From :  Joel Theriault <theriaultjoel@hotmail.com> Sent :  January 5, 2005 7:34:09 PM To :  Rick.Groves@tembec.com CC :  TheriaultJoel@hotmail.com, mstogoso@hotmail.com Subject :  More information on Herbicides please...

| | | Inbox

Attachment :	ForestryProposal.rtf (0.03 MB)

An open letter to the Citizens of Ontario regarding Forestry & Employment, (ForestryProposal.rtf)

The largest problem facing the environmental tourism industry of northern Ontario, especially remote tourism, as it pertains to forestry activities, is the method of harvest. Methods of harvest, such as Decicon style forest tending, that would better protect long-term employment opportunities created through remote tourism are not currently utilized because of additional “costs” incurred by the SFL. These “costs” include additional production hours needed to harvest, use and training on specialized machinery, and the use of new technologies.

These “costs” are not completely eliminated though as forestry companies still must perform additional work in the vicinity of remote tourism areas in a forced attempt to restore the traditional method of access to the areas (fly-in only). Although the Ministry of Natural Resources has made a commitment in the Ontario Forest Accord to the forestry industry to alleviate these additional “costs” of harvesting in the vicinity of remote tourism lakes, which were incurred to protect the values associated with these lakes, no implementation of this commitment has yet taken place. Both the Ministry of Natural Resources, through the Ontario Forest Accord, and the remote tourism industry, through the Memorandum of Understanding, agree that there should be no net increase in the “cost” of wood delivered to the mill as well as no long term reduction in fibre entering the mill.

However, forestry companies are incurring additional “costs” in the vicinity of remote tourism lakes because of additional work required to return these area to a similar level of remoteness as it was before harvesting took place. The MNR has agreed in the Forest Accord to “13. Establish incentives in relation to extraordinary expenditures on intensive forest management to grow crown timber.” Could an extraordinary expense be the additional cost of harvesting in the vicinity of remote tourism lakes due to the pledge of returning the area to a similar level of remoteness? Also in the Forest Accord are mentions of increasing utilization of Crown timber through such things as semi-commercial thinning and salvage cuts in quality stands that are not currently harvested (Forest Accord #11). Could these quality stands that are not currently harvested include the standard 120 metre no harvest reserve around remote tourism water bodies, which is commonly given in our local region. This intense forest management depends on additional man hours to harvest and manage the forest to insure that the harvest does not negatively affect tourism values such as value put by guests on the sense of remoteness and being surrounded by pristine nature. The MNR has agreed in the Forest Accord that “22. There will be a recognition of the costs, benefits and impacts associated with intense forest management activities.” Could these intense forest management activities include Decicon style forest tending in the vicinity of remote tourism lakes? Could the benefits be maintaining diversity of long term sustainable employment? What other benefits would Ontario gain from using Decicon style forest tending in the vicinity of these tourism lakes?

From the perspective of a tourist outfitter, the largest gain that Ontario would receive from using Decicon style forest tending in the vicinity of these remote tourist lakes would be increased employment opportunities in the forest and harvesting sector without jeopardizing employment opportunities created through remote tourism in the area. These remote tourism employment opportunities are being jeopardized largely due to the method of harvest currently being utilized because of the lack of the establishment of incentives in relation to extraordinary expenditures associated with labor intensive forest management (#13, Forest Accord). Forestry companies are often reluctant to maintain a similar level of remoteness in these remote tourism areas because this, in itself, incurs an additional “cost”. If crown dues were to be reduced to alleviate additional “costs” associated with labor intensive forest management, the method of harvest in the vicinity of the remote tourism lakes could be changed to Decicon style forest tending while increasing long term SFL profits. It seems fairly obvious that the method of clear cutting is too often done for the purpose of short term financial gain, as opposed to long term regional sustainability of the forest and/ or long term regional employment sustainability from forestry activities. I feel that Decicon is the best suited company to do forest tending in the vicinity of our tourism lakes due to their previous track record, intimate respect and love for the forest as is apparent by the method of forestry they have chosen, and an excellent working relationship based on mutual respect that we have developed over the years. However, due to the size of this project, and the demand that will be placed by other tourist outfitters on Decicon to harvest in the vicinity of their tourism areas, I feel that the Gagnons should devote less time running machinery and most of their time overseeing this project in a managerial position. This will insure the quality of forest tending while insuring that demand for this work is equally met by supply.

