Dedicated to preserving the old growth forests and precious waterways in Algonquin Provincial Park, this blog chronicles my research and advocacy efforts channelled through the 2010-2020 Algonquin Provincial Park Forest Management Plan.
The area proposed for protection zoning can be summarized as follows:
• 4054 hectares for sites that contribute to ecological representation of landform/vegetation features
• 200 metre waterway zone along each side of high value/main canoe routes which includes increased protection for brook trout lakes and areas of high cultural heritage value. This 200 metre zone is also consistent with widths of waterway class provincial parks outside of Algonquin Park. However, this provision may be modified in woodsheds where wood supply is an issue.
• 120 metre waterway zone along each side of high value/main canoe routes within woodsheds with wood supply concerns. However, if through the forest management planning process, wood supply issues are resolved, 200 metre zones would be preferred for these waterways
• 120 metre waterway zone around Opeongo Lake and other secondary canoe routes
• 30 metre waterway zone along low use canoe routes
• Areas of inaccessible or inoperable forest and areas that improve connectivity between existing core protection zones
The area proposed for protection zoning is increased by 98,202 hectares, and brings the total area zoned for protection from 167,544 hectares to 265,746 hectares or 35% of the
total Park area. This proposed area is comprised of forest and non-forest (rock, water,swamp, etc.). The Boards recognize that there is a large amount of area within the Recreation/Utilization (R/U) Zone that is currently not available for forest management. There are also unique prescriptions developed through forest management planning that contribute to protection of Algonquin Park’s ecological, recreational and tourism values. The Boards recommend that the area within the R/U Zone that is not part of the available forest (e.g., areas protected by Park policy (e.g., reserves on portages and water bodies), water, wetlands, rock barrens and area of concern (AOC) reserves, present and future inoperable forest) should be recognized as area not available for logging. With our Submitted to the Minister of Natural Resources – September 2009 proposal, the total area not available for forest management within the R/U Zone is 105,493 hectares.
Combining the area not available for forest management from the R/U Zone (105,493 hectares) and the proposed additions to protection zoning (98,202 hectares) will bring the
total area protected from or not available for logging in the Park from 341,495 hectares (45%) to 371,238 hectares or 49% of the total Park area. The map above summarizes the current and proposed areas for protection. Of the 98,202 hectares proposed for protection zoning, only 29,743 hectares was forested area available for forest management. Therefore, the net effect to the forest industry is a decrease of 29,743 hectares of forested area from the available forest management landbase.
The following Q&A was posted on a forestry sponsored website. My intent is to correct the propoganda, with facts, not logging add-speak. I'm constantly receiving new information so this page will be updated frequently and iteratively as I learn more. It's intended to get the facts out - and provide a comprehensive FAQ. I've left the original answers by Jeff Muzzi and added facts in BLUE. The questions were highlighted in RED just for ease of reading, no text was changed. Forestry operations in Algonquin Provincial Park - the Reality Submitted by greg_g on Tue, 10/06/2009 - 09:32. By Jeff Muzzi, Manager of Forestry Services, County of Renfrew .
Q1. I didn’t know logging was allowed in Algonquin Park!
A Logging first began in what is now Algonquin Park around 1830. It’s been ongoing ever since – almost 180 years.
Algonquin Park was created in 1893 largely in response to the timber lobby to prohibit farming there so that timbering could continue on a longterm basis. Creation of the Park allowed the implementation of a long advocated policy, based on fear of risk of fire in the forest, to “permit no isolated scattered settlers to locate amidst the pine forests” (Burke 1855:623). Despite a report early in 1895 from Peter Thomson, first Superintendent of Algonquin National Park, as it was then known, that “there is no open and flagrant violation of those provisions which forbid hunting and trapping in the Park” (Thompson 1895), Algonquins who lived in Lawrence and Nightingale Townships were evicted on the pretext that “the presence of the Indians might be a great danger to the preservation of the game in the Park” (White 1895). Chief Peter Sharbot was one of the people affected. Pine lumbering in what would later be the Park started around 1830 and peaked in the 1860's. When the Park was formed in 1893, the Parks Act prohibited logging of any species other than white and red pine. . In 1897, J.R. Booth financed a railroad between Ottawa and Parry Sound, along the north side of the park. In 1900, an amendment to the Parks Act added spruce, black birch (white birch), yellow birch, white cedar, black ash and tamarack, to the trees which could be logged from the park. The first hardwood to be extensively logged in the park was yellow birch, which was cut primarily from the 1930's to the 1950's. From about 1945 to today logging of sugar maple has steadily increased, while a wide variety of other trees are still being cut.
Q2. How much of the Park are the logging companies allowed to harvest?
A. Around 52% of the Park is area where harvest is allowed. The rest is areas where harvest is not permitted (important ecological, historical or recreational values) or areas where no logging has ever taken place – lakes, swamps, that sort of thing. Within the harvest area, all special values are protected – hawk’s nests, turtle habitat – anything that may be affected by forest management operations. The actual amount of protected park is currently 22%. The Ontario Parks, through a 2006 exercise referred to as "Lightening the Footprint" has recommended protection in the park be increased to 35% which means a 7% reduction in actual timber harvested (the balance of protection is given to non-merchantable areas such as rocks, water, swamp land etc. Refer to the Post titled "Lightening the Footprint" for specific details). The MNR concede that new Areas of Concern that would better protect wildlife are currently under review, waiting for approval. They admit they are working with outdated science.
Q3. How much of it is clear-cut?
