BIG PIC FOREST SUSTAINABLE FOREST LICENCE # INDEPENDENT FOREST AUDIT FOR THE FIVE-YEAR PERIOD APRIL 1, 2004 TO MARCH 31, 2009 ACTION PLAN

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1 BIG PIC FOREST SUSTAINABLE FOREST LICENCE # INDEPENDENT FOREST AUDIT FOR THE FIVE-YEAR PERIOD APRIL 1, 2004 TO MARCH 31, 2009 ACTION PLAN

2 INDEPENDENT FOREST AUDIT ACTION PLAN APPROVAL for the BIG PIC FOREST Prepared by: Derrick Tirschmann, R.P.F. Management MNR Wawa District Note: GreenForest Management Inc. participated in the development of the Action Plan up to March 31, 2010 Submitted by: John Peluch District Manager MNR Wawa District Endorsed by: Ginette Brindle Regional Director MNR, Northeast Region Richard B. Greenwood, R.P.F. Director, Forests Branch Approved by: David de Launay Assistant Deputy Minister, Regional Operations Division Rosalyn Lawrence Assistant Deputy Minister, Policy Division

3 Introduction Arbex Forest Resources Consultants Ltd., conducted an Independent Forest Audit (the Audit) of the management of the Big Pic Forest (Sustainable Forest Licence # ), for the period April 1, 2004 to March 31, The Independent Forest Audit Process and Protocol (IFAPP) January 2009 prepared by the Ministry of Natural Resources (MNR) provided the framework for the audit. The audit assessed the forest management activities of Marathon Pulp Inc. (MPI), Ontario Limited (Overlapping Licensee) and the Ontario Ministry of Natural Resources (Wawa District). MPI declared bankruptcy in February 2009 and PriceWaterhouseCoopers was named the Trustee. All forest harvesting and renewal activities and forest management planning related requirements were managed by Ontario Limited under a business-to-business arrangement with MPI Ontario Limited, which is an affiliate of Buchanan Forest Products Limited (BFPL), carried out harvesting activities under a series of overlapping licenses. Harvesting and silvicultural operations were contracted to various local and non-local operators. BFPL provided forest management services to Ontario Limited prior to BFPL going into receivership in March Green Forest Management Inc. received direction from Ontario Limited to act on its behalf during the IFA audit and participate in the development of the IFA Action Plan, and to provide management services until March 31, The purpose of the Independent Forest Audit of the Big Pic Forest was to assess compliance with the Crown Forest Sustainability Act (CFSA), the Forest Management Planning process, and planned versus actual management activities. The Audit also assessed the effectiveness of forest management activities in achieving audit criteria and management objectives, and the Licensee s compliance with the terms and conditions of the Sustainable Forest Licence (SFL). The focus of the Audit s activities was a site visit to the Big Pic Forest, which included: An in-depth review of management documents at the offices of Green Forest Management Inc and at the Ministry of Natural Resources office in Manitouwadge (Area office of Wawa District); Interviews with staff of Green Forest Management Inc, the Ministry of Natural Resources, and Ontario Limited ; Consultations with members of the public, the Manitouwadge Public Consultation Committee (amalgamated as the Pic River Public Consultation Committee in 2007) and Intensive field inspections of a variety of management activities that took place within the review period. The Audit Team issued 16 recommendations. This Action Plan addresses the recommendations made by the Audit Team. Responses addressing each recommendation are organized into four sections: 1. Specific action to be taken. 2. Organization/individual responsible for completing the action. 3. Deadline date. 4. Method of tracking progress of the action. The current version of the IFAPP requires this Action Plan to address the 12 recommendations directed at the Company and Wawa District MNR. Corporate recommendations (# s 1, 2, 11 and 15) will be addressed through a Provincial action plan and are not part of this action plan. Since the SFL for the Big Pic Forest was revoked on July 23, 2010, the MNR has assumed responsibility for the management of the Forest. It is the MNR s intent to have the Forest managed through a service provider agreement by April 1 st, The management responsibilities of the Forest, including the items identified in the Action Plan to be addressed by either the Plan Author or appropriate SFL representative, will be assigned to the service provider with a confirmed deadline date as required.

