Independent forest audits (IFA) are conducted every five years on all forest management units in Ontario. The IFA examine forest practises and compliance with forest management plans. Recommendations and suggestions are presented alongside background comment. Oftentimes the background discussions provide more insight into forest management than the recommendations and suggestions which are often 'modified' by Government reviewers or the industry being audited.
The following is a review of the most recent Whiskey Jack IFA. (Note: approved audits are available on the Governmnent of Ontario website along with the audit action plan and an action plan update.)
The recently completed Independent Forest Audit conducted on
the Whiskey Jack Forest by KBM Forestry Consultants is critical of forest
management in the Whiskey Jack. The
audit evidence findings, background discussions, conclusions and
recommendations describe a wide range of failings on the part of the SFL holder
and the MNR in fulfilling their obligations to manage the forest. These findings and recommendations have
significant implications for forest management in the Whiskey Jack now and into
the future. Addressing the problems
presented in the audit will require considerable investments in forest surveys,
silviculture and analysis to determine the total impacts.
Problems discussed in the audit date back as far as the
1999/04 plan term and continue to have impact through the 2004/09 term and into
the recently approved 2009/12 contingency plan.
During the most of that time the forest was managed by Abitibi. Abitibi surrendered the SFL in 2008 and since
that time the forest has been managed by the MNR, Kenora District. The MNR has assumed the role of forest
manager and is currently authoring the new FMP for the term 2012/22. To this point there has been no recognition
of liabilities associated with correcting the past mismanagement of the forest
but it is conceivable the Province of Ontario could inherit the financial costs
and long-term impacts on forest health and sustainability.
One Kenora LCC representative expressed major concerns with
the accuracy of the forest resource inventory, and the reliability of SFMM,
citing that the LCC has no expertise to satisfy them of the sustainability of
the forest and must rely on the audit.(1)
This one statement sums up all the major issues identified
by the auditors in terms of forest management planning. This is also a strong voice of support for
the audit process and its importance in ensuring MNR and the forest industry
act in the best interests of the people of Ontario in the preparation of forest
management plans.
The auditor makes 21 recommendations covering most, if not
all, aspects of forest management.
- Basic assumptions used in the 2004 strategic model
- Problems with inventory and survey data inputs
- Lack of linkages between strategic and operational silvicultural planning
- Numerous examples of poor or unacceptable silvicultural operations
Action Plans 2004 and 2009
The auditor points out that the action plan from the 2004
IFA is still outstanding. At various
times there have been indications that the action plan had been written and
possibly approved at the District Manager level but then at other times it
seems the plan simply wasn’t done. It is
important to complete and provide that plan, even though it covers an older FMP
in order to fully understand the cumulative impacts that continue to be
problematic as far as 2012 when the next FMP is scheduled for implementation.
At this point, late 2010, there is no audit action plan
available for the 2009 audit. The action
plan was a requirement. The auditees, in
this instance MNR since Abitibi is no longer involved in the forest, is
required to prepare and submit an action plan within three months of the
receipt of the final audit report. The
final audit report was sent to the Kenora LCC in early June 2010. The action plan was due in early fall 2010.
The action plan for the 2009 audit is essential, as it will
address issues that must be addressed in the new 2012/22 FMP. That FMP is approaching the time when the
public will be asked to comment on the Long Term Management Direction. The LTMD must consider the implications of
this audit and must include measures to meet the audit recommendations[2].
The ongoing lack of response to these audits is a
concern. Obviously, since issues raised
in past plans can have impacts on later plans and cumulative effects on long
term planning there is some urgency in ensuring they are addressed as quickly
as possible. The failure of those
involved to produce action plans in response to the issues raised in these
audits negates the effectiveness of the Independent Forest Audit process. As a member of the public I am concerned with
the lack of response to the audits and the problems found in management of the
Whiskey Jack Forest. The audits are in
place to ensure that the public interest in the forest has been protected.
The MNR website describes the requirements for the
Independent Forest Audit.[3]
Key Messages
There are key findings and recommendations in the audit
report that focus on the issues. In the
Executive Summary the auditor provides concise and specific conclusions based
on the examination of forest management in the Whiskey Jack[4]:
1.
