Issue Resolution March 2010 (Regional Director)

Ms. Carrie Hayward March 7, 2010

Regional Director

Ministry of Natural Resources

P.O. Box 7000

4th Floor South

Peterborough, Ontario

K9J 8M5

Email: Carrie.Hayward@ontario.ca

RE: EBR Registry Number: 010-2809

Forest Management Plan for the Algonquin Park Forest for the 10-year period April 1, 2010 to March 31, 2020 – Review of Draft Plan

Dear Ms Hayward:

I met with Mr. Winters and team on January 26, 2010. I received Mr. Winter’s response on February 8th. Although I am pleased to note Mr Winter’s commitment for improved road density management strategies, at this stage, details have not been formalized by him, so I can’t comment either way. Accepting the outcome remains “to be determined”, at present, Mr Winters was not able to mitigate any of my issues relating to road density.

The remaining issues related to SFMM modelling, natural benchmark and Management Alternative projections, increased fibre volumes, economic motivations and old growth preservation remain unresolved. Although I appreciated the insights from the planning team provided on January 26, 2010, which provided some clarification of FMP terminology, my concerns relating to the accuracy of the plan’s management alternative and natural benchmark projections relating to SFMM modelling remain, and nothing has been presented in Mr Winter’s response to mitigate them.

As I indicated to Mr Winters on January 26th, 2010, the SFMM natural benchmark and resultant management alternative (PMS 7.1) are predicating assumptions which affect all other plan outcomes, so although the issues contained within this narrative are compartmentalized into four sections for discussion purposes, there is one common and systemic problem: By accepting this plan, I am being asked to make concessions which translate into long term habitat loss for featured species such as the Pileated Woodpecker, American Marten and Moose due to unsustainable, scientifically unsupported, and factually inaccurate yield projections which will affect the entire forest, but materially impact hemlock (a 62% increase in sawlog fibre volumes over 2005), white birch (a 42% increase in sawlog fibre volumes over 2005) and poplar (23% increase). Previous moratoriums on hemlock harvest in APP as recently as the 1990’s remind us of the precarious state of our forest, and why the 2010-2020 plan must scale back hemlock harvest quotas to mitigate this species poor regeneration which is directly attributable to the combined effect of moose browse of young saplings and decades of harvesting mature canopy trees. Add to this the published calcium-loss papers from Shaun Watmough at Trent University which build a strong case that acid deposition and repeated timber harvesting are seriously depleting soil calcium reserves that could lead ultimately to a net zero timber growth rate in granitic areas such as the western Algonquin uplands. This research raises more doubt to the viability and credibility of the plan`s yield curve assumptions which simply put assert trees are bigger than previously estimated and therefore, more aggressive targets can be achieved without harvesting more trees. Shaun`s research also emphasizes the impacts harvesting has on lakes, quote: Harvesting clearly has an enormous potential impact on lake chemistry, which will become more apparent as exchangeable base cation pools in soil decline and acid inputs can no longer be buffered.

Recognizing Algonquin is Ontario’s premiere provincial park, where over 1,000,000 visitors travel each year to experience nature, wildlife, and solitude, I find it deplorable that the Ontario government has chosen to eviscerate this wilderness park for some financial gain. In keeping with the Ontario Parks act, I expect the mandate of all provincial parks to be first and foremost an ecological one, where no special interest group is given priority; rather the park’s ecological needs are put first. I therefore ask for your help in resolving what remain as serious errors in plan methodology, judgement and approach and formally request escalation for issue resolution.

I have updated my original issue resolution document submitted on January 13th. Updates from Mr. Winter’s Feb 8, 2010 Issue Resolution Response are tracked in red, my updates as of March 8, 2010 are highlighted in blue.

Cc: Mr. John Winters, District Manager, Algonquin Provincial Park

Attachments:

Appendix A – Mill Commitment by Species, sawlogs and poles

Appendix B -- Forest Roads and Forest Edges

Appendix C – Spatial Modeling – University of Toronto Paper

Appendix D – Shaun Watmough Papers (6)

Issue #1: Road Density in APP

Quote from FMP Plan Text:

The dominant logging system in the 1970s and 1980s was: fell with chain saw; skid tree length by wheeled skidder distances of 150 - 450 metres to central landings; cut, sort, and pile the products and then load and haul using trailer type trucks for distances of 42 – 210 kilometres.

Although the above-mentioned system is still used to a certain extent, the primary method now is to cut and skid to small landings, and haul tree lengths to central landings where products are manufactured. This process allows for better recovery of the more valuable forest products, provides more flexibility in haul schedules and, more importantly, reduces the amount of area required for landings in the bush. The manufacturing of treelength at central landings or yards is used for about 75% of the wood cut in Algonquin Provincial Park. For the most part these landings are located outside Algonquin Provincial Park.

Issue: The plan implies creating small landings closer to the area of operation will result in reduction of central landings in the bush. But what the plan does not mention is that in order to create more small landings, the harvester needs to create more roads to access wood. The impact a pervasive road network creates is not quantified in the plan. Nor is the plan’s assertion that more roads justify more small landings.

[Mr. Winters Issue Resolution response: “This system does not require a higher road density than previous harvest/haul systems.”]

Please provide the specific evidence to support this assertion. I find nothing in your plan that supports this assertion – no benchmark or scientific measure exists. What is stipulated in the 2010-2020 plan is the fact that reduced hauling by skidder favours improved sawlog quality –this is no doubt true. However, the ecological impacts of increased tertiary road density remain unresolved, unanswered. .

[Mr Winter’s Issue Resolution response: Road density indicators have been included in FMP-13 – this is a requirement –benchmarks have been established (plan start levels) as well as future desired levels/targets.]

FMP 13 provides the following benchmarks as it relates to road densities, and future levels:

Management Objective #1: Complete operating unit (OPU) forest management operations in the shortest time possible, and remove roads from active service following the completion of forestry operations harvest,renewal and tending). Implement access controls (water crossing remove

Indicator: Kilometres of passable road per km2 of forest (calculated from existing roads map)

Plan Start Level: 0.43 km/km2

Desired level: Consistent with plan start levels

Target: < 0.5 km/km2

This is, as I stated in my initial resolution document, circular logic – your desired level is your plan level and your target exceeds your plan which means no improvement is required or even acknowledged to be necessary. Notwithstanding the meaningless and subjective nature of the targets, the plan start level is based on FRI (which includes roads) and this has not be fully updated in over 20 years (aging tree inventory using planning algorithms does not qualify as a data update).

