Sapawe Forest Independent Forest Audit

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1 Sapawe Forest Independent Forest Audit Arbex Forest Resource Consultants Ltd. Oxford Mills, Ontario December 2012

2 Queen s Printer for Ontario 2012

3 TABLE OF CONTENTS 1.0. EXECUTIVE SUMMARY... I 2.0. TABLE OF RECOMMENDATIONS... III 3.0. INTRODUCTION AUDIT PROCESS MANAGEMENT UNIT DESCRIPTION CURRENT ISSUES SUMMARY OF CONSULTATION AND INPUT TO THE AUDIT AUDIT FINDINGS COMMITMENT PUBLIC CONSULTATION AND ABORIGINAL INVOLVEMENT FOREST MANAGEMENT PLANNING PLAN ASSESSMENT AND IMPLEMENTATION SYSTEM SUPPORT MONITORING ACHIEVEMENT OF MANAGEMENT OBJECTIVES & SUSTAINABILITY CONTRACTUAL OBLIGATIONS CONCLUSIONS AND LICENCE EXTENSION RECOMMENDATION APPENDICES List of Tables TABLE 1. RECOMMENDATIONS... III TABLE 2. AREA SUMMARY OF MANAGED CROWN LAND BY LAND TYPE... 4 TABLE 3. PLANNED VS. ACTUAL SILVICULTURE TREATMENTS ( ) TABLE 4. SILVICULTURAL SUCCESS RATES (%) BY FOREST UNIT (FU) List of Figures FIGURE 1. LOCATION OF THE SAPAWE FOREST... 2 FIGURE 2. PROPORTIONAL AREA OF FOREST UNITS ON THE SAPAWE FOREST... 3 FIGURE 3. AGE CLASS AREA DISTRIBUTION.... 5

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5 1.0. Executive Summary This report presents the findings of an Independent Forest Audit (IFA) of the Sapawe Forest conducted by Arbex Forest Resource Consultants Ltd. for the period of April 1, 2007 to March 31, Procedures and criteria for the IFA are specified in the 2012 Independent Forest Audit Process and Protocol (IFAPP). This audit addressed the forest management activities of the Ontario Ministry of Natural Resources (OMNR) Fort Frances District for the full audit term and Atikokan Forest Products Ltd. (AFP) (SFL # ) for the 3 year period between 2007 and The implementation of the 2005 and 2010 Forest Management Plans (FMPs) was negatively impacted by poor to non-existent markets for some species and products. The inability to harvest at planned levels negatively affected the achievement of FMP objectives dependent on the full utilization of the planned harvest area. The poor economy resulted in the closure and eventual bankruptcy of primary mills receiving wood from the Forest, and ultimately led to the cancellation of the SFL held by AFP. With the cancellation of the SFL, the OMNR Atikokan Area Office assumed full management responsibilities for the last year of the audit term. The inability to fully utilize the hardwood resource also limited the ability to economically harvest many low volume and/or poor quality stands. This resulted in stand by-pass or the adoption of second pass harvest strategies in mixed wood stands with a merchantable component of conifer. Without an improvement in markets, delays in the achievement of the desired future forest condition and associated benefits such as conifer wood supply and wildlife habitat can be reasonably expected. However, developments late in the audit term related to emerging markets for biofuel are expected to significantly improve hardwood utilization from the Forest. The failure to deliver consistent and effective tending during past management terms has become apparent as silvicultural effectiveness monitoring (SEM) in stands designated as free-to-grow (FTG) indicated higher than desired levels of hardwood in some forest units. Issues associated with the delivery of the tending program persist, although we did observe better competition control on sites treated during the latter years of the audit term when treatments had been undertaken earlier in the fall. We provide a recommendation for improvement in the delivery of the tending program. Notwithstanding the challenges and problems associated with low harvest level and the issues associated with the tending program, AFP and OMNR delivered a good forest management program. This included a successful renewal program, an effective silvicultural monitoring and assessment program, and a good record of compliance for all forest operations. Resource-based values were appropriately protected. Renewal and harvest operations were also generally in balance during the audit term. Forest management planning met all legal and regulatory requirements and resulted in the 2012 Sapawe Forest Independent Forest Audit i

6 production of a high quality 2010 FMP. During its tenure as the forest manager AFP largely met its contractual obligations. This audit report provides recommendations for improvements related to the submission of required forest management reports and in the delivery of the tending program. A requirement to implement an Issue Resolution Decision is also identified. We also provide a recommendation to Corporate OMNR to standardize a format for the calculation and reporting of regeneration and silvicultural success in Annual Reports, Silvicultural Effectiveness Reports and Independent Forest Audits. It is our conclusion that the Sapawe Forest is generally well-managed. The objectives of the 2005 and 2010 Forest Management Plans are consistent with the attainment of forest sustainability. Forest management practices were implemented in accordance with the Crown Forest Sustainability Act (CFSA) and the requirements of the FMP documents. We concluded that the relative small size of the unit and the small scale of forest management operations coupled with a hands-on management philosophy resulted in a high degree of local involvement and knowledge. In our opinion this effectively informed the forest management decision-making process and field operations. Based on our document review, interviews and site inspections the audit team concludes that forest sustainability is being achieved as assessed through the Independent Forest Audit Process and Protocol, and that the management of the Sapawe Forest was generally in compliance with the legislation, regulations and policies that were in effect during the term covered by the audit Sapawe Forest Independent Forest Audit ii

