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Final Report of an Independent Audit of Forest Management on the Ottawa Valley Forest for the Period 2008 to 2013 Craig Howard, RPF, CEA (SFM) Brian Callaghan, RPF, CEA (SFM) Tom Clark, M.Sc., H.B.Sc. Mark Leschishin, RPF Phil Shantz M.E.S, R.P.P. June 2014

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Page 1: Final Report of an Independent Audit of Forest …Final Report of an Independent Audit of Forest Management on the Ottawa Valley Forest for the Period 2008 to 2013 Craig Howard, RPF,

Final Report of an Independent Audit of Forest Management on the Ottawa Valley Forest for the Period 2008 to 2013

Craig Howard, RPF, CEA (SFM) Brian Callaghan, RPF, CEA (SFM)

Tom Clark, M.Sc., H.B.Sc. Mark Leschishin, RPF

Phil Shantz M.E.S, R.P.P.

June 2014

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Queen’s Printer for Ontario, 2014

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1.0 Executive Summary A team of five auditors carried out an independent audit of forest management on the Ottawa Valley Forest covering the period from April 1, 2008 to March 31, 2013. The Ottawa Valley Forest has been managed by Ottawa Valley Forest Inc. (OVFI) since the Company was granted Sustainable Forest License (SFL) # 542529 by the Ontario Ministry of Natural Resources (OMNR) on April 14, 1999. The Pembroke District of the OMNR holds the main responsibility for this Forest for the OMNR. Operations during this audit period have been conducted under the auspices of 20-year forest management plans (FMP). The initial plan was issued on April 1, 2006. The plan was rewritten, as per the normal requirements of the Forest Management Planning Manual, in 2011. The audit examined compliance with the terms and conditions of the SFL and reviewed the OMNR’s performance in meeting its obligations on the Forest. The audit included a review of the process, planning, and operational efforts associated with both FMPs as well as the plan preparation of the 2011 FMP. Records of forest management activities were reviewed, along with field verification visits to areas where a variety of forest management activities occurred during the audit period. Public input was solicited through newspaper advertising, individual interviews, and mail-in surveys. The operational practices on the Ottawa Valley Forest are conducted, in most situations, in a highly effective manner. Road construction and maintenance, harvest, renewal, and renewal assessment all fell within acceptable operating parameters. Staff from both OVFI and OMNR District have demonstrated laudable commitment to their jobs and this forest. The planning process has been challenged by the poor quality of the forest resource inventory (FRI) used to support virtually all of the forecasting planning indicators. The auditors’ most urgent recommendation is to have Corporate OMNR update this inventory and, a following recommendation, issue comment on the probable accuracy of forecasts in the planning system that are based on FRI. The reliance on a GIS-based water layer issued from Corporate OMNR has not worked well. It has caused frustration with staff at both OVFI and OMNR District. The emphasis on centralized planning of aquatic values protection has taken control away from local District experts, both biologists and technicians. There is a large challenge with communication between the OVFI and Pembroke OMNR. The compliance program is the best documented evidence of this, but the observations of this audit show it reaches beyond that. There is a need for Regional OMNR to revisit the silvicultural ground rules concerning white pine shelterwood. The auditors accept the fact that this forest represents a relatively complex ecosystem and OVFI and District OMNR have done a reasonable job of operational management. They have complied with

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required legislation, and the principles of the CFSA. They have demonstrated a commitment to the Forest and a willingness to adapt programs and practise to accommodate challenges. The audit team concludes that management of the Ottawa Valley Forest was generally in compliance with the legislation, regulations, and policies that were in effect during the term covered by the audit, and the Forest was managed in compliance with the terms and conditions of the SFL held by Ottawa Valley Forest Inc. Forest sustainability is being achieved, as assessed through the Independent Forest Audit Process and Protocol. The audit team recommends the Minister extend the term of SFL #542529 for a further five years.

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Table of Contents

1.0 Executive Summary ......................................................................................................... 3

2.0 Table of Recommendations .............................................................................................. 6

3.0 Introduction .................................................................................................................... 8

3.1 Audit Process ........................................................................................................................ 8 3.2 Management Unit Description ............................................................................................. 8 3.3 Current Issues ..................................................................................................................... 12 3.4 Summary of Consultation and Input to Audit ................................................................... 13

4.0 Audit Findings................................................................................................................ 13

4.1 Commitment....................................................................................................................... 13 4.2 Public Consultation and Aboriginal Involvement .............................................................. 13 4.3 Forest Management Planning ........................................................................................... 16 4.4 Plan Assessment and Implementation .............................................................................. 20 4.5 System Support ................................................................................................................. 24 4.6 Monitoring ......................................................................................................................... 25 4.7 Achievement of Management Objectives & Forest Sustainability ................................... 30 4.8 Contractual Obligations ...................................................................................................... 33 4.9 Conclusions and Licence Extension Recommendation .................................................... 33

Appendix 1 – Recommendations ................................................................................................. 35

Appendix 2 – Management Objectives Table .............................................................................. 58

Appendix 3 – Compliance with Contractual Obligations ............................................................. 71

Appendix 4 – Audit Process ......................................................................................................... 73

Appendix 5 – List of Acronyms Used ............................................................................................ 81

Appendix 6 – Audit Team Members and Qualifications .............................................................. 82

Appendix 7 – Trend Analysis - Year 10 Annual Report ................................................................ 83

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2.0 Table of Recommendations

Recommendation on License Extension

The audit team concludes that management of the Ottawa Valley Forest was generally in compliance with the legislation, regulations and policies that were in effect during the term covered by the audit, and the Forest was managed in compliance with the terms and conditions of the Sustainable Forest Licence held by Ottawa Valley Forest Inc. Forest sustainability is being achieved, as assessed through the Independent Forest Audit Process and Protocol. The audit team recommends the Minister extend the term of Sustainable Forest Licence 542529 for a further five years.

Recommendations Directed to the SFL Holder/OMNR District(s)

Recommendation 1: The Terms of Reference for the Local Citizens’ Advisory Committee should be updated to ensure that OMNR is not chairing the LCAC, and should be reviewed and updated at the beginning of Phase 2 of planning.

Recommendation 6: The OMNR should continue to conduct physical stream surveys to ensure the values being protected are classified accurately. Ottawa Valley Forest Inc. needs to review their GIS capacity for handling special values, such as the FMP water layer, in light of greater use of GIS technology and an expected reduction in levels of service from the local District. The OMNR should continue to support physical surveys of the streams in question with the goal of eliminating use of the unclassified stream category.

Recommendation 7: The OMNR District, with the assistance of Ottawa Valley Forest Inc., should increase the efficiency of the approach to Confidential Values surveys.

Recommendation 9: Ottawa Valley Forest Inc. shall review its residual tree retention practices and determine if the residual levels are appropriate to meet stand renewal and harvest volume objectives.

Recommendation 11: Corporate, Regional, and OMNR Pembroke District, in cooperation with Ottawa Valley Forest Inc., shall take appropriate action, including the services of outside parties, to address the longstanding compliance monitoring working relationship that has challenged the Ottawa Valley Forest for over ten years. Progress assessments shall be undertaken regularly until the issue is considered to be resolved by senior staff of OMNR and Ottawa Valley Forest Inc.

Recommendation 12: Ottawa Valley Forest Inc. shall take firmer action to elicit better cooperation from licensees and operators who are repeatedly committing non-compliances.

Recommendation 13: Ottawa Valley Forest Inc. shall update and report upon the status of the Y and Z lands in its next annual report and in each annual report thereafter until their commitment under Paragraph 16 of the Sustainable Forest License agreement is fully achieved.

Recommendation 14: When preparing the 2013-14 (Year 3) Annual Report, Ottawa Valley

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Forest Inc. shall collect sufficient evidence to support its claims that current and projected levels of free-to-grow assessments are consistent with the amount of area expected to be eligible for survey. Ottawa Valley Forest Inc. should also consider undertaking a thorough spatial analysis of its landbase to ensure that there are no gaps in areas requiring renewal treatment or free-to-grow assessment.

Recommendation 15: The OMNR in Pembroke shall share the silviculture effectiveness monitoring audit reports it produces annually with Ottawa Valley Forest Inc. Efforts shall also be made to include more quantitative data to substantiate the findings listed in the reports.

Recommendations Directed to Corporate OMNR

Recommendation 2: The OMNR must ensure the delivery of new forest resource inventories is consistent with its commitment to complete new inventories on a ten-year cycle. All inventories should be coordinated with Phase 1 management planning.

Recommendation 3: Corporate and Regional OMNR should re-evaluate how the Long Term Management Direction is documented. A discussion of the integrity of the forecasts and degree of uncertainty that is present in the Long Term Management Direction should be required.

Recommendation 4: Corporate and Regional OMNR should re-evaluate the use of “regional” or “standard” forest units. A best practice would be to utilize the same forest units from one forest management plan to the next as determined by local field foresters.

Recommendation 5: Corporate OMNR should re-evaluate the use of large tables of redundant information in forest management plans.

Recommendation 8: Corporate and Regional OMNR should clarify the apparent difference between buffer requirements for confidential values in the Forest Management Guide for Conserving Forest Biodiversity at the Stand and Site Scales and the general habitat description for the same value.

Recommendation 10: Regional OMNR shall review empirical evidence supporting the effectiveness of the silviculture ground rule for three-stage shelterwood cuts of white and red pine in southern Ontario and revise the silviculture ground rule to reflect the results.

Recommendation 11: Corporate, Regional, and OMNR Pembroke District, in cooperation with Ottawa Valley Forest Inc., shall take appropriate action, including the services of outside parties, to address the longstanding compliance monitoring working relationship that has challenged the Ottawa Valley Forest for over ten years. Progress assessments shall be undertaken regularly until the issue is considered to be resolved by senior staff of OMNR and Ottawa Valley Forest Inc.

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3.0 Introduction

3.1 Audit Process An independent forest audit of the Ottawa Valley Forest was undertaken in September 2013. The objective of the audit was to assess the performance of forest management activities conducted during the five years from April 1, 2008 to March 31, 2013 as measured against the plans, guidelines, regulations, and legislation in force during that period. The audit was conducted in compliance with the Crown Forest Sustainability Act (CFSA) (Statutes of Ontario 1994) and fulfills the requirements of the Class Environmental Assessment Approval for Forest Management on Crown Lands in Ontario (Ontario Ministry of Environment and Energy 2003). The audit assessed the effectiveness of forest management activities in achieving the management objectives for the Forest. The audit examined the compliance of Ottawa Valley Forest Inc. (OVFI) with the terms and conditions of Sustainable Forest License (SFL) #542529 for the Ottawa Valley Forest. The audit also reviewed the performance of District, Regional, and Corporate Ontario Ministry of Natural Resources (OMNR) in meeting its obligations on the Forest. Finally, the auditors offer an opinion, based on consideration of all evidence reviewed, on the sustainability of the forest management program. The audit was conducted in accordance with the Independent Forest Audit Process and Protocol (OMNR 2013) by a team of five independent auditors, consisting of three registered professional foresters (RPF), a biologist/ecologist, and a socio-economist. Their qualifications are presented in Appendix 6. The audit was conducted within a standard five-day, on-site audit program. The auditors collected evidence through document review, interviews with staff and stakeholders, and physical inspection of field activities that occurred on the Forest between April 1, 2008 and March 31, 2013. Field site visit locations were selected to evaluate harvest, renewal, tending/maintenance, free-to-grow (FTG) operations, areas of concern (AOC), road construction and maintenance, site preparation, water crossings, wildlife management activities, and other areas of special interest. On average, the auditors inspected 27% of operating areas from the audit period. Additional details on the audit process and sampling are provided in Appendix 4. This report summarizes the findings of the audit and presents recommendations that are intended to improve management and operational performance on the Forest.

3.2 Management Unit Description The Ottawa Valley Forest Management Unit is comprised of the former Pembroke Crown Management Unit, which was established in 1996 with the amalgamation of the Madawaska and Bonnechere Crown Management Units. In 1999, much of the responsibility for forest management on the unit was transferred from the OMNR to OVFI under their SFL. Effective April 1, 1999 the Forest was renamed the Ottawa Valley Forest. The boundaries of the Ottawa Valley Forest coincide with the municipal boundaries of Renfrew County. While the whole of Renfrew County is considered to be the management unit, the SFL includes only the Crown lands within Renfrew County that are managed for forestry purposes (about 29% of the total area). Crown lands in provincial parks, conservation reserves, and some other special designations

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are excluded from direct management by the SFL but contribute to non-timber objectives for Crown forests (Figure 1). Figure 1. Location of the Ottawa Valley Forest.

Canadian Forces Base Petawawa, the Petawawa Research Forest, and the Chalk River Nuclear Research Facility lands all fall within the boundaries of the SFL but are managed federally. This creates a significant gap in the landscape between the northern and southern portions of the SFL. The Ottawa Valley Forest lies within the Great Lakes-St. Lawrence Forest Region of Canada. This region is an area of temperate climate where natural succession leads to forests of shade tolerant hardwood species such as hard maple (sugar maple), beech, red oak, and yellow birch, as well as associations of white and red pine. Forest stands that are more common in the Boreal Forest Region to the north compromise a small part of the Forest. These include pure stands and associations dominated by jack pine, black spruce, and white spruce. Maintaining these minor representations of the Boreal Forest has been identified as an important component of maintaining diversity in the Ottawa Valley Forest. Common species have been grouped into ten forest units in the 2011 forest management plan (FMP) as listed in Table 1.

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Table 1. Forest Units on the Ottawa Valley Forest.

Forest Unit Code Area (ha)

Red Pine PRcc 3,761

White Pine PWus 5,2478

Mixed Conifer MXCcc 8,470

Mixed Hardwood MXHcc 34,646

Hemlock HEsel 2,375

Lowland Cedar CEsel 4,452

Oak ORus 35,572

Hardwood Selection HDsel 25,160

Hardwood Shelterwood HDus 7,329

Intolerant Hardwood INTcc 40,801

Total 215,047

Source: FMP Table 2 Crown land managed by the SFL holder for production purposes occupies approximately 65% of the total provincial Crown land within the Ottawa Valley Forest boundaries. Table 2 shows the breakdown of managed Crown land by land type.

Table 2. Managed Crown Land on the Ottawa Valley Forest by Land Type.

Land Class Area (ha)

Non managed 15,448

Non-forested Water 70,563

Other land 3,270 Forested

Non-productive 19,734 Protection 1,553

Production 215,984 Total Forested 237,271

Total 326,533

Source: FMP-1 2011 Ottawa Valley Forest Management Plan The northern half of the Madawaska Highlands Land Use Plan (MHLUP) lies within the southern part of the Ottawa Valley Forest. The FMP for the Forest explicitly incorporates direction provided in the MHLUP. Most of the MHLUP planning area enables multiple resource uses, including forestry. Access roads are maintained at close to current levels in order to maintain the natural and remote character of the Highlands area. The MHLUP does not limit the development of access for forestry purposes. However, it places stringent requirements for access control and abandonment on all new access. The Forest supports a wide variety of aquatic and terrestrial flora and fauna. Most native species found on the Ottawa Valley Forest are tolerant of natural and man-made disturbances and maintain healthy populations through time. Normal forest management activity provides a suitable environment to sustain populations of these species.

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The FMP provides more detailed oversight of provincially and locally featured species. Provincially featured species (e.g., moose, deer, pileated woodpecker, black bear, lynx, ruby crowned kinglet, and black backed woodpecker) are found on the Forest and are the subject of enhanced management attention. Locally featured species (e.g., barred owl, beaver, Blackburnian warbler, marten, northern flying squirrel, northern goshawk, eastern red backed salamander, red shouldered hawk, ruffed grouse, and white throated sparrow) also have preferred habitat identified and are under management consideration on the Forest. The 2011 FMP includes operational prescriptions for working near chimney swift, whip-poor-will, common nighthawk, pale-bellied frost lichen, five-lined skink, snapping turtle, and olive-sided flycatcher, as well as species of provincial conservation concern ( peregrine falcon and wood turtle). Algonquin First Nations have historically used most of the Ottawa Valley Forest as well as parts, or all of, the adjacent forests. Those uses include harvesting, sustenance fishing, hunting, and gathering. There is a continued interest in seeking opportunities for trapping, commercial baitfish, birch bark gathering, and gathering of other non-timber forest products. The Algonquin Land Claim is being negotiated as the audit occurs and provides significant insight into the historic use of the Forest by the Algonquin First Nations and their expected use of the land in the future. Timber continues to be a significant contributor to the local economy, although the relative strength of the forest industry was reduced between the writing of the 2006 and 2011 FMPs. Sales, wages, and taxes based on the forest industry all declined between 3% and 20% over the five-year period between 2006 and 2011. Total sales in 2011 from products harvested from the Forest were estimated at $553 million, which generated $148 million in local wages. The estimated 2,670 direct and indirect jobs created by the timber industry in 2011 were a 21% reduction from the numbers noted in the 2006 FMP. Tourism, angling, and hunting are estimated to contribute in excess of $150 million to the local economy, although not all of that amount would originate from the productive forest land managed by OVFI.