Management Objective #2: Minimize aggregate use during road construction and maintenance activities

Indicator (a): Tonnes of aggregate used per kilometres of road constructed/maintained (total)

Plan Start Level: N/A

Desirable Level: Stable or decreasing trend over time

Target (How much and When): Stable or decreasing trend over time

Management Objective #2: Minimize aggregate use during road construction and maintenance activities

Indicator (b): Road Density (km of gravel road/km2 of forest)

Plan Start Level: .95 km/km2

Desirable Level: Consistent with plan start levels

Target (How much and When) :< 1.0 km/km2

The planning team has completed a required template with nonsensical data. Road aggregate is planned for “stable or decreasing over time” based on a starting point of “N/A”. How exactly does this mitigate anything?

Indicator B is again without any context, or criteria. We have no ability to measure whether .95 km/km2 is reasonable, excessive, or even accurate and yet we are told the desirable level is (conveniently) .95 km/km2 and that the target is actually set higher than the desirable level. This is a plan engineered to meet no known standards, instead it gives absolute power and latitude to the AFA to increase roads as they see fit.

[Mr. Winter’s Issue Resolution Response: It is our goal to reduce the amount of roads within Species at Risk habitat and Brook Trout Lake areas of concern – two key values in Algonquin Park.]

If indeed it is your goal to reduce roads, as evidenced above in FMP-13, your plan, as currently written, is not congruent with this outcome. Logically, with no planned reduction in roads below current “desirable” plan levels, one of two things must happen:

- your goal is not supported with quantifiable targets and your plan must be re-done to support it; or

- you intend to reduce some roads with no clear mandate as to how much, where, what priorities, and why, near some lakes and some Species at Risk habitat (which we know is already protected by various prescriptions and AOC and marginally afforded under the LTFP recommendations), but with an FMP-13 target of “current levels” the benefits of any increased road reductions in these areas will be lost with new roads added in other areas – the net result is no change on total km of roads.

To mitigate the above issues, I have expanded on my recommendations (below in this section).

[Mr Winter’s Issue Resolution Response: To address concerns related to road quality and density I will pursue an independent review of road standards, aggregate usage and road construction practices in Algonquin Park. An independent consultant will be retained. The Final FMP will include text describing that this will be undertaken and that results of the independent review will be added as appropriate to the FMP as standards to be followed.

The 2006 Provincial Parks and Conservation Reserves Act includes a requirement that there must be a ‘demonstrated need’ for aggregate. All requests for aggregate pits will be reviewed based on this direction.

I am pleased some independent study is being planned for. However, to make any difference, there must be immediate and quantifiable improvements to both data quality and guiding principles of the plan which are manifest in FMP-13, or this review is a guarantee of nothing.

I will expand on this point for clarity: A fundamental strategy in any planning document is to develop the plan at both a macro and micro level of detail. Planning at the lowest level of detail (such as buffers, reserves by lakes, habitat restrictions etc) is at minimum required, and expected, and an attempt to document much of this has been done in the FMP as evidenced by current maps showing primary and secondary roads, road lists (name, location), provincial park act guidelines for road right of ways, basic AOC prescriptions relating to road construction, etc. This documentation is necessary to establish planning tactics which are subsequently executed through daily operational activities such as culvert and bridge removals.

However, in order to evaluate the impacts a collective road network that exceeds several thousand kilometres has on the environment as a whole, and to ensure all future road decisions are made within the context of how much we have now, what state they are in (rehabilitated, decommissioned, active) and when is one more road is too many, the road restrictions cited by the planning team which include those restrictions constrained through AOC, reserve, LTFP, or the Provincial Parks act must be translated into quantifiable and meaningful strategic measures and benchmarked against known standards in FMP-13.

As FMP-13 is currently meaningless, the plan has no framework for informed decision making, the indicators are either not available, or subjective, or circular, and the outcome is left in the hands of an entity that has a bias for profit at the expense of the environment. The net result is the park management team (Mr. Winter’s team) is ill-equipped to make any informed decision on AWS tertiary roads.

SUMMARY: To even begin to mitigate my issues, the stated objective of this independent review must be to materially and quantifiably expand and improve upon FMP-13 specifically as it relates to road densities; once done, Mr. Winter’s team must be afforded increased authority to monitor, review and investigate all road related requests. I have expanded on my recommendations (below) to offer examples.

Implications: The current method of hauling tree lengths to central landings requires extensive tertiary roads which are not published during Stage 4 (Draft Plan) for public review, rather they are proposed by the AFA as part of the Annual work schedule which is prepared after final plan approval and are approved subject to APP Park forester review. In discussions with the Park Forester, the only measure of approval I discerned was used by the planning team to determine whether a road was justified in preparation of the AWS was whether or not the road provided access to areas of future planned operation. I found this point to be moot, and frankly would expect the Park not approve roads simply for the sake of building them.

Equally uninformative is FMP 13 “Management objectives” which provides a variety of “measures” such as road density and km per road, and even subjective measures such as “Minimize aggregate use during road construction and maintenance activities”, as well as “Tonnes of aggregate used per kilometres of road constructed/maintained (total)”, and “Road Density (km of gravel road/km2 of forest).

I see these “measures” listed, but I cannot find any actual benchmark or indicator that compares what is acceptable vs what is planned for.

Recommendations:

1. Benchmarks such as “km/road” and “road density” should be presented with adequate context. A good set of criteria with related definitions is required to guide the development and evaluation of ecological benchmarks. For example:

- percent forest land-cover, forest patch density, landscape Shannon's Diversity Index, proportion of all streams with roads within 30 m, proportion of area that has changed, current, past, and planned road density and % change, proportion of all streams and bodies of water with adjacent roads vs the proportion of all streams with adjacent forest cover.

[ Mr. Winter’s Response: The specific examples you provide are either not applicable or information is not available.

What exactly is not applicable? You concede elements of patch density analysis is used in old growth and in your wildlife habitat modeling (Mr. Winter’s Response: Note that spatial modeling is used in this FMP to measure old growth and wildlife habitat metrics, specifically comparing plan start -2010 to plan end levels -2020.) To be factual, while it is true that spatial modelling is used, it is used for only a few species and a small portion of the FMP. In any case, are you saying that you don’t think its important to compare the proportion of bodies of water with adjacent roads vs. proportion of all streams with adjacent forest cover or that you don’t know how to do it?

Without further amplification, it appears I am being asked to accept no attempt will be made to monitor the ecological impacts increasing road densities have on the park because the planning team lacks technical knowledge, skill, software, and data necessary to perform an analysis at the level of expertise commensurate of their accountability in development of a forest management plan that will irrevocably and to our detriment, impact the environment we all share.

Attached is a link to an analysis done using the Shannon Diversity Index on an ant population in the rainforest. http://www.tiem.utk.edu/~mbeals/shannonDI.html

The analysis states their objective:

The following table contains data from a study of Costa Rican ant diversity (Roth et al. 1994). The authors measured diversity in four different habitats ranging very low levels of human disturbance (primary rain forest) to very high levels of human disturbance (banana plantations) to assess the impacts of different levels of disturbance on biological diversity.