7 2.0. Table of Recommendations TABLE 1. RECOMMENDATIONS Conclusion and Recommendation on Licence Extension The audit team concludes that management of the Sapawe Forest was generally in compliance with the legislation, regulations and policies that were in effect during the term covered by the audit, and the OMNR met its legal obligations. Forest sustainability is being achieved as assessed through the Independent Forest Audit Process and Protocol. Recommendations Directed to the SFL Holder/OMNR District Recommendation # 1: The OMNR District must ensure that an amendment is made to the 2010 FMP concerning the Sky Lake Road as directed by the District Manager s Issue Resolution Decision. Recommendation # 2: The OMNR District must ensure that tending treatments are effective, are conducted in a timely manner, and where needed are implemented at multiple times during the development of the stand. The backlog in area requiring treatment must also be addressed. Recommendation # 3: The OMNR District Manager must ensure that the Action Plan and Action Plan Status Report responding to IFA Recommendations are completed within the specified timeframe. Recommendations Directed to Corporate or Regional OMNR Recommendation # 4: Corporate OMNR should provide direction to standardize the reporting format for regeneration and silvicultural success (including percent achievement) for Annual Reports, Silvicultural Effectiveness Monitoring Reports and Independent Forest Audit Reports Sapawe Forest Independent Forest Audit iii

8 3.0. Introduction This report presents the findings of an Independent Forest Audit (IFA) of the Sapawe Forest conducted by Arbex Forest Resource Consultants Ltd 1 for the period of April 1, 2007 to March 31, Until its bankruptcy in 2011, the Forest was managed by Atikokan Forest Products Ltd. (AFP) under the terms of SFL # The SFL was cancelled in July 2011 and the Fort Frances District, through its Atikokan Area Office, assumed management responsibility for the Forest. In May 2012, a five year business arrangement assigned management responsibility to Rainy Lake Tribal Resources Management Inc. under an Enhanced Forest Resource License Audit Process The Crown Forest Sustainability Act (CFSA) requires that all Sustainable Forest Licences (SFL) and Crown management units be audited every five years by an independent auditor. This audit applies to the Ontario Ministry of Natural Resources (OMNR) and all licencees on the former Sapawe Forest SFL. The audit reviews the applicable Forest Management Plan (FMP) in relation to relevant provincial legislation, policy guidelines and Forest Management Planning Manual (FMPM) requirements. This includes a review of field operations and monitoring and reporting functions. The audit reviews whether actual results in the field are comparable with planned results and determines if the results were accurately reported. The results of each audit procedure are not reported on separately but provide the basis for reporting the outcome of the audit. Recommendations within the report set out a high level directional approach to address a finding of non-conformance. In some instances the audit team may develop recommendations to address situations where a critical lack of effectiveness in forest management activities is perceived even though no non-conformance with the law or policy has been observed. A further discussion of the audit process is provided in Appendix 4. The procedures and criteria for the IFA are specified in the 2012 Independent Forest Audit Process and Protocol (IFAPP). The FMPs within the audit scope include the FMP (last 3 years of implementation) and the FMP (first two years of implementation and the planning and development process) Management Unit Description The Sapawe Forest is located northwest of Lake Superior, approximately 200 km west of the City of Thunder Bay. Other communities which receive wood supply from the Forest include Atikokan and Fort Frances. Quetico Provincial Park borders the Forest 1 A list of the audit team members and their qualifications is presented in Appendix Sapawe Forest Independent Forest Audit 1

9 on the south (Figure 1). The Crossroute Forest is situated at the southern and western boundaries of the Forest. FIGURE 1. LOCATION OF THE SAPAWE FOREST Source: OMNR The Forest occupies an area of 3,015 square kilometres (km 2 ), of which 22% is water. Less than 1% is comprised of patent land. Parks, protected areas and conservation reserves occupy approximately 6% of the land base (17,188 hectares (ha). Much of the Forest is situated within the Quetico section of the Great Lakes St. Lawrence Forest Region, although a portion of the management unit is located in the Upper English River section of the Boreal Forest Region. The Forest is typical of the transition zone between the Boreal and Great Lakes St. Lawrence forests. The broad character of the forest is Boreal in nature (see Figure 2). Elements of the Great Lakes St. Lawrence Forest Region are exemplified by the presence of white and red pine. Production forest land occupies 196,738 ha. Table 2 provides an area summary of managed Crown land by land type Sapawe Forest Independent Forest Audit 2

10 50,000 45,000 40,000 35,000 30,000 Area 25,000 20,000 15,000 10,000 5,000 0 Forest Unit 1 BwDom CeLa CoMx1 CoMx2 HwMx1 HwMx2 PjDom PoDom PrDom PrwMx PwMx SbLow SpDom FIGURE 2. PROPORTIONAL AREA OF FOREST UNITS ON THE SAPAWE FOREST 2 Source: Table 2010 FMP 2 Forest Units are as follows: PrDom=red pine dominated, PrwMx=red and white pine mixedwood, CeLa=white cedar and larch, SpLow=spruce lowland, SpDom=spruce dominated (upland), PjDom=jack pine dominated, CoMx1=conifer mixedwood 1, CoMx2= conifer mixedwood 2, PoDom=poplar dominated, BwDom=white birch dominated, HwMx1= hardwood mixedwood 1, HwMx2= hardwood mixedwood 2 and PwMx=white pine mixedwood Sapawe Forest Independent Forest Audit 3