‘The audit
team found significant issues with management of the Whiskey Jack Forest, both
in planning and in on-the-ground implementation of the plan. The future forest modeled during planning,
and the one associated with the selected management alternative, is
inconsistent with the natural forest as described in the forest management
plan. The differences are magnified by
the silviculture program being implemented in that the program is inconsistent
with the forest projected by the selected management alternative and is leading
the forest even further away from the natural forest condition.’
2.
‘The
regeneration methods being practiced do not support the plan goal of
maintaining current levels of spruce forest and will result in a further
departure from what is believed to be the historic forest condition of a spruce
dominated forest described in the 2009/12 Contingency Plan. The resulting forest stands will have a
greater hardwood component and lower conifer stocking than projected. This has implications for the achievement of
wildlife habitat management objectives for species that rely on the development
of conifer dominated cover types.’
3.
The
increase of hardwood at the expense of conifer is the direct result of the
absence of a tending program, beyond a small scale spacing program. This in turn is tied to the protracted
dispute with Grassy Narrows First Nation over forest management practices on
the Whiskey Jack Forest, including herbicide spraying, and decision not to
spray herbicide during the dispute. A
lack of tending was identified as a serious issue in the previous Independent
Forest Audit. Significant effort and expense
will be required to retreat or otherwise manage sites artificially regenerated
during the audit term to align them with outcomes projected in the 2004/24
Forest Management Plan. The audit team
also found that Free-to-Grow records did not accurately reflect stand
attributes; both for the regular survey program and the survey of backlog
areas, and therefore needs review.’
4.
‘Forest
sustainability, as assessed through the Independent Forest Audit Process and
Protocol, will not be achieved unless corrective measures are immediately taken
to address the following issues:
Silvicultural practices, including a lack of
tending of artificially regenerated areas, are leading to reduced stocking of
conifer and an increased component of hardwood on the Forest. This trend does not support the management
intention of maintaining a conifer dominated forest, as set out in the 2004/24
Whiskey Jack Forest FMP.’[5]
The audit team
concluded that, with the following critical exception noted below, management
of the Whiskey Jack Forest was generally in compliance with the legislation
regulations and policies that were in effect during the term covered by the
audit, and MNR met its legal obligations. Forest sustainability, as assessed
through the Independent Forest Audit Process and Protocol, will not be achieved
unless corrective measures are immediately taken to address the issues that
silviculture practices, including a lack of tending of artificially regenerated
areas, are leading to reduced stocking of conifer and an increased component of
hardwood on the Forest. This trend does not support the management intention of
maintaining a conifer dominated forest, as set out in the 2004-2024 Whiskey
Jack Forest FMP.
Recommendation
3 of this audit must be satisfied to bring the Whiskey Jack Forest into general
compliance.
ACCC has
surrendered the SFL for the Whiskey Jack Forest to the Crown; therefore the audit
team makes no recommendation on licence extension.
Although
the auditor makes no recommendation regarding license extension since Abitibi
surrendered the SFL in 2008 they do suggest a way forward for the Whiskey Jack
Forest [7].
‘The SFL holder worked for more than a year
to secure a surrender agreement. Some of
the delays were related to assessing liability for silviculture.’ ‘The
audit team believes that the process took longer than it should have. The issue of silviculture liability should
not have been a stumbling block. The records
should be up to date and MNR should move quickly to ensure harvest and renewal
programs proceed under a direct delivery model, a forest management contract or
a new license. Funds to complete forest
renewal should be sufficient if the minimum balance has been maintained.’
Grassy Narrows
The
conflict between the Province and Grassy Narrows is mentioned at a number of
locations throughout the report. The
impasse between the two parties is linked to the cancelling of the tending
program and was a contributing factor in the failure to meet the sustained wood
supply objective in the selected management alternative[8]. The auditor offers a perspective on
resolution of the impasse.
