On behalf of the Resource…

On behalf of the Resource-Based Tourism Industry, Nature and Outdoor Tourism Ontario (NOTO) has some concerns with the proposed revisions to the Forest Manuals.

While the Forest Sector Strategy identifies the resource-based tourism industry as nothing but a stakeholder, it is important to note that tourism is one of the three largest industries in Northern Ontario. The tourism, forestry and mining industries must remain strong as these industries are what founded the north and still today, support the northern economy.

There are approximately 1100 resource-based tourism businesses and over 9,000 associated jobs. Deep in the heart of these forests lie our lodges, resorts, and remote outpost camps that attract over 1 million visitors annually from all over the world who come to relax, fish, hunt and explore our Northern wilderness. These visitors spend over $1 billion in Northern Ontario annually. 90% of these revenues remain in the region and are new dollars generated annually on a sustained basis.

Understanding the significant contributions that resource-based tourism makes annually to our northern communities and our Province, we must ensure that our forests, lakes and land base are managed properly to allow this industry to continue to exist and grow for the benefit of all in Ontario.

Concerns for Tourism Industry:

Changes to Definition of Operational Road Boundaries
This proposal refers to modifying the definition of “operational road boundary” to provide more operational flexibility and enable efficiencies for the forestry industry in the preparation and implementation of FMPs. Over the last several FMP cycles the development of Primary roads around existing tourism operations have been a challenge for many remote tourism business owners. These operations sell a remote wilderness experience that generates a higher economic return for the Province of Ontario and the northern communities. There must be a means to ensure that these types of experiences are maintained.

Without knowing how the change in definition will impact the types of access roads that will be developed in each FMP, how can we be comfortable that more primary roads will impact our remote and semi-remote tourism operations?

Roads and illegal access trails are becoming more of an issue for remote resource-based tourism operators as a result of the lack of enforcement on current forestry access roads. There are no indications as to what a new definition would look like in this proposal, nor in the Forest Sector Strategy. We are concerned that changing this definition to “allow more operational flexibility” means allowing more roads to be developed to access more harvest areas. If these roads won’t be properly decommissioned/replanted or enforced, and if proper protections aren’t in place to protect Designated Tourism Lakes, many remote tourism businesses will continue to struggle with individuals gaining access to areas previously inaccessible by road or trails leading to a loss of business and ultimately their livelihood.

The change of definition and the “flexibility” gained for the forestry industry may cause serious negative impacts on the resource-based tourism industry.

Less Oversight by MNRF Through Regulations
The guides are designed to include silvicultural practices and methods on conserving biodiversity and protecting wildlife habitat, watersheds, cultural heritage and recreation. However, with every regulatory change, MNRF appears to be stepping back from their responsibilities in the Forest Management Planning process. Sections 17 and 42 of the Crown Forest Sustainability Act were amended through the approval of Bill 132, Better for People, Smarter for Business Act which led to Annual Work Schedules no longer needing MNRF approval.

In this ERO posting, and ERO 019-0961, MNRF is greatly reducing their public consultation requirements. Bill 108: More Homes, More Choices Act led to changes to Section 18 of the Endangered Species Act which allows regulated activity to take place in areas where endangered species are found. In this proposal, MNRF is proposing to remove the requirement for the forest resource licensee and MNRF to complete a mid-plan check. The mid-plan check was used to undertake an assessment of information, changes to the land base (ex: major disturbances) or changes to policy since the approval of the FMP and determine if amendments are necessary. In the Forest Sector Strategy, MNRF continuously emphasizes that they will look into conducting applied research and monitoring and use the best available science to support the forest management planning teams.

We would like to know what mechanisms will be in place, and how MNRF will ensure proper protections are in place for not only the resource-based tourism industry, but for all the different species and their habitats, the fisheries, etc. as they continue to take steps away from their involvement in the FMP process?

In the early stages of the new FMP processes over the last several months we have seen MNRF shy away from supporting existing land use planning designations, we have seen forestry companies pushing forward with plans that include no protections for existing remote tourism businesses, we have seen plans that do not include road use plans for the public. All of this is of great concern not only to the tourism industry but to other remote recreational users on the land base.

The proposed changes to the Forest Manuals in conjunction with other changes proposed to Acts and regulations regarding forestry are of great concern for the resource-based tourism industry.

Reduction of Public Consultation Activities
We are concerned with the proposed shift to electronic communication only as many tourism operators who may be impacted by forest operations may not receive these notices when comment periods arise, or at all if they are in remote locations where internet services are limited or not available at all. Those that are in these remote settings are most likely to be impacted in some way by forestry activities and in our experience, have much to lose if they are unable to participate in the forest management planning process from its inception. We understand that it is difficult to get people to physically attend information centres based on the size of the catchment areas in the North alone but reducing the means of consultation to social media and email only may not be the answer either.