4 3 The District Manager should ensure that the FMP Steering Committee 1. MNR District gives adequate support to the Manager planning team to meet its responsibilities in the development of 2. MNR future forest management plans. 1. The District manager will establish a Steering Committee for the production of the 2017 FMP as required by the 2009 FMPM. 2. The planning team for the 2017 FMP will notify the MNR District Manager of any unresolved planning team issues following planning team meetings. 3. The planning team for the 2017 FMP will provide the steering committee with copies of all planning team meeting minutes. 4. Upon notification of an unresolved planning team issue(s), the MNR District Manager will convene the steering committee to seek solutions and provide direction to the planning team. 1. Terms of Reference 2. to District Manager 3. to steering committee 4. to Plan Author and MNR 3. MNR 4. MNR District Manager Deadline 1. September Within one day following meetings 3. Within three days following meetings 4. Within one week following notification 4 In the 2017 FMP, the planning team should clearly identify each scoping run and include a digital copy of each scoping run, the natural benchmark run, and the proposed management strategy as required by Appendix III of the 2004 FMPM. The analysis package should also clearly describe the specific inputs and how these specific inputs were defined for each scoping run. The analysis package or plan text should clearly document progress in checkpoint achievement. 5 In the 2017 FMP, existing reserves should be classified as reserved area, rather than not available forest, in the planning and base 1. Clearly identify and include in the Draft and Final 2017 FMP, a copy of each Scoping Run, Natural Benchmark and Proposed Management Strategy, as required in the approved FMPM and FIM Manuals. 2. In the Analysis Package for the Draft and Final 2017 FMP, clearly describe the specific modeling inputs and how they were defined for each run, as required in the approved FMPM and FIM Manuals. 3. In the Analysis Package for the Draft and Final 2017 FMP, clearly document checkpoint progress and checkpoint achievement, as required in the approved FMPM and FIM Manuals. 1. Big Pic 2017 FMP Analysis Package. 2. Big Pic 2017 FMP Analysis Package. 3. Big Pic 2017 FMP check points and Analysis Package. 1. Develop a strategy for the recognition of existing reserves according to the current FMPM, FIM Manuals and current guidelines (i.e. Stand and Site guide). 2. Classify existing reserves in the new Forest Resource Inventory according to the 1.Plan Author and MNR. 2. Plan Author and MNR. 3. Plan Author and MNR. 1. Plan Author and MNR 2. Plan Author and 1, 2 & 3 Draft and Final Plan dates as per the Schedule in the Big Pic 2017 Terms of Reference 1. April 1, April 1, 2014

5 model inventories as per the strategy and the current FIM Manual. MNR planning inventory technical 3. Document in the Analysis Package and FMP text the basis for existing reserve 3. Plan Author and specifications. The planning team areas in SFMM MNR should clearly document in the analysis package and FMP text the basis for the existing reserve areas in SFMM. 1. Strategy document 2. Inventory checkpoint 3. Analysis Package Deadline 3. Checkpoint and Draft and Final Plan dates as per the Schedule in the Big Pic 2017 Terms of Reference 6 In the development of future forest management plans, actual implemented renewal rates should be more consistent with the modeled renewal rates in order to support the required renewal according to the preferred management strategy. Planned renewal expenditures and revenues should be compared to actual levels in future ARs. 1. Do an analysis (forecast vs actual) which considers Current and Past Renewal Rates, Current and Past Silviculture Costs and Projected Account Balances and levels of renewal activities from the plan period 2007 to Renewal rates will be monitored to ensure that sufficient funds exist to carry out the annual renewal program and meet related FMP objectives. 3. Use the results of the analysis to set the renewal rates used in modeling and document in the Analysis Package for the 2017 FMP 1. Renewal Rate analysis document. 2. Renewal rate development spreadsheets 3. Analysis Package 1. SFL Silviculture 2. SFL Silviculture 3. Plan Author 1. April 1, April 1 3. Checkpoint and Draft and Final Plan dates as per the Schedule in the Big Pic 2017 Terms of Reference Note: Renewal rates are one of several factors in forecasting and implementing the renewal program on the forest. The actual area completed and actual monies spent would be more useful indicators of renewal program activity. 7 The SFL holder should ensure that logging operations are appropriately timed and that operators are trained and supervised in order to minimize rutting during harvest operations. 1. In development of the AWS, consideration will be given to Block selection with regards to season of harvest. 2. Prior to start-up of logging operations, the operator will be briefed by the Foreman on the acceptable site disturbance that is expected in the block. 3. The Foreman will supervise the active logging operations. 4. Compliance inspections to report on occurrences of rutting 5. Annual Reports will document compliance with rutting standards 1. SFL Operations 2. Harvest Foreman 3. Harvest Foreman 4. SFL Compliance Inspector(s) 5. Plan Author 1. April 1,. 2. Prior to Block commencement. 3. April 1, 2010 and ongoing 4. April 1, 2010 and ongoing