11 TABLE 2. AREA SUMMARY OF MANAGED CROWN LAND BY LAND TYPE Managed Crown Land Type Area (Ha) Non-Forested 69,562.8 Non-Productive Forest 13,887.9 Protection Forest 3 1,926.1 Production Forest 4 Forest Stands 169,218.3 Recent Disturbance 12,234.1 Below Regeneration Standards 5 15,286.5 Total Production Forest 196,738.9 Total Forested: 212,552.9 Total Crown Managed: 282,115.7 Source: Table FMP There are four Aboriginal communities with interests and/or traditional uses within the Forest; Lac des Milles Lacs First Nation Lac la Croix First Nation Seine River First Nation Wabigoon Lake First Nation Wildlife resources are abundant due to the location of the Forest in the transition zone between forest regions. Common species include moose, black bear, marten and lynx. Small game species include snowshoe hare, ruffed grouse, spruce grouse and a variety of waterfowl. Species identified by the provincial Endangered Species Act (2007) that are known to occur (or thought to have been present) are the eastern cougar and whippoor-will. 3 Protection forest land is land on which forest management activities cannot normally be practiced without incurring deleterious environmental effects because of obvious physical limitations such as steep slopes and shallow soils over bedrock. 4 Production forest is land at various stages of growth, with no obvious physical limitations on the ability to practice forest management. 5 Areas where regeneration treatments have been applied but the new forest stands have yet to meet free-to-grow standards Sapawe Forest Independent Forest Audit 4

12 An imbalance in the age class structure exists which can be characterized as disproportionately mature to old (Figure 3). Relative to the other age classes, there are age class area deficiencies in the year age class and the year age class. There is also a disproportionate area in the year age class. The large proportion of mature forest has implications for the provision of a balanced wood supply and the habitat for some species in subsequent planning terms, as the forest transitions to younger age classes through harvesting, natural succession and/or natural disturbances. The age class imbalance is more pronounced for conifer dominated forest units Area (Ha) Age Class FIGURE 3. AGE CLASS AREA DISTRIBUTION. Source: 2010 FMP Current Issues Bankruptcy of AFP and the Cancellation of the SFL The economic downturn in Ontario s forest sector resulted in a significant reduction in harvest activity on the Forest. During the audit term manufacturing facilities receiving wood from the Forest were idled and/or closed. In 2011, the SFL held by AFP was cancelled and the Fort Frances District, through its Atikokan Area Office, assumed management responsibility for the Forest. The decline in harvest activities resulted in the underachievement of several forest management plan objectives and reduced revenues for silviculture and road construction and maintenance. The lack of hardwood markets has also constrained the 2012 Sapawe Forest Independent Forest Audit 5

13 conifer supply available from mixedwood stands. This circumstance has resulted in challenges to the implementation of intensive silvicultural ground rules. Restoration of White Pine The white pine restoration program is reliant on artificial renewal on suitable sites. The renewal of white pine has been challenged by difficult site conditions and species susceptibility to white pine weevil and white pine blister rust. Pest management and disease control on relatively small areas renewed to white pine could pose future operational management challenges. Age Class Area Structure Much of the productive forest area is mature to over mature (44%), due to wildfire suppression, limited harvesting, tourism concerns and poor accessibility to areas of older timber. A continued inability to achieve planned harvest targets will have future implications for the provision of a balanced wood supply and habitat for some wildlife species. Remote Tourism and Other Forest Uses There are a significant number of remote tourism operations situated within the Forest. Balancing the needs of the forest industry with the needs of other forest users has historically been a challenge Summary of Consultation and Input to the Audit Details on public consultation and input during the audit are provided in Appendix 4. A public notice and an invitation to provide comment and/or complete a survey on the Arbex website was placed in the Atikokan Progress. Additionally, a random sample of 35% of the individuals and organizations listed in the 2010 FMP mailing list were sent a letter and a questionnaire requesting input to the audit process. All First Nations (FNs) with an interest in the Forest were contacted by mail with an invitation to participate and/or express their views on the management of the Forest during the audit term. Follow-up contacts were made with all FNs and interviews were held with interested respondents. A member of the LCC and a logging contractor participated in the field audit and other members of the LCC were interviewed. Additional interviews were conducted with tourism industry representatives, cottagers, Bear Management Area licencees, trappers and anglers and hunters. OMNR District and Regional staff participated in the field audit and/or were interviewed by the audit team Sapawe Forest Independent Forest Audit 6