A. Almost all of the harvest is selective – no more than 1 tree in 4 is cut. All of the trees to be harvested are marked by highly trained technicians prior to operations beginning. When clear-cuts are used (and that’s less than 4% of the area) they are used to maintain forest diversity and emulate natural disturbances, like fire. The MNR have gone on record to state the Emulation of Clear cutting does NOT emulate what nature does naturally. Clear cutting combined with fire suppression is environmentally damaging. More factually correct, the following was provided by the MNR regarding harvest methods in Algonquin: In Algonquin Park there are 3 harvest systems used; selection, shelterwood (partial cutting systems) and clearcut. The system used is based primarily on the light requirements (or shade tolerance) of the desired species. Planting trees is used only on a few selected areas with natural regeneration being the preferred method for the majority of the forest.
The most common system is selection (~55% of harvest) used for shade tolerant hardwoods such as Sugar Maple and Beech. In this system approximately 25-30% of the trees are cut with specific removal targets for each size class to ensure a multi-aged stand is maintained. Using this system the stand is harvested every 20-30 years depending on the site, and because there is multiple ages present under this system the stand can be harvested continually on this cycle.
The 2nd system used is shelterwood (~40% of harvest) common for White pine and hardwoods that are in the middle of the shade tolerance range. This is series of cuts designed to manage light levels to promote and maintain regeneration. For White pine this is a 4 harvest system. The first harvest is the preparatory cut which removes poor quality trees and promotes seed production in large dominant trees. Approximately 20 years later is the seeding cut which opens up the canopy to allow more light to reach the forest floor thereby promoting natural regeneration. The third harvest is the 1rst removal and it occurs approximately 20-25 years after the seeding cut (depending on the site, regeneration success and other factors) this is intended to improve the growing conditions of the established seedlings, approximately 60% of the crown closure remains. The final stage in the shelterwood system is the final removal which occurs approximately 20 years after the 1rst removal, this removes most of the remaining overstory and the new stand (now approximately 6m tall) takes over. Clear cut harvesting is used to emulate fire in Jack pine, Red pine, and shade intolerant hardwoods. This system is by far the least used of the 3 systems in the Park (less than 5% of all harvests).
Q4. How much gets cut every year?
A. Less than 1 ½ % of the Park’s forested area is cut in any given year. These areas can be cut again in about 25 years – in fact, there are loggers working in the Park that are cutting the same places their grandfathers, and subsequently their fathers, harvested timber. More than 50 years of modern Logging has eliminated much of the old-growth hardwood and hemlock forest in the managed forest part of Algonquin, however significant patches do still exist and are threatened with logging. Some are allocated within the current five-year management plan, others have recently been logged. These forests, some of which have been growing since the early 1600's, are irreplaceable. Trees that are 375 years old or more cannot be managed "sustainably" by modern forestry which typically works on rotation periods of 100 years or less. Q5. Are the logging companies regulated?
A. Absolutely. The Crown Forest Sustainability Act, the Provincial legislation that governs activities on Crown Land, has the most stringent rules in the world. Also, the Park forest is certified by the Canadian Standards Association as a “certified sustainably managed forest” – an internationally recognized, independent audit system that ensures forests are properly managed. The Government has licensed the harvest operations of the park to another crown agency , the AFA which means APP is essentially self- governing, with no 3rd party regulatory agency, or standard. The certification of Algonquin is being challenged by Eco-Justice as unlawful. The CFSA allows all license holders to monitor their own operations, with the only protection in the form of a 5 year audit. In the case of Algonquin, the audit was conducted by the government, not a 3rd party. It is sorely lacking in detail, and credibility. No other standard or certification that I am aware of, is granted without 3rd party independent assessment, monitoring, and review. (Example ISO140001)
From the MNR I received this response on questions relating to certification: ``The Algonquin Forestry Authority, the exclusive license holder for the Park is not certified to FSC, however they are certified to both ISO 14001 and CSA Z809 standards. These certifications are similar to the FSC program but administered by different agencies. Information on all these certifications is available online. The AFA has been certified to CSA since February 2008.``
I strongly disagree with the forester`s response regarding certifications being similar to FSC. Eco-Justice is challenging the CSA Z809. Link attached hereEco Justice CSA Challenge APP The ISO 14001 certification is a risk management approach to environmental safety, it has more to do with protecting humans than saving trees. FSC certification was developed by Greenpeace.Link attached hereFSC Certification Standards Q6. But those big logging companies – do they care about the Park, or just the “bottom line”? A. The companies that harvest and process Algonquin Park wood are, in fact, small, family-owned firms that have been in business for a very long time. For example, Herb Shaw and Sons, in Pembroke, has been operating for over 150 years; Murray Brothers (Madawaska) and McRae Lumber (Whitney) have both been operating for over a century. These folks all rely on Algonquin Park wood. They have also invested heavily over the past century to improve the overall quality of the forest and to improve habitat. Something else you should know – when times get tough (and they do in the lumber industry, it is cyclical) these folks don’t export their jobs to developing nations. They keep their people working, even if it is at a loss, and weather the storm. They support the towns where their employees work – schools, hospitals, minor sports… watch a hockey game in any of these towns around the Park, and on the kid’s sweaters you’ll see “Murray Bros”, “Visneskie Logging”, or countless other business names – all running on wood from Algonquin Park.
This is a rhetorical question. Private enterprise (in any vertical) is engaged first and foremost to make a profit. Period. The fact these companies have been in existence for 150 years is hardly comforting, in fact, what this statement does acknowledge is that these mills have been responsible for the environmental rape of the forest pre and post war eras. Values of all Ontarians are very different from what they were around the time of the 2nd World War, let alone more than 150 years ago, and the more important question is WHAT value do these businesses bring in a new world economy, how will they ensure our assets are protected, and why should they continue.
