Kirsten Corrigal…

Kirsten Corrigal

Manager, Ministry of Natural Resources and Forestry

Policy Division

Crown Forests and Lands Policy Branch

Forest Legislation and Planning Section

70 Foster Drive

Suite 400

Sault Ste Marie, Ontario

P6A 6V5

Phone: (705) 945-6680

Fax: (705) 945-6667

January 23, 2017

Dear Kirsten,

RE: EBR Registry Number: 012-8685

Thank you for the opportunity to provide comments on Ontario’s “Opportunities to Enhance Carbon Storage?” discussion paper. Collectively, our organizations have long-standing interests in Ontario’s Crown forests, protecting wildlife habitat, promoting responsible recreational use, contributing thousands of hours to volunteer citizen science, and supporting sustainable economic activity. We are also strong supporters of requirements for Free, Prior and Informed Consent (FPIC) from affected Indigenous communities, and propose that emerging commercial and conservation opportunities associated with ecosystem services provision, including carbon storage, represent an important opportunity to reconcile historic inequalities in sharing natural resources. Despite our long-standing engagement on Crown forests, MNRF did not fully engage with our organizations in the development of this discussion paper. As a result, we think the Ministry is prematurely seeking broad public input on whether government-led and/or market-led initiatives should be used to increase the ability of public forests to store and sequester carbon. This is especially true given that there is no common understanding of the problem or the state of scientific knowledge upon which to assess options and to base decisions. Importantly, the integration challenges of achieving carbon policy objectives in tandem with other land use and natural resource policies / goals, particularly the necessary identification of potential trade-offs (e.g., potential conflict between mitigation versus adaptation strategies), are not identified in the discussion paper, yet should be front and centre in the public discourse. Based on our review of the forest carbon discussion paper, there are some significant weaknesses in the fundamental premises upon which the paper is based that MNRF should first address. 1.Discussion paper ignores the fact that trees do not only store carbon in wood, they store carbon as trees.

As written, the paper suggests that forest management can “reduce its [a forest’s] capacity to become a carbon source,” (pg. 10) implying that forests need to be cut before they burn or decay in response to society’s call for greenhouse gas reductions. We appreciate that “the future net balance of C emissions and removals in Canada’s boreal forest will be affected primarily by changes in forest productivity, decomposition rates and natural disturbances,” and that an increase in, for example, boreal forest fires is predicted by the end of the 21st century. Nonetheless, the underlying presupposition that forests will burn or decay anyway therefore it’s better to harvest and store the carbon is simplistic. It disregards the variability in forest species, soils, moisture, and fire cycles across the province’s public forests. Ontario’s Crown forests differ significantly in terms of fire risk and carbon storage: with fire return intervals ranging from 100 to 500 years in the northwest, 1000-5000 years in the northeast to greater than 5000 years in southern Ontario. The assumption, that cutting forests is the optimal (and only) approach to sequestering and storing carbon in a managed forest, drives the framing of management tools described in the discussion paper. (This conclusion is further conveyed by the discussion paper’s overly simplistic portrayal of the life cycle of an unmanaged forest.) Yet in Nabuurs et al. (2007) report to the IPCC, the authors suggest a range of management approaches to maintaining forest stocks, including options that maintain or increase “the landscape-level carbon density using forest conservation, longer forest rotations, fire management, and protection against insects.” These options are not explicitly identified in the discussion paper. For example, surprisingly, the document does not discuss the potential for using forest conservation as a management tool on Crown forests (e.g., examples of possible carbon offset project activities presented on p.14), despite the many co-benefits that could be achieved by including it. While forest conservation is not the only tool for carbon storage, and its efficacy depends on local conditions, to ignore its use completely suggests that MNRF is choosing a limited, ideologically driven approach – primarily, “how do we grow and cut trees faster.” The purpose of the Crown Forest Sustainability Act (1994) more broadly proposes “to manage Crown forests to meet social, economic and environmental needs of present and future generations.” This is a significant piece missing from the discussion paper.

2.Discussion paper downplays the importance of managed Crown forests in supporting wildlife species facing significant pressures in a changing climate.