Its interpretation and conclusion:

Interpretation: We can see from our results that the diversity and evenness in this site from the undisturbed habitat (primary rain forest) are much higher than in the site from the highly disturbed habitat (banana plantation). The primary rain forest not only has a greater number of species present, but the individuals in the community are distributed more equitably among these species. In the banana plantation there are 23 fewer species and over 80% of the individuals belong to one species, Solenopsis geminata (the most common species in the primary rain forest, on the other hand, makes up about 16% of the community [Pheidole sp. 15]).

Conclusions: Different levels of disturbance have different effects on ant diversity. If our goal is to preserve biodiversity in a given area, we need to be able to understand how diversity is impacted by different management strategies. Because diversity indices provide more information than simply the number of species present (i.e., they account for some species being rare and others being common), they serve as valuable tools that enable biologists to quantify diversity in a community and describe its numerical structure.

I have underlined the salient point. Digging through the 2005 Algonquin Forest Unit Plan, I see the Shannon Index was used to chart forest diversity.  Please explain why this methodology is not relevant or used as part of FMP-13 in the context of roads and their ecological impacts?

1. Benchmarks should be directly linked with ecological implications: There should be a direct link between the benchmark and ecological implications of the project (e.g. road density as an indicator of habitat fragmentation and influence on the pattern and health of a given wildlife species.

[Mr Winters Response:  The linkage between forest access roads and ecological benchmarks has not been made.  Most of the available research on ecological impacts of roads relates to highways and paved roads, not forest access roads through continuous forest cover.  In the future as information becomes available we will use that best information.]

Appendix B is attached.  This 2008 study “Forest Roads and Forest Edges:  Their Impact on Forest Interior Birds of Algonquin Provincial Park– I quote:

There has been extensive research on the impact of forest fragmentation and forest edges on populations of

breeding birds. Many studies have focused on such factors as changes in the amounts of predation,

parasitism, and invertebrate prey within specified distances of forest edges. A literature search on these

topics was undertaken in this project, and the studies most relevant to the forest breeding birds of

Algonquin Park are included in the References section of this report. Fortunately, several meta-analyses of

studies concerning the impact of forest fragments and forest edges have been undertaken and published,

which allow for a more comprehensive assessment of these significance of these factors on forest breeding

birds.

Algonquin has been the source of considerable study for decades, and we know that birds are an indicator of forest health and biodiversity.  It is simply not true to state there is no information –  as this study states, there is a plethora of data and research available.  What is true is that the planning team has made no attempt to correlate this knowledge into meaningful benchmarks and indicators within the ecological context of road management and human disturbance at Algonquin Provincial Park, and express these values in FMP-13.

2. Satellite imagery and geo spatial software must be used to visually track and measure “outside plant” inventory. I would expect the Ministry to employ satellite imagery as a means to explore environmental variables over a larger area. An ecological assessment tool capable of cluster analysis should be used to combine the above noted variables into different groups, and resulting clusters compared to site data, which taken together can be used to rank all areas according to degree of environmental impact.   Current measures are meaningless unless they are considered within a context of cause and effect.

     

[Mr. Winters Response:  It is unclear what is meant by “outside plant” inventory and your text following this recommendation.  Satellite imagery with the necessary resolution to detect ecological trends in continuous forest cover landscapes is emerging but not cost effective at this point in time.  However, our goal is to use remote imagery and other new tools as they become available in the future.]

Outside plant inventory refers to any asset that is “outside a plant” – in other words, not in a building.  In the context of forest management, assets would include roads, and trees, and aggregate pits. 

Cluster analysis refers to the collection and compilation of assets into “like” groupings, which can then be analysed, prioritised and compared against each other, and against actual on-site evaluation done through field visits.   This type of statistical analysis bridges operational activities (what you do) with field visits (what you see) with statistical computation to monitor your activities and ensure they are congruent with your plan directives or mandates (ie “our goal is to reduce the need for more roads”) – its decisive, flexible and capable of adaptation as new information becomes available.   

Cluster analysis is another word for “patch” – for example:

In the simplified case of a landscape with only two land cover types, the landscape can be characterised by (Patil et al, 1998):

o        proportion of each land cover type

o        aggregation into patches (shape), 

o        distribution of patch size 

o        spatial distribution of patches(clustered or dispersed)

As stated earlier, your response of February 8^th indicates that patch density analysis was used for (elements) of old growth and habitat analysis, so these concepts are known to you, the question is why aren’t you using them?

I agree remote sensing can provide valuable information on land cover. Landscape indicators can be computed on classified satellite images (Patil and Taillie, 1999). However it was noted that the choice of the classification algorithm or the application of filters (Lillesand et Kiefer, 1999) can substantially modify the values of landscape indicators. Comparisons between diversity indicators can be considered objective when the area under study is small enough to fit in a single satellite image and the same automatic procedure is used for different areas or the same area in different dates (Chuvieco, 1999). Photo-interpretation of satellite images from different dates on the same area can provide valuable information on land use changes to analyse the impact of spatial policies (Smits and Annoni, 1999).

I don’t profess specific expertise in Forest Management cluster analysis– but what is far more worrisome is based on Mr Winter’s response, neither does the planning team.  Stating we don’t know, or don’t have, or will try to get equates to asking for my concurrence to accept the planning teams’ lowest level of mediocrity, in spite of the fact technologies are available now, either nationally or internationally that would materially influence and in many cases change planning outcomes.   Cost effectiveness is highly debatable when the consequences of environmental degradation to water, air and land are factored into society’s cost to maintain health and safety.  

Outside of Mr. Winter’s desire to improve road density management, and pledge to investigate this more thoroughly through an independent consultant review, I am left with Mr. Winter’s well intentioned but ultimately weak assurances that we will “do the best we can” when information and technology becomes available.  This is not an acceptable solution and does not mitigate anything, however, I can make the following recommendation (similar to the modelling recommendation) which is in the absence of best practice, spatial modelling tools, and peer reviewed science, approach road building with caution.  Since tertiary roads are tied to fibre quotas, reduce fibre quotas for 2010 to 2005 planned levels until accurate forecasting tools are in place, the consultant’s independent review has been completed and FMP-13 is updated with meaningful indicators, targets, and measures. 

ISSUE #2:  SFMM MODELLING AND YIELD COMPARISONS 2005 vs 2010

The modelling of the natural benchmark and PMS7.1 management alternative is the most contentious and questionable aspect of the entire plan.  Although I am respectful of the effort put forth by the planning team and do not trivialize their effort, if there was one reason to cast doubt on the validity of a plan, this is it. 