Q7. What do they do for the Park itself?
A. These firms donate money, time and material to Park projects – they helped build the Visitor’s Centre, restored historical sites like Basin Depot… they continuously give money to scientific research projects in the Park, such as wolf, bear and wood turtle research. Without any proof or financial statement, I have no idea how to respond to this statement, other than to make a general comment that philanthropic gestures done in the true spirit of altruism are done anonymously, not as a means to justify an end. The Forest Renewal Trust Fund mandates all harvesters contribute financially to the forest sustainment which is mandated by the CFSA. What is factually supported, is that Forest Renewal trust funds that logging is responsible to pay are directly linked to harvest levels, therefore, since the harvest is far below forecast, the contribution to silvicultural renewal is equally lacking. These forest renewal funds are designed to sustain the silvicultural costs of the forest, and to support community costs including roads. As per 2009 audited financials, APP is precariously hovering in the red. Q8. But doesn’t logging damage habitat?
A. Absolutely not. YES! Deforestation and forest degradation account for nearly 20% of global greenhouse gas emissions. Forests absorb carbon, storing incredible amounts in trees, plants and soil. When these forests are cut, most of the carbon they hold is released back into the atmosphere.This is an industrial activity, just like mining, and oil sands, it has an absolute cost to the environment. The Climate Change report issued by the MNR makes it very clear harvest extraction is linked to climate change, and all Ontario will live with the consequences of what we do todayThe regulations in place guarantee that habitat damage does not occur. In fact, logging ensures the long-term sustainability of many ecosystems. For example, wildfires in Algonquin Park are controlled, for obvious reasons; what logging does is emulate what nature would do. In fact, Algonquin Eco Watch, an organization dedicated to sustaining Park ecosystems, supports the controlled logging operations in the Park. Don’t take my word for it – check out their website at www.algonquin-eco-watch.com.One of the most damning aspects of the current forest management process is that species at risk (such as the snapping turtle) have no protection from logging, since the prescription or Area of Concern has not been drafted yet (The MNR require the approval from ESA (to be confirmed), and the two groups are notcohesive. Currently, snapping turtles are listed as a species at risk, but you can still get a fishing license to hunt them.There are absolute and real risks of species extirpation within the park if logging is allowed to continue.
Q9. Is it true there are a huge number of logging roads in Algonquin Park?
A. No. YES! There are about 2,000 kilometres of logging roads in active service at any point in time in the Park – around ¼ of 1% of the area. Keep in mind that these roads aren’t just used for logging; they are used to service the Park, for fire control, to rescue lost or injured campers, to conduct scientific research, and for the local Algonquin First Nation to access natural resources. And, the next time you are portaging your canoe, have a close look at the trail – chances are that it was originally a logging road!
A group that opposes logging in the Park has stated that there are “8,000 kilometres of roads in the Park…enough roads to go to Florida and back…5,487 kilometres of road…almost as much as the Trans-Canada Highway…” the number changes with every telling. They even claim they “ground-truthed” roads – I don’t know how you “ground-truth” something that isn’t there. Making spurious accusations about other entities motives and activities without inviting them to comment is unprofessional, and promotes poor public relations. Confining your response to what you do, will earn credibility. In any case, this "group" has published 2000 km of road, and yes, I do see "8000 km" was identified by Eco Justice in a claim under the Freedom Of Information Act in 2006. Inviting their response for clarification would be what I would expect a newspaper to do (publish both sides). Notwithstanding, roads are linear clear cuts. They are ecologically damaging, they promote divides in wildlife habitat that create unnatural corridors for predation and roadkill, they increase the risk of species conversion which is accelerated as more roads are introduced, and close proximity of roads to streams and watersheds is acknowledged by the MNR as environmentally damaging(source will be provided)
Q10. But don’t roads fragment habitat, and harm wildlife migration routes, that sort of thing?
A. In the Park, there is a permanent road system that includes public roads like Highway 60, Achray Road and others. Purpose-built logging roads, when logging operations are completed, are abandoned and rehabilitated – basically “removed” from the landscape. Old roads are re-used during forest management operations to minimize the “footprint”. Also, the width of logging roads in the Park is restricted to less than the Provincial rules allow. So, the impact of logging roads is very minimal. As above, this is simply not true. Its a perspective of a industry that needs roads to operationalize and extract timber, and anything stated here is highly biased. Q11. You mentioned the local Algonquin First Nation community – how do they feel about logging in the Park?
A. I can’t speak for the Algonquin First Nation, but you should know that they have used the natural resources in Algonquin Park – everything from fish and wildlife to birch bark and trees for canoe construction – for millennia. The Algonquins of Pikwakanagan have a community-owned logging and forest management company that employs over 50 people in the Park. Most of the other logging and forest product processing facilities around the Park employ Algonquins. But don’t take my word for it – contact Makwa Community Development Corporation in Golden Lake, Algonquins of Whitney and Area or the Algonquin Loggers Association of Whitney and ask them.
Park forestry operations are so important to the local Algonquin community that 9 Algonquin native community members sit on the forest management planning team. Today, there is an outstanding FN claim for much of the land surrounding Algonquin (More facts on this will be posted).
