I fully support eliminating…

I fully support eliminating the requirement of the mid-plan check for forest management plans. As the proposal sensibly points out, plans can be amended at any time to incorporate new policy direction, as happened recently with the revised protocol for water crossing installations. If there is no reason to suspect that ongoing FMP implementation is unsustainable, then there is no need to require a make-work project to demonstrate that it is sustainable.

I also fully support eliminating or extending the 10-year expiry date on forestry aggregate pits. Some pits could be required beyond a 10-year period (such as on main primary road systems) or could be required in a subsequent FMP shortly after expiration. What benefit is served by their expiry? Especially when, in practice, it seems that new pits can simply be opened adjacent to expired pits. I have had drawn out discussions over this with district MNRF staff and when you look at the finer points of how the system works at the operational level, it's senseless.

I know this isn't a primary focus of the proposal, but it was mentioned that the latest water crossing installation protocol would be revised to reflect new requirements for project planning for water crossings. As part of reviewing the protocol, I'd also like to propose that the protocol be revised to allow for snow/winter crossings beyond simple pure snow-fill crossings. Currently, in Sault Ste. Marie district, if a plastic corrugated pipe is used in a snow-fill to allow water flow, or logs are used with a plastic culvert to prevent the snow-fill crossing from collapsing (with everything removed prior to spring freshet), then the water crossing no longer meets the criteria for being a snow-fill crossing and MNRF review is required. These are very benign water crossings, in my opinion, and should not be subject to review or elevated planning requirements.