As the General Manager for…

As the General Manager for The Vermilion Forest Management Company Ltd., I thank you for the opportunity to comment on the revision to Ontario's forest management manuals, Environmental Registry of Ontario number 019-0715. I am writing to you today to express support for this proposal.

VFM holds the Sustainable Forest License for the Sudbury Forest Management Unit in Ontario #542442, which directly employs 10 staff by assisting 11 Forest Resource License Holders meet their forest management obligations in the Sudbury area. We also work with over 15 contractors completing a range of silviculture, forest operations and monitoring activities on an annual basis.

In general, VFM supports revisions to the forest manuals. More specifically revised manuals should:
• Emphasize on the MNRF remaining the primary on duty to consult with First Nation and Metis Communities, throughout the planning process.
• Emphasize on professional reliance, and this goes both ways, more reliance on Industry (Submission Certification) AND MNRF (Alteration Certification) RPFs during the process.
• Emphasize on reducing timelines required for review of planning stages and issue resolution process decision making by the MNRF, and stakeholders. This is supported by the addition of advance review to earlier stages of planning.
• Emphasize on the use of FIM and its technical specifications to house policy and enable responsiveness to change.
• Support to remove requirements for approval that aren’t necessary, (eg. the change of AWS to submission only – with no approval required)
• Emphasis on the importance of phase in requirements for the manuals, particularly with respect to the Silvicultural Enhancement Initiative when the working policy is ready to be implemented.

Revisions to the forest manuals should continue to focus on alignment with the Forest Sector Strategy pillar statements, as well as the partnership between forest industry and the government to manage Ontario’s crown forests.

The forest sector is an important part of Ontario’s history and critical to the future of my business and community. I would like to thank the Ontario Government and the MNRF for their leadership on this file and look forward to reviewing the finalized manuals