Issue:  The 2010 Plan is not sustainable and will result in material habitat loss for all featured species, with huge losses of habitat for Marten. The 2010 yield assumptions cannot be validated and are not sustainable. The 2010 habitat projections (PMS 7.1) which reflect harvesting impacts by species, contradict yield assumptions.  The planning team’s assertion that increased yields will not result in more trees harvested over 2005 is unfounded and wrong.  The plan is flawed and must be re-done.

Implications:  The Pileated Woodpecker, American Marten and Moose are three examples which show habitat and yield forecasts between 2005 & 2010 as contradictory and materially divergent natural benchmark projections.

[Mr Winter’s Response:  The difference in the habitat level projections for the natural benchmark is the result of a modified approach to modeling the natural benchmark in 2010 compared to 2005. The modeling approach for the 2010 management strategy is the same as 2005. The difference in the habitat projections between the 2005 selected management alternative and the 2010 proposed management strategy are a result of modifications to the harvest strategy.  Longer term projected habitat losses in the natural benchmark run are caused by natural disturbance while losses in the proposed management strategy run are the result of harvesting.]

Different harvest strategy?  What exactly is different?  Birch and poplar are still shade intolerant species.  How are you harvesting birch and poplar?  According to Gord Cummings as reiterated in the minutes of our Jan 26, 2010 meeting, “the same number of trees is expected to be harvested but the volume expectation from those trees has been reconciled up based on annual report information and more recent growth and yield data.”  In other words, you claim you underestimated the size of a given tree in a plot, such that no more trees will be harvested over 2005

[Mr. Winters Response:  Note that the natural benchmark modeling and yields are not related]  Agreed, but the natural benchmark is the baseline used in the plan to determine acceptable levels of habitat loss as a result of harvesting, and therefore, its accuracy is critical.  Furthermore, the impacts harvesting has on wildlife habitat is expressed in your management alternative, and since the harvest is the activity that produces fibre, the management strategy implicitly equates to yield, and that has been my point.   My issue remains:  the management strategy represented conceptually in habitat graphs does not correspond to the fibre volumes (yields) planned as an output to harvesting.

The 2005 data was taken directly from the 2005 Forest Management Plan.  Your planning team analyst (Norm Cottam) advised me on January 26, 2010 that the above graph was depicted correctly.

Comparing management strategies between 2005 and 2010 - The above graph depicts greater habitat availability for the Pileated Woodpecker in 2010 over 2005 – approximately 50,000 ha more of habitat is available to the Pileated woodpecker in 2010 at T3 &T4, reduced to approximately 40,000 ha more at (T5) and then the two management strategies converge around T8

According to your plan, Pileated Woodpecker habitat is reliant on the following ecosites:  11-14 (White and Red Pine); 16-26 (Intolerant and Tolerant Hardwoods including white birch, poplar and Jack Pine) and 33-34, Lowland Confir.  With the exception of Jack Pine and lowland conifer (which makes up ~5% of the total park), all other species fibre volumes are increasing over 2005 with White Birch sawlog increasing 42% and Poplar (pulp) 23%.

Mr. Winter’s Response: Changes in the term 1 level of habitat for pileated woodpecker between the 2005 FMP and the 2010 FMP plan are a result of updating the forest resource inventory.  These changes account for harvesting and natural disturbances that occurred in the 2005 plan. 

So, what you are stating is that the initial starting point is lower – we have less trees in 2010 than in 2005 because of harvesting, and this has resulted in the natural benchmark being “stepped down” at T1.

If we agree that:

-          harvesting in the past 5 years has reduced the total number of trees available for harvest in 2010

-          the natural benchmark is the baseline used to project how the forest would appear over time in the absence of harvest, and is therefore critical in the determination of acceptable habitat losses, and that;

-          harvesting results in habitat loss which is conceptually represented by the graph as a management alternative;  and that

-          fibre is the commodity procured through the activity of harvesting, and the fibre volumes have materially increased in 2010 vs 2005.

Then why is the habitat for the Pileated woodpecker greater in 2010 (PMS 7..1)  when there is an even smaller starting inventory of total trees and your plan projects an even higher fibre volume for birch, poplar and white pine (among others) ?  If you are actually claiming those birch, poplar and white pine trees are bigger than you thought, please provide explicit rationale for basal area, annual harvest area and residual basal area to explain your assumptions. 

Mr. Winters Response:  They also reflect updates to forest unit and stage-of-management (for shelterwood harvest) classifications directly influencing the amount of pileated woodpecker measured in the inventory.

Is this how you explain a materially divergent natural benchmark that projects 50,000 more ha in T5?  Are you stating your 2005 Natural Benchmark was wrong as was acknowledged by Joe Yarscaravitch in our January 26, 2010 meeting?

Please provide evidence of SFMM model changes by providing how many white birch, white pine, red pine, and poplar trees does your plan assert will be cut in 2010 and how does that compare to your 2005 forecast? Please break that out by species, age class, and size (pole, sawlog,)

The below paragraph was extrapolated from Moose Winter cover habitat (MOOSw M, L, U 16, 22, 30, 33, 34)

Please explain the following statement:

Moose winter habitat > 45,000 hectares. This target has been reduced from the last plan (88,310 hectares) to correspond with changes in the wildlife habitat matrix in SFMM. The new matrix is producing approximately 50% of the preferred habitat compared to the old matrix. The new target has been reduced accordingly \INSERT MOOSE WINTER GRAPH

 

Your plan states:  SFMM analysis does show a 5,000 hectare decrease in winter habitat over the next 30 years; however this is within the accepted bounds of sustainability

If you are cutting the same number of trees (as you claim is the rationale for your yield curve assumptions), with the same starting inventory as 2005, why is the Moose Winter habitat changing?   We know hemlock is the preferred cover species for moose, and given 62% increase in hemlock sawlog, how do you account for the increased habitat predictions (PMS 7.1) vs 2005 SMA.

Above is Moose Foraging – again, comparison of 2005 vs 2010 plan model has been done.   Directly from your plan you state:

Forest management undoubtedly creates forage and browse for moose. This is reflected both in the SFMM modelling for moose foraging areas as well as on the ground. Moose surveys in recently harvested areas of Algonquin often yield high numbers of moose. The SFMM modelling for moose forage indicates substantially higher levels of forage with forest management when compared to the natural benchmark run.

Conifer cover, which is particularly important for moose in the winter, is maintained within 75% of the natural benchmark.   Analysis of the Algonquin landscape using the Ontario Wildlife Habitat Assessment Model
(OWHAM), a spatial analysis of suitable habitat types, indicates high levels of suitable habitat for moose throughout the park. According to OWHAM, even the poorer areas of Algonquin Park can still support healthy and robust moose densities.