3.3 Current Issues The SFL is currently maintaining its traditional complement of six full-time staff. However, in the words of the former General Manager, “the Forest is one financial shock away from becoming financially unsustainable”. Prescriptions for species at risk (SAR), land removals to settle land claims, an unfavorable harmonized sales tax judgment, and continued weak markets could individually, or in combination, result in significantly reduced revenues and/or increased costs.

The Algonquin Land Claim is progressing. Settlement may affect up to 22,000 ha of land that is currently managed by the SFL. This could reduce the area available for operations on the Forest by 10%.

The last two independent forest audits noted strained relations between the OMNR District and staff of the SFL. The 2008 audit recommended Corporate and Regional OMNR resolve the “long standing controversy over the compliance program” in the District.

The demand and prices for pulp (hardwood and softwood) have affected the utilization of the annual harvest area and, to some degree, utilization at the stand level. Sawlog values, which have always helped to offset the pulp situation, are also depressed. White and red pine are key species in the Ottawa

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Valley Forest but, at the time of the audit, white and red pine lumber is imported from the United States at a price cheaper than that of local production. Planned harvest and renewal for the 2006-2011 FMP term was greatly affected by several significant blowdown events in 2006 and 2007 and emphasis switched to unplanned salvage and renewal. Based on the introduction of significant new planning direction from the Forest Management Guide for Great Lakes-St. Lawrence Landscapes (Landscape Guide), the Forest Management Guide for Conserving Biodiversity at the Stand and Site Scales (SSG) and the Endangered Species Act, it was decided to have planning teams from the Southern Region collaborate on harmonising key elements common to each of their FMPs (e.g., AOC prescription development, forest units), all of which contributed to planning delays. Direction for SAR in the Endangered Species Act and SSG introduced extensive AOC and other constraints to operational planning. Species at risk management practices are evolving but have the potential to restrict access to operational areas temporally and spatially which may result in increased costs.

Additional planning delays were caused by extended deliberations about road classifications and, consequently, approval of the 2011-2021 FMP was delayed. A one-year contingency plan was developed and approved with the full cooperation of the OMNR to keep the effort to a minimum. Operations were able to continue with minimal delay.

The implementation of the uniform shelterwood system for white pine has been evolving over the past decade. The three-cut shelterwood regime has been prescribed in situations where its applicability is questionable (e.g., basal area of desired species not uniformly distributed or too low) or has been implemented inappropriately. It is a challenge to implement two removal cuts in regenerating shelterwood stands due to low harvest volumes and high operating costs. The Great Lakes-St. Lawrence SFLs and OMNR are collaborating on developing the new silviculture guides. Updating the direction for white pine management has been a top priority and work is proceeding well. Options are also being developed to deal with regenerating stands that are in a compromised position due to conditions such as low volumes or irregular distribution of the overstory.

The last forest resource inventory (FRI) for the Ottawa Valley Forest occurred in 1987-1988. The imagery for a new FRI is available but the interpreted data will not be received until 2017. The FRI will be of limited use for management planning until 2018, when it will already be ten years or more out of date (based on imagery acquisition).

The large number and complexity of annual work schedule (AWS) revisions and FMP amendments have consumed time and resources. There have been disagreements between OMNR and OVFI over the assessment of silviculture effectiveness. Some forest operations prescriptions (FOP) used silviculture that did not follow silviculture ground rules (SGR) in the FMP. As well, the SSG and water classification tool provided by corporate OMNR are creating complexities for stream AOCs, both on the ground and in AWS planning.

3.4 Summary of Consultation and Input to Audit

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The auditors distributed 700 surveys and placed advertisements inviting comments in two local papers as well as web-based versions of the same documents. Members of the Ottawa Valley Forest Local Citizens’ Advisory Committee (LCAC) were interviewed, as were members from each of the First Nations communities with an expressed interest in the Forest. A more detailed summary can be found in Appendix 4.

4.0 Audit Findings This section provides a summary of audit findings for each principle. Detailed discussions for each recommendation are found in Appendix 1.

4.1 Commitment The Independent Forest Audit Process and Protocol (2013) requires the OMNR and OVFI to have policy statements and operational performance that demonstrate the commitment of the organizations to sustainable forest management. The audit identified that both have clear policies that identify a commitment to the sustainable management of the Ottawa Valley Forest. These documents are available for view by employees, stakeholders, and interested members of the public. The OVFI maintains third party certification of its forest management program under the Forest Stewardship Council® standard, which requires a specific and public statement of OVFI’s commitment to the principles of sustainable forest management. Operational performance, as detailed in the remainder of this report, implements the written directives. Virtually all operational activity inspected was well done and all staff interviewed demonstrated a high level of competence.

4.2 Public Consultation and Aboriginal Involvement The Ottawa Valley Forest has had an LCAC in place since 1994 to provide a forum for public input into forest management. The LCAC was established by the OMNR District Manager in accordance with the requirements of the Crown Forest Sustainability Act and the Forest Management Planning Manual (FMPM). Prior to commencing with Phase 1 of the FMP, the LCAC membership was reviewed and new members were added in 2008. During the current audit period, the LCAC membership varied from 11 to 14 members. At the time of the audit, the LCAC contained a good balance of interests with representation from a naturalist organization, recreation, independent loggers, local and regional municipal interests, the general public, cottager/property owners, anglers and hunters, trappers, and both large and small forest industries. A number of the LCAC members have been on the committee for an extensive period of time and there will be a good opportunity at the start of Phase 2 to see if they have a continuing interest in participating and/or possibly recruiting any new members. There is currently no Algonquins of Ontario (AOO) representation on the LCAC, although Algonquin leaders have been invited. Algonquin

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representatives have many opportunities to raise issues of importance and concern to them and, therefore, the LCAC may not be of high priority to them. A member of the LCAC was appointed to the FMP planning team and LCAC members were highly involved in the preparation of the plan. They feel the Committee follows its Terms of Reference, fulfills its purposes, and are satisfied with how it operates. All members of the LCAC indicated that meetings were run in a fair and inclusive fashion with members feeling free to discuss topics and issues of concern and interest. Significant efforts have been made by the OMNR, OVFI, and the LCAC to carry out field tours and site visits. This was evident during the audit where there was high participation from LCAC members. Overall, members of the LCAC consider the Forest to be well managed. A number of LCAC members were concerned with the economic challenges facing the forest products industry. An OMNR staff member was chairing the LCAC until early 2012 when two members of the Committee volunteered to be co-chairs. Having an OMNR staff person chair the committee is not in accordance with the 2009 FMPM which states, “a local citizens committee comprised of local citizens”. Also, OMNR is not listed as one of the interests that can participate on the LCAC. A recommendation is made by the audit team to adjust the Terms of the Reference of the LCAC so OMNR is not chairing the Committee (Recommendation 1). All of the standard public consultation opportunities were provided for the preparation of the 2011 FMP. A number of individuals offered public comments during the various stages of the forest management planning process. In general, fewer individuals were involved and fewer comments were made on this forest than on most other forests the auditors have assessed in Ontario. All the public comments were recorded. Diligent and sincere responses to comments were issued. There were no requests for Issue Resolutions or Individual Environmental Assessments. Overall, the public seemed to have no major concerns with the 2011 FMP. All of the Ottawa Valley Forest is in the area of a comprehensive land claim by the AOO. The AOO consist of ten communities: Mattawa/North Bay, Antoine, Whitney and Area, Bonnechere, Greater Golden Lake, Ottawa, Pikwàkanagàn, Snimikobi (Ardoch), Kijicho Manito Madaouskarini (Bancroft), and Shabot Obaadjiwan. All ten are recognized by the Crown and are involved in the negotiation of the land claim. The AOO have indicated that all of the Algonquin communities have an interest in the Ottawa Valley Forest and all, except for the Ottawa community, participated in the preparation of the 2011 FMP. This was the most extensive participation by the AOO to date. The Ottawa Valley Forest is important to all the Algonquin communities. While a number of them are physically located within the Forest, most, if not all, have members scattered throughout the Ottawa Valley. The Forest is used for both traditional and modern day pursuits, including hunting, fishing, collection of plant materials, food and medicines, and firewood. Many Algonquins also work in the forest industry in both logging and at mills. Algonquin leaders have indicated they are generally comfortable with the forest industry and with logging but they do have issues from time to time with specific forest management activities. The Algonquin communities were consulted at the start of the FMP process and each community was asked to consider their preferred consultation approach, nominate a planning team member, and begin the production of an Aboriginal Background Information Report. There was subsequent correspondence at various stages of the planning process. Nine of the ten Algonquin communities chose to have

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representation on the planning team as their principal form of consultation on the plan. Six of the nine provided Aboriginal Background Information Reports: Antoine, Whitney and Area, Bonnechere, Snimikobi (Ardoch), Kijicho Manito Madaouskarini (Bancroft), and Shabot Obaadjiwan. While the funding of native values collection exercises is limited, OMNR has done a good job of trying to combine funds across Algonquin settlement forests and for all Algonquin communities. However, some Algonquin leaders feel that the amount of funding for values identification and preparation of reports is not sufficient to properly cover this matter. The Algonquins have indicated that known values are adequately protected through the existing processes and there is no evidence of values being negatively impacted during the five-year term of the audit. Algonquin leaders did note that unknown values could be negatively impacted by forest management activities. Algonquin leaders indicated that some elders are likely knowledgeable about such values but are usually unwilling to release such information. While there are likely many reasons why they are reluctant, there is a common concern that identified values may be released publically should they be identified and even greater impact would occur. As all parties become more confident in the capacity of the FMP process to protect Aboriginal values, willingness to share them should increase. The audit team believes ongoing discussions with the AOO as part of the land claim process are providing effective measures to build this confidence. The audit protocol requires the audit team to review whether Aboriginal peoples were provided with, and whether they availed themselves of, opportunities to achieve more equal participation in the benefits provided through forest management planning. The AOO have indicated a strong interest in obtaining more economic benefits from forest management. This has been well documented, was passed on to the audit team and, most importantly, has been a subject of the negotiations in the Algonquin land claim process. Since forestry issues and interests have been a part of the land claim negotiations, it is impossible to look at the involvement of the AOO in forest management in isolation from the larger Algonquin land claim. The land claim negotiations culminated in a Preliminary Draft Agreement in Principle (PDAIP) that was made public in December 2012. The PDAIP had not yet been ratified by the membership at the time of this audit. The PDAIP includes a chapter devoted to forestry matters which recognizes the overall importance of the forest industry to the Algonquin Settlement Area and pledges that the parties agree to work co-operatively to increase Algonquin participation in, and benefits from, the forest industry. This chapter also outlines that Ontario will support measures to increase Algonquin participation and employment in the forest industry, which could include training and contracting opportunities. It also indicates that the Algonquins will continue to be active in forest management and planning. This chapter addresses the intent of Condition #34 of the Class Environmental Assessment for Forest Management (which requires OMNR District Managers to conduct negotiations with Aboriginal peoples to identify and implement ways of achieving more equal participation in the benefits provided through forest management planning) and Section #20 of the Ottawa Valley Forest SFL.

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Prior to the release of the PDAIP, the Forestry Working Group, Algonquin Land Claim Negotiation External Forestry Working Group was formed which is comprised of the AOO and Algonquin Negotiation Representatives, OMNR District Managers and supporting regional and district staff for all districts covered by the claim, and senior representatives of the SFLs covering the same area (including the OVFI). The general mandate of the Group is to discuss forestry matters, specifically items identified in the PDAIP in the land claim area. Each forest (Ottawa Valley, Bancroft Minden, Nippissing, Mazinaw/Lanark, and Algonquin Park Forest) have a sub-group established through the central Forestry Working Group to discuss local business and opportunities. While the Working Group is only in its initial stages, it has been confirmed by the AOO as an excellent forum to forge a better understanding of the challenges and opportunities facing the SFLs and the AOO. Discussions have already occurred on possible training and employment opportunities for Algonquins. The External Forestry Working Group can move forward with the intent of Condition #34. While there is no documentation on Algonquin employment levels in the forest industry, it is clear they have some involvement in various wood and logging industries throughout the Algonquin Settlement Area. A number of the Algonquin representatives indicated a desire to benchmark Algonquin economic involvement in the forest industry to assess whether progress is being made in the future. They wondered how this could be done, who could do it, and whether auditors could assess performance against it. This is a legitimate question and was central to the original intent of Condition #34. Algonquin economic involvement in the forest industry could be benchmarked and subsequently assessed. This could also be set as an FMP objective. During the audit process, the AOO identified a number of possible indicators including: Algonquin and managerial employment in the forest industry relative to all employment; number of Algonquin-owned businesses; and, number of training programs provided and participation levels. There are many impact and benefit agreements across the country between First Nations and resource companies where such indicators are measured. However, it will require the AOO, OMNR, and the forest industry to work together and would likely require access to AOO membership lists. This should be an appropriate task for the External Forestry Working Group.

4.3 Forest Management Planning

The planning process was challenged by the introduction of a new planning manual partway through the process, resulting in the production of a contingency plan that was in place from April 1, 2011 until plan implementation in July, 2011. The final 2011 FMP was a hybrid plan based upon both the 2004 and 2009 FMPMs rather than solely on the 2004 FMPM as specified in the Terms of Reference. Specific delays in plan production were attributed to the application of new guidelines and the development of the Long Term Determination of Sustainability, as well as an effort to create efficiencies amongst the three regional 2011 FMPs being developed in OMNR’s Southern Region. Three regional task teams were employed to address the Long Term Management Direction, the two new guidelines introduced in these plans, and the SGRs. In 2005, OMNR assumed corporate responsibility for production of new digital photography and its interpretation to create a digital FRI for Ontario’s Crown forests. The corporate commitment to renew FRI on a ten-year rotation remains on the Ministry’s public web site as the audit report is being written. Digital photography of the Ottawa Valley Forest was completed in 2009 and OMNR has indicated it will begin production of the FRI in 2014, with expected delivery in 2017. The audit team is concerned with

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the delayed production of this FRI. The FRI for this Forest, which is the basic data on which most long term management objectives are based, will be 30 years old before it is replaced. The currently promised FRI delivery date of 2017 will provide information that is based on photos that will be 12 years old before the next scheduled complete FMP for this Forest is delivered in 2021. The FRI is used as the basis for the majority of the quantitative evidence that supports the claim of managers that they are addressing forest management issues into the future. The auditors have recommended that OMNR must meet its ten-year production commitments for the FRI (Recommendation 2).