‘It is the audit team’s opinion that these
differences cannot be resolved without the Province setting aside many of the
requirements to manage the Whiskey Jack Forest under the CFSA and the FMPM, and
relinquishing significant authority to the First Nation to manage portions of
the Whiskey Jack Forest according to the desires of the GNFN community.’[9]
Strategic Planning
The
audit discusses a wide range of problems related to the development of the
Selected Management Alternative used in the 2004 FMP. Critical areas were highlighted:
- · Development of the base model (inventory shortcomings)
- · Unrealistic bounds of natural variation (20% below lowest limit)
- · Use of current forest condition as representation of natural forest
- · Absence of historic forest information
- · Lack of linkage between modeled silvicultural program and planned program (also noted in 2004 audit – not addressed)
- · Target to enhance red and white pine on the Forest will not be met.[10]
·
There was a general lack of detail in annual
report discussions, as required in the FMPM to provide perspective on the
achievement of plan objectives, something that may have highlighted problems
related to the disconnect between the SMA and the natural forest condition[11]
The cumulative impact of the shortcomings was
significant. Rather then manage the
forest to move toward a natural forest condition which was a key plan
objective, the SMA actually moved the forest further away from the natural
forest condition based on the historic forest condition. Hardwood and mixed woods were overrepresented
in the current condition following decades of extensive harvesting whereas the
natural forest was largely conifer. The
SMA, with all its shortcomings as described above led, to increasing hardwood
and mixed wood and decreasing conifer that was not consistent with the natural
forest objective.
The auditor recommends that the model be rerun at the end of
the 2004 plan term to determine to determine objective achievement[12]
as part of the final annual report. The
results of implementing the SMA from 2004, combined with other issues
identified including the FTG and Barren and Scatter surveys and silvicultural
shortcomings will have important implications for the current forest condition
used in the 2012 FMP. The legacy from
the 2004 FMP must be considered in the development of the LTMD for 2012.
Silvicultural Shortcomings
The legacy issues from the 2004 plan term extend to failings
identified in the delivery of the silvicultural program[13]. These legacy silvicultural liabilities must
be addressed in the LTMD and in planned operations in the 2012 FMP. The cost involved in assessing areas renewed
followed by site preparation; renewal and tending to address these liabilities
will be enormous. If nothing is done
forest health and composition will be affected for the foreseeable future and long-term
objectives in the 2012 FMP, including wood supply and provision of wildlife
habitat will be compromised.
- · Site preparation was often too light and spacing was too wide
- · Planting density decreased significantly from 2,000 to 1,334 per/ha
- · Lack of planting white spruce, red pine and white pine contrary to plan objectives[14]
- · Many areas that were seeded were not well stocked and will require fill plan/re-seeding. Under-stocking is mainly a result of … light and wide scarification
- · Large grassy areas (blank patches) on fine textured soils.
- · Lack of tending (22,000 ha) [15]
- · Silvicultural effectiveness monitoring found SGR standards were rarely met [16]
Inventory
Unless issues identified affecting information used in
development of the 2012 FMP including the forest resource inventory are
addressed the development of the LTMD will be no more useful than the SMA from
2004. The auditor discusses numerous
problems related to Barren and Scatter surveys, Free to Grow Surveys, and
silvicultural effectiveness monitoring.
In most cases (although not all; note issues with low stocking
identified in natural regenerated aspen) the results of these survey problems
will overestimate the amount of conifer in the current and future forest. The overestimation of conifer will affect
many plan objectives in the LTMD including wood supply, forest cover and
wildlife habitat (esp. caribou and marten).
- · Over-estimation of stocking in regular Free To Grow program. (18,000 ha)[17]
- · All areas planted and seeded during audit term must be reviewed.[18]
- · Inaccuracy of ‘calls’ in backlog survey (93,000 ha.). [19]
- · Inventory update required to correct assessment issues. [20]
General Liabilities
The forest manager for the Whiskey Jack Forest, however that
is sorted out, will face a wide variety of other liabilities identified in the
audit.
- · There is a shortage of seed in storage for the current renewal program and certainly for the enhanced program required to address the silvicultural shortcomings.[21]
- · Slash piles were left to accumulate throughout the forest after 2007 such that ‘ Slash management has been and continues to be an issue on the Forest’ [22] which will require considerable effort to map and clean up.
- · Grassy Narrows and Ontario continue to try to negotiate a settlement of the grievances raised by Grassy Narrows that led to the establishment of a blockade, still in effect today, in 2002.[23]
- · Site damage, including examples of extensive over stripping for road building, soil compaction, and drainage disturbances, all of which contribute to the loss of productive land must be addressed to restore the forest to its original productivity.
- · A complete assessment of water crossings must be completed to repair damage caused by erosion from winter water crossings and to address issues of old crossings which have failed or will fail in the future with the required follow up actions.[24]
Compliance
The auditor provides an overview of the Abitibi compliance
plan and the interaction between MNR and Abitibi in the delivery of the
compliance program.[25] The audit found that there was a program and
that for the most part it was delivered according to requirements in place at
the time.
