Forest Panel of Expertise Submission On Behalf of Harry Freeman & Son Limited

Transcription

1 Forest Panel of Expertise Submission On Behalf of Harry Freeman & Son Limited About Us Among the oldest family businesses in Nova Scotia, the Freeman family has operated sawmills in Greenfield, Queens County since Our company Harry Freeman & Son Limited currently employs 120 people (year round/direct) from Queens and Lunenburg counties. We are perennially the second largest employer in Queens County (next to Bowater Mersey). Many more indirect positions result from our operations. Our business produces significant economic benefits felt in Halifax and throughout Western Nova Scotia. We currently produce about 65 million board feet of lumber and value-added lumber products annually. Although small on a global scale, our lumber manufacturing operations are among the most modern, flexible and automated in Eastern North America. Computer generated (optimized) solutions maximize value and minimize waste at each successive stage of production. We are ISO 9001:2008 certified. We are energy efficient. Our bark-fueled dry kilns can dry our entire production. We have an optimized planing mill and a value-added moulding operation. Bowater Mersey uses our sawmill chips for paper production. Sawdust is shipped off-site for use in wood pellets or co-generation. There is no waste. We process a wide variety of tree species including red spruce, white spruce, black spruce, balsam fir, white pine, red pine, eastern hemlock, poplar, larch and (occasionally) hardwood species. Our family owns more than 25,000 acres of woodland. We have FSC, SFI and PEFC chain of custody certification and plan to implement ISO and a recognized third party audited forest management system. Most wood we process is grown on private lands from Kings/Halifax Counties and west. We normally receive authority to harvest one million board feet of logs from Crown lands each year. Our three fulltime Forest Technicians (one of whom is also a biologist) develop and supervise the implementation of management plans on Company and private lands. Management plans they develop for Crown lands require approval by Crown officials. We understand that through inadvertence we did not receive your Panel s first request for our submission. We appreciate this opportunity to make a belated submission. Forest Management Goals and Practices The diverse nature of forests means that no generic forest management prescription can be applied to all lands. Several different management approaches may make economic and environmental sense on the same site. A variety of management options including clearcutting, planting and herbicides must be available to the landowner. Flexibility is more important than ever given the uncertain impacts of climate change and other threats such as exotic pests and airborne pollutants. Although well-documented in public records, it is poorly understood that there is more forest land in Nova Scotia today than a century ago. Shorter rotations (which grow more wood) have tended to shift

2 2 age class distribution toward younger stands. Nonetheless, Nova Scotia forests have been worked intensively since early settlement and remain very robust. We work in the purportedly elusive Acadian Forest every day. Current best management practices may require some fine tuning in the interest of particular goals. However, forest management is a long term venture and there is no need for immediate, radical change. Radical changes intended to produce short term results would have a severe negative effect on families, rural communities and the general prosperity of the Province. Urban society is far more dependant on forestry than most people understand. Current regulations requiring clumps and riparian zones are a very significant operational and financial burden on landowners. These should not be expanded. There is conflicting evidence about their benefit which seems to depend upon what environmental effects are considered. In our view a one size fits all approach for rivers, lakes and streams is too onerous. Consideration should be given to reducing the width of riparian zones where reasonable. Where clearly beneficial, these types of restrictions should apply to all landowners (not just forestry operations). There will be opportunities for broad scale management in larger blocks of Crown owned lands. However, connectivity and landscape level planning will generally be impractical on private lands given the large number of small private woodlots and owners. The current clumps and riparian zones are generally sufficient to address landscape level planning on private lands. Further restrictions in the interest of landscape level planning should require voluntary participation or financial compensation. We are among those developing non-timber products (blueberries and cranberries) on our lands. It is essential to recognize that many proposed value-added and non-timber products (such as the hardwood fine furniture proposed by GPI Atlantic) are simply not viable. These must be critically evaluated to ensure they do not squeeze out established businesses which have supported communities for many years. Crown Land Management The current uncertainty about the limits of future Protected Areas creates problems. Crown lands should adopt a zoning model which designates a substantial land base for intensive forest management. Zoning would permit a broad array of management practices to be used on Crown lands designated for intensive management. The certainty created by zoning would also reduce delays at the IRM stage and in management plan approval. It is possible to grow a lot more wood on lands zoned for intensive management (estimates are that we could up to double the AAC in Nova Scotia). Zoning sufficient lands for intensive management could enable the Province to meet its 12% target for Protected Areas without negatively impacting forest production. The Crown should have much better stand level information about its forest inventory. The Crown does not maximize its AAC and often proposes to harvest overmature stands with dead or diseased