The 2011-2021 FMP includes 245 pages on the Long Term Management Direction along with a 186-page analysis package and five tables documenting the results. Most of the projections are made for 120 years and include Simulated Range of Natural Variation. The plan objectives flow from the Long Term Management Direction. The 2011 FMP includes 38 objectives, each with several indicators, based upon modeling projections. The auditors have completed a review of the smaller number of objectives included in the 2006 FMP. There is no discussion on the accuracy of the projections in the Long Term Management Direction. The auditors recommend that Corporate OMNR re-evaluate how the Long Term Management Direction is documented and include a discussion of the integrity of the forecasts and degree of uncertainty that is present (Recommendation 3). Forest units are a basic building block of forest management. Ontario’s adaptive forest planning system is dependent on connectivity between plans. On the Ottawa Valley Forest, forest units changed between the 2006 and 2011 FMPs in response to discussion about amalgamation of two or more SFLs in the region. The data used to track progress (e.g., FTG data) has been challenged. Planning has been complicated by the severing of important linkages between management plans. Although the regional Long Term Management Direction team established a new set of forest units, the forest units used for the 2011 FMP did not adequately capture the full and unique character of the Ottawa Valley Forest. The auditors have recommended that consistent forest units be used across plans and that they originate locally (Recommendation 4). Table FMP-9 in the 2011 FMP summarizes the host of objectives and indicators in 13 pages. This table is only readable with the use of a magnifying glass, which is unacceptable for a public document. Tables such as this currently dominate management plans but do little to provide transparent and understandable information. The auditors have recommended OMNR re-evaluate the use of large tables of redundant information in FMPs (Recommendation 5). The FMP description of landscape pattern and processes, habitat for selected wildlife species, and a description of fish and wildlife resources, existing roads, and land uses was reviewed. Protective measures for species that are required by the Endangered Species Act and other notable natural resources, such as significant old growth stands and wetlands, were also reviewed. The Forest is currently dominated by mature forest. The FMP presents a trend for mature and old landscape classes to decline then rebound over the long term. This pattern shows an abundance of habitat for species dependent on mature and old forests, which is an expected outcome when partial

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harvest systems are used most often, and a consequent limit of habitat dependent on pre-sapling habitat where the same harvest systems rarely result in open areas. The largest and most economically important forest units, white pine and red pine, met the old growth requirements of the provincial policy. At “plan start” in 2011, there were 57,655 ha of these forest units classified as “old” and they are projected to stay within the Simulated Range of Natural Variation (60,342 ha +/- 17,000 ha) into the future. Representation of old growth conditions in uneven‐aged tolerant hardwood forests (e.g., CEsel, HEsel and HDsel forest units) is not modeled as the current inventory is not capable of differentiating age classes in these forest types. The large number of objectives and targets for wildlife, including provincially- and locally-featured species, SAR, and landscape characteristics, shows a significant effort in detailed planning and diligent observance of the direction in the FMPM. The modelled forecasts of hundreds of indicators project that a reasonable achievement of the desired future forest condition may be possible. For the modelling that supported the 2011 FMP, the initial landbase available for each forest unit was reduced by the proportion reserved by AOC prescriptions in the 2006-2011 FMP. This accounted for an overall 9% of the landbase designated as forecast reserves. The use of the SSG for the creation of forecast AOC layers creates more modified harvest areas instead of absolute reserves. This means the area of available production forest and the allowable harvest area may be underestimated. The planning team did not reduce the forecast in order to be cautious. This was a good decision given the challenges implementing some AOCs for water and some confidential values. Overall, the planning team provided a thorough analysis of the current forest condition in the FMP. They have documented the predicted implications of the chosen management alternative on the required range of habitat. The audit team reviewed the values maps used in the FMP. Orderly plan production and implementation are dependent on a regular and rigorous updating of values. Biological values, like nest locations, are susceptible to change. A number of nest locations were verified in the field during the audit. Both OVFI and OMNR staff demonstrated professional capacity to locate and verify these occurrences. Maps had a high level of accuracy considering these dynamic values. In 2009, there was a new direction based on the SSG that classified water bodies as having high, moderate, or low potential sensitivity (the FMP water layer). Both the OMNR and OVFI in this District have struggled to implement this direction. To assist in the implementation of the process, the OMNR Forest Branch undertook to update the GIS-based water layer for FMP planning teams. This mapping was used to assign the boundaries for cut blocks during the AWS and is the basis for compliance reporting. There were errors found in the original issue of the FMP water layer and more have been found in subsequent updates. It appears the intent of the SSG approach to AOCs around water was to increase the opportunity to harvest wood while “creating a mosaic of shoreline forest conditions that will sustain … many ecological functions”1. Application of the new SSG requires use of this special mapping of water in addition to the

1 Page 37 - Forest Management Guide for Conserving Biodiversity at the Stand and Site Scales

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regular Natural Resource Values Information System (NRVIS) water layer. This is because assignment of low, moderate, and high sensitivity is not intuitive, nor does it rely on field verification. For example, an ephemeral stream that field observation would assign to the low sensitivity category might be elevated to a high sensitivity category if the GIS review found the ephemeral stream led to an unclassified stream. Given that an unclassified stream has, by definition, not been field verified, the default position of the GIS analysis assigned the highest level value to the stream and, consequently, the highest level of protection to ephemeral streams draining into it. This is very different from the previous guides which relied heavily on field interpretation. Now, field interpretation is often not possible and line marking of water must be done with heavy reliance on the GPS. This was regarded by the audit team as unnecessarily precautionary and operationally demanding for a value of moderate conservation value. Use of the FMP water layer requires a custom GIS product from Corporate OMNR to create the AOC boundaries derived from the NRVIS water layer. Delivery to the District has not worked out to date. It is now apparent that this process is very complex. The auditors concluded that the complexity of the method for assigning the FMP water layer for AOCs is currently unmanageable, despite the best efforts of competent staff at both the District and OVFI. Corporate OMNR needs to deliver the FMP water layer in a manner that requires only basic training for District and OVFI personnel and minimal maintenance. Until that is delivered, a recommendation is made for the District to use a more intuitive, field-based approach for the interim application of AOCs around water (Recommendation 6). The Endangered Species Act created a requirement for locating rare, threatened, or endangered species, classified as Confidential Values, prior to forest operations. A significant increase in effort was made by OMNR after the Endangered Species Act came into law. However, the nature of these surveys means that there is a period of catch up to get ahead of forestry operations. There are some other factors which have magnified the problem in central Ontario. For example, partial harvest systems mean that the logging operations move across the landscape more quickly, and the large number of contingency blocks that are included annually in the AWS mean there is an additional area to cover. Maps for use in planning related to the Endangered Species Act are typically not available until March when operations begin in April. The blocks are not sorted by “probability of harvest”. There are commonly short timeframes available for these surveys. To the audit team, there appears to be opportunities for making the survey system for Confidential Values more effective. The audit team is recommending that OMNR District should, with the assistance of OVFI, examine the efficiency of their approach to Confidential Values surveys (Recommendation 7). The audit team reviewed the process used to ensure that ecological and cultural values were identified and appropriate AOC prescriptions incorporated by the planning team in a timely manner. Good information was available for most AOC prescriptions and reasonable alternatives were considered. Mapping was accurate with the significant exception of the FMP water layer discussed above. Several forest-dependent species have been identified as threatened or endangered. For one species in particular, which the auditors are unable to specifically identify because it is a confidential value, there have been two recent directives with inconsistent direction. In the field this dichotomy causes inefficiency. Apparently two map layers are tracked, one for forestry, one for other forest users. The OMNR should review the linkage between the Endangered Species Act and the CFSA and integrate the objectives and protection of SAR with the planning and implementation of forestry

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operations. The audit team is recommending that OMNR clarify the dichotomy between the two directives (Recommendation 8).

4.4 Plan Assessment and Implementation During their examination of the field operations, the audit team assessed the appropriateness of the FMP in describing the field conditions, if field implementation of the 2006-2011 and 2011-2021 FMPs reflects the direction and assumptions asserted in each respective FMP, and if the areas where actual operations were undertaken reflect the eligibility and selection criteria listed in the plan. Overall, the auditors were satisfied that the Ottawa Valley Forest land base conditions encountered in the field closely reflected the descriptions embodied in the FMP texts. There is a high degree of diversity on the Ottawa Valley Forest. Tree markers often find themselves making refinements to marking prescriptions or stand boundaries and making applicable adjustments to the FOPs. The FOPs are usually prepared for each stand (polygon) or sub-stand that may be found within the stand boundaries. It is not uncommon for the initial polygon to be subdivided into several sub-stands, with each sub-stand being assigned an individual FOP. Tree-markers document any prescription “variables” that may have been applied to accommodate changes in the stand structure. Analysis of planned versus actual yields using data from the 2010-11 Annual Report showed yields were mostly underestimated over the past 20 years (Table 3). Table 3. Planned vs. Actual Yields for the Ottawa Valley Forest (2010-11 Annual Report).

Period Planned Harvest (m3/ha)

Actual Harvest (m3/ha)

1990-1996 60 70

1996-2001 81 78

2001-2006 73 87

2006-2011 77 81

The total forecasted yield of 73 m3/ha in the 2011-2021 FMP is less than actual yields attained over the past 15 years. The higher actual yields achieved in the recent past are attributed to improved markets for lower quality products (i.e., pulpwood) and increased salvage efforts. Considerable effort was made during preparation of the 2011 FMP to improve upon the accuracy of the yield curves. A new approach was utilized for forecasting yields in the clearcut forest units by making use of the Empirical Variable Stocking Yield that was prepared with the assistance of OMNR Regional staff. Growth and yield projections for the uneven-aged forest units were developed in the same manner for the 2011 FMP as used for the 2006 FMP, including continued use of the SFMMTool VBAR (volume to basal area ratio) estimates. These efforts are intended to result in a higher level of congruence between planned and actual yields in the current plan. However, the unreliable condition of the FRI may hinder this achievement. The areas considered eligible and selected for various treatments, including harvesting, renewal, tending, and maintenance, conformed to the eligibility and selection criteria that were established in the

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2006 and 2011 FMPs. Any changes that were made to operations were addressed by amendments or revisions to the appropriate planning documents.

Application of the SGRs and FOPs were found to be appropriate for the stand conditions that were encountered in the field. The prescriptions and the prescription adjustments observed in the field were generally appropriate for the specific site conditions that were encountered. A good example is the situation when an unforeseen component of white pine is encountered in an intolerant hardwood stand. If sufficiently large, the white pine area is marked for shelterwood management rather than as a clearcut. Some of the prescription adjustments within very small areas seemed impractical, requiring return treatments to isolated areas. The auditors accept that conscientious staff were trying to apply the most appropriate FOP on every square meter of forest. However, the fineness of the application probably exceeded the ability to manage it in a cost-effective manner. The audit team was satisfied that field operations were consistent with forest management modeling assumptions used in the 2006 and 2011 FMPs in terms of base model inputs that could be practically assessed at the field level and recognizing the limitations of the vintage FRI on the Forest. The nature and types of operations conducted were consistent with the types of operations utilized for modeling purposes. The residual minimums as prescribed in the FOPs were being retained in the selection and shelterwood management stands and, in several cases, significantly more trees were left standing than required, particularly under the shelterwood and clearcut systems. The unharvested volume represented forgone economic opportunity and the additional shade cast by the residual structure was likely to hinder growth of planted or natural seedlings. A recommendation has been issued directing OVFI to ensure there is full harvest utilization, particularly in final removal shelterwood sites (Recommendation 9). In the clearcut areas, appropriate measures were being taken to retain snag trees for wildlife purposes and appear to approximate the intended retention levels. Increased use of mechanical and chemical site preparation was evident as prescribed in the 2011 FMP and in response to issues identified in recent assessments with securing successful white pine regeneration. The auditors were comfortable that road-building and landing construction were being kept to a minimum and not excessively reducing the productive forest landbase. A representative sample of the non-timber value AOCs was selected where forestry operations have been conducted during the five-year period of the audit. The number of values sampled was large relative to other forests. This is a reflection of the high density of values in this landscape and the extent of their documentation.

There were no exceptions to any of the implementation manuals or guidelines used to develop the AOC prescriptions that applied to non-timber values. Overall, assignment of values protection was in keeping with the SSG. Note that the assignment of protection to water bodies was encumbered by the problems with identification of sensitivity as previously described. Buffers for certain Confidential Values were also previously discussed and a recommendation was made related to clarity of the directives and the level of effort in surveys. Other than these two situations, the auditors found appropriate field application of the prescribed AOCs.

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The application of the white-tailed deer habitat guidelines is particularly well done in the District. The protection of the critical thermal cover (CTC), which requires field identification of the best cover in each deer yard, is challenging. The process, which originated in Pembroke District, begins with a model that ranks the cover stands and helps set target levels of retention. In the field, CTC stands are flagged for retention after verifying them in aerial photographs to ensure they are suitable. The spatial distribution of thermal cover for each yard is examined. The FMP prescribes the Conditions on Regular Operations, listed in the FOPs for each block. Ottawa Valley Forest Inc. works the designated CTC stands into their FOPs for each block. The audit looked at this in the field at a location where a small band of cover was maintained because of the presence of a very active deer trail. It is a notable achievement to be able to apply planning concepts to values as subtle as deer trails. The renewal program on the Ottawa Valley Forest relies substantially on natural regeneration (about 70% of the total program). The shelterwood system is applied to mid-tolerant species such as white pine and red oak and relies primarily on natural regeneration. The shelterwood system was practiced on just under 50% of the area harvested on the Forest during the audit term. Shade intolerant species, such as red pine, poplar, and white birch, are managed under the clearcut system. Most of the overstory is removed in a single harvest operation. Regeneration was through natural methods, or sites were planted or seeded. Clearcutting was applied to 38% of the area harvested on the Forest. The selection system is applied to good quality, uneven-aged stands dominated by shade tolerant species such as hard maple and hemlock. The aim is to maintain an ideal stand structure containing residual stems with a variety of diameter sizes. Stands managed under this system on the Ottawa Valley Forest were once harvested on a 15-20 year cutting cycle. Cutting cycles were extended in the 2011 FMP, as it was found with the 2006 FMP allocations that stand structure and timber quality did not meet the expected standards for proper selection management. The current issues with sub-standard quality are attributed to past harvest practices that may have retained insufficient post-harvest basal area and cutting cycles that were too short for local growth rates. Selection harvest cutting cycles have been extended to 40 years under the current 2011 FMP with the expectation that stands will recover from past practices. There were 10,915 ha regenerated during the 2006-11 term, which represents 66% of the planned renewal program of 16,660 ha over the same period. Natural renewal (7,650 ha) comprises 70% of the total renewal program. The planting program (3,220 ha) was above the planned level of 2,575 ha. The auditors note that the level of achievement for renewal (66% of the planned renewal level) exceeded the harvesting level of achievement (58%) over the same period. Tree marking is a critical aspect of a substantial proportion of the renewal program. All tree marking work is conducted by qualified individuals employed or contracted by the harvesting licensees. All tree marking work is audited by OVFI staff to ensure compliance with the marking guidelines, AOCs, and FOPs. Reliance upon natural renewal under shelterwood-managed sites has become more tenuous in recent years, mostly due to inadequate seed crops on the residual stems. This is particularly the case for white pine renewal, which has received considerable attention on the Ottawa Valley Forest due to the commercial and ecological importance of this tree species. Implementation of the uniform shelterwood system for white pine has been evolving over the past decade, based on recent survey outcomes

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demonstrating unsatisfactory renewal of white pine in many cases. Ottawa Valley Forest Inc. believes that the three-cut shelterwood regime may have been prescribed in less than ideal situations or implemented improperly. In stands where initial white pine composition is inadequate, a two-cut shelterwood regime may be employed, consisting of a regeneration cut and a final removal cut. They had found that there was insufficient volume available to make both a first removal and final harvest economically feasible. In other cases, OVFI staff had found that the final removal harvests can cause significant damage to the advanced natural regeneration that the shelterwood system has been designed to create. The auditors’ observations support these conclusions and they recommend that Regional OMNR conduct a detailed review of the white and red pine shelterwood SGRs and identify the stand conditions where a two-stage shelterwood system (i.e., utilizing only a single removal harvest) may be applied (Recommendation 10). Ottawa Valley Forest Inc. has now adopted a strategy of following up most white pine regeneration cuts with mechanical and chemical site preparation to remove undesirable competition and ready the site for supplemental planting with container stock. Chemical site preparation is achieved through the deployment of ground-based, air-blast sprayers pulled by skidders. Chemical site preparation is being applied more frequently compared to the past, as this treatment has been found to offer higher success in securing crop tree survival. Red oak renewal is inclined to rely more heavily on natural renewal owing to the difficulties of storing acorns over extended periods. Mechanical site preparation may be used but opportunities to employ chemical site preparation may be limited if natural oak regeneration is present in the understory. Little activity has occurred on the Westmeath seed orchard and, in fact, very little information is available about this white spruce seed orchard. Staff of OVFI were not aware of its current condition. Both the Grattan and Westmeath seed orchards could serve potentially important roles as sources of genetically improved seed for the renewal program on the Forest and other surrounding SFLs. Tree improvement work is a reimbursable expense under the SFL Forest Renewal Trust Fund. Partnerships for managing tree orchards and tree improvement areas exist on other SFLs which could serve as examples for establishing funding and working arrangements on the Ottawa Valley Forest. It is suggested that Ottawa Valley Forest Inc., in cooperation with the District and Forest Genetics Ontario, make efforts to determine the status of the Westmeath seed orchard and determine if it can be utilized as a source of genetically improved seed for use in their renewal program. In general, the audit team witnessed an effective renewal program, where sites are treated promptly and with appropriate prescriptions. Only a few situations were observed where competition was overtopping regeneration and could have benefited from a tending treatment or re-treatment. The auditors were comfortable with the level of knowledge and familiarity with the land base that OVFI staff exhibited and, based on that, would expect these remedial treatments to be completed in the near term. Tending activities occurred on 4,445 ha over the 2006-11 term, including 814 ha of ground chemical/mechanical cleaning in plantations, 1,405 ha of spacing/thinning in shelterwood stands, and 227 ha of stand improvement cutting in uneven-aged managed stands. All of the tending achievements and stand improvement cutting in uneven-aged managed stands were closely tied to the level of harvest in selection-managed stands.

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The overachievement in spacing/thinning in shelterwood stands is primarily attributed to extra support funding provided by the Forestry Futures Trust, Project #707-1-R27, which assisted in enhancing shelterwood and selection management by enabling the removal of otherwise unmarketable species and products.

