Comments on A Blueprint for…

Comments on A Blueprint for Success: Ontario’s Forest Sector Strategy Draft EBR Posting No. 019-0880

• I see that one of the intents of the strategy is to lower costs related to the regulatory burden and the management planning process. Based on my participation in the forest management planning process it is clear that companies only put in the minimum effort necessary to meet the planning requirements now. Poor planning effort manifests itself in a large number of plan amendments and AWS revisions almost before the ink is dry on these planning documents. Now you want to reduce regulations and water down the planning process. You might want to rethink this!

• On page 12 you highlight the things that are currently done to achieve sustainable forest management. Are you sure that you have an accurate picture of what is actually happening with respect to each of the 7 actions that you describe?
o For example, you have a rigorous forest management planning system on paper but other forest benefits don’t get a lot of consideration in the process. An example of this is wolverine habitat. The current planning process does nothing to ensure that habitat, especially for breeding females, is protected. We have also seen significant declines in other forest species such as birds, marten and moose. MNRF to date haven’t been able to prove that their approach to habitat management as part of the forest management planning process is actually working.
o The compliance program is based largely on self-compliance and reporting. I have dozens of photographs of wood that has been piled and abandoned, merchantable tree length wood left in cutovers, site damage, waste oil from machinery oil changes dumped in gravel pits and, garbage in cutovers. These compliance problems were reported to MNRF and yet very few if any show up in compliance inspections or result in charges. Then we see annual reports that tout how high compliance is!
o There currently is a well defined public consultation process but very few of the public concerns really get addressed. Take a look at the process to define the “Desired Forest and Forest Benefits”. Why not look at the Trout Lake Forest for example.

• If you want to make the forest industry more competitive you need to reduce wastage. I described wood that was cut but then abandoned as one example of this. If you look at FMP11 for the 2021-2031 plan for the Trout Lake Forest you will see that 35% of the available volume for harvest is wasted. Wastage may actually be greater than this because the company is now cutting stands that are as young as 44 years!
• While I am critical of watering down the planning process or regulations, I do agree with most of the other actions proposed in the document.