3 3 trees and no remaining commercial value. With better information Crown foresters could improve habitat and timber quality on Crown forest lands while maximizing stumpage royalties. Our father Harry Freeman II (the son in Harry Freeman & Son) was a well-respected environmental scientist with countless publications who served as a referee for a number of peer reviewed scientific journals. After his retirement from the federal public service with the highest (Research Scientist 4) designation and his appointment as Scientist Emeritus, Dad continued to take a keen interest in environmental matters. Dad favoured much smaller Protected Areas than those ultimately adopted. He preferred actively managed multi-use areas like Ontario s Algonquin Provincial Park and was a strong believer in human intervention to improve habitat. Dad studied the impact of acidification on Atlantic Salmon for many years. He was outraged by Government publications citing the pristine waters of the Tobeatic, most of which are well-documented to be dead or dying and no longer support salmonids due to acid deposition. He advocated liming the Tobeatic to restore habitat. We agree with our father s realistic view that active management will be required in Protected Areas to create habitat and remedy existing and future threats to the environment. Private Land Management Many find it easy to endorse strict land ethics because the burden will fall on someone else. In our view private landowners should generally have access to the full array of forest management tools. Ironically, existing forest management practices in Nova Scotia are already well ahead of the curve. We also have a well-established silviculture system which accommodates a wide variety of management strategies. DNR (with Dr. Eldon Gunn) has developed and implemented a very accurate forest inventory modeling and management system. The huge number of private landowners and small woodlots involved means that the enforcement of the existing rules can be a challenge. Increasing the severity of restrictions will compound this problem. The continued movement toward third party audited certification of forest lands will encourage greater compliance (legal compliance is audited in all schemes of certification). It is important to recognize that forest lands represent the retirement savings of many (primarily rural) Nova Scotians. Private landowners should be compensated when management restrictions impact them financially. Moreover, fairness requires that the same rules should apply to all landowners without discrimination. Owners with management objectives including timber production should not be singled out. Support For Private Landowners and Industry We believe in silviculture and recognize the medium to long-term benefits that the Registry of Buyers system will deliver. However, Nova Scotia sawmills should not be required to pay for silviculture on private lands owned by others. Our competitors outside the Province do not bear this expense. BC sawmills pay as little as 25 /m 3 for standing timber. We pay up to $40/m 3 and are required to pay another $3/m 3 for silviculture. Temporary funding has reduced this burden during the recent housing crisis. We need a permanent solution.

4 4 Silviculture should be funded through public sources. Alternatively, the Province could fund silviculture through a small annual land management surcharge collected from all landowners (including sawmills). There should be no distinction among the large and small, industrial and private. Every landowners should be treated the same when it comes to silviculture funding. The certification of small private woodlands in Nova Scotia is particularly difficult due to the number of properties and landowners involved. Government should intensify its efforts to facilitate the certification of private and industrial forest lands under internationally recognized systems. Government must create a regulatory environment that allows the forest industry to compete. Government imposed burdens such as restrictive forest policies, taxation, energy policy, transportation, environmental laws and labour regulation all impact competitiveness. These burdens must not materially exceed those found in other jurisdictions. Forest Protection A strategy of active management and remediation should be developed to ensure REAL PROTECTION. All lands in the Province (including Protected Areas) should be actively protected against all fires, insects and pests. Approved herbicides and pesticides should be available for use on all lands in the Province (including Protected Areas). It is a travesty that the pale winged gray moth devastated large areas of Keji Park including stands of old growth hemlock. Treatment with BTK (refined from soils) could have mitigated this loss. No steps were taken to control the BSLB impact on Point Pleasant Park until it was too late. These kinds of mistakes should not be repeated. Problems like these should be actively addressed. Climate change will have a substantial if largely unpredictable impact on our forest ecosystems. Flexible forest protection policies providing a broad range of options make the most sense against this backdrop of this uncertainty. Rigid forest protection policies should be avoided. Forestry use accounts for less than 1% of Canadian pesticide sales (which include herbicides, insecticides, fungicides and the like). Over 90 times more pesticides are used in agriculture than in forestry. Over 5 times more pesticides are used by homeowners than in forestry. Vision (aka Round Up) when used on forest lands is applied perhaps once in 50 years. Despite this limited use, herbicides are important to protect the regeneration of new forests. The regulated use of approved herbicides should be continued. According to a recent DNR study, only 13% of NewPage plantations met regeneration standards when herbicides were not used. Poor regeneration clearly impacts wood supply. Used primarily in food crops, Vision is the most common herbicide worldwide. Identical products are registered for use in more than 130 countries and are approved for use on more than 100 food crops. Comprehensive independent studies on many plants and animals (including farm workers) confirm that Vision has low toxicity on non target organisms and does not accumulate in soils.

5 5 The WHO has concluded that Vision has very low toxicity, does not induce sensitization, and shows no mutagenic, carcinogenic, or birth defect activity. Purported links to non-hodgkin s lymphoma are based on a discredited 1999 case study by Hardell and Eriksson which has been repeatedly dismissed by many leading researchers as superficial, inadequately designed, poorly analyzed and meaningless. Vision is very safe. Stewardship and Education Few Nova Scotians understand forest management and the key role of the forestry sector. This is generally true throughout the Province - even in rural communities with clear ties to the forestry sector. There should be a renewed emphasis on forestry curriculum in public schools from a broad, balanced perspective. The recent wave of bad news has led some to wrongly conclude that the Nova Scotia forest sector is doomed. Many forestry operations have temporarily or permanently suspended operations - this is a worldwide phenomenon. Yet we are already seeing the signs of recovery. Nova Scotia industry has and will continue to change. We will continue to be a pillar of the economy. And we will require qualified employees trained through the public school and community college systems. All courses required for regulatory compliance should be concise and offered in Nova Scotia at low cost. The internet should be used both for public education and for delivering the courses required by regulation. Legal Framework We sometimes sell ourselves short. Forest Policy in Nova Scotia is delivered through a welldeveloped legal framework. Nova Scotia is a recognized leader in forest management regulation and practices. Although some modest adjustment may be warranted in the near term, forest management involves long term planning and objectives. Our forests have been working forests for 400 years. There is no pressing need for radical changes in the interest of immediate objectives. It is neither practical nor possible to reinvent our forests in a just few years. Wood is an environmentally superior building product. It is energy efficient in buildings, renewable, sequesters carbon and has far lower embedded energy than alternatives such as concrete, plastic and steel. Several provinces have modified their building codes or taken measures to prefer wood use in public buildings. The Nova Scotia government should adopt a wood first policy. To do so would be environmentally responsible and benefit many Nova Scotia businesses, their communities and employees. All of which is respectfully submitted.