From the perspective of Decicon, for over 15 years we’ve been in the forestry industry and have evolved with new technologies to become more proficient, while increasing the quality of our work and decreasing negative environmental impacts. Although we have had many opportunities to join the conventional logging system of clear cutting, we have chosen forest tending. We have done this although it is less profitable due to factors including the implementation and training on new, costly technology and lower production per man hour. This should be a clear indication that profit is not our only driving force as it pertains to forestry practices, as opposed to many in the forestry field. However, just as important as our machinery as it pertains to minimizing environmental impact, is our frame of mind and training system. Studies show that it costs a minimum of $30,000 per employee to train employees on cut to length equipment, and our training system likely exceeds this amount. Our training system is currently utilized and well known (largely in other Boreal forests around the world).

It should also be noted that not just any individual is suited for this type of work as our cutting procedures require significant patience while harvesting to protect smaller flora. For this reason, as indicated by our previous track record, we feel that we should be closely involved in the implementation of this proposal. Our recognition that profit is not all that should drive a forestry company, our experience with this method of cutting, and our excellent working relationship with Air Ivanhoe, other tourist outfitters, the MNR, and industry makes us the best candidate to oversee these projects. We feel that tending to the shoreline and beyond (islands) in the vicinity of tourism operations can successfully be done through our method and oversight of forest tending, while maintaining employment opportunities from multiple types of tourism. One example of our forest tending operations running concurrent with tourism operations while maintaining tourism employment opportunities can currently be found on the Pineland-Martel Forest.

Missinabi Headwaters, an eco-tourism company based out of Racine Lake/ Chapleau District, currently guides environmentally friendly hiking tours directly through our forest tending operation sites. Missinabi Headwaters has chosen their current hiking route to include our forest tending site due to the nature of our harvesting. Guests of Missinabi Headwaters, and no doubt others, are disappointed and discouraged with the conventional method of clear cutting but are enthusiastically delighted to discover that a more environmentally friendly method of harvesting is possible and actually taking place before their eyes. In this instance, our method and oversight of forest tending has not only maintained tourism employment opportunities, but as we are a primary attraction on the hike, we are actually generating tourism employment opportunities. (Reference the attached letter in appendix A1 for more information from Missinabi Headwater regarding how Decicon harvesting has effected their business.) In another instance, we have tended the forest bordering a drive in tourism lake, in an area that could have considerably decreased the visual aesthetics of the lake, without any noticed visual effect.

Scorch Lake, approximately 15 kilometers by highway to the East of Foleyet, is directly located next to Mooseland Lodge, a drive in tourism lodge and WhitePine Lodge, a seasonal campground/ RV park. Scorch lake is used frequently as a fishing attraction for guests from these lodges and is bordered on the West side by a large hill, rising approximately 500 feet from water level and located approximately 1 kilometer from the lake. Using the conventional method of harvesting on this hill would have clearly been a visible scar upon the landscape, greatly decreasing the visual aesthetics of the lake and potentially even decreasing potential tourism employment opportunities from this lake. Tourist operators may have been less likely to send their guests to this lake, as guests often visit Canada to experience pristine nature, which does not coincide with barren land, visible after the conventional system of clear cutting. Dale Vickers, owner of Moose Land Resort, was not unaffected by the cutting operation however, as he was able to use our trail networks for fall bear hunting operations. Thus, this is another great example of a potentially problematic harvest which could have greatly reduced tourism potential for the area actually benefitting both the outfitter and the forestry company.
It has been indicated by Air Ivanhoe pilots that guests in the airplane, when questioned about the Scorch Hill, do not even realize that the block was tended a couple years ago. It would seem that a natural progression from harvesting in the vicinity of drive in tourist establishments to fly-in tourist establishments will take place as the demand to harvest timber in the vicinity of these fly-in remote tourism lakes is ever increasing with the decreasing availability of merchantable timber.
We feel that once again, forest tending can take place concurrently with remote tourism while insuring that the three requirements for long term survival, as detailed by MNR internal experts, are met. According to Haider and Hunt in Remote Tourism in Northern Ontario: Patterns of Supply and a Motivational Segmentation of Clients (1997)submitted to the Centre for Northern Forest Ecosystem Research, “While all resource based tourism is, to a certain degree, susceptible or sensitive to disturbance by other land users, most notably timber management, remote tourism’s emphasis on pristine nature and remoteness makes it much more vunerable. The major effects of timber management on resource based tourism have been identified as:
access, caused by newly constructed forest roads that provide access for road-based anglers and hunters to previously ‘remote’ areas;
aesthetics, caused by client’s perceptions of cut areas that are visible from the ground, the lakes, or the air;
noise, generated by harvesting equipment and logging road traffic (Environmental and Social Systems Analysis, Ltd., 1987)” (p. 3).

