RE: Creation of the Amethyst…

RE: Creation of the Amethyst Highlands Fish and Wildlife Enhanced Management Area (ERO #013-4408)

As the planning forester at Greenmantle Forest Inc (GFI) I would like to express my concerns regarding ERO posting #013-4408: Creation of the Amethyst Highlands Fish and Wildlife Enhanced Management Area (EMA). Specifically, I would like to provide my apprehensions as they relate to the Policy Report Management Direction with respect to road construction and timber harvest on the Lakehead Forest portion of the proposed EMA.

While I am not against the creation of an Enhanced Management Area in concept, I am not in support of the spirit with which it has been created nor can I support the Management Direction as described in in the proposed Crown Land Use Policy Atlas Policy Report.

As an Ontarian, I cannot support a change in land designation that functionally prohibits well planned and considered natural resource extraction that will provide direct and indirect benefit to scores of individuals so that a few fisher-persons and camp owners can retain a back country experience. It is my experience and opinion that this proposal has been initiated by a few individuals who have had unfettered access to an area of Crown land that was relatively free from development. The perceived threat of forest management activities including road construction and harvesting has resulted in those few individuals exploiting the Land Use Planning process for their own benefit under the auspices of the protection of “… regionally unique and sustainable angling experience, as well as other back country recreational opportunities”. The relative uniqueness of this group of lakes has never been objectively established. Further, as far as I am aware, the brook trout is not an endangered species in need of such a high level of protection. It has been through sheer persistence that this group of individuals has been able to gain the support of the Thunder Bay District MNRF to pursue a change in land use designation that is so restrictive to development that it makes the economical management of Crown Forest infeasible.

With respect to resource extraction, primarily road construction, the Policy Report specifies that no new roads, winter or otherwise, are permitted within 1000 metres of “focal lakes”, nor are new roads permitted within 120 metres of “secondary lakes” and no roads are permitted at all within areas described as “groundwater recharge areas” (GWR). Hereinafter these areas will collectively be referred to as the No Roads Zone or NRZ. Once mapped, the NRZ completely severs access from the north, provides very limited access from the northwest and some possible access from the southeast and east.

Access from the southeast and east seem to be possibility based on the EMA description, however it is financially and practically not possible. Access from these directions requires access to and the crossing of private land and use of private roads, both of which carry with them a degree of uncertainty that is unacceptable for access the amount of area within the EMA as described. Even if permissions could be obtained for private land crossings, topographical constraints and values crossings such as natural gas pipelines and electrical lines, streams and rivers erode the financial and practical viability of access.

Access to the EMA can come from the northwest, north of Sprat Lake between Sprat and an un-named Lake to the southwest of Mackenzie Lake or between Sprat and Question Mark Lakes. Access to the north of Sprat Lake has significant topographical constraints and is not financially feasible or environmentally preferable. Access between Sprat and Question Mark Lakes is a viable option; however, it is far from certain. As the road heads east it would be forced into a narrow corridor between the NRZ associated the un-named Lake to the south of Mackenzie Lake and Bisect Lake. This narrow corridor is difficult to approach from the west due to steep rock drop-offs. Once beyond Moose Lake, road access could extend only another kilometer east before the NRZ and topography limit any further access. Road access could extend north for approximately one kilometre before the NRZ limits further access. Access to timber along Bisect Lake to the south is possible assuming that the road coming from the west could be constructed. In all, roads from the northwest are the only possible option and are far from certain. Even with the access options described, less than 700 hectares can be managed for forestry purposes of the approximately 7,000 hectares of the EMA within the Lakehead Forest.

During discussions with the MNRF on this topic in the spring and summer of 2018, it was made clear to the Thunder Bay District that the only viable entry point to the area being proposed by this EMA was heading south, off of Greenwich Lake Road, on an existing forestry access road north of Clegge Lake. GFI provided detailed descriptions of where and how we could access the area within the proposed EMA and made it clear that road construction near many of the “focal lakes” is necessary to adequately manage the Crown forest within. The geographic restrictions placed on road construction as described in the Policy Report make the access routes described to the MNRF impossible. Without the access point from the northwest and the ability to place roads near “focal lakes”, the area within the proposed EMA is functionally severed from forest management activities in perpetuity.

Given what I have described above, it is my position that the MNRF is not being forthright with what is and is not being permitted to occur within this EMA. It is not realistic to expect activities necessary for forest management to occur (i.e. timber harvest and road construction) given the restrictions described in the policy report as well as the surrounding topography, private land and other existing values.

Should a change in land use designation proceed, I could support an adaptive management approach that would consider the effects of road construction and timber harvest that has occurred to-date as well as the effects of wind turbine construction. Forest management plans are prepared every 10 years, I would propose that during the planning process those effects – if any – are considered and, if necessary, changes are made to the appropriate portions of the forest management plan. These changes or adjustments could include road use management strategies including road restrictions; area of concern prescriptions; or conditions on harvest operations.

Thank you for your time