(Source for the historical analysis): Link here:History of APP Historically, as previously noted above, Algonquins who lived in Lawrence and Nightingale Townships were evicted on the pretext that “the presence of the Indians might be a great danger to the preservation of the game in the Park” (White 1895). Furthermore, historical records show that soon after Algonquin Park was formed in 1893 all 46 of Chief Peter Sharbot’s community were evicted from Nightingale and Lawrence, the two townships they had occupied since 1849 (Bennett 1895; Reed 1894; Reed 1895, White 1895). William Perley was a lumber baron who established extensive mills in Ottawa at the head of Chaudière Falls and whose facilities extended to nearby Victoria Island, a traditional Aboriginal gathering location prior to industrialization (BiFw-87), long known for its significance as the sacred spiritual meeting ground of many Aboriginal Nations and a sacred site where tobacco offerings were placed in the bedrock potholes created by the swirling water (Allen 2004a:41; Gillis 1982:681; Thumbadoo 2005:15). Perley was described as a leading man of the Dominion and was involved in such activities as service on the Executive Committee for a lavish ball held for the Governor General in the Senate Chamber (Leggo 1878:206, 207). Before Perley died in 1890 his influence as a railroad builder, financier, lumber tycoon, Vice President of the Liberal Conservative Association of Ottawa and Conservative Member of Parliament in Sir John A. MacDonald’s Government, may well have had a direct impact on Chief Peter Sharbot, his neighbour across Farm Bay at Galeairy Lake (Gemmill 1887:152; Mackintosh 1879:470). Today, the Ontario Heritage Act requires Historical Artifacts within Algonquin Provincial Park be preserved, however, the Ministry of Natural Resources Archaeological Site Potential model has faulty logic since it does not recognize many wetlands or water courses as water so timbering can occur right to the shorelines of some lakes, beaver ponds and creek banks. Obviously the MNR model is largely inconsistent with provisions of the Ontario Heritage Act. Fortunately officials from Algonquin Park and the Algonquin Forestry Authority recognized the importance of the Peter Sharbot Homestead site soon after the discovery and greatly extended the usual 30 metre forestry “no-cut” zone along the shoreline reserve to a 150 metre radiant reserve from the datum point near the barn. The datum point is over 100 metres from the shoreline. This decision effectively suspended the scheduled 2005 forestry operations in the immediate vicinity of the Sharbot Homestead property. The responsiveness of these officials is to be commended since they previously depended on. Interestingly the majority of the Sharbot Homestead is in a zone well back from the shoreline in an area considered until now by Ontario Parks to have no archaeological potential so forestry operations had been planned there. Within two metres of Chief Sharbot’s barn foundation, a structure 7 by 10 metres, tree markers had marked trees for cutting without recognizing the foundation. Q12. Who is complaining about the logging in the Park?
A. Not the visitors. The fact that people do not complain directly to the park management is an indicator of nothing, except perhaps frustration. It is also true that through increased public pressure to reduce harvest in Algonquin, the logging has become less visible to the recreationalist. APP is the only provincial park that still allows logging operations to continue.With close to 1,000,000 visitors to the Park in a year, there are less than 10 complaints about logging. Every effort is made to keep logging and recreational uses of the Park separated. Logging in the summer is restricted to small areas well away from other Park users, and the road and harvest systems are designed to have minimal impact on canoe routes, scenery – anything that might negatively affect other users. The results of these efforts speak for themselves – most Park visitors are unaware that forest management activities even occur in Algonquin.
Q13. But I see lots of stuff in the newspapers and magazines that say logging is destroying the Park!
A. One group is very vocally opposed to logging in Algonquin Park. That group, CPAWS – Wildlands League (www.wildlandsleague.org) constantly bombards the press and politicians with hyperbole about Park logging operations. They don’t feel particularly constrained by the truth. They continually misrepresent the facts and make unsubstantiated allegations. Interestingly, on their website, they have a pie chart showing that 86% of their revenue is spent on “Conservation Programs”. Since they are a charitable organization, they are required to submit a T3010 Return (Registered Charity Information Return), to Revenue Canada (www.cra-arc.gc.ca). Have a look. You’ll see that in 2008, 53% of their revenue went to “salaries and wages”, 12% to “consulting” and 8% to “travel”. I leave it up to you how Wildlands League defines “Conservation Programs” …
By contrast, Algonquin Eco Watch, whose vision statement is “to assess, protect and sustain the Algonquin ecosystem for the future”, do not pay any wages or salaries. They do their work because they love the Park – and they support logging!Again, to state CPAWS is the only opposed group, is false. In 2007, the Ontario Parks Board made recommendations to lighten the ecological footprint of logging, recognizing that logging is ecologically damaging. The recommendations proposed by the Minister for adoption in the 2010-2020 FMP will add another 13% to the protected land area, up to a total of about 35%. The public response to the OPB recommendations to reduce ecological footprint resulted in about 6000 responses in letters and emails from various individuals and conservation groups' websites. The anti-logging responses outweighed pro-logging by about five to one.
Q14.If logging is good environmentally, economically and socially, why does the Park need “protection” from it?
A. It doesn’t. What Algonquin needs protection from is overuse and abuse of campsites (please leave a light footprint when you visit!); invasive species (please clean your camping equipment and watercraft before you come to Algonquin, and please don’t bring firewood in!); and littering (seems like a no-brainer, doesn’t it?) Also, some conservation groups are very concerned about the increasing cormorant population, and how that will affect the sustainability of fish populations in the Park. Things happening outside the Park – climate change, development, invasive species – will ultimately have the biggest impact on Park ecosystems. This is again, a view of a logger, and a community bent on logging. It is not representative of Ontarian`s, who own the park (simply because you live near it, does not give you preferential rights to how it should be managed). Ironically, Muzzi notes the importance of climate change and species conversion but demonstrates his poor grasp of science by stating both are issues òuside the park`. Logging is directly related to climate change and species conversion is directly related to clear cutting. Further, as per the Ontario Parks Lightening the Footprint Mandate: The new Ontario Parks Act states that parks must now be managed to protect their ecological integrity - simply put, parks should be managed so that they reflect their natural, undisturbed condition as much as possible. In Algonquin, the past nature reserve and wilderness zone additions along with any new OPB adoptions to be announced, is progress being made in the right direction, towards protecting and restoring ecological integrity.