The OMNR has reported a number of instances where deficiencies have been found during stand improvement work undertaken during the 2012-13 period. Staff of OVFI recognized that shortcomings in communications with their contractor may have occurred, leading to substandard work being performed according to their own assessments (which were performed to verify OMNR’s findings). The auditors were able to visit one of the sites in question and confirm that the work was deficient in some aspects. When possible, the contractor was sent back to correct the work but in some cases remediation was not possible. The OMNR has also asked the Forestry Futures Committee to investigate its claim that monies may have been paid for work that was not performed. The auditors understand that this matter is still under discussion among OVFI, OMNR Pembroke, and the Committee. In the stand improvement cutting treatments inspected, residual crop trees were generally of high quality, with exceptions being required to leave lower quality trees that served as wildlife habitat or were retained in order to maintain appropriate spacing in selection and shelterwood situations. Tending treatments have been declining over the past ten years. Much of the decline can be attributed to changes in reporting procedures relative to stand improvement operations. From 1990 to 2000, all harvesting in shelterwood and selection management stands were considered to have included a stand improvement component and were recorded as such in the annual reports. Since 2001, only stand improvement projects that directly receive Forest Renewal Trust or Forestry Futures Trust funding are included in the actual reporting numbers. Stand improvement operations seldom occur without dedicated funding to compensate operators, nor does harvesting in shelterwood and selection management stands necessarily include a stand improvement component. The use of chemical site preparation by OVFI on many sites has replaced chemical tending, a strategy they believe will be more efficacious and reduce overall chemical use.

4.5 System Support Ottawa Valley Forest Inc. is certified by Forest Stewardship Council®. This means OVFI and other forest workers have been audited for their compliance to the Human Resources requirements of the Independent Forest Audit Process and Protocol. This requires that awareness, education, and training programs are in place to ensure general knowledge as well as knowledge specific to an individual’s responsibilities in the sustainable forest management system. Document management and control was examined for both OMNR and OVFI. The OMNR has a significant information technology infrastructure. All basic requirements, such as off-site backup of values and inventory information, are carried out as part of the corporate procedures. The auditors made a recommendation earlier in this report related to the management of the FMP GIS information layer related to water bodies. That recommendation addresses the interpretation of values rather than the actual transfer and management of data. The GIS needs for OVFI are managed in house. Almost all of their information is managed electronically, through the GIS or other databases. Appropriate agreements are in place to cover confidentiality and security of information. Provision of maps, prescriptions, and other field related files were

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professionally managed during the audit. Forest Information Manual technical requirements for base information and other values, FRI, FMPs, AWSs, amendments, and annual reports follow procedures, including electronic submissions through the FI Portal. This provides backup of FMP data and other information critical to forest management.

4.6 Monitoring Compliance Monitoring The OMNR in Pembroke prepared and approved annual compliance plans for the Forests program using a risk-based approach. These plans included a forest compliance activity schedule, a risk rating matrix, and a risk summary by SFL activity block. The OMNR does not share its annual compliance plan with OVFI. The level of monitoring being conducted by OMNR is sufficient to ensure that the SFL holder and the overlapping licensees are meeting the legislative requirements and their obligations. Ottawa Valley Forest Inc. has recently implemented a notification protocol that informs OMNR regarding the operational status of its blocks (e.g., start-up, suspended, and released/completed) in accordance with the requirements of the Forest Compliance Handbook, 2010. There have been occasions prior to this time where OVFI has failed to notify OMNR regarding activity start-ups. The auditors viewed the shortcomings of OVFI on these matters as minor in nature. Ottawa Valley Forest Inc. prepared a five-year Forest Compliance Plan and a ten-year Forest Industry Compliance Strategy for the Ottawa Valley Forest. The ten-year compliance strategy met the requirements of the FMPM and compliance handbooks. Annual Compliance Plans were also prepared by OVFI for each of the five years as required. There were 620 compliance inspections filed over the audit term. The frequency of inspections has remained steady. Ottawa Valley Forest Inc. and the Overlapping Forest Resource Licensees (OFRLs) use the Forest Operations Inspection Program (FOIP) as a tool for tracking the status of their operations, thus continuing to submit start-up and suspension reports through the FOIP system. This information is then used to develop monthly operations status summaries which are forwarded to the OMNR in Pembroke. The objectives of OVFI's 2011-2021 Compliance Strategy include a training component that emphasizes the value of providing compliance training and education to staff, OFRLs, and contractors. The two primary mechanisms for delivering training are through the quarterly Compliance Committee meetings and the annual meeting with the operators each Spring. The auditors confirmed that adequate training is provided by OVFI to its staff, shareholders, OFRLs, and contractors. A significant part of training for OFRLs and front-line workers is supplemented through the routine interactions between OVFI and OFRL staff in the field. Ottawa Valley Forest Inc. has cultivated good working relationships with OFRLs and contractors. Although their casual approach to training front-line staff is not formally structured or documented, it appears to be successful based on OVFI’s overall compliance record (over 95%) over the audit term. Interviews with OFRLs confirmed that OVFI uses a tailgate training approach to ensure that their workers understand what is expected. The auditors are satisfied that OFRL workers and contractors are receiving relevant and adequate environmental awareness and compliance training.

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Four OVFI staff are certified compliance inspectors and carry out these functions as regular aspects of their job duties; two staff focus on harvest operations while two others focus on the silviculture aspects. None of the ten OFRLs are “qualified overlapping licensees”, in that they are not solely responsible for all compliance functions of monitoring, inspecting, and reporting under their overlapping license, and for the training/education of their employees. They must work cooperatively with OVFI regarding such matters. However, many of the overlapping licensees have staff that are certified inspectors or hire individuals who are qualified to conduct compliance inspections. Compliance reports related to harvesting and access are filed by compliance inspectors for the OFRLs and are approved by OVFI; most are reported promptly, according to interviews with OMNR and reviews of the FOIP reports. In nearly all cases of non-compliance, OVFI and the OFRLs identified and implemented corrective action soon after the infraction was discovered. Table 4 shows the compliance inspections filed during the audit term and their results. Table 4. Compliance Inspections Conducted by OVFI and OMNR. OVFI Compliance Inspections (2008-2013)

Activity Inspected

Total number of reports

In compliance

Not in compliance

Access 156 154 2 Harvest 421 416 5 Renewal 32 32 0 Maintenance 11 11 0 Protection 0 0 0 Total 620 613 7

OMNR Compliance Inspections (2008-2013)

Activity Inspected

Total number of reports

In compliance

Not in compliance

Access 48 43 5 Harvest 130 123 7 Renewal 17 14 3 Maintenance 11 11 0 Protection 0 0 0 Total 206 191 12

A sustained effort is made by OVFI to communicate with its shareholders, OFRLs, and contractors on the importance of compliance. Compliance information is conveyed at least annually under classroom-like situations and often through field contacts. OVFI appears to maintain a good level of rapport and communication with their shareholders, OFRLs, and contractors. To assist licensees with keeping their operations compliant, OVFI has recently compiled a set of checklists that is part of the harvest release package provided to each OFRL and reviewed before operations are scheduled to begin within a particular block. The harvest release package includes harvest instructions (derived from the FOPs), the most current maps, any AWS revision conditions, a road access and abandonment plan, and the OMNR-issued cutting approval. A copy of the harvest

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release package must be kept on site at all times. The checklists also make reference to the Standards and Guidelines in the Ottawa Valley Forest package that has been recently assembled by OVFI. This package, also known locally as “the Operations Binder”, is essentially a compilation of standard operating procedures and includes a copy of the AOC prescriptions and descriptions of the standard operating conditions (i.e., Conditions on Regular Operations and Conditions on Roads, Landings, and Aggregate Pits) that apply to the OVF. Licensees are encouraged to contact OVFI staff if they are unclear on any aspect of their planned operations. Assistance is provided by OVFI to OFRLs operating in blocks adjacent to private land to ensure that boundary lines are accurately established and that access agreements, if necessary, are negotiated and signed with the private land owners prior to the start-up of operations. Non-compliant findings from OVFI inspections fluctuated from 0.0% to 2.4% per year during the audit term, while non-compliance frequencies from OMNR reporting fluctuated from 0.0% to 17.6% per year. Such reporting disparities are not uncommon and have been frequently encountered on other audits. There were 22 non-compliance incidents reported over the audit term, all of them assessed as being minor in significance. The issues most commonly included were failing to obtain proper approvals prior to installing water crossings, improperly installed water crossings, not following AOC prescriptions, and not adhering to conditions associated with the operation of gates. Ten penalties totaling $9,400 were assessed on OVFI, or OFRLs operating on the Forest, during the audit term, three of which were related to offences discovered during the previous audit term. Thirteen remedial compliance orders and at least four written warnings were also issued. The rest of the non-compliances were resolved by self-corrective actions being taken by the culpable licensee. The FOIP database shows that the non-compliance frequency trend had declined during most of the audit term, but this trend has reversed recently. There have been increases in the number of non-compliances noted by OMNR in the last year of the audit term, for which penalty notices have been recently issued. Since April 1, 2013, there have been seven non-compliances identified, resulting in $16,000 in fines, a repair order, a compliance order, and two written warnings being issued to OVFI. Although the determination of corrective actions and fines occurred after official end of the audit scope (March 31, 2013), the fines all relate to stand improvement activities that occurred during the audit term. Compliance monitoring has been a long-standing issue on this forest. The two previous audits have included specific recommendations on the matter, but it was apparent during our field inspections that acute differences of opinion on compliance between OMNR and OVFI staff remain. A recommendation has been issued requiring this issue be dealt with urgently at senior levels of the OMNR and OVFI (Recommendation 11). Most non-compliances involved a small number of licensees and operators. Further examination revealed poor communications, and the licensees and operators not keeping OVFI informed about their actions or intentions, sometimes led to non-compliant situations. The auditors have recommended that OVFI manage these operators more deliberately (Recommendation 12). Silvicultural Monitoring

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Various types of surveys are employed to monitor silviculture effectiveness, which include: (1) post-cut assessments, (2) survival monitoring of natural and artificial regeneration, (3) frequent and informal regeneration assessments (normally ocular surveys), and (3) FTG assessments. Post-cut assessments involve ocular surveys or establishing a series of informal plots, or a combination or both, which are documented for further follow-up. The post-cut assessments, for example, ensure that the prescriptions have been attained in uneven-aged (selection) managed stands (i.e., HDSel and HESel) by measuring the proportion of acceptable growing stock versus unacceptable growing stock. In shelterwood situations, the post-cut survey assists in monitoring the outcome of the harvest and determines if the planned subsequent treatment (depending on stage of management) is appropriate, or if the SGR requires adjustments. Free-to-grow assessment surveys and associated reporting are completed after the regeneration harvest in clearcut forest units and in group openings associated with group-selection prescriptions. For shelterwood prescriptions, OVFI now conducts FTG surveys after the final removal harvest, usually within three years of this stage of harvest. Ottawa Valley Forest Inc. formerly conducted the FTG surveys following the regeneration cut stage in the shelterwood systems. This change in timing was introduced in the 2011 FMP. With the change of timing of FTG assessments in the shelterwood system, the time between the regeneration cut and final removal cuts could be as long as 10 to 40 years, depending on the forest unit. Ottawa Valley Forest Inc. introduced the Year 10 Interim Regeneration Report protocol in the 2011 FMP to provide a formal opportunity to document the state of regeneration and silviculture effectiveness for the shelterwood forest units. In the opinion of the auditors, this is a very good initiative. The Year 10 Regeneration Assessments are scheduled to occur in the tenth year after the regeneration harvest was completed. The final harvest is used in blocks where the regeneration cut may have required multiple years to complete. The results of Year 10 Regeneration Assessments establish whether renewal projects under the shelterwood system are on track for success and provide a source of data necessary for improving both silviculture and planning. The results of the Year 10 Regeneration Reports are documented in the annual reports as a complementary table denoted as “Table AR-10a” to distinguish this information from the FTG results. Areas harvested under uneven-aged silviculture systems (i.e., uniform selection system) are tree-marked according to prescriptions. Compliance monitoring of the harvest operations ensures that only trees designated for cutting are harvested and that logging damage to residual trees is minimized. A post-cut assessment is also conducted to confirm the status of the residual stand. The auditors understand that the development of parameters for evaluating silviculture effectiveness for stands managed under the selection system is a topic of ongoing discussion in the Southern Region. The auditors would support a more formalized process for measuring silviculture effectiveness of uneven-aged, managed stands. All tree marking, regardless of silviculture system, is audited by OVFI with ocular and/or plot assessments and documented. Copies of the audits are made available to OMNR Pembroke upon request. Overall assessment of silviculture effectiveness is conducted on a Forest-wide basis through regular reporting as required by the FMPM and the Forest Information Manual. A commentary and an evaluation of program achievements and effectiveness are provided by OVFI when the annual reports are submitted.

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The 2003 independent forest audit recommended that OVFI and OMNR jointly devise a format for OVFI to use for assessing and reporting on the silvicultural efforts and accomplishments on class X, Y, and Z lands. There were areas that remained pending in 2007 and have not been reported upon since. Ottawa Valley Forest Inc. should update and report on the status of the “pending” or “part pending” areas in the next annual report and continue to report on the status of the Y and Z lands in future annual reports until these areas meet the silviculture standards (Recommendation 13). Over the five-year 2006-11 operating term, 6,079 ha of renewal area were surveyed for regeneration success, which represents 37% of the planned level of 18,869 ha. Ottawa Valley Forest Inc. attributes the shortfall in achievement to three factors:

(1) the redirection of survey staff to mapping and assessing blowdown areas during the first two years of the plan term;

(2) the lack of removal cuts on which the FTG survey for shelterwoods are estimated; and, (3) only 61% of planned harvest area was actually harvested, which would have impacted

assessments within the 2006-11 term (intolerant clearcuts and areas with residual forest post-harvest).

The auditors are somewhat concerned that the actual level of monitoring has not been keeping pace with the levels projected in the FMP and not quite keeping pace with the actual levels of harvest and renewal over the past 21 years (which predates the SFL). The Year 10 (2010-11) Annual Report recognizes the shortfall in the regeneration assessment effort, but does not outline a clear action for addressing this deficiency. There are complexities inherent with tracking areas due to the logistics associated with the various silviculture systems employed on the Forest (e.g., risk of double counting treatment areas) and the weaknesses of relying on tabular data. Staff of OVFI are confident that their FTG assessment program is consistent with the levels eligible for survey. However, the auditors would prefer to see more convincing empirical evidence to support their claim since the current tabular data in not conclusive. The auditors have recommended that OVFI address this issue by conducting a thorough analysis as part of the 2013-14 (Year 3) Annual Report (Recommendation 14). The OMNR has conducted silvicultural effectiveness monitoring assessments but has not shared these reports with OVFI. The auditors have recommended that OMNR does so (Recommendation 15).

Annual Reports Annual Reports for the first four years of the 2008-2013 audit term were available for the auditors to examine. The 2012-2013 annual report was not due to be completed until after the audit. The reports met the guidance requirements. Ottawa Valley Forest Inc. was very attentive in meeting the annual report submission requirements for nearly all reports for which data was available during the entire audit term. The annual reports are well done. The level of analysis and commentary satisfactorily meets the applicable FMPM requirements.

4.7 Achievement of Management Objectives & Forest Sustainability

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Forest sustainability is the overriding goal of the CFSA. The success of forest management activities in meeting that goal has been assessed in terms of meeting the objectives they were designed to achieve. By reviewing planning commitments as detailed in the 2006 and 2011 FMP against achievements and analysis shown in Appendix 2, and as reported in the Year 10 Annual Report (Appendix 7), and observations during this audit, the auditors have assessed sustainability on the Ottawa Valley Forest. All aspects of the Year 10 Annual Report have been completed in a satisfactory manner. The findings are consistent with observations made throughout this audit. Two essential elements drive all other ecological and economic opportunities. The first is the depletion of stands through harvest or natural disturbance. The second is renewal of the forest after the depletion has occurred. These elements are still completely relevant in this assessment and the findings of the audit team have been generally favorable. Observations at harvest locations confirmed that utilization and harvesting practices were generally good to excellent. Logging damage to residual trees, regeneration, and skid trail coverage was minimal where observed on all sites and within the standards that have been established for the Forest. Overall implementation in terms of retention and removal of appropriate trees (e.g., removing poor quality stems, retaining wildlife trees, and retaining sufficient basal area and diameter classes) exceeded minimum requirements. In some systems, particularly red pine clearcut sites visited by auditors, there was too much residual left standing. In the opinion of the auditors, this left too much lost economic opportunity on site and too much shade on the ground. The renewal program implemented by OVFI is impressively aggressive. Sites were commonly mechanically and chemically site prepared and planted and manual tending, usually with brush saws, was a common follow-up treatment. The staff in charge of silviculture with OVFI have done an excellent job of implementing this program and continue to search for techniques that can help to renew the forest more efficiently. The renewal program is tested at the FTG stage. Table 5 provides greater detail of the level of FTG survey effort, listing the degree of silvicultural success and regeneration success for each forest unit by type of disturbance. The table shows that the Forest, as tracked by this indicator, is regenerating, with all forest units in excess of 90% renewal except for red oak. Table 5. Free-to-grow Survey Results on the Ottawa Valley Forest by Forest Unit (areas in ha).