This proposal intends to insure that the needs of resource based tourism are met concurrently with the needs of forestry companies as is required per the CFSA. The CFSA dictates to the MNR that all forestry operations conducted must be in accordance with the following principle, “The long term health and vigor of Crown forests should be provided for by using forest practices that, within the limits of silvicultural requirements, emulate natural disturbances and landscape patterns while minimizing adverse effects on plant life, animal life, water, soil, air and social and economic values, including recreational values and heritage values” (CFSA 1994, sec. 2). The current matrix of government stumpage fees is not in accordance with the CFSA as it forces tourism companies and logging companies to compete for resources, a situation which we believe is unacceptable and not necessary. In many instances, as we’ve referenced, forestry operations can be completed without any adverse effects on tourism economic values and can actually be beneficial to tourism economic values (see attached letters). Forestry operations can be beneficial to both resource based tourism and non resource based tourism (eco-tourism) if done using this template. However, the template includes the short term expenditure of additional resources, A.K.A. “Costs”, a concept that in many cases goes against corporate policy. Corporations with the largest single committement to short swing shareholder profits are generally unwilling to make extra ordinary expenditures. Harvesting in the vicinity of tourism lakes and while maintaining the viability of the tourism establishment, in itself, requires an extra ordinary expenditure. However, a common method of harvest is used, regardless of the presence of a tourism establishment. As it pertains to its effects on remote tourism, camp owners are generally given the choice to shut down for a season or drive away repeat clientele if noise from logging machinery is audible while guests are present at the camp. A second and long term effect is that signage is generally needed to restrict overland access and maintain a viable remote tourism camp.

However, court cases and past experience indicate that signage is not an effective tool to restrict overland access and as such, forestry operations requiring the use of signage to restrict overland access are not consistent with the CFSA as they do not minimize adverse economic effects on tourism. Signage does nothing but advertise to the general public that first, a road exists leading to a remote tourism lake, and second, this is the road. Pinch points will be created in the template system throughout the tending network to allow for maximum overland access opportunities, without jeopardizing the viability of the remote tourism area. Pinch points will only be used if the viability of the remote tourism areas is jeopardized and will be reopened once the threat has dissipated.

Pinch points are areas in which access can be restricted through removal of natural and/or man made sections of forestry road. These pinch points may include removable bridges (bailey bridge) and/or a winter crossing, and especially narrow road sections where trees may be felled, and swamp sections where fill may be removed and trees felled. Visual aesthetics and the lack of noise from forestry equipment are also considered important elements to maintaining a viable remote tourism operation, and forestry operations will occur to insure that these needs are fully met.

Large clear cuts with a 120 metre reserve do not conform to the CFSA as they do not maintain a sense of visual aesthetics for guests that pass over this area next to the lake in an aircraft. Guests most often ask when they see these clear cuts in the immediate vicinity of remote tourism lakes if they can drive to the lake on which they paid premium dollar to pass their fly-in vacation. Also, summer cutting that is audible from the shoreline of the lake while guests are present does not conform to the CFSA as noise heard by guests decreases the quality of trip they are experiencing and does not maintain, support, or enhance employment opportunities from these remote tourism lakes. Guests will likely inform their friends of the logging noise furthering the damage done by the noise from forestry operations.
The solution these problems seems to stem from this proposal. A better understanding of the solution to the complex nature of this problem are likely to be found as pilot projects using this proposal as a template occur. We anticipate implementation of this pilot project by Fall 2004 and are enthusiastic to commence a better relationship between tourist outfitters, forestry companies, Ontario residents, the Ontario government, and our environment.