The audit also references problems with specific elements of
the compliance program such as inconsistent compliance interpretation leading
to disagreement between Abitibi and MNR regarding compliance status. The auditor was also concerned with the high
level of ‘in-compliance’ reports submitted by Abitibi versus the ‘not in
compliance’ reports from the MNR.
Essentially, MNR reported a much higher number of not in compliance
reports against the few submitted by Abitibi.
Note that while it isn’t unusual to find more MNR non-compliance reports
than those of the industry, the auditor suggests the ratio in the audit term
was a problem.
The auditor reported on some specific site related issues.
·
Soil damage related to forest operations
resulting in lost productive land
·
Accumulations of slash piles contrary to slash
management commitments in FMP leading to further loss of productive land
Forest management plans normally include an estimate of
productive forest area lost to road construction. There are no similar estimates of losses
caused by the other factors discussed in the audit report however they might be
substantial and obviously the total lost land exceeds the conservative FMP
estimate. There will be long term
impacts on forest productivity and associated impacts from soil erosion,
damaged drainage systems and so on.
The compliance program failed to prevent these poor
practices even though the FMP included provisions to protect forest sites
during operations[29],
controls on installation and removal of winter water crossings[30]
and requirements to manage slash piles[31][32].
The total area affected and the resulting withdrawal of
productive forestland should be determined and used to further net down the
area available for forestry purposes in the 2012 FMP.
Conclusion
The MNR is within weeks (as of mid-January 2011) of
releasing the long-term management direction (LTMD) for the 2012/22 Whiskey
Jack Forest FMP. The Local Citizens
Committee was provided with a presentation by the MNR highlighting the critical
elements of the LTMD.
The LTMD appears to ignore the implications of addressing
the findings, conclusions and recommendations in the 2009 IFA. Once again, as in 2004, the plan is written
on the basis of an inventory that may include errors that are known and which
could be corrected. If in fact, for
example, the barren and scatter survey covering some 93,000 ha overestimated
conifer and overall stocking then more than 10% of the productive forest may be
misrepresented in the inventory. If the
failures in the silvicultural program including the prevalence of gaps and
holes in renewed areas, lower than anticipated stocking and errors in working
group typing then those areas further misrepresent the true condition. If the analysis isn’t done to determine the
current path of the forest into the future given the problems listed in the IFA
then it is impossible to estimate the future condition.
Clearly, the ongoing dispute with Grassy Narrows must be
resolved. The IFA provides background
and offers an opinion on a solution however there is no recognition in the LTMD
of the implications a resolution to the issue might have.
In my view, the audit findings, conclusions and
recommendations must be addressed before the LTMD is released otherwise public
confidence in the LTMD will be eroded.
[1] IFA Local Citizens Committee Page 62
[2]
IFA Recommendation #21
[3]http://www.mnr.gov.on.ca/en/Business/Forests/2ColumnSubPage/STEL02_167046.html
[4] IFA Executive Summary page ii
[5] IFA 4.6 Silvicultural page 17
[6] 2009
Independent Forest Audit Annual Provincial Action Plan
[7]
IFA 4.8 Contractual Obligations page 23
[8] IFA Page 52
[9]
IFA 4.2 Public and Aboriginal Involvement page 7
[10] IFA Page 35
[11] IFA Recommendations #19 and #20
[12]
IFA Recommendation #20
[13] IFA Page 14
[14]
Whiskey Jack FMP 2004/09 Objective #2
[15] IFA Page 15
[16] IFA Page 18
[17] IFA Page 17
[18]
IFA Recommendation #12
[19] IFA Page 17
[20] IFA Page 18
[21] IFA Page 39
[22]
IFA Page 36
[23] IFA 4.2 Public and Aboriginal Involvement
Page
[24] IFA Recommendations #15, #16 and #17
[25] IFA page 19 Compliance
[26] IFA Recommendation 16 page 42
[27] IFA Recommendation 17 page 44
[28] IFA Recommendation 15 page 41
[29]
Whiskey Jack FMP 2004/09 App. 5 Guidelines for the Protection of the Physical
Environment
[30]
Whiskey Jack FMP 2004/09 Sec. 2,4,5 Access Roads
[31] IFA (2004) Recommendation #7
[32] Whiskey Jack FMP 2004/09 Objective #4
Sustained wood Supply
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