Forest Unit Total Area

Forest Unit

Assessed

Projected Forest Unit

Other Forest Unit

Total Area Not Successfully Regenerated

Silviculture Success

Regeneration Success

CE1 (Lowland Cedar)

4.8 4.8 0.0 4.8 0.0 100.0% 100.0%

CM1 (Mixed 41.8 35.3 6.5 41.8 0.0 84.4% 100.0%

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Upland Conifers)

HE1 (Hemlock)

51.0 35.3 15.7 51.0 0.0 69.2% 100.0%

INT1(intolerant Hardwoods)

1,832.5 857.5 791.6 1,649.1

183.4 46.8% 90.0%

MW1 (Mixed wood)

2,651.5 863.1 1,788.4

2,651.5

0.0 32.6% 100.0%

MW3 (Mixedwood with White Pine)

284.7 120.6 164.1 284.7 0.0 42.4% 100.0%

OR1 (Oak and Oak Pine)

374.7 57.7 235.7 293.4 81.3 15.4% 78.3%

PJ1 (Jack Pine)

10.9 0.0 10.9 10.9 0.0 0.0% 100.0%

PR1 (Red Pine 2 Cut)

107.7 57.8 49.9 107.7 0.0 53.7% 100.0%

PW1 (White Pine 3 Cut)

642.1 263.0 357.6 620.6 21.5 41.0% 96.7%

PW2 (White Pine 2 Cut)

77.4 37.8 34.5 72.3 5.1 48.8% 93.4%

Total Harvest

6,079.1 2,332.9 3,454.9

5,787.8

291.3 38.4% 95.2%

Total Forest 6,079.1 2,332.9 3,454.9

5,787.8

291.3 38.4% 95.2%

The low rates of silvicultural success are of interest. Silvicultural success measures how effective the renewal program is in growing back the planned forest type. Low rates of silvicultural success are noted for the white pine and red pine forest units. This has been attributed to failed plantations, particularly where efforts were made to convert hardwood-dominated sites to white pine using planting stock. Many of the attempted conversion sites were prone to white pine blister rust which negatively impacted survival rates. Shelterwood renewal success may have been reduced by leaving too much residual basal area following harvest, thus preventing sufficient light from reaching the forest floor to sustain regeneration. A number of strategic changes were incorporated by OVFI into its silviculture program. For example, conversion of intolerant hardwoods and mixedwoods to white pine has been reduced and confined to sites considered to be low risk for blister rust. Conversions to other species such as red pine or spruce may be undertaken instead. Artificial regeneration (tree planting) has been implemented in shelterwood areas when good seed crops are not forecasted or when adequate natural regeneration has not established within three years of the harvest or site preparation treatment. More effort has been made to ensure crown spacing allows sufficient light to penetrate to the understory. More

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emphasis is also being placed on removing mid-story canopy that competes with the emerging regeneration. It is surprising that red and white pine renewal is a challenge on this Forest, if only because it has sustained white pine processing operations for over a century. However, on nearly every site visited there was evidence of fire history and this tool has been virtually removed from the land base in recent years. The soils and sites on this Forest are clearly competitive, and support the growth of many species. Ottawa Valley Forest Inc. has an impressively adaptive silviculture program. The auditors are satisfied that they are evaluating every tool available to try and improve this performance. The measurable indicators of forest sustainability, created from the four objective categories in the FMP, have been monitored and reported on by OVFI. Appendix 2 shows the auditor’s independent assessment of progress towards achieving those objectives.

There are three main types of indicators used for assessing objective achievement in the 2009 FMP: 1) forecasting, 2) monitoring, and 3) compliance. Of the 262 quantitative objective indicators for the Ottawa Valley Forest in the 2011 FMP, 117 are forecasting indicators, 93 are combined forecasting/monitoring indicators, 43 are monitoring indicators, and 9 are compliance indicators. For the monitoring and compliance indicators, many of which have been in place for a number of years, the auditors are confident that OVFI and OMNR have the capacity and capability to compile the data necessary to measure near term progress for the sustainability indicators. The OMNR and OVFI have used a host of modelling tools that measure progress towards achievement of objectives. The forecasting indicators are calculated at the time of plan preparation. Many (210) of the indicators are fully or partially assessed at the time that the FMP is prepared. These are all dependent on the veracity of the FRI and, as has been noted earlier, the FRI on this Forest is not accurate. The auditors have no reason to challenge the mechanics used to model the future development of the Forest. The far future outcomes defined in both the 2006 and 2011 FMPs demonstrate the significant consideration of a broad base of ecological, economic, and social factors that influence and are influenced by the sustainability of the Forest. In that regard, OVFI and OMNR demonstrate a comprehensive program that strongly supports a finding of sustainability. Having stated that, the auditors would also note that the use of computers to replace, rather than support, field observations is troubling. As an example, the poor rollout of the GIS water layer in support of the SSG has caused frustration between OMNR and OVFI and has failed to meet the objectives of the SSG. The tool clearly has great merit if it is used to account for spatial relationships. It should not be used to replace field surveys. The FRI on this Forest is not current, and this has emerged as one of the most significant issues on this audit. At the time this audit was planned, it was expected that a new FRI would be delivered in 2014. By the end of the audit, that had shifted to 2017. The FRI will be 30 years old before it is replaced, and currently offers an accuracy of about 55%. Yet it is the base data for evaluation and promise of forest conditions as much as 120 years into the future. Of the 56 objectives listed in the 2006 FMP, the auditors assessed 40 as being achieved, 9 as being partially achieved, 5 as inconclusive, and 3 that were not achieved. A 70% objective achievement rate seems low, but a review of the auditors’ conclusions shows that two factors (the 2006 and 2008

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blowdown and the soon to be updated FRI) influenced conclusions on 11 of the 14 objectives. In the case of the FRI, objective targets were initially incorrect due to FRI errors. The error has been identified, and will be reassessed when the new inventory is delivered, in conjunction with preparation of the 2023 FMP. The blowdown event interrupted progress towards confirming achievement of objective targets on 6 of the indicators. In every case, this will be reassessed when those areas are assessed for FTG status in the next five years. The objective to increase the representation of the PW1 forest unit was not achieved because some of this forest type was in the blow down area, which left the area classified as PW1 at the 2001 levels. Current levels have been assessed at 94% of the 2026 target. Free-to-grow assessment of the blowdown area that has planned renewal to PW1 should bring the actual level closer to the target. Simply not been enough time has elapsed to assess this situation. There has been notable movement in the development of an Aboriginal rights and title claim by the AOO. Discussions and negotiations about the claim have been ongoing since the 1990s. First Nation communities and individuals actively participate in planning, operations, and recreational use on the Ottawa Valley Forest. All parties have expressed hope that this long standing negotiation will result in an improvement of social, economic, and cultural futures in the area. Area of concern prescriptions have been effectively administered. They offer strong protection for defined ecological and cultural values in real time. Road construction and maintenance were judged to be effective. Road water crossings are a potential source of sedimentation into streams and are always the subject of particular attention from the auditors. Water crossings were found to be in good order and the aquatic values suitably protected. Operations adjacent to aquatic habitats were consistently within practice standards established for operations in riparian zones. The auditors conclude that the ecological components of the Ottawa Valley Forest, which are most likely to be influenced by forest operations, are being managed in a sustainable manner.

4.8 Contractual Obligations The audit team reviewed the terms and conditions of SFL #542529. The Company met its contractual obligations throughout the audit period. Appendix 3 provides detailed comments on the performance of Ottawa Valley Forest Inc. in achieving each of its stated management objectives.

4.9 Conclusions and Licence Extension Recommendation The auditors have concluded that operational practices on the Ottawa Valley Forest are conducted in most situations in a highly effective manner. Road construction and maintenance, harvest, renewal, and renewal assessment all fell within acceptable operating parameters. Staff from both OVFI and OMNR District have demonstrated laudable commitment to their jobs and this forest. The planning process has been challenged by the poor quality of the FRI used to support virtually all of the forecasting planning indicators. It seems incredible to issue an FMP that offers comments a century into the future when the basic information at a forest unit level is wrong half the time. The auditors’

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most urgent recommendation is to have Corporate OMNR update this inventory and then issue some comments on the probable accuracy of these forecasts. The reliance on a GIS-based water layer issued from Corporate OMNR has been problematic. It has caused frustration with staff at both OVFI and OMNR District. It has moved the decision making on aquatic values away from staff with expertise in aquatics. It has not resulted in the improved application of AOC envisioned in the SSG. There is a large challenge with communication between the OVFI and Pembroke OMNR. The compliance program is the best documented evidence of this, but the observations of this audit show it reaches beyond that. It is, in the sixteen year experience of this audit team, more challenging and less effective than for any other forest in Ontario. There is also a need, and it must be led by OMNR at the Regional level, to revisit the SGRs concerning white pine shelterwood and determine the stand conditions under which it is appropriate to apply a two-stage shelterwood regime. The auditors accept the fact that the Ottawa Valley Forest represents a relatively complex ecosystem and the OVFI and District OMNR have done a good job of operational management. They have complied with required legislation and the eight principles of the CFSA. They have demonstrated a commitment to the Forest and a willingness to adapt programs and practise to accommodate challenges. The audit team concludes that management of the Ottawa Valley Forest was generally in compliance with the legislation, regulations, and policies that were in effect during the term covered by the audit, and the Forest was managed in compliance with the terms and conditions of the Sustainable Forest Licence held by Ottawa Valley Forest Inc. Forest sustainability is being achieved, as assessed through the Independent Forest Audit Process and Protocol. The audit team recommends the Minister extend the term of SFL #542529 for a further five years.

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Appendix 1 – Recommendations

Independent Forest Audit – Record of Finding

Recommendation #1

Principle: 2 Public Consultation Criterion: 2.1 Local Citizens Committee (LCC) Procedure(s): Review and assess whether the LCC met the purposes and conducted its activities in accordance with the applicable FMPM.

Background Information and Summary of Evidence: An OMNR staff member was chairing the LCAC until early 2012 when two members of the Committee volunteered to be co-chairs. Having an OMNR staff person chair the committee is not in accordance with the 2009 FMPM which states, “a local citizens committee comprised of local citizens”. Also, OMNR is not listed as one of the interests that can participate on the LCAC.

Discussion: Having an OMNR chairing the LCAC is a poor committee/governance practice and could put the committee into a conflict of interest with OMNR under some circumstances. For example, the FMPM outlines specific roles for the committee Chair, such as consulting with the OMNR District Manager on the categorization of amendments (section 2.2.1 of the FMP). The above being said, having the OMNR staff person chair the LCAC did not appear to be a major area of concern for the committee members, nor did it result in any conflict of interest. In many forests, the LCCs are highly dependent on OMNR staff for their organization and functioning and, in those cases, the OMNR staff can be an important facilitator for the committee as a way of lessening the burden on the Chair.

Conclusion: The current Terms of Reference for the LCAC has the OMNR staff person as the committee Chair. It is, therefore, recommended that the Terms of Reference for the LCAC be updated to ensure that OMNR is not chairing the LCAC. The Terms of Reference needs to be reviewed and updated at the beginning of Phase 2 of planning.

Recommendation 1: The Terms of Reference for the Local Citizens’ Advisory Committee should be updated to ensure that OMNR is not chairing the LCAC, and should be reviewed and updated at the beginning of Phase 2 of planning.

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Independent Forest Audit – Record of Finding

Recommendation # 2

Principle 3: Forest Management Planning Criterion: 3.3.2 Forest Resource Inventory (FRI) for the FMP Procedure(s): 1. Assess (including achievement of FMPM checkpoint) whether the FRI has been

updated, reviewed, and approved to accurately describe the current forest cover that will be used in development of the FMP including:

• depletions and accruals • forecasts of depletions and accruals/assumptions for the remainder of the

current plan term • discussion of reliability of these forecasts/assumptions • classification of lands by land ownership and land types including productive

Crown forest land base 2. Assess implications of the FRI on development of the FMP by considering land

ownership, land type, provincial forest type, and age class.

Background Information and Summary of Evidence: The chronology of the FRI is as follows: 1987 - New FRI produced for Pembroke Crown Units (paper copy only) 1995 - FRI updated for 1996-2001 plan. The 1996-2001 update was not archived by OMNR and was lost

during the OMNR reorganization. 1997 - the original 1988 FRI was converted to a full digital database that could be managed with a

Geographic Information System (GIS). The data conversion was complemented by an extensive updating project from 1987 to 1996 for the 2002-2007 plan.

2003 - FRI updated to incorporate new water layer 2008 - FRI update of depletion areas for 2001-2021 plan OMNR announced plans to redesign the FRI program in September, 2005. Responsibility for the production of the FRI shifted from the forest industry to OMNR. Planned enhancements to the FRI program included a move to a ten year re-inventory cycle from a twenty year cycle. The managers of the Ottawa Valley Forest anticipated, as stated in the 2011 FMP, that the next re-inventory of the Ottawa Valley Forest was tentatively scheduled for delivery in 2014, based on digital aerial photography acquired during the summers of 2006-2009. Correspondence from Corporate OMNR to the auditors indicates that 2014 is when OMNR will start processing the digital photography, and that the planned delivery date of the complete FRI is actually 2017. This inventory will essentially be nine years old before planning begins in 2018 for the 2021-2031 period.

Discussion: Traditionally new inventories were scheduled to be delivered two years prior to the implementation of the FMP, although that has not commonly happened in Ontario. Today, most inventories are being delivered after a management plan is completed. Given the move to ten year management plans, this can mean that a new inventory is delivered up to 11 years prior to its use in a

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new plan. New inventories can be used in an existing plan if there is a desire to coordinate the old and new inventories. This can be very onerous and time consuming, and would require a major amendment(s) to the plan. The Trends Analysis (Year 10 Annual Report, Appendix 7) provided in support of this audit indicates the current inventory is estimated at 55% accurate. That is to say ”the planned harvest area is actually verified on the ground to be the same forest unit as represented in the inventory“ about half the time. The FRI provides descriptive information about the timber resource on each management unit, including stand age, stand height, species composition, and stocking level. The inaccurate inventory has operational consequences at the most basic level. The Ontario system requires identification of areas that could be reasonably harvested during the ten year period of an FMP. The considerations for identifying these areas include tree species composition and age class of the harvest area. Silviculture ground rules are prepared assuming harvest block composition is consistent with that in the FRI. Harvest block assignments are issued assuming harvest area age and species composition is known, and harvest operators arrange delivery contracts to mills assuming a planned quality and quantity of wood fibre will be available. The auditors witnessed discussions between OMNR District and OVFI staff noting the high number of AWS amendments, which are partly driven by finding the actual species composition and stand quality different enough from that used for planning to require different harvest and regeneration strategies. It is important to note that other factors also influence revisions and amendments, such as changes that are due to special feature/AOC values information, unmapped small-scale recent natural disturbance events, road access challenges, and timber product market cycles. The planning system used in Ontario forecasts forest growth 120 years into the future based on this data. It interprets data to model projections of habitat for a wide variety of species and timber growth. Many plan objectives rely on this data as evidence to support the conclusion that the forest is managed sustainably. The auditors are aware that no FRI will be entirely accurate, but it seems illogical that the production of this key evidence would be allowed to lag when so much of the planning system uses the information to forecast the future of the forest with precision and confidence. It is essential that the production of FRI be given a higher priority by OMNR. The auditors view this as a fundamental challenge to the integrity of the forest management planning system in Ontario.

Conclusion: The FRI must be delivered within the ten-year timeframe to which OMNR has committed to credibly substantiate the long term objectives of forest management plans.

Recommendation 2: The OMNR must ensure the delivery of new forest resource inventories is consistent with its commitment to complete new inventories on a ten-year cycle. All inventories should be coordinated with Phase 1 management planning.

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Independent Forest Audit – Record of Finding

Recommendation # 3

Principle 3: Forest Management Planning Criterion: 3.4.1 Proposed Long-Term Management Direction Procedure(s): To review and assess the development of the FMP long- term management direction (LTMD).

Background Information and Summary of Evidence: The 2011-2021 FMP includes 245 pages on the Long Term Management Direction along with a 186-page analysis package and five tables documenting the results. Most of the projections are made for 120 to 150 years and include Simulated Range of Natural Variation. The presentation of these projections is very precise but contains few cautions on the accuracy of the information. The Trends Analysis provided for this audit indicates the current inventory has an estimated accuracy of 55%.