SOLUTION

Decicon style forest tending is a more systematic harvest that allows for the largest variety of recreational activities to take place, both during and after the harvest. Remote tourism can flourish within a minimal distance of non-remote recreational activities if the harvest is conducted under our template. Often times, our forestry operations actually increase potential for tourism opportunities, and we feel that this will once again be the case, when it is used in the vicinity of remote tourism lakes and rivers with our oversight.

It must be understood that this method of forest tending is contrary to the more conventional system of clear cutting in that it a rolling forest concept, in which tending would be taking place on an ongoing basis, presumably forever. Under the conventional clear cut and replant system, harvesting in the area is not generally expected to occur for another 60 to 80 years. However, we expect to be using cut to length equipment (where applicable) and carefully selecting mature timber on a twenty year or less basis. We expect to capture increased volume from each stand, but on a longer term than the conventional clear cut method of forestry. If feasable, immature timber will be left to grow where it stands to maximize long term volume from the stand. However, the method of harvest will greatly depend on the forest composition. There will be times when the most immature timber would be removed to make way for larger timber to reach full potential before harvest (thinning). There would be instances in which a mature jack pine stand next to (even bordering) a remote tourism lake would be best to clear cut (though it would be done in a way to minimize negative visual aesthetics - likely columns parallel to the shore). There would be instances when much of the timber is mature, but there are still a good amount of immature (I.e. 20 year old) timber, and we would harvest the mature timber, while making the best effort to leave the immature timber intact.

Not only will this method of harvest, under our supervision, increase volume of wood being delivered on a continual basis to the mills, but will increase long term sustainable employment opportunities in the forest. This method of forest tending, due to its increased focus on regional sustainability of the forest (rapidly rolling process), would also be the best candidate for long term regional employment sustainability. In addition to long term employment sustainability, we expect a major immediate short term increase in employment opportunity when this method of forestry occurs under our supervision. The major set back to immediate implementation of this template, as we envision it, is that no party is willing to incur the additional “costs” associated with this template.

The MNR has agreed that the ultimate beneficiary of additional costs incurred by the forestry company should take the burden of these additional “costs”. From a tourist outfitter prospective, I feel that my personal employment will not be affected if every fly-in lake we operate was to become drive in accessible and we sold our airplanes. There would always be enough work for myself and my family at the main lodge and our guests could use their own vehicles to visit our camps. Those who would stand to lose the most would be the resident of Ontario, more specifically, those who wish to remain in Foleyet, because their employment opportunities would be greatly diminished. Thus, they, not I, are the ultimate beneficiary. Renewable, environmentally sound industry itself indicates that the masses are to benefit from it. The government of Ontario is the designated agent of these masses of people and as such, is responsible for their well being. Thus, if the people stand to loose employment opportunities because this plan is not implemented, the government of Ontario has failed in its most important duty, to protect the interests and lively hood of its citizens. It is fairly clear to understand that the ultimate beneficiary of employment diversification and employment opportunities in Ontario is the government of Ontario as the government is the representative of the people.

One incentive that the government of Ontario could use to alleviate additional costs incurred by the forest companies would be a reduction of crown dues in the vicinity of these remote tourism lakes. An interesting question would be, “Is the government actually paying the additional cost of additional labor in these areas by reducing crown dues or are crown dues in these areas decreasing the overall government financial well being?” High crown dues may be directly causing several negative financial impacts for the Ontario government including jeopardizing (often destroying) employment opportunities in the remote tourism sector due to the method of harvest, and often times forcing logging practices which are not consistent with the concept of regional sustainable employment opportunities from forestry. Decreased employment opportunities would also lead to increased numbers of unemployment and welfare recipients. Thus the concept of payment of crown dues in the vicinity of remote tourism lakes may be counter intuitive to the governments objective (money in the government slush fund) and actually costing the government more financially than they are receiving when several factors are taken into account.