Forest management can also lead to greater exploitation and higher success rates during the hunting season by opening up previously inaccessible areas to vehicular traffic. Moose in hunted areas often avoid linear features such as roads – thus road density is often negatively associated with the health of the moose herd.

Its worth noting that your own plan states an ecological relationship between road density and moose herd populations, and yet your FMP-13 for Road density ignores this.  But I digress.  Regarding your hypothesis for moose foraging, I obtained my own local opinion from Mike Wilton, a former MNR biologist and co-founder of Eco Watch.  His feedback:

Interestingly, prior to the native hunt, when no moose were being legally harvested in the Park, the moose population on the west side, where the preferred timber harvest is selection, was higher than on the east side, where uniform shelterwood prevails.  Since selection seeks to retain shade for shade-tolerant species regeneration and since uniform shelterwood opens up the canopy, thus encouraging more regeneration, there will/must be more foraging potential in the east, where the population has been lowest, than in the west, where the population has always been highest (this can be verified from survey data).

The 2005 natural benchmark implies that the moose population will crash with no human intervention (management).  The 2010 natural benchmark says basically the same thing. 

To summarize:  even with less forage per hectare available due to timber harvesting methods in the west, the moose population is higher than the east, where more forage per hectare is available.  To imply that zero management will cause a catastrophic decline in available forage contradicts existing moose management knowledge. Further, to imply that timber  will dramatically increase moose numbers as a result of increased available forage (utilizing the selection system) contradicts the higher population of moose within areas where, I believe, selection harvesting would theoretically keep them at a lower level (than areas utilizing the uniform shelterwood harvest system).  Finally, available forage (food) has never been identified as a limiting factor in moose populations.  Any moose population fluctuations in Algonquin Park, subsequent to the major deer die-off in the 1960's and '70's, have always been the result of a winter tick (a small but deadly ecto-parasite) infestation. This too is well documented in the literature..

Given the above along with the decision to model hemlock as selection in the plan (which actually creates less forage) please explain the below statement:

The SFMM modelling for moose forage indicates substantially higher levels of forage with forest management when compared to the natural benchmark run.

Below is American Marten habitat and natural benchmark comparison – again taken directly from your 2005 and 2010 plans.  According to your plan text, Marten require mature forest, downed woody debris and cavity trees in Eco Sites 11, 16, 18, 20-22, 30-34

 

Note the significant step down in habitat and natural benchmark at T1 – ~ 130,000 ha less habitat. (Note labelling for 2005 Management Alternative and 2005 natural benchmark should be reversed)

If your yield curves don’t result in more trees being harvested, why is the marten loosing over 130,000 ha of habitat?  Your response of February 8^th indicates your FRI updates stepped down the starting inventory on habitat. I find it impossible to concede you depleted that much area in 5 years.  In any case, here is your 2005 Graph complete with “Lower bound of sustainability” at approximately 175,000 ha

 

With your FRI updates, your natural benchmark and PMS7.1 trend below your 2005 lower bound of sustainability?  How can you claim your 2010-2020 Draft plan is sustainable when it directly contradicts your 2005 assertions?  Your 2010 plan and its assumptions are untenable.

I will revisit additional aspects of Mr. Winter’s response in detail below.   Below is Section 2.4 of your Analysis package.   I am concerned with all modelling assumptions and projections, but the hemlock plan forecast is the most egregious, and with a limit to my time, my efforts will remain focused on this species.

2.4 Initial Areas of Uneven-aged Available Forest

Uneven-aged management applies to tolerant hardwood stands (HDSEL forest unit) and hemlock stands (HESEL forest unit) managed under the selection silvicultural system. The average maximum biological upper limit for basal area is set at 32m2/ha for HDSEL and 42 m2/ha for HESEL. Although there are some stands that may exceed these limits, they are representative of the average forest condition for these forest units. This is in keeping within the range of past management plans and other management units in the Region. SFMMTool was used to determine basal area using its age/site class/stocking algorithm. SFMMTool then applies the average AGS/UGS (quality ratio) to these stands (50/50 for both HDSEL and HeSEL). Area below the minimum BA for each growth curve was then summed and entered into that minimum BA class (i.e. 18 m2/ha. for HDSEL and 22 m2/ha. for HESEL, SFMM does this automatically after T1 anyways). As for the calculation of AHA for the uneven-aged forest units, the BA assignment means little as the selection calculation is “simulated” and not “optimized” as it is for the even-aged forest units. The initial BA distribution for the uneven-aged forest units is shown below:

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Your plan states: SFMMTool was used to determine basal area using its age/site class/stocking algorithm. SFMMTool then applies the average AGS/UGS (quality ratio) to these stands (50/50 for both HDSEL and HeSEL).

Since there are a number of known limitations in using SFMM to provide an indication of the historic age class distribution, I’m puzzled by planning team`s inclusion of the above chart?  What precisely is this graph intended to depict?  It is poorly labelled; the right side of the graph contains data which is truncated and meaningless.   

(It is well known that the SFMM is a deterministic model, which provides no indication of the variation in age class distribution and that SFMM assumes that the lifespan of an individual cohort in a single sample of the population represent all age classes.  This methodology oversimplifies and ignores the combined impacts of natural and anthropological disturbances)

[Mr Winter’s Response:  Yield Comparisons:

For development of this FMP an available harvest area is calculated using the SFMM model.  This represents the maximum allowable harvest area for each forest unit. Yield estimates are applied to area harvested to forecast expected volumes. 

Yield estimates have been generally increased in the 2010 FMP because previous forecasts were under-estimating yields (m3/ha) when compared to actual yields produced (2000-2008 time period).  Yield curves were developed using the latest science-based methodology endorsed by the MNR.]

How did you calculate the volume of fibre (m3) per ha?  My forest management for dummies guide states:

In uneven-aged stands trees of three or more ages are spatially intermixed within the stand and

grown continuously without uniform rotation length. Uneven-aged stands and forests are managed

by volume in terms of specific numbers of trees in each DBH class and it requires you calculate the area which is (Area =radius² x p) where radius = Diameter at Breast height (DBH) /2 and p = 3.14 ) and then multiply the resultant area by the height of the tree.  Simplified I conclude:  Even-aged models give yield estimates as a function of stand age, whereas models used in uneven aged situations (like Hemlock) are based on functional relationships between yield (ie how fast a tree grows) and tree size distribution (ie how big each tree is).

Since uneven-aged stands contain trees of three or more ages that are spatially intermixed throughout the stand and stocking (ie stand density) is the total basal area by diameter class groupings (Smith 1986), please provide how many hemlock trees are planned to be cut in 2010 vs 2005, and break out as :

             1) Recruitment stock:  total basal area in trees greater than 1 cm DBH,

            2)  Polewood growing stock:  basal area in trees greater than 9 cm DBH and

            3)  Sawlog components:  basal area in trees greater than 24 cm DBH.