Discussion: Model projections used for the development of the Long Term Management Direction present results as certainties. However, the detail and precision presented is not accompanied by any identification of the weaknesses of the forecasts. The FMP does not adequately discuss the relationship between the projections of indicators and the underlying data. The FRI is the dominant data which drives the models used in the planning exercise. FRI data has been developed to be accurate at the Working Group and Management Unit level but its accuracy is reduced when used for forest units and habitat types. Ground surveys and timber cruises used to confirm FRI accuracy but this has not been done for 20 years. Taking FRI data and applying successional assumptions and habitat relationships is a very imprecise practice which then carries through to the long term forecast of such attributes. Management plans rarely discuss the accuracy of the FRI and how it influences projections. Forest modeling forecasts are more accurate in the near term than they are in the long term. Unfortunately, FMPs usually do not discuss uncertainty related to indicator forecasts, which builds a false sense of confidence in these forecasts. It is common practice in Ontario FMPs to alter forecasts if the results of a single indicator deviates from the Simulated Range of Natural Variation only 50 years in the projected future. This is counter to the adaptive planning process operated by OMNR and a reflection of poor planning practices. Such mid- and late-term targets and constraints (used to alleviate a presumed future failing in the forecast) can severely limit current opportunities and result in unexpected collateral issues.

Conclusion: Forest management plans contain too many indicators. Uncertainty is not considered when the Long Term Management Directions are developed. Forest management plans do not discuss information accuracy and forecast integrity.

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Recommendation 3: Corporate and Regional OMNR should re-evaluate how the Long Term Management Direction is documented. A discussion of the integrity of the forecasts and degree of uncertainty that is present in the Long Term Management Direction should be required.

Independent Forest Audit – Record of Finding

Recommendation # 4

Principle 3: Forest Management Planning Criterion: 3.4.1.1 FMP achievement of Checkpoint ‘Support for Forest Units and Habitat Classifications’ (2004 FMPM) or ‘Support for the Current Forest Condition’ (2009 FMPM) Procedure(s): 1. Assess achievement of the checkpoint for development of forest units (2004 FMPM)

or current forest condition (2009 FMPM) for the FMP, including rationale, and managed Crown productive forest by forest unit.

Background Information and Summary of Evidence: The Long Term Management Direction team for the 2011 FMP established a new set of forest units for three regional forests. This complicated planning by severing important linkages between management plans. Previous plans used locally-derived forest units while the 2011-2021 FMP uses quasi-regional forest units.

Discussion: Forest units are a basic building block of forest management. On this forest they have changed. This limits the connectivity between plans and data used to track progress (e.g., FTG data). Ontario’s adaptive forest planning system is achieved, at least in part, through connectivity between plans. By changing forest units to a regional standard, that connectivity is reduced. The regionalization of forest units eliminates to some degree the local applicability of FMPs.

Conclusion: Revising and changing forest units reduces linkages between plans, does not provide for adaptive management, and does not allow for simple comparison of planned and achieved silviculture and forest composition goals.

Recommendation 4: Corporate and Regional OMNR should re-evaluate the use of “regional” or “standard” forest units. A best practice would be to utilize the same forest units from one forest management plan to the next as determined by local field foresters.

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Independent Forest Audit – Record of Finding

Recommendation # 5

Principle 3: Forest Management Planning Criterion: 3.4.1.4 FMP achievement of the Checkpoint ‘Support for Proposed Management Strategy’ (2004 FMPM) or ‘Support for Management Objectives’ (2009 FMPM) Procedure(s): For plans prepared under the 2004 or 2009 FMPM:

1. Assess progress towards achievement of the checkpoint by reviewing the results of the desired forest and benefits process by considering

• whether the purposes of the desired forest and benefits meeting were achieved • the process used to refine the desired forest and benefits to ensure they are achievable

2. Assess achievement of the checkpoint including by reviewing the FMPM requirements and determining whether

• reasonable objectives, indicators (including desirable levels) and appropriate targets been developed by the planning team with the assistance of the LCC

• the 4 CFSA objective categories have been addressed • the objectives and indicators incorporated the results of the desired forest and benefits

meeting For plans prepared under the 2004 FMPM:

3. Assess achievement of the checkpoint including by reviewing the modeling analysis (Strategic Forest Management Model (SFMM) &/or other approved model) used to develop the proposed management strategy, including the available harvest area (AHA) and the forecasted forest condition, and assess

• whether these levels provide for forest sustainability in the long term • balancing achievement of all management objectives • appropriateness of any modifications made to the base model • presentation of management strategy to the LCC

Background Information and Summary of Evidence: Table FMP-9 in the 2011 FMP summarizes the host of objectives and indicators in 13 pages. This table is only readable with the use of a magnifying glass, which is unacceptable for a public document. Tables such as this currently dominate management plans but do little to provide transparent and understandable information.

Discussion: An FMP is a public document which must be clear, transparent, and understandable to the public. The current trend is to provide as much information in tables as possible. However, with more and more technical information being provided, these tables are becoming so detailed that they are effectively useless.

Conclusion: Tables such as FMP-9 provide little value, especially if they are to be informative to the public.

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Recommendation 5: Corporate OMNR should re-evaluate the use of large tables of redundant information in forest management plans.

Independent Forest Audit – Record of Finding

Recommendation # 6

Principle: 3 Forest Management Planning Criterion: 3.3.6.1: Procedure: Review use of the values maps in production of the FMP including whether the series of values maps includes the required content, were produced and updated for each stage of FMP production and provided for use by the plan author.

Background Information and Summary of Evidence: In 2009, there was a new direction based on the SSG that classified water bodies as having high, moderate, or low potential sensitivity (the FMP water layer). Both the OMNR and OVFI in this District have struggled to implement this direction. To assist in the implementation of the process, the OMNR Forest Branch undertook to update the GIS-based water layer for FMP planning teams. This mapping was used to assign the boundaries for cut blocks during the AWS and is the basis for compliance reporting. The initial iteration of the FMP water layer contained errors. All of the SFLs and Districts in southern Ontario, Pembroke in particular, are challenged by the mapping of water. The staff have kept excellent records of the ongoing problems. Each year since 2009, OMNR, at several levels, has attempted to address the problem as follows: Jan 2010 - receipt of FMP water layer from Forest Branch; problems identified by District Mar 2010 - water layers given to OVFI by OMNR; OVFI found problems using the layers for AOC creation Apr 2010 - requested the water layer be integrated into OMNR’s corporate datasets; request denied Sept 2010 - project submission by Forest Branch to upgrade the tool used to update the water layers

(completion date Nov 2010) Apr 2011 - Forest Branch still working on tool Sept 2011 - tool still not working; OMNR editing water layers manually to provide to OVFI; both OMNR

and OVFI have low confidence in data Nov 2011 - OMNR and OVFI decide to let OVFI run high sensitivity sites with a 30 m buffer then modify

them in the field Feb 2012 - OMNR creates new water layers and offers to run the water AOC and give to OVFI (one time

only) for use in 2012 AWS; agreement between OMNR and OVFI that OMNR will manually update water in each year’s AWS operating areas

Mar 2013 - OMNR gives OVFI updated water layers for 2013 AWS; OVFI unhappy about the number of changes Apr 2013 - direction from OMNR District Manager (after discussions between OMNR and OVFI) to

retract the March 2013 water layers submission and for OMNR staff to stop editing the

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water layers Apr 2013 to present - OMNR notifies OVFI of changes to the water layer (following Forest Information Manual)

but does not edit the water layers or send water layer updates to OVFI. Intention is to prepare new water layer using the tool from Forests Branch for Phase 2 planning of the FMP.

Throughout, there were communication problems between OMNR and OVFI. On more than one occasion OVFI was not using the version of the water layer expected by District staff. The OMNR Forest Branch could not provide timely delivery of a software solution for implementation of the SSG. The OMNR has significant GIS capacity at District, Region, and Corporate levels; the Company has 20% of one person’s time. The situation has been exacerbated by the number of unclassified streams on the Forest. The water layer process seems to have lost sight of the merit in completing the physical stream surveys required to ensure that the GIS program is using information that accurately classifies streams. If one of the principle objectives of the SSG is to improve the efficiency of values protection, it is logical that OMNR should maintain a commitment to complete the inventory of streams in the OVFI watersheds given that, otherwise, an unclassified stream is assigned to the highest level of AOC protection (larger buffer).

Discussion: It appears the intent of the approach in the SSG to AOCs around water was to increase the opportunity to harvest wood while “creating a mosaic of shoreline forest conditions that will sustain … many ecological functions” (page 37, SSG). Putting this into practice has been difficult. Application of the new SSG requires use of this special mapping of water in addition to the regular NRVIS water layer. This is because assignment of low, moderate, and high sensitivity is not intuitive, nor does it rely on field verification. It requires a GPS to do the calculation. This is very different from the previous guides which relied heavily on field interpretation. Now, field interpretation is often not possible and line marking of water must be done with heavy reliance on the GPS. As a result, the delivery of the FMP water layer is necessary. For OMNR and OVFI, delivery requires a custom GIS product from Corporate OMNR to create the AOC boundaries derived from the NRVIS water layer. This product is referred to as the FMP water “tool”. As the above chronology shows, this has not been delivered. Once delivered, it will require ongoing maintenance. It is now apparent that this process is very complex. The OMNR should consider rethinking the application of AOC water buffers. The OMNR has been adapting to using alternative means on an ad-hoc basis. This could include use of the NRVIS water layer (which is more manageable) along with a more intuitive field assessment. Further, the computed water layer may need to be supported by additional work to physically survey and accurately categorize the streams themselves.

Conclusion: The complexity of the current method for assigning AOCs to the FMP water layer is currently unmanageable, in spite of significant effort by competent staff. The OMNR managers at the District level have been adjusting the expectations for mapping requirements on a regular basis while awaiting a technological solution to the problems. Making this approach work will require agreement between OVFI and OMNR on the appropriate field resolution and determination of boundaries. The OMNR may need to adjust the expectations

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for precision of boundary marking for compliance purposes. This does not mean “enabling non-compliance”, as one reviewer commented. The OMNR defines compliance through the FMP. Precision is part of that definition. The alternative is that OVFI will not be able to fully use the flexibility of the SSG to access more wood. Currently, the result is counterproductive, substituting a complex system for a simple system with no wood supply benefit and no evidence of ecological benefit. The OMNR should continue to conduct physical stream surveys to ensure the values being protected are classified accurately.

Recommendation 6: The OMNR should continue to conduct physical stream surveys to ensure the values being protected are classified accurately. Ottawa Valley Forest Inc. needs to review their GIS capacity for handling special values, such as the FMP water layer, in light of greater use of GIS technology and an expected reduction in levels of service from the local District. The OMNR should continue to support physical surveys of the streams in question with the goal of eliminating use of the unclassified stream category.

Independent Forest Audit – Record of Finding

Recommendation # 7

Principle: 3 Forest Management Planning

Procedure: 3.3.6.1 Review use of the values maps in production of the FMP including

whether the series of values maps includes the required content

Background Information and Summary of Evidence: The Endangered Species Act created a requirement for locating rare, threatened, or endangered species, classified as Confidential Values, prior to forest operations. A significant increase in effort was made by OMNR after the Endangered Species Act came into law. However, the nature of these surveys means that there is a period of catch up to get ahead of forestry operations. There are some other factors which have magnified the problem in central Ontario. For example, partial harvest systems mean that the logging operations move across the landscape more quickly, and the large number of contingency blocks that are included annually in the AWS mean there is an additional area to cover. Maps for use in planning related to the Endangered Species Act are typically not available until March when operations begin in April. The blocks are not sorted by probability of harvest, i.e., there is no timing information provided to identify the earlier or later harvest blocks. There are commonly short timeframes available for these surveys because of the time of year when visibility is possible. As it stands, only a fraction of the blocks needing surveys are covered. It is recognized that values collection and identification is challenging from a resourcing perspective, additions and changes to current surveys should be made with respect to efforts already being implemented that are significant in scale, scope, planning, training and associated resource allocation. The audit team feels that increasing efforts will not be required for the long term.

Discussion: There appears to the audit team to be opportunities for making the survey system for

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Confidential Values more effective. This requires communication between OMNR District and OVFI at a high level. For example, providing earlier maps of likely areas that will appear in future AWSs would be helpful. A year early would be ideal. Training of additional staff to assist may be possible. The OMNR could consider engaging qualified volunteers. Obviously, there are concerns with this approach, but none that the audit team found insurmountable. Ottawa Valley Forest Inc. could help in the classification of sites that are not likely to be harvested.

Conclusions: A number of ideas were put forward to improve the productivity of the Confidential Values surveys. These should be considered and acted upon.

Recommendation 7: The OMNR District, with the assistance of Ottawa Valley Forest Inc., should increase the efficiency of the approach to Confidential Values surveys.

Independent Forest Audit – Record of Finding

Recommendation # 8

Procedure: 3.5.2.1 Review the AOC prescriptions and assess whether adequate information was available for AOC planning

Background Information and Summary of Evidence: For one SAR, or confidential value, there have been two recent directives. Although these changes occurred in the summer of 2013, outside the audit term, the Independent Forest Audit Process and Protocal allows for auditors “to pursue investigations outside of the normal 5-year period where professional judgment [is] likely to provide a materially enhanced understanding of the management of the forest”. A general habitat description was provided in June of 2013. It states that habitat includes “…suitable wetlands or water bodies… that extends up to 2 km from an occurrence…”. The document states category 2 habitat has a moderate level of tolerance to alteration before their function is compromised. At the same time, a new regulation was put in place stipulating, in brief, that following the FMP is equivalent to being compliant with the Endangered Species Act. In practice, this means that when the AOC is planned, it will be based on the SSG. In April of 2013, OMNR Southern Region provided a note to staff identifying the AOC field protocol for this confidential value. The purpose of the protocol is to set out the “current direction for the application of the AOC prescription”. The AOC prescription in that document is based on “Suitable aquatic habitat within 1000m of an Element Occurrence is defined as wetlands, lakes, ponds, or streams…”.

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Discussion: There is lack of consistency between the two directions, the most prominent being that the general habitat direction refers to “risk” up to 2 km from a reliable observation of a confidential value. To an outside reviewer, the latter habitat description should be more current. However, the habitat description and the regulation requiring that the AOC be based on the SSG were released simultaneously. Attempting to clarify the priority, the guidance on page 101 of the SSG states, “Future habitat descriptions, habitat regulations, or associated policy documents (e.g., statements of intended actions identified in the government’s response to recovery strategies) developed under the ESA may contain additional species-specific direction that supersedes direction in this guide and that must be followed to ensure compliance with the ESA.” Although a website for updates is provided, this is no longer functioning. This statement would allow both the habitat description and the OMNR-endorsed southern protocol for certain confidential values (an associated policy document) to redirect the AOC prescription. In the field, this dichotomy causes inefficiency. Apparently two map layers are tracked, one for forestry and one for other forest users. Conclusions: The audit team makes no judgment on the appropriateness of one approach or the other. The OMNR has spent a considerable effort in attempting to make the AOC for the confidential value more operational. Nevertheless, the AOC needs to be seen to be consistent with the best science; otherwise the entire forest policy framework for sustainable forests is in doubt. The OMNR should review the linkage between the Endangered Species Act and the CFSA to provide advice and recommendations on how to best integrate the objectives and protection of SAR with the planning and implementation of forestry operations.

Recommendation 8: Corporate and Regional OMNR should clarify the apparent difference between buffer requirements for confidential values in the Forest Management Guide for Conserving Forest Biodiversity at the Stand and Site Scales and the general habitat description for the same value.

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Independent Forest Audit – Record of Finding

Recommendation #9

Principle: 4 Plan Assessment and Implementation Criterion: 4.3 Harvest operations must be conducted in compliance with all laws and regulations including the CFSA, approved activities of the FMP including SGRs, AWS and FOPs. Procedure(s): 4.3.1 - Review and assess in the field the implementation of approved harvest operations and determine whether the harvest and logging methods implemented were consistent with the FOP, the FOP was consistent with the SGRs, and that actual operations, were appropriate and effective for the actual site conditions encountered.

Background Information and Summary of Evidence: In red pine shelterwood situations, the auditors observed occasions where the residual basal area appeared to be higher than the target number listed in the FOPs. Under a three-cut shelterwood system, the residual tree spacing objective following a regeneration cut is 40-50% canopy crown closure (roughly ½ to ¾ crown spacing between residual trees), and 30-40% canopy crown closure (roughly full crown spacing between residual trees) following the first removal cut.