14 4.0. Audit Findings 4.1. Commitment The IFAPP commitment principle is deemed to be met since AFP had obtained Sustainable Forest Initiative (SFI) certification (QMI-SFIS ). OMNR has updated policy and mission statements which have been widely distributed by internal newsletters and are prominently displayed on office bulletin boards and the OMNR website. All contacted staff were aware of OMNR direction, sustainable forestry commitments and Codes of Practice. Our assessment is that all commitment requirements were met Public Consultation and Aboriginal Involvement Standard Public Consultation FMPM public consultation requirements for the development of the 2010 FMP and amendments to the 2005 and 2010 FMPs were met. All the constituencies contacted during the audit (tourism, trapping, LCC members, forest industry, other interest groups) indicated that they had been made aware of the FMP process and that they were provided with opportunities to become involved and to identify values. Our sampling of OMNR s public correspondence documents indicated that all communications were appropriately documented, timely responses were provided, and public comments were considered in the approved FMP. Some of the public consultation dates for the 2010 FMP planning process were delayed by up to 3 to 4 months. Enough flexibility had been built into the planning process schedule that the approval of the plan was not affected. Interviews with some individual stakeholders and some members of the planning team indicated that there was erosion in communication between the forest managers and the general public following the bankruptcy of AFP. This period coincided with a heavy staff focus on the 2010 planning process and other causal factors 6.associated with the unprecedented downturn in the forest industry. We do not make a recommendation on this issue since conditions related to the identified concerns have stabilized and there are indications that communications have since improved. 6 Factors included; the bankruptcy AFP s parent company in 2009; the appointment of an interim Forest manager from 2009 to 2011and related changes in planning team members and the assumption of management responsibilities by OMNR Sapawe Forest Independent Forest Audit 7

15 Issue Resolution Opportunities to make a request for Issue Resolution or an Individual Environmental Assessment (IEA) were clearly identified in the planning processes (2010 FMP development, 2005 and 2010 FMP amendments) conducted during the audit term. One formal issue resolution request was received during the preparation of the 2010 FMP. The issue resolution process implemented was consistent with 2009 FMPM requirements and resolved at the District Manager Stage. The part of the District Manager s decision which involved construction of the Sky Road and the harvest of associated blocks was to be implemented by way of an amendment, (including public consultation) to the 2010 FMP. The decision has not been implemented in the two and a half years since the approval of the 2010 FMP. It is important that the decision be implemented as soon as possible in order to preserve the integrity of the Issue Resolution Process. We provide a recommendation to address this concern (Recommendation # 1, Appendix 1). Individual Environmental Assessments No requests for an Individual Environmental Assessment were received during the audit term. Local Citizens Committee The Atikokan Resource Management Advisory Committee (RMAC) is a standing local citizens committee whose members are appointed by the OMNR District Manager and include representatives from Aboriginal communities and specific interests groups (e.g. trappers), as well as "representative citizens" with a more general interest in the Forest. The Terms of Reference for the LCC were been regularly reviewed and updated (e.g and 2012) as required. The Committee was actively involved in the implementation of the 2005 FMP. Minutes of Committee meetings show on-going involvement providing advice and comment on the full range of plan implementation activities (e.g. Annual Work Schedules, Compliance activities, road construction, etc.). For the development of the 2010 FMP a committee member participated on the planning team, and there were regular updates to the full committee. RMAC participated in nine joint meetings with the planning team. RMAC members expressed a high level of satisfaction with efforts by the OMNR and forest industry to keep them informed. We note that the LCC self-evaluation report indicated the members felt that they had provided value to the forest management planning and implementation processes. The LCC statement in the 2010 FMP states "... the MNR, the Sapawe Forest Planning Team, and RMAC were able to come to a positive consensus in a friendly non- confrontational manner which is a tribute to mutual respect in a small community." Our assessment is that the LCC was effective, well managed and productive Sapawe Forest Independent Forest Audit 8

16 Aboriginal Participation While there are no First Nations (FNs) located within the Forest the adjacent communities of Seine River First Nation, Lac La Croix First Nation, Wabigoon Lake Ojibway Nation and Lac Des Mille Lacs First Nation identified interests on the Forest. For the development of the 2010 FMP, all FMPM requirements for Aboriginal involvement in the forest management planning process were met. An information session was conducted in the Wabigoon Lake community and the Seine River and Wabigoon Lake FNs provided representatives to the Planning team. Aboriginal Background Information Reports and Community Demographic Profiles were updated for the development of the plan. Our discussions with OMNR staff indicated that there was a general lack of Aboriginal Values Information available for the planning process. Our assessment is that the OMNR took all reasonable steps to obtain additional information; however, the decision to provide that information, and to what extent, rested with the individual FN. OMNR utilized what it had, and where additional information was provided, values maps were updated. The OMNR produced Condition 34 Reports 7 during each year of the audit term. Report format and content met all requirements. Employment opportunities were provided to FN individuals at local mills and in woodlands and silvicultural operations (e.g. Rainy Lake Tribal Contracting Ltd.). A significant development was the signing of a five year business arrangement (May 2012) which assigned management responsibility to Rainy Lake Tribal Resources Management Inc. under an Enhanced Forest Resource Licence Forest Management Planning Despite the challenges of the forest sector downturn and turnover in planning team membership, AFP and OMNR staff produced a high quality forest management plan. Despite the failure to meet some original checkpoint dates and some public consultation dates the FMP was approved on time 8. The management unit description in the 2010 FMP met or exceeded the requirements of the FMPM. Management unit inventory information (e.g. Forest Resource Inventory (FRI)) and other descriptive information (i.e. historic forest conditions) was effectively integrated into the FMP and was appropriately used to inform the development of plan objectives and strategies, the Long Term Management Direction (LTMD) and other forest management activities and operations contemplated in the FMP. The social and economic description, the interpretation of those data in the local context, and the assessment of economic value to the local community were excellent. 7 Condition 34 from the 2003 Class Environmental Assessment requires OMNR District Managers to conduct negotiations with Aboriginal peoples to identify and implement ways of achieving a more equal participation in the benefits provided through forest management planning. 8 Some checkpoint dates were 200 days behind schedule and some public consultations dates were delayed by 3-4 months Sapawe Forest Independent Forest Audit 9

