On page 10 you note "Ontario…

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019-3514

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54504

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FSmith Consulting

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On page 10 you note "Ontario supports implementation of sustainable forest
management practices on private woodlots through initiatives like the Managed
Forest Tax Incentive Program."
This isn't entirely accurate, and is definitely incomplete. The MFTIP program provides for Good Forestry Practices as defined by the Forestry Act, but does not necessarily provide for any direct forest management unless the author of the plan is an RPF. There is a big difference between those plans produced by an author who is an RPF and one who is not. Namely, RPF-authored plans may be prescriptive, whereas plans produced by a non-RPF author may only be descriptive of the forest resources encountered. Hence, these are Good Forestry Practices, but are not necessarily forest management as within the context of timber products such as biomass.
Further, this reference is incomplete as it does not speak to the role of RPFs in Ontario in ensuring the public good through sustainable forestry. Ontario does indeed support the implementation of sustainable forest management practices through the Ontario Professional Foresters Act, which sets out exactly this charge to the registered professionals governed by this legislation. This most definitely is something that should be referenced within a Biomass Action Plan for which Registered Professional Foresters will play a critical role in implementing and ensuring sustainability and serving the public good.
I encourage you to rethink the wording of this section as well as the omission noted here.