We have had a large change in ownership of tourism businesses since the last round of FMPs. For those new owners who have not been through the process before, we see a need for assistance to guide them through the process. Without the Information Centres how will they get the support they need? Will they still be offered the opportunity to meet with MNRF and forestry companies to get their questions answered?

In addition to using social media and email, we strongly recommend these notices continue to be posted on the ERO so that the tourism industry and organizations like ours may have ample opportunity to share the information and comment as the opportunities arise.

Reduction of Opportunities to Protect Tourism Values including Endangered Species
Declaration Order MNR-75 also set several planning conditions and guidelines which were included in the Forest Manuals, including additional protections and prescriptions for Areas of Concern. While we understand that Enhanced Management Areas and Moose Enhancement Areas, Designated Tourism Lakes etc. are identified and protected via CLUPA, we are concerned that exempting forestry from the Environmental Assessment Act will lead to less protections for endangered species, species at risk, and for the fisheries in regions where forestry activities occur.

The Forest Sector Strategy did not provide any information as to what type of protections we will see for areas of concern. Without Declaration Order MNR-75, what mechanisms will now be in place to ensure their sustainability? Several operators are already struggling to ensure that proper buffer zones are in place around Designated Tourism Lakes. Several operators are also struggling to maintain the level of remoteness surrounding their businesses as a result of forestry activity (specifically clear cuts) and the lack of enforcement on forestry access roads.

As an industry that promotes wilderness experiences to guests from all over the world, ensuring that healthy habitats for endangered species, moose, bear, deer, other game and small furbearing animals are maintained is of utmost importance. With the exemption of environmental assessments for forestry activities, how will endangered and non-endangered species be managed for and protected through forestry planning?

We recommend that MNRF develop and communicate a clear and uniform process to protect habitats for all species to be incorporated into the forest management planning process.

Issue Resolution
For tourism operators, in the current system, if issue resolution with MNRF and the forestry companies fail, the declaration order allows them to request an Environmental Assessment bump-up through the Director of the Ministry of Environment, Conservation and Parks (formerly MOECC). Without Declaration Order MNR-75, operators will no longer be able to request an Individual Environmental Assessment to try to find a solution where all parties are satisfied. Since EA Bump-up requests will no longer be available, it will be critical that a stronger issue resolution system is in place when conflicts are unable to be resolved in the forest planning process.

Our organization, through working with its members has participated in a number of issue resolution meetings and have noted some definite inconsistencies. A more uniform and guided approach to gathering data and evidence to best inform this process is needed.

We recommend that the current issue resolution protocols are reviewed and modified to create a more uniform and guided approach.

Strengthen and Support Resource Stewardship Agreements
These proposed changes will significantly reduce the opportunities for engagement with tourism operators. New owners in the industry need to have those one-on-one discussions with forestry companies and MNRF. The RSA process can help to fill this void. Currently, support for the development of Resource Stewardship Agreements is inconsistent from forest to forest. More support from MNRF for the RSAs is necessary to ensure the interests and values of the tourism industry are acknowledged in the FMP. These business to business agreements will nurture cooperation and respect.

MNRF should strengthen and support Resource Stewardship Agreements consistently across all forests. MNRF should support the review and updating of the current RSA Tool kit in collaboration with NOTO, and the Ministry of Heritage, Sport, Tourism and Culture Industries.

Additional Comments
In the early stages of the new FMP processes over the last several months we have seen MNRF shy away from supporting existing land use planning designations, we have seen forestry companies pushing forward with plans that include no protections for existing remote tourism businesses, we have seen plans that do not include road use plans for the public. All of this is of great concern not only to the tourism industry but to other remote recreational users on the land base.

We have deep concern that some of these changes in this and other forestry related proposals are moving land use planning away from MNRF and into the Forest Management Planning process. This approach does not provide adequate oversight nor equitable representation. Our industry provides fishing, hunting, and other outdoor recreational activities. Resident recreational users wish to have those same experiences as well. The oversight of such important and critical Provincial resources should not be governed or leaning towards a singular focus when multiple industries all have concerns, ties and dependence on those resources. Having land use planning revolve around the needs and impacts of one industry does not benefit all users of Ontario’s natural resources equitably.

There is room for both industries on the land base. We understand the lessening of burdens, in fact we (tourism industry) can relate, but we need processes in place to ensure that forestry does not diminish the resource-based tourism industry’s viability or economic contributions.