17 However, we note that adequate data for First Nation communities and the tourism industry were not available to the planning team. The lack of data makes it more difficult to assess the socio-economic impact of forest resource allocation and management decisions on these constituencies. We do not provide a recommendation to address this concern as the lead responsibility for the collection of socio-economic data on FNs and the tourism industry does not rest with the OMNR or the forest industry. The assessment of the social and economic impact of the Proposed Management Strategy (PMS) was made using a non-modeling Analysis Process [2] which compared differences between the 2005 and proposed 2010 FMP related to timber volume, silvicultural expenditures and non-timber activities and values. The FMP (Table 17) summarizes this assessment for various activities (e.g. tourism, mining) and identifies positive and negative impacts of the PMS on non-timber activities as well as possible management solutions to address these concerns (e.g. the need for specific harvest block design and area-of-concern prescriptions to minimize the impacts of forest management operations on visual and acoustic aesthetics values important to ecotourism). We concluded that the use of this approach was appropriate, and concur with the planning team s conclusions about the socio-economic impact of the PMS. The number of required alterations to the plan was relatively small (~300). Our review of the alterations indicated that they were required, appropriate and incorporated into the FMP. Our 30% sample of FMP Amendments and Annual Work Schedules lead us to conclude that amendments were thoroughly prepared, documented and completed in a timely manner. It is our assessment that the Strategic Forest Management Modeling (SFMM) was well done. Inputs into the model (i.e. land base areas, etc.) and the decision rules (i.e. natural succession rules, fire cycle, etc.) were reasonable and appropriate to conditions on the Forest. Wood supply commitments (165,000m 3 /year for Spruce/Pine/Fir (SPF), 100,000 m 3 /year poplar and 28,000m 3 /year white birch) were not met for all terms modeled. SPF commitments were met in later management terms (after Term 6). Poplar and white birch commitments were slightly underachieved. Future FMPs will need to consider reduced or an alternative wood supply for hardwoods. We do not provide a recommendation to address this concern as SFMM modeling for the development of the next FMP will address the sustainable wood supply. We note that hardwood yields have historically been over-estimated when compared to volumes realized from operations. The planning team was aware of this issue and appropriately reduced projected hardwood yields. A comparison of planned vs. actual yields during the development of the next FMP is expected to further refine hardwood yield estimates so we do not provide a recommendation to address this concern. [2] This process is allowed when timber volumes do not exceed the previous plan volumes by more than 10% Sapawe Forest Independent Forest Audit 10

18 Silvicultural Ground Rules (SGRs) 9, Silvicultural Treatment Packages 10 (STPs) and Forest Operations Prescriptions (FOPs) were appropriate for the forest cover types and site conditions. All planned harvest, renewal and tending activities were consistent with achievement of the Long Term Management Direction (LTMD). We are concerned that SGRs have not been fully implemented with respect to tending requirements and discuss this issue in Section 4.4. A recommendation is provided (Recommendation # 2, Appendix 1). Forecast renewal activities were consistent with those projected in SFMM and supported the achievement of FMP objectives. Area of Concern (AOC) prescriptions were developed for identified values. Species at Risk (SAR) listed under the Endangered Species Act and dependent on the Sapawe Forest were appropriately considered in the 2010 FMP. Objectives and protection measures associated with those species were developed 11. All requirements for the protection of resource based tourism values were addressed, from initial consultations through to the protection of values by use of AOC s and Resource Stewardship Agreements. We conclude that planning process for the 2010 FMP met FMPM requirements and that a high quality management plan was produced in spite of the problems and challenges which arose as a result of the bankruptcy of the SFL holder Plan Assessment and Implementation The full implementation of the FMPs was negatively impacted by the economic downturn in Ontario s forestry sector. Lower than planned harvest levels resulted in the underachievement of planned targets for post-harvest silvicultural treatments. Table 3 presents the area planned vs. the area treated during the audit term. A further discussion of the delivery of the forest management program on the unit is provided in the following sections. 9 Silvicultural Ground Rules specify the silvicultural systems and types of harvest, renewal and tending treatments that are available to manage forest cover and the type of forest that is expected to develop over time. 10 A Silvicultural Treatment Package is the path of silvicultural treatments from the current forest condition to the future forest condition. STPs include the silvicultural system, harvest and logging method(s), renewal treatments, tending treatments, and regeneration standards. 11 For example, an AOC was developed to protect whip-poor-will nesting sites and the FMP provides for AOC protection of cougar dens should any be located Sapawe Forest Independent Forest Audit 11

19 TABLE 3. PLANNED VS. ACTUAL SILVICULTURE TREATMENTS ( ). Activity Planned Area (Ha) Actual Actual Actual Actual Actual Total Area Treated (Ha) Percent of Planned (%) Normal Harvest Salvage Harvest Renewal 10, ,633* 3, , < 1 Natural 4, N/A Artificial Total Renewal Site Preparation Plant 4, , Seed 1, ,668 1, , , , Tending 4, , Precommercial Thinning Harvest During the audit term the area and volume harvested was well below planned levels due to weak market conditions and mill closures, higher than anticipated bypass, lower than anticipated stand volumes and the diversion of harvest to salvage areas. Conifer utilization was marginally higher than hardwood utilization. All harvesting operations utilized the clear cut silvicultural system. Salvage harvest 12 accounted for 6% percent of the actual area harvested. Salvage operations focused on timber damaged in a 2007 blowdown event which affected an estimated area of 3,971 ha. A lack of markets and the remote location of salvage harvest blocks in the northern portion of the unit resulted in operations on 199 ha which yielded 23,055m Salvage harvest is defined as the recovery or harvesting of timber that has been killed or damaged by natural causes, such as fire, wind, flood, insects and disease. 13 Salvage harvest volume was comprised of 22,533m 3 of conifer species and 522 m 3 of hardwood Sapawe Forest Independent Forest Audit 12

20 The lack of markets for hardwoods during the audit term resulted in the redirection of the harvest into conifer dominated stands 14. The implementation of second pass harvesting strategies 15 in mixed wood stands and the collapse of the hardwood markets resulted in some instances where wood was left in the bush 16. The FMP LTMD is reliant on intensive silviculture practices to address issues of medium term wood supply and long term wildlife habitat supply. If hardwood markets were to remain weak, the inability to fully harvest stands containing merchantable aspen or birch may limit the area available for intensive silviculture treatments 17 and reduce the survival or growth of desired crop trees. This could result in unplanned forest unit transitions to hardwood dominated forest types. We note that the low harvest levels and efforts to market wood somewhat mitigated hardwood utilization issues during the audit term. Additionally the award of an annual supply of hardwood fibre to Atikokan Renewable Fuels through the Stage II Provincial Wood Supply Competitive Process (January, 2011) and the announcement by Ontario Power Generation (OPG) that it will convert its Atikokan Generating Station from coal to biomass fuel should dramatically improve hardwood utilization and mitigate the issues identified with respect to weak markets for hardwood. We provide a further discussion of this issue of hardwood utilization in Section 4.7 During the audit we visited 13% of the area that was harvested during the audit term. All sites inspected were approved for operations in the AWS. Harvest prescriptions were implemented in accordance with the Silvicultural Ground Rules (SGRs) and individual forest operations prescriptions were prepared and appropriately implemented on each block. It is our assessment that harvesting operations were generally in compliance with all applicable guidelines and with AOC prescriptions associated with the harvest site. There was little evidence of site damage. This lack of damage is noteworthy given that a proportion of the harvest (~19%) occurred on Ecosites 11 and 12 where modified practices and exception monitoring were required to protect shallow soils 18. Forest Operations Inspection Reports (FOIPs) for the audit term confirmed our finding that there were relatively few issues of non-compliance associated with harvest operations (See Section 4.6). 14 Harvest approvals required a minimum 70% of conifer and maximum 30% hardwood content for mixed wood stands. 15 Second pass harvest operations where only the first pass has occurred by the expiry of the current forest management plan. These areas are identified to allow for completion of the harvest in subsequent plans. 16 It is our understanding that approximately 9,250 m 3 of unutilized poplar remains in the bush and that it has deteriorated to an unmarketable condition. This issue of marketing the fibre was complicated by the bankruptcies of AFP and Buchanan Woodlands Inc. during the audit term. We were informed that OMNR is investigating the possibility of utilizing the wood as hog fuel at the Resolute Forest Products mill in Fort Frances, but low natural gas prices had hampered initiatives to market the material as biofuel. 17 Residual hardwood trees can reduce the effectiveness of silvicultural treatments (site preparation, artificial renewal, aerial tending), reduce the area available and result in the suppression and mortality of desired crop tree species by competing hardwood seedlings. 18 Full tree harvest on Ecosites 11 and 12 is an exception to the Silviculture Guide to Managing for Black Spruce, Jack Pine and Aspen on Boreal Forest Ecosites in Ontario Sapawe Forest Independent Forest Audit 13