This newer approach addresses the question of what's best for the park from an ecological and conservation-oriented base, rather than what's best for a group of park users. The new Ontario Parks Act recognizes this basic change in park management - this means that user groups cannot be the primary force defining management, whether they be loggers or recreationalists. The well-being of the park's natural features, maintaining and restoring integrity for ecological reasons, must now be the main defining principle. Q15. Why in the world doesn’t the Provincial government tell us how successful, ecologically sound, and important Park logging is?
A. I can’t answer that. I’m absolutely mystified. I can . The logging revenues as published in this thread do not cover expense, and with the rising dollar, demand will only decline further. Based on 3 year actuals, the harvest revenues will not exceed 58% of forecast at the end of the 5 year period. Operationally, the logging is barely break-even, in fact the audit acknowledges the stumpage fees are in arrears which means loggers are taking Ontario taxpayer assets without paying for them. (See Revenue Analysis and reports below) The MNR have acknowledged logging in APP is environmentally destructive, and the Environmental commissioner's report on Climate Change is the final nail in the coffin. The MNR admit to frustration with dated science, and the species at risk increase. Only 3 % of the park is milled with engineered products, this is a telling indicator of poor innovation and a lack of forward thinking and planningIn Algonquin Park, the Ontario government has “got it right”; they’ve adapted a multi-use management strategy that integrates social, economic and environmental factors effectively; they’ve brought industry, recreation and First Nation interests together with enormous success; and they’ve done it for over 100 years. The multi-use approach in Algonquin Provincial Park has been emulated and admired worldwide; I have absolutely no idea why they aren’t bragging about it at every opportunity.
Q16. How do I get more information?
A. Start by learning about the forest management planning process. All Crown forests in Ontario are very tightly regulated, including Algonquin Park. The process for planning how these forests are managed is very transparent, and public scrutiny and comment are welcomed. The Algonquin Forestry Authority’s website (www.algonquinforestry.on.ca/) is a good starting point.
Communities around the Park – County of Renfrew, South Algonquin Township, Hastings County, Pikwakanagan First Nation, among others – all rely on forest products from Algonquin Park to sustain their businesses, and they would be glad to answer questions about the importance of their local forest industry.
How much do these communities care about their local forest industry? As part of the forest management planning process there are a series of “open houses” where the public is invited to comment on the proposed forest management plan. In July 2009, open houses were held in a number of locations around the province, including Toronto and Ottawa. Guess how many people showed up in Toronto? Zero. Not a soul. How many showed up in Barry’s Bay, where the forest industry is absolutely vital? 130.
Visit the local communities – places like Barry’s Bay, Killaloe, Whitney, Mattawa, Golden Lake…you are sure to meet a Park logger whose great-grandfather logged in Algonquin Park. Ask them if Algonquin needs “protection” from logging!
Below are questions I asked the MNR directly. However, appending them here creates a comprehensive FAQ. No response from Muzzi on these, so the response in white is from the MNR. I will add my perspective inblue.
Q17. Is Fire suppression actively practised in APP, if so, why and where. How long has fire suppression been part of the forest management activities Fire suppression has occurred since approximately the 1930’s and continues to actively occur in the Park, although linked this is managed separately from forestry in the Park. Fire suppression is required to protect the many values present within and adjacent to the Park including: canoeists, Park infrastructure, Petawawa military base, private land, etc. There are provisions for fire management set out within the Algonquin Provincial Park Management Plan (APPMP) and the FMP must comply with the APPMP. Specifically related to fire the APPMP states that “All fires within Algonquin Park will receive a suppression response”. Please note however that the development of a new Fire Management Plan for the Park is ongoing and is scheduled to be completed by 2012, a possible component of this plan will be measured response to fire within the Park depending on fire origin, location, and values at risk.
Q18I'm a bit confused by the following statements (as I understand them from your LTMD): The Pileated woodpecker habitat is expected to be reduced in the next 5-7 years because (as I understand it) the forest is old, and is returning to early successional. In laypersons language, I intrepret this to mean the trees are dying due to old age (everything dies eventually if we leave it long enough)...and so the forest is naturally cycling. The confusion for me is in an unmanaged forest, the woodpecker would thrive with the deadwood. But in managed forests, my understanding is that trees are harvested before they die (naturally). So what I don't follow is why the Pileated woodpecker habitat would be at risk if the forest is old.