Your response indicates you changed your yield curves, but where did you get your data to support tree size and growth rate?  Your Analysis package says “MNR information” which is decidedly vague.  Please provide explicit answers to explain how the hemlock yield curve was calculated referencing methodology and providing actual source data.  If you claim your yields are based on actual volume harvested, I have compiled the last 4 years below:

2005 Planned hemlock sawlog m3 = 126,656 /5 years = 25,331m3 per year

Plan Year	Hemlock 2005 Plan volume m3	Hemlock Volume (m3) Actual	% Plan
2005	25,331	14,333	57%
2006	25,331	14,789	58%
2007	25,331	9987	39%
2008	25,331	15,118	60%
Average	25,331	13,549	53%

Fibre volumes for hemlock sawlogs (which excludes pulp) in 2010-2020 is 205,442 m3 /5 years = 41,088 m3 – that is 3 times greater than a four year average of hemlock yield actuals (which include pulp). 

Your average hemlock plan yield for 2010-2020 is 39.58m3/ha compared to the 2000-2005 average plan yield of 24.74m3/ha.  You are claiming you can harvest ~15m3/ha more hemlock in 2010 from the same available harvest area without cutting any more trees recognizing the forest has less trees as a starting inventory?  How can you possibly assert that is true? 

Below are your yield deltas (details)  between 2010 and 2005 by species, I have highlighted in GREEN the hemlock yield differences which range as high 35% more in 2010 over 2005 – where is the data to support these?

Diff

INTCC PjCC PrCC SbCC HDUS MWUS LCUS OrUS PwUS SFUS HeSEL HDSEL TOTAL

T1 -6.2% -25.7% -19.1% 13.9% 26.4% 23.9% 24.6% 5.8% 38.7% 23.1% 22.8% 8.0% 16.0%

T2 -8.9% -24.6% -7.9% 22.5% 5.1% 38.9% 72.2% -4.1% 112.5% -5.8% 30.6% 7.4% 24.3%

T3 -11.0% -26.7% -7.5% 26.2% 47.0% 33.4% 70.0% 15.5% 103.9% -4.7% 35.4% 12.0% 27.8%

T4 -4.7% -27.5% -13.5% 23.5% 47.9% 40.8% 28.5% -8.1% 33.4% 13.4% 29.6% 14.1% 23.2%

T5 -5.2% -23.4% -14.7% 37.2% 38.5% 102.8% 28.0% 34.8% 8.7% 4.0% 26.8% 19.6% 24.3%

T6 -7.5% -23.4% -33.4% 63.1% 25.6% 53.6% 44.9% 9.1% 20.1% -4.3% 24.3% 27.7% 27.8%

T7 -1.1% -24.2% -7.6% 41.0% -1.2% -2.9% 78.8% -8.1% 24.0% -14.8% 24.0% 34.5% 22.0%

T8 -20.5% -28.1% -10.0% 46.2% -37.0% 14.4% -6.8% 1.5% 54.2% 0.7% 23.0% 37.8% 24.9%

T9 -14.2% -36.7% -19.0% 50.4% -43.0% 63.3% -38.6% 10.5% 52.2% 10.9% 22.2% 38.3% 28.4%

T10 -13.2% -32.7% -11.3% 55.4% -1.5% 17.3% 45.8% 16.6% 56.8% -8.7% 21.5% 38.1% 27.4%

T11 -14.5% -35.4% -24.4% 63.2% -17.7% 8.3% -2.1% 27.6% 25.5% 11.8% 20.8% 37.9% 23.8%

T12 -13.8% -34.6% -19.8% 56.1% 17.3% 35.4% -23.5% 6.0% 33.8% 3.3% 20.3% 37.5% 24.1%

T13 -14.2% -20.5% -18.6% 35.5% 33.5% 62.2% -9.5% -2.4% 25.9% -4.2% 19.8% 37.2% 33.8%

T14 -11.2% -44.3% -18.0% 22.5% 48.7% 42.2% 14.6% 30.6% 46.0% 7.0% 19.7% 36.8% 42.0%

T15 -8.3% -20.1% -14.6% 17.9% 17.2% 7.7% 43.8% 12.3% 26.8% 0.7% 19.7% 36.4% 26.6%

Your plan for hemlock states:

• A residual area of 32 m²/ha of hemlock will be left – the plan asserts the hemlock stand with grow at a rate of 0.35 m²/ha/year to 42 m²/ha in a 25 year period, at which time 7.39 m³/m² of basal area  will be cut leaving 32m²/ha which will grow back in the next 25 years, noting this is an average cycle.

How did you determine the growth rate?  Did you factor in the known impacts of moose browse as explained in Issue #4?  What about calcium loss resulting in a net zero growth rate?

Your model forecasts the forest can sustain a harvest of 7.39 m³/m² of basal area once every 25 years.  A one year harvest in a stand at 42 m²/ha basal area equals 310.38 m3/per ha.  Since the plan states Algonquin has 25,990 ha of available hemlock, the model projects the hemlock forest would sustain 322,671m3 of hemlock per year (310.38 m3 x 25, 990ha/25 years).  This figure seems inconsistent with a realistic understanding of forest ecology and harvesting in hemlock stands.

Below are the calculations taken directly from your plan:

• The area available for hemlock per 2010 plan is 25,990 ha / 25 years = 1039 ha/year (Table 7 in Plan text reports this as a yearly value for hemlock at 1038 for 2010-2020 plan and compares that to 1024 ha for 2005 plan.)  I conclude this is how the plan reports the increase in available harvest area for hemlock is only 1.4% from 2005
• For 5 years the 2010-2015 plan forecasts 205,442 m3 of hemlock sawlog volume (per mill commitment FMP-19 noting I have not included pulp) which will be harvested from 5190 ha (1038 ha/year  x5 years) which means 39.58 m3/ ha of hemlock sawlog is planned to be harvested annually.
• Section 3.2.1 Hemlock of your plan text states:

For 5 years the 2005-2010 plan forecasts 126,656 m3 of hemlock sawlog volume (per mill commitment noting I have not included pulp) which was planned for harvest from 1024 ha which equals 24.74 m3/ha

Subsequent harvests will occur in about 25 five years time once the regeneration is well established. The irregular composition and structure of many hemlock stands may allow for a shorter cutting cycle as long as overall hemlock shelter is not reduced. A cutting cycle of 25 years and a growth rate of

.35 m2/ha/yr have been used in the SFMM model

Harvesting will discriminate against hardwoods and leave high levels of hemlock basal area (32 square metres per hectare).