All forest management objectives and strategies are interconnected. “Tweaking” management approaches, such as intensifying post-harvest regeneration and increasing salvage harvest, will undoubtedly have implications throughout the system and impact other management goals. For example, the discussion paper does not acknowledge the vulnerability of Ontario’s forest ecosystems to climate change (directly and indirectly) and subsequent impacts on other forest species. Climate change is a serious threat to terrestrial biodiversity. Species and ecosystems may be unable to keep pace with rapid climate change projected for the 21st century (e.g., most plant species can only migrate at 1/10th the required speed to match climate change). Further, northern latitudes (north of 40°) are expected to experience the greatest temperature increases due to climate change. From a global perspective, scientists estimate we’re now losing species at 1,000 to 10,000 times the natural background rate of about one to five species per year. From a provincial level perspective, climate change is thought to already be resulting in negative impacts on many species that rely on northern ecosystems (e.g., birds, moose, coldwater fish ). Further, it threatens to shrink the overall area of boreal forest, shifting it northward, upslope, and towards coastal regions. Supporting the adaptation needs for other species must be part of the discussion (e.g., the role of climate refugia and corridors must be part of a comprehensive forest management strategy in a changing climate). Carbon considered separately from other values has great potential to cause significant unintended consequences.

As stated by the IPCC (2007),

“developing the optimum regional strategies for climate change mitigation involving forests will require complex analyses of the trade-offs (synergies and competition) in land-use between forestry and other land uses, the trade-offs between forest conservation for carbon storage and other environmental services such as biodiversity and watershed conservation and sustainable forest harvesting to provide society with carbon-containing fibre, timber and bioenergy resources, and the trade-offs among utilization strategies of harvested wood products aimed at maximizing storage in long-lived products, recycling, and use for bio-energy”.

The potential trade-offs must be part of the dialogue with the public from the outset of the program.

3.Discussion paper focuses on an approach to “enhance carbon storage” (essentially a repackaging of “maximizing timber yield”) that could take us 20 years back in terms of resource management.

A singular focus on maximizing forest carbon stocks through management shares the same practical and conceptual limitations of maximizing timber yield, including:

(i)A reductionist approach to management that precludes a consideration of the complexity of the underlying biological and physical systems. For example, the outdated concept that “fires are waste,” now replaced with “fires are carbon pollution,” is implied throughout the paper.

(ii)A failure to consider large levels of natural variability which mask the effects of overexploitation, rendering it undetectable until its consequences are severe and often irreversible (e.g., species become rare, threatened or endangered). For example, time-lags in biological responses to climate change may have major consequences for natural communities in a climate-altered world.

(iii)An inherent bias, arising from the fact that wealth and the prospect of wealth generate political and social power that can be used to promote unsustainable levels of exploitation of resources. This bias narrows the range of options considered, leading primarily to solutions that are consistent with the current economic model, as seen in the limited strategies discussed in the discussion paper.

(iv)Lastly, scientific understanding and consensus are hampered by the lack of controls and replicates. There is a propensity to apply the same approaches across entire forest ecosystems. As a result, despite lip service to “adaptive management,” alternative management hypotheses are not adequately tested, and awareness of management shortfalls and unforeseen consequences take decades to determine with no alternative should they fail.

4.Discussion paper ignores uncertainty associated with carbon storage and sequestration in forests in a changing climate. While there is no doubt that managed Crown forests are an important component of carbon (C) cycling in Ontario, forest ecology is complex and the environmental drivers are changing. The discussion paper ignores uncertainties inherent in modeling future forests in a changing climate. We understand that most forest modeling suggests that the role of Canada’s forests as carbon sinks is changing. Yet, there remains significant uncertainty as to how climate change will affect both forest productivity and carbon levels. Uncertainties about the response of ecosystem carbon fluxes to changes in environmental drivers remain high, with existing process models not agreeing on the magnitude, regional distributions, and in some cases even the direction, of the net changes in carbon fluxes.

The discussion paper does not adequately consider the impacts that changes in moisture, insect infestation and disease (e.g., tree mortality), fires (including younger stands), herbivory and nitrogen levels will have on forest growth – yet many of these factors are expected to change, potentially drastically, due to climate change. The long term effects of harvesting on carbon dynamics are not well understood, especially for anything other than live biomass (e.g., belowground components, bryophytes, course woody debris, fine woody debris), and soil. Some studies have shown that management practices favoring lower harvesting frequencies and higher structural retention sequester more carbon than more intensive practices (not mentioned in the discussion paper). Other studies suggest that young forests (whether through forestry or natural disturbance) are very often conspicuous sources of CO2 because the creation of new forests frequently follows greenhouse gas emissions associated with disturbance to soil and existing vegetation that outpaces net primary production of the regrowth. Also, studies have suggested warmer temperatures and increased disturbance frequencies will likely result in a shift from conifer-dominated to deciduous-dominated stands. There are important differences between conifer and mixedwood forest in terms of how long they store carbon.