Your interpretation is generally correct however some of the “trees dying” is actually just harvesting in later stages of management, it is actually a combination of both natural succession and harvesting. The reduction in Pileated woodpecker habitat is largely due to as you mentioned the converting of older forest to younger forest such as occurs after the final removal in a White pine shelterwood as discussed above. This reduction in habitat is temporary as areas that are currently too young to be considered Pileated woodpecker habitat age into the acceptable or preferred habitat range. Wildlife habitat management is a constant balancing act and while Pileated woodpecker habitat may be reduced over the short term, habitat for species that prefer younger forests is correspondingly increased. The dynamic nature of forests and wildlife cause short term increases and decreases in preferred habitat naturally and according to our model projections the forestry activities planned should maintain Pileated woodpecker habitat within an acceptable range of the natural benchmark. The Forest Management Guidelines for the Provision of Pileated Woodpecker Habitat can be accessed here if you would like some background information: http://www.mnr.gov.on.ca/MNR_E000515.pdf
Q19What does the OWHAM provide vs SFMM - is this model unique to APP or is it used elsewhere (in other FMPs). OWHAM is the Ontario Wildlife Habitat Assessment Model, it is a spatial model which projects the area of available habitat for selected species based on the initial forest inventory and the proposed management strategy. SFMM is the Strategic Forest Management Model and it is a non-spatial that projects the available harvest area and volumes based upon inputs related to landscape, wildlife, and old-growth targets for the management unit. Both models are used provincially for every FMP produced. NOTE: Below answers are sourced from an independent wood supply audit done by KBM Forestry Consultants to provide a 3rd party perspective on the viability of the Ontario Parks recommendations to Lighten the Footprint. Full Audit here KBM 2006 Wood Supply Audit APPI have added my comments in Blue - for discussion on December 1 with the MNR.
Q20 Why does the Forest maintain higher than utilized harvest levels (ie 75% of the park or now with LTFP, 65%)? The MNR Wood Supply Report also describes the need to maintain higher than utilized harvest areas to ensure the availability of certain products, such as grade 1 sawlogs and veneer that are found in heterogeneous stands of lower grade material. In addition, transportation and localized use patterns within the Forest vary from one section to another.My interpretation is that popular is one such example of lower grade material, but Grade 1 sawlogs I would assume to be Sugar Maple for furniture/flooring since Maple does not grow in a homogeneous stand. The other statement supports my assertion that increased harvest targets allow for more roads, and through examination of the Financial Statements (These will be posted below on the fact sheet) The AFA recieves $2M a year for roads from the MNR for any road that is shared, therefore the logging community builds roads for free..its therefore cheaper and easier to just build a road to get to the tree than figure out a more efficient method of harvest. Q21 What could be done to reduce the footprint without affected the fibre quota? Other models such as Patchworks2 might be better suited for further analysis. Patchworks is capable of integrating operational and strategic analyses, as spatially explicit harvest allocations can be developed over long-term planning horizons. One of the benefits of a spatially explicit analysis is that it can allow for various weights to be placed on operating areas. For example, a win-win scenario may be found by assigning different weights in the harvest scheduling process to areas with high recreation and/or ecological value. These weightings would mean that harvest is avoided as much as possible, but not fully prohibited, within these areas. This could reveal opportunities for protecting recreational and ecological values while maintaining an economically viable wood supply. If warranted, the framework and extent of further analysis should form part of the negotiation and discussion process. It should be noted that analyses are costly and time consuming and cannot fully eliminate uncertainty. However, further analysis can reduce uncertainty and explicitly define the trade-offs. Above all, the usefulness of computer simulation is in decision support not decision making.Using GEO spatial software instead of the SFMM which is non-spatial and tabular (ie rows of data), is what I discussed with the MNR in early November on the phone and was told the spatial software would not be available until 2010 (after the plan). My position is that the plan can be re-drafted with this new software to accommodate increased protection zones. Q22 What is the difference between standing timber sales and product sales when reported as Revenue by the AFA? Per The Forest Owners Guide To Federal Income Tax The following definitions: Date of Disposal: This is the date the timber is cut. Defintion of "cut" It is not generally practical to measure timber in the woods as it is cut, so "cut" is more often defined as the date of disposal first determined, which could mean at a log landing, wood yard or mill. This definition of cut is used to the advantage by owners to qualify for Section 631(b) which is capital gains status that allows you to report at a lower tax rate than if it was reported as revenue. The owner must have ownership of the lumber long enough to qualify for this exemption, often at time it is felled, it is not long enough, but practical consideration for the time it was measured often means the holding period is met. Defintion of Owner: An owner is any taxpayer who has the right to cut and sell timber. If however, the contract includes stumpage fees, the cutter is simply performing a logging service and do not qualify as an owner. Definition of Product sales: When standing timber is cut, and the logs or products manufactured from them are sold, the entire proceeds must be reported as ordinary income (unless section 631a).Based on my crude understanding 631a does not apply since this is crown timber. The main point here is that Product sales are reported as Revenues by the AFA using the GAAP rule below. What is GAAP rule the AFA uses to recognize timber revenue? Revenue from product and standing timber sales and forest renewal charges are recognized when the wood is delivered.
Question for MNR: What does delivered mean - is it to the mill? Or if not where?
This whole bullet is to qualify my assumption that the logger gets paid to cut wood, but the crown doesn't get to report it as revenue until it is milled which is why we have Accounts Receivables in the range of $4M. For clarification. The assumption here is "cut" is a definition the logging industry can use to its advantage which means merchantable wood owned by public interests is controlled by private enterprise. To be cross referenced with Pricing and Tenure issues.
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 Mr. Winters:
I have taken considerable time to review the Algonquin Provincial Park Draft Plan for 2010-2020 published on December 1, 2009. I have several serious issues with the Draft plan. As an aside, I note with frustration the plan is no longer available for electronic review on the EBR website. Having a public review of Draft Plan demands the Ministry provide the plan throughout the entire 60 day inspection period. Disabling the website discourages public involvement. Please consider this letter a formal request for issue resolution.
Please confirm receipt of this letter (via email) and the two attachments.
Thank you
Attachments: Mill Commitment by Species, sawlogs and poles
Old Growth Stands in APP (Jpeg)
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.[1]
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.
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:
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.
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.
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.
