Re: ERO# 019-0880 …

Re: ERO# 019-0880 Ontario’s Forest Sector Strategy Draft

The Ontario Maple Syrup Producers’ Association( OMSPA) is a member based organization representing close to 600 maple producers across Ontario. The Association provides information, network services, training on various aspects of the maple production cycle and represents the maple sector at various levels of government alongside resource, private and academic partners. It also provides consumers with information on the benefits of using maple products, where to obtain locally produced maple syrup, and emphasizes the high quality of maple syrup made in Ontario. The Ontario maple industry contributes well over 60 million dollars to the economy in direct and indirect benefits annually.

Observations:

Presently, most of the maple syrup produced in Ontario comes from private land. However, there are many producers who derive maple products from Crown land adjacent to or near their private operations. We are proposing that any increased allocation of sugar maple and/or red maple stands from crown land would be a strong strategic and economic advantage to Ontario. It is clear from the strategy document that Ontario is under utilizing the available harvest area in the Area of the Undertaking(AOU) by 15 million cubic metres annually, some of that are maple species particularly in the Great Lakes-St. Lawrence forest. OMSPA would suggest that an allocation of maple stands, for maple syrup production at even a small percentage, would have absolutely no effect on the long term available harvest allocation for other forest value users.

We suggest that a focus on non timber values(NTV) be incorporated into this strategy. We can’t speak for other potential edible commodities such as mushrooms and berries, but the mention of maple syrup only once under cosmetics and food reduces the economic importance of the maple industry. It appears that most of the focus in the document is geared towards the boreal forest and the potential product and economic value from that area. We will argue that on top of the 4 Expected Growth in Global Forest Products Demand in Next Decade (pg13) a fifth section on non timber value needs to be added and explored seriously.
This entire strategy should not be just about “cutting more wood” and being innovative about accomplishing that; it needs to strategically explore a more holistic approach so that small business owners in the AOU, rural communities and any aboriginal cultural and economic initiatives can benefit.

Towards Inclusion:

The maple syrup industry and its goals and objectives as a viable economic driver in rural communities, needs to be more prominent in this strategy. An Economic Benefit of the Maple Industry in Ontario study( attached) was released in 2013 and determined the maple industry contributed over $53 million to the Ontario economy. We estimate that now that has risen to well over $70 million. In a study funded by the Ministry of Agriculture, Food& Rural Affairs which explored the feasibility of a bottling plant in Northern Ontario( Feb 2018, attached), the availability of crown maple forests in the Algoma, Nipissing, French-Severn and Bancroft Minden forests were analyzed. Findings follow:

Access to maple stands on Crown land: Ontario and other provinces

In a 2013 study it was estimated that in Quebec, 11% of the 282,970 ha. of Crown land with tappable maple stands were used for maple syrup production; in New Brunswick it was 8% or 170,000 ha. In contrast only 0.04 % of the 643,273 ha. on Crown land in Ontario ( the area measured in 2011) with tappable maple stands was used for maple production. It was also estimated that if this rate was raised to 2%, an additional 1.8 million taps could be put into place. This shows the enormous potential to expand maple production by accessing Crown land in Ontario.

Maple stands on Crown land

The MNR&F provided excellent analysis and feedback for the Bottling Pant Feasibility Study in 2018. Their analysis identified blocks of Crown land in Northern Ontario suitable for producing maple syrup. Areas were ranked according to established criteria including proximity to roads, terrain characteristics, planned harvest and adjacency to private maple stands. Areas that received the highest overall ranking were Algoma, Nipissing, French-Severn and Bancroft-Minden. These are areas where there are maple syrup producers that would greatly benefit from the ability to lease small sections of crown land to augment their existing production. This would increase their production, creating jobs and boosting their economic worth sustainably and economically.

Ontario has more maple stands than Quebec
Sources- OMNR 2012 RNQ 2002, Ecoressources 2012

Culturally, Quebec has been a “sugar maker” society, much more so than Ontario, which tends to be a “logging culture”. As a result the Quebec government has put much more resources into the maple syrup industry over the last 50 years than any other maple producing state or province combined. Hence, Quebec now boasts they produce 90 % of Canada’s maple syrup; which they do. However, Ontario has the potential to dramatically increase the production of maple syrup due to its sugar maple stand statistics…both on private and crown land. The provincial tappable stands, in hectares, follows:
- Ontario: 1,325, 843
- Quebec: 620,000
- New Brunswick: 139,230

Ontario has double the maple stands than does Quebec……Ontario has the potential to dramatically benefit from the economic potential for a future growing and strong maple industry. It is time for Ontario to recognize that and put appropriate strategies in place to achieve that.

