I support any allowances for…

ERO number

019-1006

Comment ID

44191

Commenting on behalf of

Clergue Forest Management Inc.

Comment status

Comment approved More about comment statuses

Comment

I support any allowances for extensions to the amount of time in between IFAs. I question their value overall as the MNRF provides extensive oversight of FMP development and implementation at both the district and regional levels and is generally far more qualified to assess such matters than auditors who may not even have experience in Crown forest management. Many SFLs are also audited annually by third-parties as part of forest certification programs. There is also a luck-of-the-draw element to IFAs where the scope and quantity of IFA findings, and the burden of required action plans to address IFA findings, is dependent, to a significant degree, on the auditor hired to conduct the audit, further calling into question the effectiveness of the entire program. If IFAs are going to be required into the future, then the more time between them, the better.