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 asserts an unproven, manual modelling methodology (excel spreadsheets labelled Shelterwood Harvest Proportion Estimator) that utilizes “local expert opinion” of unnamed sources that cannot be peer reviewed. The FRI inventory has not been reconciled to support the 2010 fibre quotas. The 2010 Plan is not sustainable. The 2010 planning assumptions cannot be validated and are not sustainable. The planning approach and methodology in 2010 is incongruent with previous planning assertions, and in some cases, contradictory
Implications: The implications of this unproven and poorly substantiated approach to predictive modelling can be seen by comparing the 2005 natural benchmark and habitat predictions for the Pileated Woodpecker to the 2010 natural benchmark and resultant habitat predictions for the same species.
The 2005 data was taken directly from the 2005 Forest Management Plan. To overlay the 2010 data, I manually plotted values from the graph presented in the 2010 plan since it was only provided conceptually in PDF format. I ask that you review the above graph and confirm its correctness.
I find the disparity of results between two plans issued by the same planning team a mere 5 years apart disconcerting, especially when viewed within the context of the following facts:
The 2005 plan predicted a habitat loss of > 100,000 ha with a 10 year period. This is impossible even under the most aggressive harvest conditions. Both plans have considerable flaws in their assumptions and management approach. For example:
The 2010 plan states:
The result of these changes is a forecasted yield that is higher than what was originally being produced by SFMM. This new yield is 16% higher than the overall yield forecast in the 2005 FMP and is generating 19% more volume in the first term of the model (from a similar total harvest area). The total average forecasted yield in SFMM for the 2010 Proposed Management Strategy is now 57.4 m3/ha which is more consistent with historical yields and is almost identical to the actual yield realized in the recently submitted 2007-08 annual report.
The 2005 FMP stated:
The total forecast utilization in this plan has increased by 1,048,710 m3 from the last forest and is close to current levels of harvest. While the total available harvestvolume has only increased by 284,121 m3, there is no unutilized harvest volume identified in thisplan as there was in the 2000 FMP. All available harvest volume is being forecast for utilization with an increase of 511,916 m3 of open market volume from the 2000 FMP
How can the 2010 plan increase yields by 16% over 2005 when the 2005 plan stated “all available harvest volume is being forecast for utilization”. There is no cohesion between the 5 year plan forecasts, or their planning assumptions, theory, and approach. Worse, each plan continues to forecast increased percentiles of yield that will result in ever higher volumes, without actual inventory reconciliation. This is another shortcoming of a plan that is done without access to accurate FRI using a non-spatial modelling application.
Practically this cannot be ignored, because if we are to assume the 2005 planning assumptions are even directionally accurate, with the increased volumes forecast in 2010, the forest will literally run out of trees.
KBM Forestry Consultants published a comparison of planned versus actual yields for the Forest for terms beginning 1985. They state actual yields have historically surpassed planned yields by approximately 30-35% for the 2 terms previous to 2005. The also state the average yield achieved in the previous 10 year period was 57 m3/ha (1995-2005)
Using a combination of manual spreadsheets, conjecture, and extrapolations from scientific papers (elements of the Landscape Guide), the 2010 plan asserts the plan yield forecast is consistent with this historical yield trend of 57.4 m3/ha. There is no evidence in the 2010 plan to state this is anything more than a business plan architected to meet business targets. The KBM Auditor acknowledges this in their 2006 APP Wood supply analysis:
Ontario’s growth and yield data base is growing, but most estimates of growth and yield are still basedupon expert opinion rather than empirical evidence. Therefore, estimated changes to the forest over time also have a large measure of conjecture built into forecast. Even where empirical evidence exists, yield estimates based on broad strata and age rarely illustrate a strong correlation to the data. Irrespective of the methodogy used to formulate growth predictions, our forecast are always restricted by our incomplete knowledge of the current and future states of the ecosystem[2]
Further, it is illogical and wrong to assume that a plan forecast is sustainable or correct when the assumption ignores the volumes by tree species, and the physical and finite land base they occupy.
You acknowledged this in your 2005 FMP by stating:
“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 lookingat average yield per hectare and comparing to known standards. “
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.
Recommendations:
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.
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.
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.
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.
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 increased almost 600% 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.
The above analysis was compiled from AFA Income Statements issued by the Ministry of Finance. Some observations:
-Direct program costs (cutting, hauling) are not offset by product sales.
-In spite of increasingly aggressive plan yields, product sales have declined 25% since 2006
-Losses are understated. The Ontario Taxpayer contributes $2M annually in the form of road subsidies
-Stumpage fees are in arrears. The cost to renew the forest has exceeded what has been collected from the customer (mills)
From a strictly financial perspective, it would be more cost efficient to simply leave the forest alone, since the cost of harvesting and regeneration is not being recovered. The economic outlook for 2010 and 5 years into the future offers little hope that the demand for wood products in Algonquin has increased. There is no market for pulp, and due to CFSA statutes, the mills must process pulp at a loss.
Yet in spite of all economic indicators to the contrary, we have a plan that states 16% more fibre will be harvested over the 10 year term, with 91% increased volume allocated to the open market.
There has been considerable media attention in the Pembroke and Whitney areas stating the precarious position these towns are in, and that the financial needs of these small towns must be met through the Algonquin harvest. I am sympathetic to the needs of Ontarians, and could concede that perhaps the only reason to harvest Algonquin which is actually a park, is to prevent further layoffs and bankruptcies. The harvest in the past 5 years at best could be considered workfare.