  Below is your data, stating a hemlock yield of 7.39 m³/m² of basal area per year will be cut.

The above graph depicts a growth rate for hemlock over 50 years - where did the starting point basal area assumption of 20 m2/ha come from? 

“[Mr Winter’s Response:  yields and subsequent available volume information has been developed based on the latest science and reviewing results of actual volumes over recent years”]

Projecting such a high sustainable yield of hemlock per year I think you would have to agree is absurd.  Yes, your plan states there are assumptions for tree marking and variation in stand age and density that will adjust your model output, but what precise science methodology rationalizes moving from the SFMM plan forecast of 310.38 m3/per ha per year to 39.58 m3/ ha of hemlock sawlog planned for harvest annually. 

The inconsistent calculations in the plan leave me convinced that there is little science or practical management involved.  The total result seems more like guessing than a careful calculation of the sustainable harvests.

In summary, I find nothing scientific here – researching basal area calculations for forest management of uneven age stands I do find approach can vary, but calculation is done either by Weibull distribution to emulate a three tiered stand with tree sizes ranging from 1 cm to 9 cm and larger for sawlog (@ 24 cm DBH or more) or using BDQ or (as I will cite later in this narrative) spatially using software to calculate gaps in trees due to browsing and skid trails.  The aggressive yield curves also contradict Vasiliauskas thesis (increased gaps due to moose browse) along with the net zero growth rate due to harvesting.  I speak more about these issues in the Old Growth (Issue 4) section.

Your 2005 FMP stated:

“Estimation of volumes from partial harvesting systems is difficult at best and to estimate by species presents many challenges. The test of how well volumes are estimated can be checked by looking at average yield per hectare and comparing to known standards

What are your known standards?  Please provide explicit evidence including source data and methodology to support your hemlock yield assumptions.)

[Mr Winters Response: The overall forecasted increase in sawlogs is 16% over the 2005 FMP, and is directly proportional to the increased yield forecast from the new yield curves (from generally the same available harvest area level).  Pulp volumes have also increased compared to the 2005 FMP.  Open market volumes have increased but commitment levels have been maintained.  ]

As provided in my initial issue resolution submission, the 16% increase is an average – and ignores the increase in yield by species, the number of ha each tree species has, and the age/size, growth rate, and harvest method of the individual tree.  Hemlock sawlogs have increased 62% over last plan forecast – and what is more distressing is the fact the number of ha available in the forest has decreased by 5,000 since 1995.  This means the forest has lost 5,000 ha of hemlock permanently, due to harvesting practices that are not sustainable. 

Justifying your plan yields by stating they have an “overall increase of 16%” is a gross over-simplification which is oblique and meaningless.

In summary, the inherent flaws of non-spatial modelling tools “create a divergence between the optimal predictions of the model and what will actually be achievable”.  The crude and subjective modelling approach used in the 2010-2020 Forest Management cannot promote any degree of accuracy and the fact the plan yields forecast mirror historical is only evidence of a plan that has been contrived to meet pre-determined goals.  The plan must be redone.

Since the lexicon of Forest Management is important, I’ve checked for the MNR definitions on yield and volume to frame future discussion - included here primarily for my benefit:

Stand Density:   The number of trees usually expressed on a per hectare basis.

Basal Area:   1) Of a tree, the area in square metres of the cross section at breast height of the stem.

2) Of a stand,

Volume:   The amount of wood in a tree, stand or other specified area according to some unit of measurement or some standard of use (e.g. m3 or m3/ha)

Gross Total Volume (GTV):   Volume of the main stem, including stump and top as well as defective and decayed wood, of individual trees or stands.

Gross Merchantable Volume (GMV):   Volume of the main stem, excluding a specified stump and top, but including defective and decayed wood, of individual trees or stands.

Net Merchantable Volume (NMV):   Volume of the main stem, excluding stump and top as well as decayed wood, of individual trees or stands.

Yield:   Growth or increment accumulated by trees at specified ages expressed by volume or weight to defined merchantability standards.

Yield Curve:  A graphical or mathematical representation of the yield of a given species, on a given site, at a

given time

Recommendations:

1. Adopt the KBM Auditor best practice recommendations of the 2006 Wood Supply Analysis and re-issue the 2010-2020 plan using a spatial analysis tool for natural benchmark and management alternative forecasting. 

[Mr Winter’s Response:  I do not believe that the spatial forest estate models currently available would do a better job at forecasting natural benchmark trends or management alternatives.  The strength of spatial models is in shorter-term operational planning, as opposed to long term forecasting of forest development or wildlife habitat.  Note that spatial modeling is used in this FMP to measure old growth and wildlife habitat metrics, specifically comparing plan start -2010 to plan end levels -2020.]

For selection managed forests, the use of spatial modelling to create more accurate harvest targets has been proven.

The attached paper from the University of Toronto states:

Under standard selection silviculture, trees are harvested individually, or in small groups, with the aim of retaining trees across a full range of size classes (Nyland, 1998; OMNR, 1998). In eastern North America, the typical selection harvesting regime removes one third of the basal area every 20 years, and the size distribution of residual trees typically is approximated by a negative exponential distribution (many stems in small diameter classes and few stems in larger diameter classes).For example, group selection in southern Ontario calls for creation of multi-tree gaps (as large as 0.2 ha) that are interspersed among single-tree gaps (OMNR, 2004). In addition, logistical considerations, in particular physical impacts related to the felling and skidding of harvested timber (and minimization of such impacts), very commonly result in multi-tree gaps. Thus, even in cases where the objective is single-tree selection, gaps of various sizes are inevitably created during harvesting operations.

In this paper, we describe and test a harvesting algorithm designed to simulate selection silviculture as practiced in the tolerant hardwood forests of central Ontario, Canada. There were three objectives that guided the design of our harvesting algorithm. The first objective was to mimic the harvesting regime employed at our primary field site, the Haliburton Forest andWildlife Reserve. In particular, we designed the algorithm so that it could reproduce the observed spatial distribution of harvested trees (hereafter “stumps”) and their observed diameter distribution. The second objective was to design the algorithm so that it could also simulate alternative harvesting regimes, including regimes that may differ in the intensity of harvesting, the size-specificity of harvesting, and the spatial pattern of harvesting. The third objective was to design the algorithm so that it would be simple to use (i.e., has just a few intuitive parameters) and could be implemented in any spatially explicit individual lbased forest simulator, including the most recent version of SORTIE-ND (http://www.sortie-nd.org/index.html).

