This policy is the first meaningful policy to take steps to consider climate change in forest management. It is appropriate for forest health; it is noted that implementation of this policy comes with a significant cost increase to SFL holders.
The red tape is increased in approvals to use seed outside of approved areas. Timely consideration of requests is important to ensure business is not negatively impacted. This approval process also needs to consider operational and business issues that may cause a need for such a request. Also, the approval process should be clarified to specify treatment of seed for species at risk.
The mandatory direction in appendix one that "Forest Managers should deploy seed within the current geographic range of the species" is appropriate. Range expansion consideration should only be considered for approval for SAR where consistent with recovery strategies. There is no landscape policy direction for managing species rangers in light of climate change so range expansion should not be even considered for anything but SAR per recovery strategies. Management of landscape range changes effecting composition over the landbase is outside of the scope of this seed use policy that is implement by individual SFL holders or those with funding from MNRF. Managing shifting ranges needs to have a strong consultation process before any such implementation. If consultation considers managing ranges is an important step in climate considerations, then a specific policy direction that ensures a coordinated effort at the FMP planning level to ensure consistent widespread application.
Recognize that, for SFL holders, seed collection and use in practice is a 5-8 year process from collection to planting or seeding so policy implementation efforts will take many years to transition to fully meeting the intent of considering climate change as outlined in the policy.
Also recognize while transfer options are justified as minimal risk in the policy, the SFL holder implementing transfer options as proposed, from southern sources, carries the risk of increased re-fill plant or seed cost if the actual does not match policy predicted performance. FFT should consider funding such re-fill efforts.
Thank you for an enabling policy that considers climate change.
Submitted November 15, 2019 4:37 PM