Additionally, in the discussion paper, the portrayal of the lifecycle of an unmanaged forest is overly simplistic. Not all forest types in Ontario are even-aged, and not all forest types begin to decline and die at “80-100 years”. Long fire intervals allowing for changes in canopy dominance and development of uneven-aged forests are important components of Ontario’s managed forest too, particularly in the eastern boreal forests. Take, for example, when the first cohort is replaced by shade-tolerant conifers such as balsam fir, white cedar, white spruce and black spruce. The fact that complexity even exists is not explained or represented in the discussion document.

We think the certainty communicated through the discussion paper is seriously misleading. The best way to manage forests to store carbon and to mitigate climate change is hotly debated – not only among stakeholders and forest managers, but also among scientists. Several studies have shown that uncertainties in the contemporary carbon cycle, the uncertain future impacts of climatic change and its many dynamic feedbacks can cause large variation in future carbon balance projections (see research cited above). The limited representation of the complexity of the problem we face suggests an inherent bias at the very outset of the discussion. For example, the benefit of avoiding logging of managed but previously not harvested forests is not raised within the discussion paper, despite scientific support to consider this opportunity. Many scientists think that dramatic increases in the area of forest conserved must be a vital component in any credible strategy to address the threats posed by climate change. The discussion paper also does not consider the potential for greenhouse gas reduction benefits of reducing harvesting levels.

We are concerned that the development of forest carbon policies based on these limited assumptions, especially while concealing the probability of error, and the consequences of developing policy based on erroneous assumptions, could lead to irresponsible management options.

5.Discussion paper overestimates the importance of harvested wood products by excluding many carbon emissions that result from their production

We found the lack of acknowledgement of the carbon emissions associated with the production of harvested wood products very misleading, as well. In a recent scientific publication on the greenhouse gas emissions, sequestration and storage profile of the US forest products industry, the researchers did not consider harvested wood products in isolation of the emissions associated with their production (i.e., they included the full chain including net carbon sequestration in forests, carbon stored in forest products, direct emissions from forest product manufacturing, and emissions associated with end-of-life). As a result, the US study reported a net transfer in greenhouse gas emissions into the atmosphere. In contrast, the MNRF discussion only portrays “forest carbon” – thereby highlighting the carbon benefits of harvested wood products, while ignoring the carbon costs of developing them (Fig. 1).

We understand that there is value, at least from a carbon storage perspective, to replacing more energy intensive products (such as steel) with wood products. It also seems evident that shifting industry production (and societal consumption) to a greater proportion of longer lived forest products (e.g., furniture instead of paper) would have the dual benefit of avoiding CH4 emissions from landfills, as well as increasing carbon retention in the harvested wood product carbon pool. However, processing and transportation of forest products also generate significant CO2 emissions — sometimes accounting for more than half of the total carbon footprint of forest products. Further, current research on carbon stored in harvested wood products has shown inconsistent results. For example, some research has shown they will have released most of the carbon stored after 100 years, even when wood is used for construction purposes.

By shifting the management of forest carbon to emphasize forest products, as the paper does, the discussion must also acknowledge how demand for Ontario’s forest products, and the types of products, will impact the ability of these products to achieve stores in carbon. If harvested wood products are to be considered in the carbon discussion, the full range of market factors, including the softwood lumber dispute and other trade agreements, labour and electricity costs, global economic realities, demand for newsprint, Canadian dollar and so forth need to also be discussed.

In conclusion, our organizations are committed to a thoughtful and scientifically rigorous discussion on how to address climate change and meet our GHG reduction goals, but we are concerned about some of the serious shortfalls in the discussion paper which may serve to mislead the Ontario public. We think it is critical that MNRF address the uncertainty inherent in developing carbon-focused forest management approaches and consider this issue from a systems perspective in order to avoid the development of policies that deliver no net benefits to reducing greenhouse gases in the atmosphere.

Sincerely,

Dr. Anne Bell

Director of Conservation and Education

Ontario Nature

Paul Berger

Representative

Citizens United for a Sustainable Planet

Dr. Faisal Moola, PhD

Director General

Ontario & Northern Canada

David Suzuki Foundation

Graham Saunders

President

Environment North

Shane Moffatt

Head of Forest Campaign

Greenpeace Canada

Larry McDermott

Executive Director

Plenty Canada

David Miller

Executive Director

Algonquin to Adirondacks Collaborative

Jim Johnston

President

Friends of Algoma East

Susan Moore

President

Friends of the Salmon River

Kurt Hennige

Past-president

Kingston Field NaturalistsKurt Hennige

President

Lennox & Addington Stewardship Council

George Thomson

President

Quinte Field Naturalists

Ron Prickett

President

Sault Naturalists’ Club of Ontario & Michigan

David Legge

President

Thunder Bay Field Naturalists

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[Original Comment ID: 207911]