Hello, This elimination of a…

Hello,

This elimination of a the duplication of ESA is a good first step, but altogether not enough. While I trust you will continue to the huge job of working towards resolving the issues caused by the Urban control of Rural areas (issues that do not affect the day to day lives of Urban people but have profound affects Rural people) and the travesties of what the liberal government put in place, here are a few considerations:

- FMP Table 11 has tripled in size since the last FMP. While it is all great that dealing with SARS in the application of forest harvesting operations may be dealt with solely through the CFSA, it may be of little to no help until we as a society define an acceptable risk threshold/tolerance in relation to impact of SARS. Biologists will still be ever-present in the FMP process. The biology profession (with no professional oversight - other then someone else from the choir doing peer reviews, no code of conduct, and no socio-economic obligations) is the least credible profession we have in, and most insensitive to, society today. And, it is important to note, biologists livelyhoods depend on the species of their expertise being important i.e. risk = importance. The more at risk a subject species the more funding/control they can justify from/over society - it is a job security measure....they are creating a market for their services by suggesting risk to a species. Without more oversight/scrutiny of the biology profession, how can we be sure the scientific methods were disciplined enough to come to accurate conclusions about, and realistic accomodations for, risks to species.

- the latest Forest Management Planning Manual mentions the term "socio-economic" as an objective of the plan no less then 150 times, yet the current system fails terribly at defining a measurement method to see if the plan has achieved that objective.....'keeping the doors open' can't be the indicator of success. Especially in Southern Region, the FMP process requires spending excessive amounts of time/resources and money performing ridiculous tasks such as modelling the forest 100 & 1000 years out, engaging stakeholders who are disinterested and unaffected by forestry operations, and allocating blocks on largely inaccurate inventory and poor assumptions rather then on an analysis of feasibility for each cutblock (which would not be onerus). The FMP Manual is designed for large homogeneous forests in the north and through its design hand-straps smaller more complex forests in the south. One size does not fit all, and Southern Region either requires more exemptions from the Forest Management Planning Manual or a Forest Management Planning Manual of its own.

Tenure is a big issue still. The SFL model provides no incentives for SFL's to perform well, and very little ramifications for poor performance....and they all stick together, one SFL is not competing against another, forms of collusion do occur i.e. consulting eachother on setting renewal rates. SFL's performance has stagnated to lethargic.
The system caters to large:
- it is less work for SFL's to administer the harvest of one large harvest than that of a number of smaller harvests, and it is also harder to force a large company to do something - not that is it not management to administer multiple small operations, but SFL's are going to do as little as they can if given the choice.
- there is a fear factor too in controlling large companies so SFL's often take out their forest management grievances on small defenseless companies, and leave large ones alone.
- the welfare state favours large companies, again there is a fear factor, especially in SFL's like Westwind that have a 'Large Mill' Industry Board Member on their Human Resources Committee. Its not hard to see how much roads money/subsidies large companies received compared to small ones....it is well documented.
- the larger the company, generally the larger the municipal center they congregate too, visa versa with small.
- logging companies, simply due to the spread out distribution of forests will always be small business.
In conclusion, the more marginalised small companies, the more marginalised will become smaller municipal centers, the more liability the Province takes on for Villages in big financial trouble, like for example Sundridge. Need to find a way to solve that.

Loggers have been severely marginalised in Ontario, see Logging and Sawmilling Journal bi-annual survey and the article "Charting Industry Trends". Ontario loggers faired the worst across Canada. While the Province continues to leave the success of the logging industry primarily with Ontario Mills, Ontario Mills have typically done a terrible job of supplier/supply chain management. The symptom of this is most observed for suppliers that have product diversity, e.g. consider for instance hardwood forest industry. A hardwood tree may have a veneer log, then a saw log, and pulp in the top. Neither the veneer mill, the sawmill, or pulp mill takes responsibility for that supplier, and they cannot design pricing to ensure sustainability of the supplier.

Pricing plays into this. One glaring example is that log dues are charged to LOGGERS on the basis of end products like lumber, veneer, and pulp. Log markets/pricing DO NOT follow end product markets/pricing however. When residual value charges apply because of a good markets for an end product, it does not necessarily translate into log value. So when a market is hot, residual charges apply, and a logger may be getting punished for good markets.]

Land-use and access is big issue. Lands for Life Living Legacy was a hack-job done in a hurry on the basis of bad and incomplete information, and will plague the industry forever if its not fixed. Double the area could have been given up from Forest Operations Landbase with much less significant impacts had the process been well thought out. There is a huge opportunity for this Provincial Government to free up low cost wood while creating more Parks, a win-win.

I give this perspective as the Mayor of Joly Township, from 8 years on the Board of Directors for Westwind Forest Stewardship, as an active member of the French Severn LCC, having served on the 2019-29 FMP Team for the French/Severn Forest, as a Board Member on the Near North Chapter of the Ontario Woodlot Association, as a Level 2 certified tree marker, and as the owner of forest harvesting business that has survived 20 the last 20 years - my most impressive feat considering the statistics.

I have started to author a book, A Loggers Perspective of the Forest Industry in Ontario 2000-2020.