January 23, 2017…

January 23, 2017

Kirsten Corrigal

Ministry of Natural Resources and Forestry

Crown Forests and Lands Policy Branch

70 Foster Drive, Suite 400

Sault Ste. Marie, ON P6A 6V5

705-945-6680

Re: EBR Registry Number: 012-8685 – Ontario’s Crown Forests: Opportunities to Enhance Carbon Storage? A Discussion Paper

Dear Ms. Corrigal,

EACOM appreciates the opportunity to comment on the discussion paper regarding opportunities to enhance carbon storage in Ontario. We support the position that Ontario’s forest sector can contribute to Ontario’s Climate Change Strategy and emphasize the sector’s strides in reducing greenhouse gas emissions to date, as well as the existing contribution to sequestering carbon under the robust regulatory forest management framework in the province.

We have reviewed the discussion paper and would like to provide the following comments:

•We are concerned that managing specifically for forest carbon could become a competing use and an alternate demand for Ontario’s Crown Forests. This could create shortfalls to Ontario’s SPF (spruce, pine, fir) sawmill industry.

•We are concerned that adjusting current forest policy and adding additional objectives and targets for reducing GHG emissions or increasing carbon storage to forest management plans would place additional financial and implementation burden on the forest industry. Current forest management requirements are already a major contributor to carbon sequestration efforts and adding additional targets would add to the challenge of balancing multiple uses and values across the landscape.

•We are concerned that a forest carbon policy will create potential conflicts with current Acts, such as the Crown Forest Sustainability Act and the Endangered Species Act, which could require significant time and effort to reconcile them with the new forest carbon policy.

•We expect that identifying the legal ownership of carbon emissions and offsets on managed Crown forests under a new forest carbon policy would be required, and may be a challenge.

Although outside the scope of this discussion paper, we recommend that MNRF provides support to MOECC regarding the creation of a framework that could encourage or assist private landowners in pursuing and implementing forest carbon projects on private land. There is opportunity for such projects to not only allow private landowners to get involved in contributing to carbon storage, but to gain from many other benefits that come with improved forest cover on private land (e.g. MFTIP eligibility, ecosystem services, increased property value, improved forest cover).

EACOM continues to be committed to engaging with MNRF on matters associated with the sustainable forest management framework and forest policy development. We look forward to continued discussion on this subject.

Sincerely,

Keith Ley, R.P.F

Chief Forester, Ontario

EACOM Timber Corporation

[Original Comment ID: 207897]