Mr. John Winters January 13, 2010
District Manager
Algonquin Provincial Park
P.O. Box 219
Whitney, Ontario
K0J 2M0
Whitney, Ontario
K0J 2M0
Email: john.e.winters@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 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 harvest volume has only increased by 284,121 m3, there is no unutilized harvest volume identified in this plan 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 based upon 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 looking at 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.
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