The Plan acknowledges all of this with the following summation:
Up until 2007, pulp mills actively increased their purchases of sawmill-produced pulp chips. This resulted in sawmills installing roundwood chipping plants at their mill yards. These chip mills use pulp quality hardwoods for raw material which has had a beneficial impact on forest utilization. Recently however, from 2006 to present (2009), the weakening economy has reduced demand for forest products worldwide and has resulted in numerous temporary and permanent mill closures across the province affecting all forest product sectors. The state of the forest industry of central and eastern Ontario is reflective of this global situation. There have been numerous pulp mill closures in the region resulting in reduced demand for low-end material.
However, with a material allocation of fibre to open market operators, the fibre quota mix proposed in the 2010-2020 plan intentionally competes with fixed price mills, and instead of supporting the mills, or the people of Ontario, this plan has the opposite effect. Increasing open market quotas will increase supply at the expense of demand. This is a fundamental principle of all capitalist markets. We know Forestry is not immune to the impacts of over supply, the Ministry of Mines and Northern Development has been very clear that the future for Ontario wood supply is not secure unless market competitiveness is introduced.
Presumably in the assumption that all the fibre will be milled, the Plan has also predicted unprecedented annual stumpage fees in the millions (I cannot recall the number and the Plan is no longer available electronically). I do recall the forecast for stumpage fees was significantly higher than any actual reported in the last 4 years. When I inquired with the planning team how any of these financial targets could be met, I was told this exercise was not done and that my inquiry could not be addressed.
How can any of this be accepted as a truth, when the plan justifies the natural benchmark could not be sustained for economic reasons (The Old growth targets were reduced to 75% based on economic data that stated planning at 100% of the natural benchmark would not be economically sustainable.)
I asked point blank what specifically was economically impacted in the old growth evaluation (ie what trees would have to be harvested to meet the economic needs of the forest), and I was told this wasn’t known. This leaves me with two possible explanations:
- The plan has been architected without a sound business case and any economic assertions made to justify the harvest are mere guesses, made without the necessary financial underpinning. The Planning team doesn’t know.
- The information is purposely being withheld from me.
Neither option is acceptable, and both may seem harsh, but there is evidence of both. One example is the AR-11, which was previously published and distributed. The plan yield references the 2008 AR-11 as justification for harvest volumes, yet when I asked for the report, I was told the AFA no longer issues this report to the public. Why?
How can the Public make informed decisions on a draft plan when all evidence to support planning decisions is either not publicly available, or not actually known?
Conclusion: In summary, it is clear the fibre quotas allocated through fixed priced contracts for the existing mills are not sustainable, and to manage this exposure, the plan is hedging its bets against the community by spreading its risk, in the knowledge that the price of fibre will continue to fall. Ironically, the plan’s increased open market allocation will actually hasten the closures of the very mills the plan has pledged to support.
On a personal note, what is also obvious is that the Ontario Park recommendations for “Lightening the Ecological Footprint” were categorically ignored. The 2010 plan forecasts the most aggressive fibre quotas in at least 2 decades, at a time when the people of Ontario publically expressed their disapproval of logging in a provincial park. I personally feel Algonquin Provincial Park enjoyed the publicity of LTFP, but the actual impact LTFP had on the forest plan for 2010-2020 is nil. I find this particularly shameful.
Recommendations:
Regardless of financial motivation, reduced transparency, and market conditions, the mandate of the Ministry is to follow the CFSA. The 2010-2020 plan must be re-done with a management approach that follows the CFSA and plans first and foremost for ecological reasons.
ISSUE #4: Old Growth targets are not being met
.
I see no meaningful discussion taking place when definitions for Old Growth remain polarized. The Ministry has ignored any published scientific peer reviewed study that in simple lay person language states trees must be allowed to live and die in the forest in order to sustain the planet. White Pine, Red pine, Hemlock, Yellow Birch – all these species must be represented in a forest beyond the age of onset to meet CFSA requirements.
In spite of this, the plan takes a familiar position, and states the forest is unnaturally old and lacks younger, not older age classes. The plan states:
Figure 7 in the plan depicts a lack of younger age classes, especially 60 years of age and less. Heavy cutting prior to the turn of the century has caused this skewed age class structure. Future forest inventories will also show a lack of younger age classes (40 years and less) due to the use of the uniform shelterwood system. In these instances, the new forest is developing under the canopy of the original forest and the age of this new forest will not be depicted in the forest inventory until the original forest canopy is harvested (i.e. final removal cut).
What figure 7 ignores is the age classes > ~200 years (again, I’m working from my notes since I can’t present the graph here because the website is disabled). It’s a bell curve, yet the Ministry has chosen to focus only on certain aspects of the forest. As noted in Issue #2, we know aerial FRI inventory updates is biased to tree height and is highly unreliable in predicting what the actual age of the forest is. In spite of this, aggressive targets for hemlock and pine are planned for harvest. The Ministry has made this possible by defining old growth first by age of onset, and second, as an area (or stand) that has not been previously industrialized.
This is circular logic. By harvesting any existing stands that are not disturbed by humans, the state of the stand changes and by Ministry definition, is no longer defined as “old”. It’s a tactic that ensures the forest will never be returned to a pre-industrialized state which required 50% old growth stands. Table FMP-13 indicators are once again, evidence of nothing. The fact 100 indicators are met or all are met is irrelevant when policy decisions designed to meet fibre quotas override all scientific evidence to the contrary.
Recommendations:
1. Below is an old growth analysis performed by Dr. Peter Quinby. Revise the fibre quotas to protect these old growth stands.
[1]Algonquin Park Draft Forest Management Plan 2010-2020 Page 5, Plan Text