6 1. Annual Work Schedule. 2. Block start-up forms. 3. In-progress reports as required. 4. FOIP Reports 5. Annual Reports Deadline 5. Nov. 15, The District OMNR and the SFL holder must ensure that adequate records are maintained to enable the assessment of the silvicultural effectiveness of renewal treatments on all forest unit sites (with particular emphasis on SB1 forest unit sites). 1. The SFL holder will maintain records of silvicultural treatments and assessments of treatments as required by the Forest Information Manual and related Technical Specification. 2. The SFL holder will report assessments of treatments as required by the Forest Information Manual and related Technical Specification. 3. The MNR will maintain records of silvicultural effectiveness monitoring and report the results. 4. The MNR and SFL holder will meet to discuss the results of the silvicultural assessments and silvicultural effectiveness monitoring. 1. SFL silvicultural records 2. Annual Report submissions 3. Annual SEM report 4. Meeting minutes 1. SFL 2. SFL 3. MNR 4. MNR and SFL 1. Ongoing by Nov Ongoing by November Ongoing by March 31, 4. Ongoing by Jan. 15, 9 The SFL holder must ensure that conifer renewal sites are monitored to ensure timely tending interventions and ensure that the planned tending strategies are appropriate for the site/stand conditions on the treatment area. 1. SFL will follow the new pre and post-spray procedures, and document the SEM program assessments, as described in Section (pg. 204) of the FMP. 1. SFL silviculture records. 1. SFL Silviculture 1. Annually by November 15th 10 The SFL Holder should critically review and evaluate the 1. The company will evaluate the effectiveness of its Debris management strategy to 1. SFL Silviculture 1. Sept 1, 2011

7 effectiveness of its Interim Debris ensure that the desired outcomes are being achieved. This strategy will ensure the Management Strategy to ensure integration of techniques that support developing Bio-fibre markets and reduce area of that the adopted management slash piles and chipping debris to aid in the regeneration of these areas. procedures are implemented and 2. Document the results/recommendations of the evaluation in a summary report 2. SFL Silviculture that slash management techniques are satisfactorily achieving the strategy goals and objectives. 1. Company records 2. Summary Report Deadline 2. November 15, The SFL holder must ensure that Annual Reports meet all FIM and FMPM requirements with respect to content and submission deadlines. The outstanding requirement to resubmit the Annual Report must be immediately addressed. 1. The Company will submit complete Annual Reports, resubmissions and final copies as per the approved and current FMPM and FIM time frame. 2. The MNR will have the opportunity to review Annual Reports as required by the FMPM and FIM. 3. The Company will complete and resubmit the outstanding Annual Report. 1. Forest Information Portal 2. Forest Information Portal 3. Forest Information Portal 1. Plan Author 2. MNR 3. Plan Author 1. Annually by November 15 and subsequent resubmissions as required 2. Within 30 days of receipt of Annual Report 3. Completed May 31, The Wawa District must ensure, on an annual basis, that sufficient financial and human resources are available to satisfactorily meet Core Task requirements and obligations for Silvicultural Effectiveness Monitoring. 1. The NE Region will make funds available to the District for silvicultural effectiveness monitoring (SEM) 2. The MNR District Manger will commit to directing the received funds for Silvicultural Effectiveness Monitoring where appropriate. 3. The MNR Area Supervisor will assign performance targets to appropriate staff to complete SEM assessments. 4. The MNR and/or Technician will carry out the SEM assessments and report the results 1. Regional Director 2. MNR District Manager 3. MNR Area Supervisor 4. MNR and/or Technician 1. May June July 1 4. March Regional funding allocations to identify dedicated SEM funds to District 2. District Work Plan to identify SEM funds 3. Performance Plans for MNR and/or Technician to identify SEM

8 assessment targets 4. Annual SEM reporting will identify funds made available for assessments and fund spent. Deadline 14 The SFL holder and OMNR District must ensure the Action Plan responding to IFA recommendations is prepared and submitted within the required time. 1. Upon receipt of the IFA Report, the MNR will contact the company forester to agree on which recommendations each party will prepare actions to and a timeline for a draft Action Plan. 2. A draft Action Plan will be forwarded to the NE Region and Forest Branch office for comment. 3. The NE Region and Forest Branch will provide comments to the MNR 4. Any revisions will be completed and a final Action Plan sent to the MNR District Manager for submission to the appropriate approvers. 1. to company forester 2. to NE Region representative 3. to MNR 4. to MNR District Manager 1. MNR 2. MNR 3. NE Region Representative 4. MNR 1. Completed February 3, Completed March 11, Completed March 19 & 23, Completed September 09, The SFL holder must address the backlog in area requiring free-togrow survey. 1. The Company will work toward assessing the current backlog FTG. 2. The company will work toward assessing the forecasted assessment areas. 3. Report the results of the FTG assessments in the Annual Report 4. Ensure incorporation of FTG results in Big Pic 2017 FMP Planning inventory. 1. Company FTG records 2. Company FTG records 3. Annual Report 4. Inventory Check point Note: A new FRI for the forest is expected by the fall of The new FRI will likely have classified some of the area not meeting a regeneration standard from the previous FRI, as new stands. In particular areas harvested in the 1960 s and 1970 s which were classified as B & S (LowNat) in the previous FRI. 1. SFL Silviculture 2. SFL Silviculture 3. Plan Author 4. Plan Author 1. April 1, March 31, Annually by November 15th 4. Inventory Checkpoint as per the Schedule in the Big Pic 2017 Terms of Reference