The primary ecological test…

ERO number

019-1006

Comment ID

45228

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Individual

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Comment

The primary ecological test in all forest audits is damage to an ecosystem that persists. It is in fact one of the tenets of the governments Forest Policy Framework, which is embedded in every FMP and is a regulatory requirement:

“Maintaining ecological processes is essential for the functioning of the biosphere, and biological diversity must be conserved in the use of forest ecosystems.
And
“Forest practices, including all methods of harvesting must emulate, within the bounds of silvicultural requirements, natural disturbances, and landscape patterns.

When damage from a forest activity is short term, and there are long term wildlife or productivity benefits, then the tradeoff is acceptable.

How do you get credible independent assessments of this? The interval between audits in a ten year audit cycle is too long for effective scrutiny to be brought to be appropriately addressed.

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

The five-year audit period is consistent with the adaptive management cycle identified in the FMPM. It is fundamental to showing effectiveness of prescriptions. In the 2017 FMPM this determination is to be made by the plan author and/or forest manager.

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 continue 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.

If the forest is not certified to a 3rd party system such as FSC or SFI, will there be some requirement to be one certified?

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