21 Renewal, Tending and Protection Renewal As a result of the shortfall in achieving harvest targets renewal targets were not achieved. However, the actual area renewed is generally in balance with the actual area harvested (80% of the area harvested was renewed). This level of accomplishment largely reflects renewal initiatives by the OMNR after the cancellation of the SFL. Artificial renewal techniques were more frequently adopted than natural renewal strategies because the SGRs for the majority of the harvested blocks required seeding or planting as the preferred renewal treatment rather than natural renewal. Tree planting achieved 43% of planned levels and seeding achieved 48% of the planned level. Natural regeneration achieved 3% of the planned levels. The field audit examined 17% of the renewal activities implemented during the audit term. All inspected sites were approved in the AWS and were implemented in accordance with the applicable SGRs and silvicultural treatment packages (STPs). It was our conclusion that the renewal program was effectively implemented with renewed areas generally achieving high stocking levels of desired species. An objective of the 2010 FMP is to restore white pine on the Sapawe Forest. The pine restoration initiative is a minor component of the artificial renewal program 19. During the plan term white pine renewal targets were not fully achieved with approximately 110 ha of the planned 150 ha being planted with pine. White pine is highly susceptible to white pine blister rust (Cronartium ribicola) and damage by white pine weevil (Pissodes strobi). The success of the white pine renewal program is highly dependent on the identification of sites and prescriptions 20 suitable for establishment and growth. It will also be dependent on the capacity of the forest manager to monitor and implement control measures on a relatively small scale across dispersed sites. Our discussions with OMNR staff indicated that they were well-aware of the issues and challenges associated with white pine renewal. Our site inspections included a stop at a white pine renewal site established in a previous management term where weevil and blister rust damage was prevalent and several audit term sites where pine had been successfully established. On these sites there was evidence of good planning to reduce the potential for tree mortality and damage (e.g. pine was planted on upper aspects to for improved air circulation and on well-drained sites). The objective of restoring white pine on the landscape is laudable from the perspective of biodiversity conservation. Biodiversity objectives associated with the renewal and 19 The pine renewal program (red and white pine) comprises approximately 4% of the artificial renewal program. The annual target for white pine renewal during the audit term was 38,000 seedings/year. 20 Planting in mixtures as opposed to pure plantations, under planting rather than planting in open areas etc Sapawe Forest Independent Forest Audit 14

22 conservation of pine are being met, albeit on a small scale. An effective silvicultural monitoring program is in place and proper planning and selection of sites occurred during the audit term. Site preparation activities achieved 34% of the forecast levels. Mechanical site preparation treatments were completed on 1,573 ha of the planned 4,574 ha. Chemical site preparation was also used less frequently than planned with approximately 49% of the planned area receiving treatment. The lower than forecast levels of site preparation are a result of reduced harvest area, difficult site conditions (e.g. shallow soils, exposed rock) and other areas having favourable conditions for direct renewal treatments. It is noteworthy that an effective prescribed burn (139 ha) was implemented in While the primary objective of the exercise was to research fire behaviour(s) and to reduce the fire hazard in storm damaged areas, the burn was effective in promoting the renewal of jack pine on the treated area. Site preparation activities inspected in the field were effective in exposing mineral soil for either planting or seeding and we did not observe any environmental damage. Tending A strategy in the FMPs is to implement intensive silviculture activities (artificial renewal, tending, and pre-commercial thinning) as a means to offset projected wood supply shortages. The success of the strategy is contingent on FMP targets for harvest being largely achieved. Effective thinning programs can yield higher volumes per unit area by concentrating growth on fewer stems while tending promotes the establishment and optimal growth of desired crop tree species by reducing site competition for resources. Harvest, tending and pre-commercial thinning targets fell well short of projected levels which delayed progress towards addressing the projected volume shortfall. Precommercial thinning achieved only 24% of the forecast area (750 ha planned vs. 180 ha treated). The small scale of the thinning program suggests that the volume contribution from thinning will not significantly contribute to future stand volumes. Chemical tending achieved 49% of the forecast target as a result of the lower-thanplanned harvest levels. Tending activities were conducted in compliance with all laws and regulations and conformed to activities approved in the FMPs. A backlog in the area requiring tending currently exists (4,000 ha) due to poor weather conditions which resulted in the cancellation of spraying treatments and/or difficulties in securing contractors during the seasonal spray window 21. The procurement of aerial herbicide contractors was negatively affected by competition for services from management units with larger programs. The use of fixed-wing aircraft is currently being examined as an alternative to the use of helicopters. We believe this is a progressive and innovative approach to address a longstanding issue. 21 Spraying had occurred too late in the fall after leaf discolouration limiting the effectiveness of the application Sapawe Forest Independent Forest Audit 15