“The Partnership for Public Lands agrees that they will not oppose the beneficiary pay concept for resource stewardship agreements”, which provide additional protection to remote tourist outfitters from the normal application of the tourism guidelines. This would seem to indicate that the government should pick up the tab for extra expenses and due to the previous discussion, it would seem that there will be extra expenses. However, a reduction or complete elimination of crown dues in the vicinity of remote tourism lakes to allow for a more manual labor intensive harvest would seem to be in the best interest of all parties including the forestry industry, the tourism industry, the citizens of Ontario, the government of Ontario, and our environment and would leave no party to “pay” for the additional “cost”.

We feel that to best protect the long term employment opportunities created through forestry and tourism, the following general template should be immediately implemented in the vicinity of remote tourism lakes.

0-2000 metres: Red zone- Danger/ most sensitive cutting zone for sustainable remote tourism.
Preference will be given to cut to length and/or horse logging in this area including the current 120 metre reserve given in our area and on all islands suitable for forest tending. Site may be prepped for co-generation support. Area open for conventional logging if approved by RTO and Decicon.

2001-4000 metres: Yellow zone- Semi- sensitive zone for sustainable remote tourism.
Preference will be given to cut to length, horse logging, cut and skid (chain saw/ skidder) for environmentally sensitive areas or areas needed to secure pinch points. Site will likely be prepped for co-generation support. Area open for conventional logging if not environmentally sensitive or needed to remain as a visual wall to secure a pinch point.

4001- 6000 metres: Blue Zone- likely the least sensitive zone depending on topography. Preference will be given to conventional logging unless geographical or environmental reasons dictate otherwise and as such the site will be prepped for co-generation support. Cut to length, horse logging, cut and skid, chain saw/ skidder may be used as alternatives to conventional logging if circumstances dictate an alternate method of forestry.

One thing that makes Decicon style harvesting very different from many other styles is that emphasis is placed on having the forest dictate to the foresters, which method of harvest would be best suited for that particular forest stand. We will not anticipate to fully apply these paper specifications to the forest (as there will no doubt be more), but will allow the forest to dictate how our specifications are to be implemented. “Cost”, as defined as expenditure of capital, will not be our only guiding principal in determining how the forest will be harvested.

Several prescriptions that we feel will be utilized in the Red and Yellow Zone include:

- Depending on the forest composition, the red zone will be preferably tended before the yellow. This would allow the forest time to regrow and help insure that the area in the immediate vicinity (1000 meters) of the remote tourism lake is functionally roadless. The inside ring should be tended first, and harvesting should progressively work away from the remote tourism lake, as opposed to the current method of harvest. Under the current method of harvest, the full road must remain intact until the last section of the forest is harvested. Under this template, it would allow for harvesting in the immediate vicinity of the remote tourism area (up to the shorelines and including the islands), and natural barriers could more easily be implemented to secure the remoteness of the area because the forest behind the harvest area would still be present, acting as a net for overland access.

-No operations between November 20th and May 1st (Error in original transmission: Actually to Read May 1st to November 20th) unless agreed upon by the RTO and Decicon. Exceptions to this rule made if both the RTO and Decicon agree and feel that operations will not be audible from the lakeshore if guests are present and will not encourage unplanned overland access. The area in the immediate vicinity of the remote tourism lake will be functionally roadless.

*** Functionally roadless is defined as impassable by ATVs, Argo’s, and Snowmobiles. ***

- Hydraulic Oil: Organic/ non toxic hydraulic oil used in all forestry equipment. This would minimize environmental damage caused by hydraulic hose failures.

- Machine specific applications to remove/reduce rutting/ site disturbance and reduce damage to standing and existing timber that is not yet marketable and/ or merchantable.

- Road width within 3000 meters is to be a maximum of 10 meters. Upon the recommendation and reasoning for extending the width of the road given by Decicon, exceptions to the rule will be made. Exceptions to this 10 meter road width rule would be for such things as turn around points and meeting points. Road width is to be minimized to avoid environmental damage and so that the road may be made impassable by ATVs, Argo’s, and Snowmobiles if necessary.

