – a guild founded on the best science that is applied throughout Ontario - has adequate direction for ground water recharge areas associated with known brook trout spawning site. This direction should be implemented per the Guide, nothing more. It is disappointing that MNRF has proposed in this EBR posting a plan that did not follow its own policy direction. This sets a very poor precedence; it says policy direction isn’t worth following.

Remoteness does not protect spawning sites nor the lake itself – those should be protected per the Stand and Site Guide as is done for all managed Crown Land. At the open house the biologist from MNR spoke of his fear of suckers getting into the lake. No prescription protects against this fear. MNRF should manage the landbase for multiple values in an adaptive management framework and should not manage for fear. The prescriptions in current policy – Stand and Site Guide - that are applied throughout the managed Crown Land of Ontario should be implemented, nothing more.

When I spoke to and MNRF person at the open house, I appreciated her time to answer my questions. When asked about this proposed prescription and what is done elsewhere, she said that this prescription was more strict for this proposed area, than what happens elsewhere on Crown Forest. The reason she said was that it is required to protect something bad from happening to these healthy brook trout populations. Fear based prescriptions are not science based prescriptions; Provincial policy is founded on sound management practices based on the best science such as the Stand and Site Guide; implement the Stand and Site Guide, nothing more, nothing less. But this management should be soley through the FMP process, not a CLUPA area.

Managing the landbase through the forest management plan process ensures review of how management actions are working on the land base- adaptive management actions. This review is done by outside auditors, as directed by MNRF, who review all aspects of management. This independent process is missing from CLUPA process; and as CLUPA is, in practice, a ‘once done’ management approach to slap a prescription on and walk away indefinitely. In CLUPA, no one independent from the situation, is responsible to go and see if the intent was even met, or if the prescription is too heavy handed. This proposal leaves no room for adaptive management. I say ‘once done’ in practice as it seems another lengthy, non-transparent and difficult process for an amendment would be needed to change area-specific land use policy.

Remoteness address the cottage owners desire to have their own park. This all started in 2006 from a ‘no-in-my-back-yard’ concern when a forest company wanted to put a road close to cottages. Having a goal of remoteness for this area is unacceptable. Especially when their back yard is Crown Land. I believe these cottage owners have over-inflated concern for brook trout to justify keeping access out. The severity of this proposed prescription does not help brook trout, it is for the cottagers to keep access farther away. Brook trout are protected per the Stand and Site Guide; not a private park. Using the CLUPA process to ensure their own private fishing and hunting area is an inappropriate use of the system, and disappointing that MNRF has catered to it for so long. Especially disappointing is that MNRF has not implemented their own policy for brook trout – i.e. Stand and Site Guide - and has addressed in this proposal managing fear, and for a few cottages private gain, rather than managing for a healthy sustainable forest.

Forest activities should be allowed to be conducted per the Stand and Site Guide in the whole area including road access. Recharge areas around spawning sites Stand and Site Guide direction should be implemented. The prescription as proposed is not acceptable and much too strict for no scientific reason. Simply implementing the Stand and Site Guide means that multiple values can be met. Simply implement the Stand and Site Guide as part of an approved FMP, with no CLUPA designation. No access or other restrictions. This area is not ‘remote’, it should be open to all; it is public land.

A last note on management. If this proposal passes it will not be because of good science, but fear based opinion type management. If it does pass, much to my disappointment, this indicates that the Province has chosen to let nature manage the area. If that is the case, the area should be excluded from any future forest fire suppression activities, if nature is defined as the manager as this proposal relegates, let fire manage it. Only fire or forest management to emulate natural disturbance maintains a healthy ecosystem.
Thank you