The interval between audits…

The interval between audits in a ten-year audit cycle is too long for effective scrutiny to be brought to the manner and extent to which issues identified in an audit have been appropriately addressed. At present, part of the IFA process is for auditors to review how issues identified in the previous audit have been addressed. For some types of issues, say poor regeneration practices, waiting 10 years to assess whether an appropriate remedy has been implemented is too long - after 10 years the issue could be more entrenched, harder to rectify, and damage to the forest could have occurred. If a ten-year audit cycle is to be implemented there should be a process by which independent scrutiny is applied prior to the 10-year interval to assess implementation of corrective measures to address issues identified as findings in the previous audit.

The 5-year audit cycle is working - There are fewer instances of audit failure now than there used to be and this is at least in part due to the IFA process. If the system is working, why tamper with it.

The five-year audit period is consistent with the adaptive management cycle identified in the FMPM in which scrutiny is brought to the extent to which sustainability of forest management is being achieved. In the 2017 FMPM this determination is to be made by the plan author and/or forest manager. There has been a comparable requirement for such determination in previous versions of the FMPM. In no circumstance has the plan author of forest manager provided an opinion that sustainability was not being achieved. This opinion has been provided even in circumstances in which the IFA program has found that sustainability was not being achieved or that critical issues existed. Given the importance of this determination, it is important that independent scrutiny continues to be used to provide objective assessment. Waiting 10 years to find that a forest is not being sustainably managed is too long and at odds with the adaptive management cycle identified in the FMPM, which requires such an assessment every five years.

The government's proposal includes an opportunity for the Minister to extend the 10-year audit period based on a number of considerations including - extension of plans, contingency plans etc; amalgamation or division of MU's, new license, balancing the number of audits.... More strikingly there needs to be identification of conditions in which the audit period should be less than ten years, including
a) If the results of the previous IFA were poor (i.e. identification of critical exceptions or a finding of non-sustainability);
b) change in tenure holder,
c) if the forest is not certified to a 3rd party system such as FSC or SFI

The proposal states that the goal is to reduce total program cost and workload for the forest industry and streamline program delivery by government "while maintaining the effectiveness of the program to ensure that Ontario's Crown forests are managed in accordance with the CFSA" The workload that companies bear to undertake IFAs occurs once every five-years. This does not seem extreme. In addition, cost for companies is slight - they do not pay out of pocket for anything other than staff time. While there is no doubt that the audits are inconvenienced (once every five years), this does not seem a sufficient basis up which to compromise the effectiveness and integrity of a program that has provided useful input into improving Ontario's forest management system.

Rather than water down the IFA, the MNRF should find opportunities to herald its success and draw attention to the improvements brought to the system through the IFA program and its findings of sustainability that the audits usually provide. MNRF has been poor at highlighting to the public and forest industry customers the good forest management that audits generally identify and the fact that the audit program exists and is an integral part of the province sustainable forest management system