As a representative for a…

As a representative for a SFL in the province - I recognize that this ERO posting covers a wide variety of proposals. So comments are in point form. I also recognize that the details for these proposals have not been developed and I urge the Ministry to consult with industry on the details of implementing these proposals so the net benefits are realized and we don't replace one reduction of red tape with an increase in a different type of red tape or a process that does not meet the needs of MNR and industry both.

1. I am in favor with streamlining efforts for forest industry on SFL licence areas. Our overlapping license agreement holders often cite burdensome and often delayed delivery of items like harvest approvals as directly and indirectly increasing costs and in some cases reducing their ability to harvest on Crown land. This is counter to the Ontario Forest Sector Strategy wherein provincially, regionally and locally we want to see an increase of utilization of the available harvest area.

2. harvest approvals are often the source of delays so streamlining this process, and allowing harvest approvals to be automatically renewed - perhaps with a different suffix number. e.g. Approval 12345 could be 12345-26 in 2026 and automatically renew to 12345-27 in 2027 and so on. These approvals also need to be able to be easily amended -e.g. addition of area from a business to business arrangement between our SFL overlapping license agreement holders or a Forest Management Plan amendment additional area etc. So hopefully the details will been enabling and i applaud the effort. Similar comments for Forest Resource Licences, mill licenses etc.

3. Single FMP - one management plan. This would be a positive opportunity for some units, especially those that have traditionally small volumes harvested and with rising costs of FMP production through mandatory spatial modelling, will be critical for some companies to remain viable while producing FMPs. However, some forests are not in a position - geographically or otherwise - to share the costs of FMP production by writing one plan. There should be some acknowledgement of that regarding expectations. e.g. currently the system requires the same FMP costs for a forest cutting 100,000m3/year as one that is cutting 1 Million m3/year.

4. Permit to Remove - This is not aimed at forest industry and i applaud efforts to better enable financial investment and revenue generation on Crown forests outside of the forest industry. However, when these activities may negatively impact the forest industry, a streamlined approach may further erode our ability to be part of discussions to minimize or mitigate. It cannot always be about merely notifying existing license holders".

A few examples
i) permits to tap maple trees on Crown land may seem harmless but tapping sugar maple trees results in staining of the wood on the bottom, most valuable log so future high quality wood supply is negatively impacted. In many or most cases, forest industry has already invested into these stands tree marking, stand improvement, removing poor quality trees following provincial silvicultural guidelines and practices and careful logging. Indirect costs of forest management planning, inventory etc all fall on the shoulders of the SFL. So for someone to come along and get fast tracked permits - or even slow tracked permits - to undo those efforts and financial investments having contributed nothing, it is a major concern. When the tapping operation is installed, infrastructure like tubes/lines for sap movement makes logging and tapping incompitble activities. At worst it means effectively losing access to portions of our SFL including areas beyond the tapping area, at best it means coordinating timing of logging with when the tapping is suspended with silvicultural and allocation scheduling likely not being in synch.

ii) roads for non-forestry purposes being fast tracked without due consideration to concerns of forest industry - e.g. a cottage road or other type of road across Crown land planned that goes through high quality forest, including areas with significant silvicultural investment. e.g. Tree marking/stand improvement etc OR, $1500/ha and 20 years invested into regeneration efforts only to see a road right away destroy not only the obvious impacted trees but also the root systems of those high quality maple trees away from the road work. SFLs need to not just be notified but be part of the review process. There are forestry requirements for some values not to have a road through a forest patch in order to meet some habitat requirement. If a non-forestry entity then puts the road there, it negatively impacts implementation of FMP and its objectives and may mean forest industry must find and work around a similar patch to replace that habitat type.

iii) we have seen groups given permits for biking trail establishment in some high valued SFL areas - including where significant time and financial investments have been made in forest management. Another forest allowed a group to get permits to basically establish a private camp site system across SFL areas - including charging camping fees and a reservation system - with those permits, significant issues have arose as users of infrastructure don't expect to see/hear forestry operations and industry ends up with a black eye plus, in some cases, be excluded from working around those spots seasonally - normally avoid summer season is recommend/required but MNR also has dozens of values identified in Stand and Site Guide for Biodiversity Conservation that also limits summer management activities.

5. Personal Use harvesting authorizations - my context here is in the Great Lakes-St. Lawrence Forest Region but comments might be more widely applied. First and foremost, need restrictions in place so people are not working on active operations as my logging community indicates they are responsible for safety incidents of individuals coming onto their forest operations (there is a history). So allowing/facilitating cutting of the most dangerous trees in the forest to fell - dead standing trees - by people with no requirement for Chainsaw certifications nor personal protective equipment PPE. In the GLSL, at least, we often leave dead standing trees to meet wildlife habitat objectives so allowing the public to come along and clear out those dead standing trees can result in stand level biodiversity objectives being compromised.

6. MICE- Manufacture in Canada Exemptions have sometimes been so painfully slow that operators lost the opportunity to realize much needed additional revenues - e.g. to access a veneer market for a very small part of their volume but that small volume can help achieve the overall financial feasibility of the harvest operation.

thanks for the opportunity to comment.