Why does what the maple industry suggest matter?:

The Ontario maple industry contributes over $70 million directly and indirectly to the Ontario economy. It is important to Ontarians culturally, economically, historically and socially. It is an excellent source of 2nd and 3 rd crop income for farmers and can be a driver for community stability and growth in rural Ontario. We would share some specific feedback from segments of the draft strategy:

The Future of Ontario’s Sector:

Putting more wood to work:
A study commissioned by the New Brunswick Natural Resource Ministry( not released) in 2012 showed that the tapping of a hectare of maple forest vs cutting it, showed longer term economic benefits to society. OMSPA suggests that tapping maple trees is sustainable for the long term and can create a more robust economic impact to local communities.

Fostering innovation, markets and talent:

The maple industry has gone through a dramatic innovative cycle in the last 10 years. Ontario producers are investing in new technology and systems. Maple equipment dealerships have more than doubled in 15 years. OMSPA commissioned a far reaching marketing strategy in 2014 that has poised Ontario to displace Quebec maple syrup in the domestic market in Ontario. Our producers are doing a better job of making quality maple syrup.

Promoting stewardship and sustainability:

OMSPA has formally endorsed third party certification for maple producers and has actively worked to educate and inform producers on mechanisms to achieve that. OMSPA has promoted the involvement in the Managed Forest Tax Incentive Program ( MFTIP) to its members as well as certification under the Forest Stewardship Council( FSC). We are, and can be, a credible partner in managing crown land assets under the direction of the respective approval permits.

Putting More Wood To Work: ( pg 18)

OMSPA supports the goals as indicated. We would emphasize that potential tapping of crown land maple stands is not a threat to the sustainability of the forests in the AOU( or private for that matter). Tapping maple trees can ensure they are present for 100 years….and if cut with tapped stained wood, can contribute to the needs of the pulp sector and for wood pellets ( which more maple producers are using by the way)

Initial Areas for Action:

We wish to comment on this section and share what we feel are issues that need to addressed in a conclusive way in this strategy.

Removing Policy Barriers to Accessing Wood

This is important to our industry. We encourage the allocation of select stands of sugar maple to producers were appropriate. While we appreciate that this paper is a higher level policy approach; we sincerely hope that the potential final document and implementation of this strategy would look favourably or partnering with the maple industry on accessing crown forests for maple syrup production.

Scenario explanation:

OMSPA members have not had huge success in accessing crown maple forests. Producers who are adjacent or close to smaller sections of crown blocks can drastically improve the “bottom line” in their profitability by accessing crown land chunks to bolster their existing operations. They just can’t afford to find a 100 acre chunk of private land to reasonably expand. Some of these parcels may be no greater than 50 acres and at times surrounded by private land. Only they can gain access…not a commercial harvester.

The field staff of MNR&F have been reluctant to entertain proposals from maple producers to access these blocks due to “ resistance from the Sustainable Forest License(SFL) holder”. Given the fact, as stated in the Forest Sector Strategy paper, that only half of the sustainable harvest allocation is actually harvested annually……is this reasonable?
And, there is disposition and rental policy in the Lands directives that allow a process for rental under a Land Use Permit( LUP). And, further, discussions with SFL Managers, specifically in the Southern Region by OMSPA, have resulted in a very open and approachable environment. The SFL mangers understand they are a component of the local societal and economic fabric…they need to be responsive to all potential beneficiaries of the Crown forest they have licenses on. We emphasize that the crown forests should be of benefit to all reasonable sectors. As such the MNR&F can and does put conditions on any potential lease rental agreement through LUP process on Crown land…not the SFL’s. It has been done and can be easily done if there was the collective will, direction and follow up.

