Comments: Changes to the Forest Sector Strategy

This is a comment that was posted by SCGC board member Phil Brennan on Ontario’s Environmental Registry regarding the Forest Sector Strategy. 

In today’s world, more than ever, good forest management needs to reflect a balance between different uses and needs of the forest.  

You do not double industrial output without making provisions for education and research (we must have ecological reserves to study and compare growth with our silvicultural practices); make effective provisions for biodiversity; build into the planning process strong provisions for mitigating climate change (planting trees has limited potential and it is wiser to take care of what we have); including provisions that are supported by experts for the sustainable management of wildlife and fish; building in protections and future growth potential for tourism; effective protection of natural heritage; including strong provisions for species-at-risk (e.g. caribou habitat); and, incorporating the social needs of affected communities through transparent consultation.

Specifically, I have the following concerns:

1. The commitment to sustainability must specifically address all the points above throughout the development of the final strategy.  Window dressing is not acceptable. 
2. Any plan to reduce so-called red tape needs to specifically chart the pros and cons of the existing and proposed changes to legislation – if the Class EA for Forestry is to be replaced in whole or part – how will the new rules insure that the public has the same opportunities to affect change as in the current assessment approach. Transparency here is critical.  If there is an intention to change the ‘area of the undertaking’ this must be clearly articulated in any proposal and needs public scrutiny.
3. The pros and cons of changing from the current FRI based inventory approach need to be documented in a scientific and professional document for the public,  including the provision of clear information on the new remote sensing technology that is proposed and the manner in which it is verified on the ground. 
4. It is not at all clear how the proposal will provide for additional wood supply certainty.  That’s what the current forest planning manual and requirements has already been designed to do.  
5. While I applaud any logical efforts to increase the sustainable harvest, the challenges around this need to be more specifically articulated.  The reality is that for economic reasons we have lost pulp mills, sawmills (quality is a factor here), and board mills.  Ontario has been looking for ways to use its surplus birch and poplar supplies for decades.   Even on the private lands, particularly in Southern Ontario, the challenge is utilizing poor quality trees, not saw logs due to a long history of high grading.
6. Increasing growth potential in our forests suggests a more intensive forest management and greater utilization of lower value material on harvested sites.  This suggests spending more money on forest management and it is not at all clear where that money would come from.  On private land,  the Ontario government  walked away from more intensive forestry work under the Woodlands Improvement Act and the Forestry Act in the last two decades to save money – hard to imagine us going back to programs like that in the near future under our current budget challenges. 
7. Forest fires and insect and disease attacks, particularly in older forest tracts can be expected to have a significant impact on all uses of the forest and harvesting  and this needs to be addressed in developing new targets for the harvest in Ontario.  We must learn from the Australian situation. With these things in mind, I support the development of a rigorous and professional ‘Provincial Climate Change Impact Assessment’ and having it factored into moving forward with forest management and wood supply solutions in Ontario. 
8. The document notes that Ontario has developed its own provincial policy as an alternative to the federal output-based pricing system to reduce carbon emissions in the section on maximizing the use of mill by-products to fight climate change.  Everyone who knows anything about fighting climate change knows that the Ontario approach is very weak and expected to fail.    If Ontario wants to use climate change arguments as part of its strategy to increase industrial output, you now need to have credible experts document the proposal.  
9. The proposed Forest Sector Advisory Committee must include NGO’s that represent the interests of the non-timber industry for any strategy to be implemented properly. 

Thank you for this opportunity to comment.

Phil Brennan