- Any bridges built or culverts installed to conduct forestry activities must be constructed by Decicon or supervised by Decicon. Bridges and culverts are to be temporary and made to fit OMNR standards and regulations. Emphasis will be placed on removable bailey bridges, wooden bridges, and winter crossings as it has been our previous experience that these methods of water crossing are the most environmentally friendly as they cause the least amount of foreign matter to enter the waterbody. They are also, due to their mobility, an excellent tool to insure the long term marketability of remote tourism areas.

- For road fill locations (for natural drainage locations) for the purpose of extracting wood or cutting within 6000 meters, perhaps wood chips could be used in conjunction with gravel or sand, with the maximum possible percent of wood chips used and the least amount of gravel or sand used. If a road network is not needed for forestry operations within 2 years, the mix of wood chips/ sand/ gravel can be removed to once again allow for natural drainage if the fill jeopardizes the viability of a remote tourism camp. However, the road may be made impassable at any time if unplanned overland access should occur. We agree that if 6000 meters are given to us for joint supervision, the RTO will not hold the SFL liable in court for lost revenue due to unplanned overland access.

- Minimize forest composition change. Sustaining the natural balance/ percentage of the basal in the area and in the arrangement found before harvesting. Manual tending may be necessary to maintain the natural composition/ arrangement of the forest stand prior to harvest. It may be possible to create government work programs for those who are unable to find private sector work for the purpose of manual forest tending. Manual forest tending could be used to eliminate the need for herbicide use in the AOC zones, which may (is likely) in the future be found beneficial to our environment and ourselves.

For many years, we did use DDT and other now known extremely toxic chemicals as herbicides and pesticides. The government actually approved and encouraged the use of DDT without knowing what long term effects this would have on the environment or Canadian Citizens. Recent developments in prescription drugs further examine this view that we may not truly know what the health effects of the drugs (herbicides) we use are because we may not know what to look for. We believe that forest tending in our zones will be successfully done without the use of herbicides if government work programs/ government funding can be used to cover these additional “costs”. However, the concept of “cost” should never only be measured in dollars and cents. We do not believe that a full understanding of the effects of the currently used herbicides can’t possibly be known, much as was the case when DDT spraying was encouraged. Likewise, under a universal health care system such as ours, the true cost to the government if 2, 4-D (the herbicide currently used in forestry applications) is shown to have long term health effects may greatly outweigh any short term savings. We do know that in several countries, 2, 4-D has already been banned due to suspected negative health and environmental effects.

We may wish to template the current system being used by the government of Quebec as it pertains to alternatives to pesticide use, with or without modifications to better suit our forest and provincial needs. Another interesting alternative to manual labor alone would be the use of grazing animals like sheep, cows, or even moose. We believe that studies have been done in the past to evaluate the viability of using sheep and other animals to graze deciduous plants, an environmentally sound method of halting forest composition change after harvesting due to an influx of deciduous chutes. Perhaps the most viable method and a natural progression when this type of sustainable forestry occurs is the increased use of co-generation plants. Perhaps, manual thinning shortly after tending to reduce forest composition change is not in fact necessary as tending operations are intended to be on an ongoing basis with currently existing type specific machinery. An approach to this seemingly problematic situation will only be developed through trial and error if efforts towards this goal are supported, maintained, and enhanced by the government.
At the very least, this could be a pilot project to help us better the relationship between the forestry industry, the tourism industry, Ontario residents, the Ontario government, and our environment by utilizing exiting legislation to allow for the utilization of new technologies, which are more environmentally sound, and which would better protect the long term employment opportunities for all Ontarians. Also, utilization of new technologies which are more environmentally sound would be consistent with the concept of continuous improvement in forestry, a concept, desired on paper, by all parties.

We feel that this approach is extremely consistent with the CFSA as it pertains to minimizing adverse tourism economic values due to forestry operations. However, above and beyond minimizing adverse effects on economic values, we’re also fighting to minimize adverse effects on our heritage, as a 3rd generation remote tourism outfitter and a 3rd generation forester. And as always, even more important than our heritage, is our belief that this change will be benefitting our environment, which has supported all of us for our entire lives. We believe that this positive new approach can and will unite the forestry industry and the tourism industry, and will secure the long term needs of each industry (not to mention diversity of employment as a whole), as is outlined in the Tourism and Forestry Industry-Memorandum of Understanding (2000, June 7).

Prepared September 13, 2004 by: