Please see the attached…

Please see the attached comments.

Comments on Ontario’s Draft Forest Sector Strategy Report
“A Blueprint for Success”

Thank you for the opportunity to provide comments on the Draft Forest Sector Strategy Report.
I offer the following comments and viewpoints on the Draft Ontario Forest Sector Strategy;

1. The first point that I must make is the Report provides a very one sided discussion and viewpoint on many of the very pertinent issues, concerns, etc, that affect the Forest Industry in Ontario.
2. The second point that I would make is that the Draft Forest Sector Strategy Report is lacking in details on how these objectives will be achieved.
3. A third point is that I found it very disingenuous for the Ministry to submit 5 other strategies and policy changes related to forest management and the forestry industry on the Environmental Registry at the same time at the Draft Forest Sector Strategy Report.

The decision by Minister Yakabuski to initiate the development of a Forest Sector Strategy is a very positive step. In his opening comments Minister Yakabuski states “This draft forest sector strategy is based on what we heard ...” From the content of the draft Strategy this statement appears to be factual. The problem is that the Minister appears to have only heard from a very select group. It is my understanding that many other stakeholders requested to be heard at the sessions and were denied that opportunity. I personally requested an invitation twice to attend the North Bay session. I was denied both times and the reason i was given was that there was no more room for attendees. I suggested that for an important session like this that maybe the Minister’s staff could have found a venue that provided additional room and time. To be told there is no more room at the Inn was in my opinion disrespectful, disingenuous and suggested some underlying motives. Why was there no sessions in the City of Greater Sudbury (the city in Northern Ontario with the largest population)?
In the summary of the draft there is the following “the draft strategy will support existing businesses and help create more opportunities and prosperity in northern and rural Ontario while ensuring high standards of sustainable forests.” It continues “we listened to indigenous, municipal and industry leaders, entrepreneurs and people from communities across Ontario who shared their ideas on the development of the strategy.”

It appears that the Minister was willing to hear from the Forest Industry, Scientists, Economist, etc. etc. but had no time for the other stakeholders that utilize and depend on a sustainable forest. What information, concerns, ideas, etc. did the Minister hear from the non invited Interest Groups and stakeholders from the Sudbury area? I am a member of a Local Citizen’s Committee (LCC) for the Sudbury Forest. Our mandate is outlined in the Forest Management Planning Manual. Our LCC consist of a wide range of stakeholders that represent many interest groups that have a vested interest in our forest. We participate in the development of Forest Management Plans, provide advice and recommendations to MNRF District Managers, participate in forestry field visits, participate and provide comments with respect to Independent Forest Audits. I spoke on several occasions at our LCC meeting on the Minister’s refusal to invite our Committee and the rather negative comments received from his staff. The Minister’s refusal to invite other stakeholders was an egregious error and reflects poorly on the value of a one side strategy.

Several of the Forest Industry representatives that were granted an invitation to the North Bay session have told me that the time they were allotted for comments was very short. The reason given for the limited time was that the Minister had another commitment at the North Bay Fur Barn. If as the Minister’s states in his comments that the Forest Industry is a vital and important component of Ontario’s economy would it not follow that he would take the time to hear from all stakeholders? Was the Photo Op at the North Bay Fur Barn more important that dealing with the concerns related to our crumbling Forest Industry?

Once again, in the recently announced Forest Strategy and Policy Engagement Sessions there are no sessions planned for Sudbury. Please explain how this can be considered an unbiased approach when we are not included once again. If you can spend 3 days in Timmins and North Bay certainly a fair and transparent process would have found some time for the people in Sudbury?

In the strategy’s second pillar it refers to increased forest growth and use of available wood supply. It also mentions providing wood supply certainty. These are admirable objectives however the strategy falls very short in providing how these objectives will be reached. At present the Sudbury Forest is utilizing 40 to 50 % of the available allocated harvest area (AHA). The allocation for Spruce, Pine and Fir is being utilized however the utilization of less desirable species remains a huge problem. The local producers have stated that there is no market for low grade pulp and some hardwoods. When I check into wood pellets at our local stores, the pellets come from Alberta, Maine and other areas outside Ontario. When I check local suppliers for construction lumber for my projects the FSC wood products with the lowest prices comes from New Burnswick forests.

It is my understanding that the wood supply is there and available. It is the markets that are not. Do you know how we deal with logging slash (tops and unmerchantable wood)? The answer is that we burn the slash piles, how can that be considered as an acceptable practice? The problem facing the Ontario Forest Industry is the high cost of products and lower markets. If you are producing something that no one wants or needs at a higher cost that your competitors you may want to look at your Business Plan.

The suggestion in the Strategy that Ontario is considering the return to building wooden bridges seems a bit far-fetched. The better utilization of mill by products has been an important consideration for years. We need to be working on market development plans not talking about building wooden bridges. What is our next great idea, to build wooden sailing ships to haul our wood to markets overseas?

For the past number of years the Ontario Government has been reducing the Public Sector. One of the areas that has been negatively impacted is the Ministry of Natural Resources and Forestry. The strategy suggests the growing of the talent in the Forest Sector with education and training. This must include the MNRF staffing levels. In some cases valued MNRF staff decided that there are better working conditions and opportunity in the Private Sector than with the Government. The result is that MNRF has a smaller staffing base to draw from, when they can fill these positions. In order to have a viable Forest Industry operating within the guidelines and a sustainable forest you need people.

Several years ago the Provincial Government reduced its involvement in forestry compliance. Compliance inspections and monitoring is now a responsibility of the Forest industry. If you do not have Shepherds to mind the flock the wolves will soon take over the flock.

In the Strategy there are many references to the Indigenous Sector. This is a very positive objective. The development and strengthening of Indigenous partnerships must be valued part of any Provincial Forest Strategy. What appears to be missing is how the Strategy will accomplish this lofty objective.

The five changes and strategies placed on the Environmental Register (019-1020, 019-0715, 019-1006, 019-1005, 019-0961) recommends the modernization of the forest management approval process and reducing duplication. If the Ministry is truly interested in hearing from the other stakeholders would it have not been more appropriate to listen to the input, comments, concerns, etc. from these stakeholders related to the Draft Forest Sector Strategy Report before issuing any amendments, changes, etc. This approach would seem to be a major example of the Ministry putting the cart before the horse.

I have been involved in numerous FMP processes and yes they are long and arduous. The present FMP Planning Manual was updated in 2017 and if I am not mistaken had similar guiding principles as stated above. Some of the suggested amendments proposed in EBR Registry Number 019-0715 state that changes would modernize and streamline requirements and reduce workload, time and costs in the preparation and implementation of FMP’s. All of this sounds good however recently we have seen the Government make changes to established Acts, Policies and Procedures that in my opinion provide a reduced level of protection and stewardship to Ontario’s natural resources

Are these Manuals being updated and changed based on need, good and improved science, proven cause and effects, the need for more/less consultation, stakeholders (non forestry) needs, etc, etc? The government motto “Open for Business” sounds great however there need to be some guardrails in place to provide for the protection and needs of “all” stakeholders not just the select few. Recently, in the Sudbury Forest we have seen proposals that would reduce protection for Species at Risk, smaller buffer zones, clear cutting to roadside, reduced time restrictions, etc. etc. These proposals would appear to be in conflict with the needs of the non forestry stakeholders that have a vested interest in the Sudbury Forest.

I want to thank you once again for the opportunity to comment on the Draft Forest Sector Strategy Report. If you have any questions, concerns, etc. with any of the information provided please contact me at your earliest convenience.