Discussion: Tree retention following the final removal stage must follow the SSG requirements (an average of 25 living or dead trees (≥10 cm diameter at breast height [dbh] and >3m in height) per hectare, of which at least 10 trees must be large dominant [or “veteran”] trees). In several cases the level of residual basal area remaining after final removal stages was excessive, and in one case was observed to be 70 trees/ha. Discussions with OVFI staff indicated that there was a historical bias on the Forest to use a conservative approach to retaining residual cover in the shelterwood harvests. There are several consequences to excessive retention. The FOPs and the SGRs that support them assume a level of residual structure that is a balance between providing sufficient standing timber to meet ecological and natural seeding needs, and opening up the canopy sufficiently so that the new stand has sufficient daylight to grow. Too little structure can reduce natural seed contribution that is important to new stand development and can reduce the perching and cavity nest opportunities that are mandated in harvest regulations. However, too much residual structure can result in an unneeded abundance of seed but too much shade for that seed, or the planted seedlings, to grow with expected vigor. The site will develop differently than planned and the long term management objective, an optimized value incorporating ecological and economic considerations, will not be met. Timber left behind that is surplus to regulated requirements represents a lost economic opportunity. The revenue gained through harvest must offset operational costs with a profit if any harvesting enterprise is to be sustainable. Leaving the revenue that surplus timber represents on the stump must significantly reduce the potential for harvest operators to maintain their businesses.

Conclusion: Given that the shelterwood system is the most dominant form of silviculture system utilized on the Ottawa Valley Forest, full utilization through harvest operations should meet stand renewal and harvest volume objectives.

Recommendation 9: Ottawa Valley Forest Inc. shall review its residual tree retention practices and determine if the residual levels are appropriate to meet stand renewal and harvest volume objectives.

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Independent Forest Audit – Record of Finding

Recommendation #10

Principle: 4 Plan Assessment and Implementation Criterion: 4.3 Harvest operations must be conducted in compliance with all laws and regulations including the CFSA, approved activities of the FMP including SGRs, AWS and FOPs. Procedure(s): 4.3.1 - Review and assess in the field the implementation of approved harvest operations and determine whether the harvest and logging methods implemented were consistent with the FOP, the FOP was consistent with the SGRs, and that actual operations, were appropriate and effective for the actual site conditions encountered.

Background Information and Summary of Evidence: In shelterwood cuts, the auditors confirmed situations where there was insufficient volume for operators to complete the second and final removal cuts in a manner that offered a reasonable economic opportunity and protected the advance regeneration.

Discussion: The SGRs for white and red pine shelterwood direct three stages of harvest. This system is designed to encourage natural regeneration and allow for economically viable harvest at each of the regeneration cut, first removal cut, and final removal cuts. In some circumstances, sites of current show there is insufficient volume to enable two viable removal harvests, and too much advanced regeneration at the final removal stage, which leads to unavoidable and unacceptable damage to the renewing forest. Meeting the intended objectives of the SGRs has proven challenging in some situations. Ottawa Valley Forest Inc. would welcome the flexibility to reduce the number of removal harvests to a single operation, particularly in those circumstances where stand conditions support two removal cuts. The shelterwood SGRs have been in place for some time, but it is apparent that additional flexibility should be permitted for managing white and red pine within the shelterwood silvicultural treatment regime. The Silvicultural Guide for the Great Lakes-St. Lawrence Conifer Forest in Ontario allows for flexibility to reduce the number of final removal cuts and states that a two-stage shelterwood harvesting regime is acceptable. Opinions on practicing two-stage shelterwood in white pine and red pine differ between OMNR Pembroke District and OVFI staff, with OMNR staff discouraging the reduction of removal harvests to a single stage. District staff feel that paring down the removal harvest to a single stage will reduce timber volumes potentially produced by stands managed in this manner. In the opinion of the auditors, Regional OMNR needs to provide the leadership to resolve the differences in opinion and consider establishing parameters to guide local practice when the implementation of a two-stage shelterwood is appropriate.

Conclusion: Regional OMNR shall review the silviculture prescriptions for managing white pine to ascertain the stand conditions where two-stage shelterwood may be acceptable. The parameters under which two-stage shelterwood may be applied shall be clearly defined and incorporated in guidance provided to field practitioners. The SGRs in the Ottawa Valley Forest 2011 forest management plan should be modified accordingly to incorporate the approved parameters developed under this review.

Recommendation 10: Regional OMNR shall review empirical evidence supporting the effectiveness of the silviculture ground rule for three-stage shelterwood cuts of white and red pine in southern Ontario and revise the silviculture ground rule to reflect the results.

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Independent Forest Audit – Record of Finding

Recommendation # 11

Principle: 6 Monitoring Criterion: 6.2.1 SFL Holder Compliance Planning and Monitoring - To review and assess whether an SFL compliance program has been developed and implemented to effectively monitor program compliance and effectiveness in accordance with the conditions of the SFL, the FMPM, and FIM, including standards established by the Minister. Procedure(s): 6.2.1.4 Examine whether the SFL has continued to maintain their overall forest management oversight role related to development and maintenance of the compliance plan and its implementation.

Background Information and Summary of Evidence: Compliance monitoring has been a long-standing issue on this Forest. The two previous audits have included specific recommendations on the matter, and it was apparent during the auditors' field inspections, observed interactions between OMNR District and OVFI staff, and interviews, that acute differences of opinion remain between OMNR and OVFI staff on compliance matters. From the 2003 Independent Forest Audit Recommendation 14: Staff from OVFI, its shareholder organizations and MNR should jointly calibrate their perceptions of non-compliances to make for consistent reporting. Recommendation 15: MNR and OVFI should request that the Regional DM and GM Committee, with input from MNR Main Office, review and consider ways to improve the compliance monitoring situation on the Ottawa Valley Forest, including in particular the appointment of a regional compliance advisor. Recommendation 16: Regional OMNR should organize a regional compliance workshop to bring together compliance staff from Southern Ontario SFL companies and District Offices. Recommendation 2: OVFI and MNR should review the SFL conditions in Appendix F to ensure that they remain worthwhile and determine appropriate guidelines for assessing compliance. The two parties should also review and agree on a method of assessing compliance with the SFL Appendix E condition From the 2008 Independent Forest Audit From the executive summary: There were significant differences in interpretation of the results of compliance programs over a relatively long period of time, including the previous audit period. Although considerable progress was made in addressing this issue on many fronts, and in particular in assessing Free to Grow candidate stands, OVFI and MNR still have substantial challenges ahead in agreeing on what constitutes acceptable practices in forest access, harvest and renewal activities. The two parties to the SFL operate with mutual respect and exercise professionalism but there is a lack of trust and empathy that lie at the root of the problem. From Section 3.61: The District Compliance planning and implementation has been a source of controversy during this and the previous audit terms. The Company believes that the level of oversight and fines are disproportional

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compared to other forest management units and out of line with the performance of the contractors in a complex forest environment. MNR is confident that they are administering compliance in the appropriate way. The previous audit identified this as a problem and made several recommendations to address this issue. In response to the above controversy identified in the previous audit, MNR and OVFI worked on a terms of reference to study the problem in 2005. The terms of reference exercise was abandoned by the Company and it commissioned its own review by an independent consultant. This action by the Company “dismayed” the District Manager who then directed his staff to not participate in the Company-led review. The independent report was dismissed by MNR as being biased. The actions taken by both the Company and MNR illustrate the magnitude of this controversy. The compliance records were reviewed carefully by the audit team. The reports leave the impression that the Forest is not being managed well. This impression is in striking contrast to the audit team’s field observations. This controversy over MNR’s implementation of its compliance program has become counterproductive to the execution of the forest management program on the Ottawa Valley Forest. The positions taken by MNR District staff are likely entrenched. For this reason, MNR’s senior management from either the Region, Management Branch, or both must take steps to resolve this situation in a timely manner. Recommendation 7: MNR Region and/or Corporate MNR must take steps to resolve the long standing controversy over the implementation of the compliance program in the Pembroke District. Having auditors encounter this same persistent working relationship issue for the third consecutive audit should strongly underscore the need that serious action must be implemented to immediately correct this situation.

Discussion: This is not a straightforward issue. An example follows: Enforcement actions were taken on issue #266181, where OVFI was recommended a single administrative penalty of $15,000. In addition to the fine, OMNR recommended a repair order, ordering OVFI to remediate the damage by site preparing, planting, and tending the affected site until it is declared FTG. In this case, 73 ineligible red oak trees (64 that were marked with blue paint and 9 that were less than 12 cm dbh and unmarked) were cut down within a 10 ha site during a stand improvement operation. The auditors inspected the site, along with OVFI and OMNR personnel. The operator error was clear. The oak trees looked to be on average 15 cm dbh, and were well formed. They were clearly marked with blue paint. The tree marker had clearly selected these as being an important component of the future stand. The instruction for stand improvement clearly stated blue painted trees should be left but they were not. The OVFI compliance inspector viewed the site following a snow fall, and the blue paint marked trees were apparently hidden by the snow. No non-compliance was identified. The OMNR compliance inspector viewed the site in snow free conditions, and by the records provided, did a good job of documenting the extent of the removals. The initial contact to OVFI was met with a casual response, based on their previous inspection and on the good work the contractor had performed previously. When OVFI got on site in snow free conditions, the error was evident.

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The rest of the stand looked good and the acorn crop was abundant in 2013. The oak regeneration a season after treatment was evident and, by the subjective measure of the observers on site, appeared to be healthy and well on the way to meeting the silvicultural objectives of the treatment. There was no impact to AOCs or other ecological values evident. In the rationale for the penalty amount, OMNR claimed that the future stand structure has now been compromised, and used the estimated future value of timber expected to be harvested from the entire 10 ha impacted by the removals as part of the basis for the penalty amount. Other factors were also considered in determining the penalty amount, including the response from OVFI and any indication of remorse by the guilty party. The auditors agree that the removal of the red oak trees is truly regrettable and that unclear communications between OVFI and its contractor and the contractor and its workers were contributing factors to this non-compliance. However, the auditors suggest the rationale used to determine the penalty amount is exaggerated. The OMNR procedure FOR 07 06 06 allows the District Manager significant latitude in determining penalty amounts, but the auditors believe that the penalty amount assessed in this case is excessive and does not consider a progression of penalty amounts based on compliance history over the previous three years. In the three years prior to this non-compliance, no fines had been imposed on OVFI. The auditors note that there were no values or AOCs, other than the trees mistakenly harvested, affected by the infraction. In the auditors' opinion, the apparent seriousness OMNR has assigned to this incident in terms of ecological harm is questionable. In discussion with the auditors, OVFI admits that mistakes were made and the project should have been better supervised at the start-up. Ottawa Valley Forest Inc. has a policy where contractors are required to repair substandard performance at their own cost and are also assessed a nominal fee to compensate for the extra time OVFI staff must spend to remediate issues. The auditors agree that OVFI should be responsible for implementing the necessary repairs, within reason, under the repair order to remediate this site, but suggest OMNR re-consider the penalty amount it has imposed on the Company in this case. A second example follows: The auditors witnessed the site on a stream crossing that was the subject of a non-compliance (Inspection Report #590325). In this case, a single culvert installation had been approved as part of the AWS. When the operator reached the site, it was evident that the value in question was not a single stream, but was braided into two distinct channels. The operator notified OVFI of the situation. Ottawa Valley Forest Inc. requested approval for the culvert change from OMNR on August 17. The operator installed the pipes prior to receiving approval from OMNR and OMNR issued a $500.00 administrative penalty. The evidence cited in the compliance report, and the inspection that took place during the audit with the Company and OMNR Compliance inspectors present, showed no ecological values had been impacted. The District does not include OVFI in its District Disciplinary Committee meetings which evaluates non- compliances. Comments collected through Interviews with both OMNR and OVFI staff suggested that the meetings had become confrontational and unproductive. The auditors consider this to be more evidence of the entrenched positions of both parties cited in the 2008 independent forest audit. The overall impression of the auditors is that the compliance program, as noted in past independent forest audit reports, is not operating effectively. There was personal interaction evidence, witnessed by each of the auditors, as well as objective evidence (some of which has been cited here) that showed a frustrating and dysfunctional system.

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It is obvious that OMNR’s approach to compliance monitoring has not supported the development of an effective working relationship with OVFI or contractors. Adjustments must be made that will foster a more positive and constructive approach toward identifying and correcting non-compliant performance. It simply should not take 15 years for a regulator and operator to develop a productive working relationship that involves critical aspects of the resource management program. Although some steps were taken in response to previous audit recommendations to attempt to improve the working relationship relative to the compliance monitoring program, more substantive action is required.

Conclusion: Given the longstanding nature of this issue, the auditors suggest that continual assessment of the compliance monitoring program by both OMNR and OVFI is required to ensure a productive outcome. The auditors also strongly feel senior OMNR staff should be involved to help guide the adjustment process and lead the assessment to ensure that progress is being made. Consideration should be given to engaging the assistance of third party individuals or facilitators to help find solutions. Ontario Ministry of Natural Resources and OVFI should consider documenting the results of these compliance program assessments in their respective annual compliance plans. Whatever actions are taken, the audit team wants to ensure that this issue is finally resolved by the next independent forest audit in five years.

Recommendation 11: Corporate, Regional, and OMNR Pembroke District, in cooperation with Ottawa Valley Forest Inc., shall take appropriate action, including the services of outside parties, to address the longstanding compliance monitoring working relationship that has challenged the Ottawa Valley Forest for over ten years. Progress assessments shall be undertaken regularly until the issue is considered to be resolved by senior staff of OMNR and Ottawa Valley Forest Inc.

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Independent Forest Audit – Record of Finding

Recommendation # 12

Principle: 6 Monitoring Criterion: 6.2.1 SFL Holder Compliance Planning and Monitoring - To review and assess whether an SFL compliance program has been developed and implemented to effectively monitor program compliance and effectiveness in accordance with the conditions of the SFL, the FMPM, and FIM, including standards established by the Minister. Procedure(s): 6.2.1.4 Examine whether the SFL has continued to maintain their overall forest management oversight role related to development and maintenance of the compliance plan and its implementation.

Background Information and Summary of Evidence: Based on examination of the evidence, observations during the field visits, review of the compliance reports, and interviews with industry and OMNR staff, the auditors conclude that OVFI is providing a generally effective oversight role in the conduct of its compliance monitoring program on the Ottawa Valley Forest. However, there is room for improvement. Review of the non-compliances found that the lack of clear communication was the underlying cause for several of the infractions.

Discussion: Examination of the records revealed that certain licensees and operators were involved with the non-compliances more often than others. Further examination revealed that the more troublesome operators were poor communicators and were not keeping OVFI informed about their actions or intentions, which sometimes led to non-compliant situations.

Conclusion: Ottawa Valley Forest Inc. must start taking a firmer position with these poorer performing operators and find ways to elicit more cooperation from them. Ottawa Valley Forest Inc. should explore constructive and persuasive approaches to change the non-cooperative behaviour but, failing that, should be prepared to take more aggressive steps such as cancelling contracts and harvesting privileges to demonstrate their commitment to preventing non-compliances, or more potentially serious non-compliances, in the future.

Recommendation 12: Ottawa Valley Forest Inc. shall take firmer action to elicit better cooperation from licensees and operators who are repeatedly committing non-compliances.

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Independent Forest Audit – Record of Finding

Recommendation # 13

Principle: 6 Monitoring Criterion: 6.3 Silviculture Standards and Assessment Program - To review and assess whether an effective program exists to assess area that is successfully regenerated to the projected forest unit (silvicultural success) or to another forest unit (regeneration success) in accordance with the applicable FMPM, FIM, FOSM and SEMMO. Procedure(s): 6.3.2 SFLs include requirements to meet silviculture standards in the FMP on either Category 2 lands or Class X and Y lands. SFLs with Class Z lands are required to undertake tending on these areas but are not responsible for meeting the silvicultural standards on these lands.

Background Information and Summary of Evidence: The 2003 independent forest audit recommended that OVFI and OMNR jointly devise a format for OVFI to use to assess and report on the silvicultural efforts and accomplishments on class X, Y, Z lands. This process was intended to address the need to ensure that harvested areas categorized as X, Y, Z lands meet silviculture standards per the SFL agreement and to confirm their regeneration status. In response to the recommendation, OVFI and OMNR staff began working cooperatively in 2004 to compare the original source maps (1:50,000 scale, signed by OMNR and OVFI in 1999 detailing the X, Y, Z lands) to OVFI's GIS spatial silviculture data and historical silviculture information to determine what activities had occurred on the areas. There was no tabular data compiled at the time that the original X, Y, Z maps were created, therefore a total sum of the areas designated as X, Y, or Z land was unknown. The Y and Z lands were mapped manually and supported with a spreadsheet database listing the status of each parcel of land. Status labels were assigned to each block (e.g., accomplished, pending, removed); results were summarized in a report and a spreadsheet was produced in 2007. The audit report contains a summary table along with a commitment that the table would be updated annually in the annual reports starting in 2007. However, No X, Y, Z summary status tables were found in any of the annual reports produced for the Ottawa Valley Forest during the audit term.