Providing Wood Supply Certainty, Ensuring Use and Attracting New Investment:

The Ontario maple industry does not want to displace any industry, persons or investments in the utilization of crown forests. In fact, we would seek out and encourage partnerships that enhance the value and return on investment on Crown forests. For example: We have history of maple producers working with SFL’s to mark out and selectively harvest Mh stands that then allow the installation of plastic tubing pipeline for an approximate 15 year period. After that period, the stand may be ready( or may not) and the tubing has deteriorated to the point of replacement. The tubing comes down; harvester does another select or “cleaning cut” and the maple producer puts up new line. Everyone agrees and understands before hand, it is in the conditions of the permit and everyone wins. This is not complicated. Again, the Crown has the ultimate authority to set conditions.

In this section in the strategy (Pg 19), the wording clearly states: More effective and nimble mechanisms will be considered to see wood utilized and made available in a way that supports existing mills and forest operators, but that also attracts new business and new investment for under utilized wood. ( Underline ours). The document states that the Crown forests are being underutilized dramatically ( by half) annually. Would the allocation of a few thousand hectares of maple forest for maple syrup production pose such a significant risk to the overall forest industry? Are not the economic advantages of partnering with the maple syrup industry relevant and potentially significant?

Fostering Innovation, Markets and Talent ( Pg 24)

OMSPA supports the goals as outlined and will share background and rationale on 4 of the 6 goals indicated:

Redesign the business support program to modernize and innovate:

To show that the maple industry is serious about expansion, significant funding was received in 2014 to embark on an aggressive marketing and promotion strategy for Ontario Maple Syrup. This initiative saw the move towards a “ made in Ontario” approach to improve quality of production and aggressive domestic marketing to displace Quebec maple syrup on the market. The access of potential maple stands whether they are private or crown are part of that strategy.

Invest in the next generation of forestry products:

OMSPA would share that maple syrup is a “forest product”; one that is recognized as a natural plant based sugar and one that has gained huge popularity as an alternative to compound white sugar. We suggest that policies and processes for non timber forest products be reviewed and revised. It needs to be included as a component in this section of the strategy.

Increased awareness of Ontario’s forest sector and sustainable forest management:

OMSPA would argue that the maple industry was recognized by Jacque Cartier in his journals back in the old world. We tap maple trees that can reach 200 years old. New sustainable tapping guidelines are proving to sustain maple trees almost indefinitely. Many of our producers have MFTIP plans, and also have certification that promotes sustainable management of their resources. We too share the goal and can deliver on that goal.

Release a carbon calculator tool:

We would welcome this and would also add that the maple industry is working on a green strategy that would take into account responsible resource management, carbon sequestration and social responsibility for burning fossil fuels in the production of maple syrup.

Under these goals, the opening sentence for Areas for Action state that “ ….program has been designed to make Ontario open for business, deliver maximum value and create broader opportunities for businesses, taxpayers, and communites across the province ( underline ours). The maple industry wants to be part of that action. And on pg 25…. “ To accelerate commercialization of next generation forest products and technologies, Ontario will work with CRIBE, industry, indigenous communities, and other partners ( underline ours) to develop value chain roadmaps.” The maple industry wants to be included as a viable partner to achieve what is stated.

Promoting Stewardship and Sustainability:

There are goals indicated in this section for both 2022 and 2030 that are laudable and applicable for involvement by the Ontario maple industry. We believe we can be a credible partner in both managing and utilizing the forests in a sustainably responsible way. Maple operations can provide an economic benefit to small rural communities and enhance shoulder season tourism. We can be a partner in fighting climate change by recognizing the maple forests as a valuable carbon sink. We are seen as a “green industry”, one that can stand the scrutiny of any potential reviews on the proper use of our forests.

Improving Collaboration in Managing Forests:

The Ontario Maple Syrup Producers' Association supports the intent of this section in the draft strategy. We want to be a partner in working to better utilize the forests that we are privileged to have in Ontario. Our desire is to grow the maple industry in Ontario and as a result contribute to the economic growth of maple producers and the communities they engage in. We suggest that non timber forest products be more fully integrated into forest management planning and practices. The benefit to Ontario should be apparent and the partnership opportunities are endless.

Advisory Committee:

When a Forest Sector Strategy Advisory Committee is struck, the Ontario Maple Syrup Producers’ Association would appreciate the opportunity to get involved.