The ability to specify the gap size distribution is also essential for simulating selection silviculture because it emulates a primary parameter that managers manipulate to promote the regeneration of different species. At the same time, the ability to set harvest targets is important because managers must balance the need to regenerate desired species with the need to maintain timber supply. In order to simulate harvesting practices under selection silviculture, we must be able to represent variability in gap sizes, while conforming to the harvest targets. The harvesting algorithm we have developed can achieve both of these tasks simultaneously, and thus is capable of creating various harvesting scenarios under the selection system. Once our algorithm is incorporated into an individual-based forest stand simulator, it will be possible to study long-term forest stand development and dynamics under various harvesting scenarios. Such studies may yield new insights into the dynamics of managed stands and provide guidance in designing new management regimes.

The field data used for the empirical algorithm were collected in Haliburton Forest and Wildlife Reserve (45◦15_N, 78◦34_W) as part of a related study on tree growth (Jones, 2006). As is typical of the Great Lakes—St. Lawrence region (Rowe, 1972), the upland hardwood forests of Haliburton Forest are dominated by sugar maple, American beech, eastern hemlock, and yellow birch. The forest has been managed under selection silviculture for the past 40 years, and was selectively harvested for yellow birch and and white pine (Pinus strobus L.) prior to that time. The spatial extent and harvest date of each cut-block has been recorded for the last 20 years.

2. Update FRI inventory and reconcile the volumes by ha by age class by species to yield forecasts and compare the result to known (ie published) standards.

Mr. Winter’s Response:  This has been done.  Increased yield forecasts have been incorporated into this FMP based on actual yields generated and reported in recent annual reports.  This explains why more available volume has been forecasted.

As documented in detail above, no scientific logic or data has been provided to explain why you claim you can get 62% more fibre from the same amount of available harvest area, with the same growth rate (which is highly doubtful given the research from Trent University).

January 26, 2010 minutes:  Gord Cumming responds that projected declines in preferred habitat are more a result of natural forest succession than harvesting.  The volume of the harvest was adjusted (yield curves) and confirms that the changes are not the result of taking more trees.

Are you going on record to state 130,000 ha of Marten habitat has been lost in 5 years due to FRI updates?  That is the difference in natural benchmark and habitat projections between 2005 and 2010 plans.    Since your own FRI reconciliation of depletions between 2005 and 2010 show your 2010 plan for Marten has exceeded the lower bound of sustainability, this is justification for bump up, as your harvesting practices in the past 5 years have irrevocably destroyed critical habitat of a vital ecosystem that many creatures (not just Marten) rely on.

Your SFMM model algorithm has clearly been manipulated to favour a predetermined plan outcome for 2010 increased fibre, or your 2005 plan is wrong, or both.  It’s impossible to know the extent of the problem without any supporting data or a common thread of logic to support your assertions.   More worrisome, at the January 26, 2010 meeting, your own minute’s state:

I asked how do we address the relationship of volume and habitat and is concerned that there should be a reconciliation of volume based on actual volume harvested.

Norm Cottam responded (again these were your notes, not my edits):

Norm Cottam mentioned that calculating wildlife habitat and calculating volume are separate procedures. 

Why would a planning team member cite a process as a reason for materially divergent fibre volumes that cannot be explained?  The use of disparate databases, unpublished science, manual spreadsheets, and conjecture is no doubt the reason for the divergent and blatantly contradictory plan projections contained in your habitat modelling produced in two plans in the past 5 years.  As I mentioned to your planning team on the 26^th and will restate here again:

The purpose of your plan is to provide measurable, quantified and accurate projections of habitat loss as a result of an industrial activity (harvesting) using best practice proven methodology, supported by peer reviewed science and actual data.  If you cannot reconcile your manual processes to provide meaningful and directionally accurate projections that explain the impacts of your activities on habitat now compared to those projected a mere 5 years ago, then you have failed and the plan must be redone

3. Perform a “post mortem” after each 5 year term before embarking on a new “management” approach.  The predictions and promises made in 2005 are abandoned in 2010.

Mr. Winter’s Response:  The 2010 natural benchmark trends and wildlife habitat forecasts have been improved based on the latest science and the incorporation of new research into the models.

That is a motherhood statement with absolutely no evidence to support it.  Your claim of improvement is the subject of this long narrative and has yet to be proven.  New research – again, I ask, what?  Your plan states “MNR data” – you continue to reference annual reports that are never disclosed, or expanded upon.  Your model assumptions on age class are “simulated” and your basal area predictions sketchily compiled guesses.

4. In the absence of best practice, spatial modelling tools, and peer reviewed science, approach forest fibre quotas with caution.  Reduce fibre quotas for 2010 to 2005 planned levels until accurate forecasting tools are in place and FRI inventory is reconciled.

Mr. Winter’s Response:  “Fibre quotas” or commitment levels have been maintained at 2005 FMP levels in the 2010 draft plan.  Available volume in excess of these levels has been placed in the open market category. Commitment levels are reviewed by MNR with the approval of each plan to ensure they are achievable and consistent with the proposed management strategy.  Accurate forecasting tools were used and the FRI inventory was reconciled.

Your assertion that you have excess fibre just sitting around (without harvesting more trees to get it) is simply wrong and untrue.  You have not provided any data or scientific logic to support that.  As far as stating the commitments are economically achieveable, that is the subject of Issue #3 below.

In light of the above, I have the following additional recommendations:

5. Introduce a hard constraint into your SFMM management strategy that recognizes the anthropological impacts of harvesting combined with moose browse on hemlock affecting regeneration which will prevent a harvest of hemlock that exceeds existing mill commitments (eliminate open market allocation). 
6. Introduce a hard constraint into your SFMM management strategy to limit white and yellow birch and poplar to 2005 mill commitment levels.
7. Accepting #5 and #6 are required to provide the absolute outer bound for harvesting tolerance; given the obvious contradictions and modelling errors inherent in habitat modelling, the Plan Model (Natural Benchmark and Management Strategy) must still be redone.  Employ expert 3^rd party assistance to accurately calculate plan yields for all species with particular emphasis on Marten, PIWO and habitats dependant on white pine, red pine, polar, birch, (yellow and white) and hemlock.

ISSUE #3:  2010 Plan is financially motivated to reduce reliance on existing mills and does not follow the CFSA

Attached is a comparison of plan yields for the 5 year terms 2000-2005 and 2010-2015.  This illuminates the aggressive fibre quotas, particularly increased saw log fibre quotas of Hemlock which are projected to increase by 62% in 5 years.  What’s most disturbing is the aggressive open market allocation of sawlogs which has almost doubled over past term. 

Issue:  It is evident that the financial implications of an unsustainable pulp market have trumped the ecological needs of a forest.   In order to offset the poor return on pulp, saw log volumes have increased exponentially. The 2010-2020 Management Alternative (PMS 7.1) has been re-engineered to support increased saw log quotas needed to offset unproductive pulp.