23 Our site inspections indicated that the effectiveness of the tending program was variable. On some ecosites competing vegetation had been effectively controlled while on others the increased presence of hardwoods was resulting in stand species compositional shifts. Additional tending will be required to achieve the desired forest unit. FTG survey reports indicate that the principle factor affecting the FTG status of renewed areas is the abundance of competition. The abundance of competition was attributed to ineffective tending treatments in past management terms. Our review of recent FTG results indicates that white birch remains pervasive in the understory particularly within the conifer mixedwood, hardwood mixedwood, and upland spruce forest units after an initial spray treatment. OMNR silvicultural effectiveness monitoring results confirm our field observations with respect to the variability in the effectiveness of the tending program. The SEM report states The abundance of competition can be attributed to a lack of effective tending treatments over the past few years This trend is not believed to continue; in more recent compliance inspections (2009) four of four inspections noted that the herbicide application was very effective. The 2010 SEM report indicates that The stands generally meet the targets and requirements of the SGRs but since there has been a severe reduction in the amount of tending, the stands are showing potential signs of conversion. We provide a recommendation to address the backlog in area requiring tending treatments and to ensure that tending treatments are effective, are conducted in a timely manner, and in some instances are implemented at multiple times during the development of the stand (Recommendation # 2, Appendix 1). We note that the legacy of ineffective tending treatments in previous management terms is becoming evident in silvicultural effectiveness monitoring surveys conducted in stands which had been declared as Free-to-Grow 22 (FTG). The SEM report concluded that between the declaration of free-to-grow and complete crown closure, species composition can continue to change. In the absence of additional tending treatments after free-to-grow relatively pure conifer stands can become mixed. Species compositional shifts occurring after the free to grow declaration can result in inaccuracies in the FRI, inaccuracies in the forest unit designations used in forest management planning and inaccurate yield predictions. The post-ftg SEM monitoring undertaken by OMNR has enabled adjustments to successional pathways and other SFMM inputs where warranted. We do not provide a recommendation with respect to tending post free to grow stands as effective tending treatments applied early in stand development and/or at multiple times during stand development can reasonably be expected to moderate against future significant shifts in species composition. 22 Free-To-Grow stands meet stocking, height, and/or height growth rate as specified in the silvicultural ground rules and are judged to be essentially free from competing vegetation Sapawe Forest Independent Forest Audit 16

24 Slash Management The 2007 IFA provided a recommendation that AFP ensure that its slash management program was silviculturally effective. In response to the recommendation the 2010 FMP provides direction with respect to the management of roadside logging debris. Slash has been inventoried and classified according to its potential for use as biofuel or for treatment in conjunction with other mechanical site preparation activities. We note that with the identification of potential biofuel opportunities the slash pile burning program was curtailed in However, distance to biofuel markets (Fort Frances, Thunder Bay) and low prices for natural gas resulted in the removal of only 1,287 m 3 for biofuel. Slash management treatments were applied on 1,617 ha during the audit term. Treatments included piling and the spreading of chipper debris. Initially some problems were encountered with the depth of chipper debris but corrective actions were implemented to address situations where chipper debris depth exceeded 12 inches. Mechanical site preparation with disk trenchers through chipper debris and linear slash accumulations were undertaken to facilitate artificial renewal treatments. Renewal on areas managed for slash is being monitored to determine the effectiveness of the treatment strategy. We inspected several areas which had been furrowed and successfully renewed by planting. The 2010 FMP also provides for harvest areas to be made available to the public for the collection of fuelwood following the completion of the commercial harvest operation, and areas of roadside slash from past harvests are also considered as candidate fuelwood collection areas. We note that the low level of harvest activity has had the beneficial effect of further limiting slash accumulations. Historic slash accumulations do exist (approximately 3,000 ha) and the opportunity to actively manage those accumulations has been limited by access and/or site conditions. Programs are in place to address the backlog during the 2010 FMP term. It is our assessment that an effective slash management strategy is in place and that slash management strategies have been implemented to the extent possible (pending the resurgence of biofuel markets or the return to more traditional harvest levels). Protection A 2007 outbreak of Jack Pine Budworm (Choristoneura pinus pinus Freeman) in the Fort Frances District resulted in the spraying of a portion of the Sapawe Forest with Bacillus thuringiensis 23 to control the insect. The spray program was appropriately planned, complied with the requirements in the FMP and was effectively delivered. 23 Bacillus thuringiensis subspecies kurstaki (Btk) is a bacterium found naturally in soils. It is used worldwide as a biological pest control agent to control forestry and agricultural insect pests Sapawe Forest Independent Forest Audit 17

25 Access Forest access was planned in the FMPs and AWSs and access roads were constructed in accordance with the relevant forest management guidelines. A roads and water crossing monitoring program was implemented during the audit term (aerial surveys were completed in 2007 & 2008). During our field site inspections we noted that the lack of harvest activity has resulted in the deterioration of conditions on many roads. Funding for road construction and/or maintenance under the Forest Roads and Maintenance Agreement (FRMA) was substantially limited as a result of the lack of harvest activity. A sampling of invoices submitted to the FRMA found that the invoices were complete and accurate. While we did not observe evidence of environmental damage arising from erosion, or conditions of immediate public safety concern, we note that a considerable proportion of the roads will require funding support to improve conditions should there be resurgence in harvest operations. Water crossings observed during the field audit were generally well constructed. Our review of FOIP records confirms that there were relatively few issues with respect to water crossing installation and maintenance. The 2007 IFA provided a recommendation requiring better compliance with provincial standards (i.e. Aggregate Resources Ontario Provincial Standards) for forestry aggregate pits 24 (FAP). AFP responded with an enhanced training program and OMNR increased the compliance priority for pit inspections. Our interviews and document review indicate that there was improvement in forestry aggregate pit management during the audit term. Pits examined during the field audit complied with the required operational standards. Renewal Support The planned renewal support programs were well documented in the FMPs and were sufficient to meet the planned silvicultural program requirements during the audit term. The shortfall in silviculture reduced requirements to collect seed or undertake other renewal support activities System Support The IFAPP human resources principle is deemed to be met as the Forest was SFI certified. 24 The 2009 FMPM provides the applicable criteria for Forestry Aggregate Pits and the 2010 FMP lists the operation standards Sapawe Forest Independent Forest Audit 18

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