Discussion: ?The auditors note that the 2007 X, Y, Z land report indicated that relatively small areas of Y and Z lands were considered “pending” or “part pending” in terms of meeting the silviculture standards (i.e., areas that may have been treated but have not yet received updates or assessments). Under the terms of the SFL (Paragraph 16), the SFL holder is committed to ensuring that the Y and Z lands meet the silviculture standards described in the FMP.

Conclusion: As there were areas that remained pending in 2007 and have not been reported upon since, the OVFI must update and report on the status of the “pending” or “part pending” areas in the next annual report and continue to report on the status of the Y and Z lands in future annual reports until these areas meet the silviculture standards.

Recommendation 13: Ottawa Valley Forest Inc. shall update and report upon the status of the Y and Z lands in its next annual report and in each annual report thereafter until their commitment under Paragraph 16 of the Sustainable Forest License agreement is fully achieved.

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Independent Forest Audit – Record of Finding

Recommendation #14

Principle: 6 Monitoring Criterion: 6.3 Silviculture Standards and Assessment Program - To review and assess whether an effective program exists to assess area that is successfully regenerated to the projected forest unit (silvicultural success) or to another forest unit (regeneration success) in accordance with the applicable FMPM, FIM, FOSM and SEMMO. Procedure(s): 6.3.3 - Assess the actual level of the overall monitoring program including whether the amount of area eligible for survey is consistent with past levels of harvest and whether all areas are being addressed.

Background Information and Summary of Evidence: Over the five-year 2006-11 operating term, 6,079 ha of renewal area were surveyed for regeneration success, which represents 37% of the planned level of 18,869 ha. Ottawa Valley Forest Inc. attributes the shortfall in achievement to three factors:

(1) the redirection of survey staff to mapping and assessing blowdown areas during the first two years of the plan term;

(2) the lack of removal cuts on which the FTG survey for shelterwoods are estimated; and, (3) only 61% of planned harvest area was actually harvested, which would have impacted

assessments within the 2006-11 term (intolerant clearcuts and areas with residual forest post-harvest).

Discussion: The auditors are satisfied that OVFI maintains a satisfactory silviculture effectiveness monitoring program, but are concerned that the actual level of monitoring may not have kept pace with the levels projected in the FMP or with the level of harvest and renewal over the past 20 years. The Year 10 (2010-11) Annual Report recognizes the shortfall in the FTG assessment effort in the most recent years, but does not outline a clear action for addressing this deficiency. Although there is likely no doubt the factors described above detracted from OVFI's ability to reach its assessment targets, these reasons do not relieve OVFI from its silvicultural effectiveness monitoring obligations. The auditors examined this issue more closely and utilized the harvest and renewal long-term trends data in the 2010-11 Year 10 Annual Report to estimate the appropriate level of assessments that should be conducted annually. The data for the 21-year period from 1990 to2011 were reviewed. The harvest data was sourced from Table AR-10 (which does not include selection harvest areas) and the renewal numbers from Table AR-9, and compared to actual survey accomplishments/year over the 2006-11 period and projected survey levels estimated over the 2011-21 period: 1990-2011 Average actual harvest = 2,825 ha/yr Average actual renewal = 1,524 ha/yr 2006-2011 Average FTG Survey = 1,216 ha/yr

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Projected level of FTG assessments for 2011-2021 = 17,452 ha or 1,745 ha/year The 1990-2011 average actual renewal numbers quoted above have been adjusted to discount for area renewed under the selection system and for supplemental planting activities in regeneration cuts under the shelterwood system (to avoid double-counting). For reference, 460 ha/year were harvested under the selection system, which are considered to be perpetually renewed, over the same 21-year period. Staff of OVFI pointed out other possible imprecisions with the data, such as all stages of shelterwood harvest being included in the harvest/salvage area recorded in Table AR-10, and in the approaches used for recording harvest areas during the earlier pre-GPS technology days. These caveats may help explain the gap in the average harvest and renewal numbers presented above. During the analysis, the auditors became aware of the complexities that arise while attempting to track the landbase where shelterwood, selection, and clearcut systems are all practiced on the same landbase. Despite the complexities, the data still suggests that there might be a slight shortfall in the level of FTG assessments that have been conducted in recent years. The level of renewal over the 21-year period (1990-2011) averaged 1,524 ha/year. Analysis undertaken by OVFI in its own Year 10 Annual Report stated that there were possibly 19,381 ha remaining to be surveyed for FTG as of 2011 (which would equate to 1,938 ha of surveys required over the next 10 years), according to the data in Table AR-10. These numbers suggest that the level of FTG assessments should be higher than the average 1,216 ha/year conducted over the past five years. The projected level of FTG assessments over the 2011-2021 FMP term is expected to be 1,745 ha/year. Although still early in the term, the area assessed for FTG during the first two years of the current FMP term averaged only 832 ha/year. Staff of OVFI believe the assessment numbers will increase significantly over the next few years, as substantial areas salvage harvested during 2006 and 2007 (approximately 3,900 ha) are expected to soon become ready to survey.

Conclusion: The analysis demonstrates that the rate of annual assessment effort has not kept pace with actual harvest or renewal levels over the past 21 years. Additional effort is needed to ensure that assessment levels are closely aligned with actual harvest and renewal levels. The auditors recognize OVFI’s stoic level of monitoring at all phases of the operations, including the post-harvest surveys and the post-treatment calibrated ocular surveys. However, the auditors believe that even more resources may be needed to ensure that the 2011-21 FMP commitments are achieved (2,328 ha/year). During the 2011-12 season, the FTG effort amounted to 857 ha, well short of the expected annual average and well short of the planned effort of 1,500 ha of FTG and Year 10 Interim Regeneration Reports in the 2011-12 AWS.

Recommendation 14: When preparing the 2013-14 (Year 3) Annual Report, Ottawa Valley Forest Inc. shall collect sufficient evidence to support its claims that current and projected levels of free-to-grow assessments are consistent with the amount of area expected to be eligible for survey. Ottawa Valley Forest Inc. should also consider undertaking a thorough spatial analysis of its landbase to ensure that there are no gaps in areas requiring renewal treatment or free-to-grow assessment.

Independent Forest Audit – Record of Finding

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Recommendation 15

Principle: 6 Monitoring Criterion: 6.3 Silviculture Standards and Assessment Program - To review and assess whether an effective program exists to assess area that is successfully regenerated to the projected forest unit (silvicultural success) or to another forest unit (regeneration success) in accordance with the applicable FMPM, FIM, FOSM and SEMMO. Procedure(s): 6.3.2 - Assess whether the management unit assessment program (SFL and District) is sufficient and is being used to provide the required silviculture effectiveness monitoring information.

Background Information and Summary of Evidence: Ontario Ministry of Natural Resources in Pembroke has conducted silvicultural effectiveness monitoring audit assessments over the 2008-2011 period on the areas declared FTG or on current renewal and maintenance operations being conducted by OVFI. Each report focused on different aspects of OVFI's SEM or renewal and maintenance programs, selected at the discretion of District staff. Funding provided for the program was usually insufficient to cover all of the items that potentially could be examined, including the core task items. Representative samples of 5% and 10% were selected from areas scheduled to be surveyed for FTG status for selected years. All audits are conducted using ground-based surveys. Audits of the forest operations prescriptions and current silviculture operations were comprised of visual assessments and professional opinions on their effectiveness. A report of the audit findings was prepared annually and only one report (2008-09) was shared with OVFI.

Discussion: Limited data was presented to substantiate the observations or opinions recorded in OMNR's SEM reports. In some cases, the reports are simply a compilation of observations and commentary offered by various staff, with brief analysis provided. Interactions with OVFI staff in developing the reports appear to have been very limited. Overall, the report found several discrepancies with OVFI's data and were highly critical of many of OVFI's silviculture practices. For example, missed areas were found within treatment blocks or quality of the work was questioned. Although the issues found by OMNR staff likely deserve further examination by OVFI, the language used in describing the shortcomings is not very constructive and its presentation not conducive to strong relationship-building between the two organizations. As noted under the compliance monitoring criteria, and in the previous audit report, the tone of the silvicultural effectiveness monitoring reports reflect the ongoing strained relationship and differences of opinion between OMNR Pembroke District and OVFI staff. There continues to be is a difference in perception between OMNR and OVFI of what constitutes good forest renewal practices just as there are differences of opinion regarding compliance issues – there has been little change in this condition since the previous audit report. OMNR has not shared the silvicultural effectiveness monitoring reports with OVFI since the 2008-09 version, as OMNR staff conveyed that the report was not well received. Despite OMNR's reservations, the auditors believe that it would be useful to share silvicultural effectiveness monitoring reports with OVFI, particularly where there are noticeable discrepancies, to determine if adjustments to the stand attributes or silviculture practices are warranted. The OMNR in Pembroke and OVFI should also consider conducting more joint field sessions to discuss silvicultural effectiveness monitoring matters and ensure that the measurement techniques used by each party are understood.

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Conclusion: The auditors believe that there is merit in having OMNR's results shared with OVFI if only, at the very least, to initiate discussions in those cases where discrepancies in the findings for particular blocks/stands are being found. OMNR should also include more quantitative data in the silviculture effectiveness monitoring reports to support its findings.

Recommendation 15: The OMNR in Pembroke shall share the silviculture effectiveness monitoring audit reports it produces annually with Ottawa Valley Forest Inc. Efforts shall also be made to include more quantitative data to substantiate the findings listed in the reports.

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Appendix 2 – Management Objectives Table 1

2

Objective Auditor Assessment

Auditor comments

QUANTITATIVE OBJECTIVES Landscape Level Objectives and Forest Diversity (FD)

FD-1 Improve the distribution of all seral (development) stages (all forest) across the management unit by the year 2101. The target distribution of seral stages is:

Target

for DFFC*

(ha)

Current (ha)

2011 (ha)

2010 (ha)

FD-1.1: Presapling and Two-storied

19,064 31,638 36,070 19,936

FD-1.2: Sapling and Immature

72,757 31,614 35,216 97,350

FD-1.3: Mature and Uneven

67,922 133,392 122,945 63,266

FD-1.4: Late

70,244 33,361 35,334 46,872

Achieved Distribution of seral stages as of 2011:

Target for

DFFC* (ha)

2006 (ha)

Target 2011 (ha)

Actual 2011 (ha)

FD-1.1 Presapling and Two-storied

19,064 31,638 36,070 39,196

FD-1.2 Sapling and Immature

72,757 31,614 35,216 39009

FD-1.3 Mature and Uneven

67,922 133,392 122,945 128826

FD-1.4 Late

70,244 33,361 35,334 22462

The objective achievement is to be measured at the beginning of each FMP term based on the most recent FRI update. Table AR 14 shows an increase in the abundance of FD-1.1 beyond the 2011 target and beyond the long term target largely due to extensive blowdown in 2006 and 2007. This may be corrected through harvest scheduling. Table AR 14 notes initial estimates for FD-1.2, FD-1.3, and FD-1.4 are all likely to have been incorrect due to FRI error. FD-1.2 and FD-1.3 have increased and decreased

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respectively towards the desirable range. FD-1.4 shows a decrease away from the desirable range. Given the statement that the 2006 FRI likely included an age error, it is not possible to confirm that the actual change is real. However, both the FD-1.2 and FD-1.3 age classes, which are virtually impossible to change within the tools available to managers, are tending towards the desired long term target. The auditors are willing to accept this as evidence that the objective is being met for these two seral stages, and that harvest scheduling may assist in moving seral stages FD-1.1 and FD-1.4 towards the long term target.

FD-2 Maintain or increase the representation of white pine and red pine forest from 2001 levels.

FD-2.1: Increase the representation of the PW1 forest unit.

Not Achieved

Actual 2006 (ha)

Target 2026 (ha)

Actual 2011 (ha)

Target 2101 (ha)

TARGETS 39,063 39,843 37,478 47,000

The level has declined from the 2006 area and away from the long term target largely due to blowdown in 2006 and 2007. That reduced the PW1 forest unit to the 2001 level. The blowdown area had not been assessed to FTG status at the time of the audit. The auditors witnessed generally effective Pw regeneration, although there are disputes with OMNR on the overall silvicultural effectiveness monitoring assessments. Effective regeneration of Pw areas that were blown down may change this conclusion when these stands are formally assessed at FTG.

FD-2.2: Maintain or increase the representation of the PR1 forest unit

Achieved Actual 2006 (ha)

Target 2026 (ha)

Actual 2011 (ha)

Target 2101 (ha)

TARGETS 6,513 6,886 6,875 13,281

This target has been met.

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FD-2.3: Reduce the degraded PW2 by harvest and conversion to PW1 (PR1).

Inconclusive

Actual 2006 (ha)

Target 2026 (ha)

Actual 2011 (ha)

Target 2101 (ha)

TARGETS 15,448 15,563 16,028 8,767

The movement away from the long term target is largely attributed to errors in the FRI in 2006 and to Pw natural and artificial regeneration that falls below PW1 levels. The information available does not allow meaningful assessment of how much the objective shortfall is due to FRI errors and how much is due to renewal that failed to establish PW1 stands. The silvicultural program witnessed by the auditors was as intensive as could be expected. There is a reasonable expectation that competition will be better managed on pine sites with the use of more effective herbicides. It seems unlikely that the value of the future forest would warrant the additional silvicultural investment needed to correct stands that are already established. It is not possible to confirm achievement of this objective and premature to categorize it as a failure.

FD-2.4: Maintain or increase the sum of the PW1, PW2 and PR1 forest units.

Partially met

Actual 2006 (ha)

Target 2011 (ha)

Actual 2011 (ha)

Target 2101 (ha)

TARGETS 61,024 62,261 60,380 69,048

The decline in the area was attributed to the blowdown in 2006 and 2007. The current level is slightly above that noted in the 2001 FMP. The data does not support a conclusion that the forest is trending towards the long term target. As noted for objective FD-2.1, this could change when the blowdown area is assessed at FTG. The silviculture program witnessed appeared to be effective. The auditors conclude that the objective is being partially met.

FD-2.5: To convert a minimum of 20% of MW3 harvest 30 sites to PR1 and PW1 forest units (75:25)

Partially met Target – 233 ha (PR1) 78 ha (PW1) AR 14 notes 73 ha of MW3 sites were declared FTG to PW1 during 2006-2011. The

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2006-2011 233 ha salvage harvest associated with the blowdowns in 2006 and 2007 resulted in reduced regular harvest which would consequently affect renewal activities. This objective has been partially met.

FD-3 Minimize the loss of the OR1 forest unit from 2001. Maintain above 30,454 ha (80% of 2001).

Achieved

Actual 2006 (ha)

Target 2011 (ha)

Actual 2011 (ha)

Target 2101 (ha)

TARGETS 38,086 37,980 38,155 34,540

This objective is being met.

FD-4 Maintain the representation of the HE1 forest unit from 2001.

Achieved

Actual 2006 (ha)

Target 2011 (ha)

Actual 2011 (ha)

Target2101 (ha)

TARGETS 2,256 2,256 2,417 2,256

The current FRI identifies a slight increase in the HE1 forest unit. The objective is being met. The confidence in this assessment would be significantly improved if the accuracy of the FRI were quantified.

FD-5 Maintain the representation of the CE1 forest unit from 2001.

Achieved

Actual 2006 (ha)

Target 2011 (ha)

Actual 2011 (ha)

Target2101 (ha)

TARGETS 4,972 4,971 5,052 4,791

The increase in the CE1 forest unit is attributed to FRI corrections and the post-harvest succession of mixedwoods to CE1. The objective is being met.

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FD-6 Maintain or increase the representation of the PJ1 forest unit from 2001.

Partially met

Actual 2006 (ha)

Target 2011 (ha)

Actual 2011 (ha)

Target 2101 (ha)

TARGETS

1965 1965 1709 2063

111 ha of jack pine were lost in the 2006 and 2007 blowdowns and 59 ha have been harvested in the last plan. The balance (86 ha) is attributed to FRI errors. AR 14 notes that there are currently 138 ha of new jack pine artificial renewal projects planned, which will still leave the target short by 118 ha. No harvest of the PJ1 forest unit is listed in the planned harvest in the 2011 FMP. The 2011 target was not met but the data supports a trend towards the long term objective. The objective is being partially met.

FD-7 Increase the representation of diminished forest types within forest units: • red spruce, white spruce in CM1; and • yellow birch in HD1

FD-7.1: Area of Red Spruce working group in CM1 (ha).

Achieved No red spruce working group was identified at the start of the 2006 FMP. 18.5 ha are noted in the 2011 inventory. The auditors accept this as a trend in the right direction. The open target of increasing the area of red spruce has been met.

FD-7.2: Area of White Spruce working group in CM1 (ha).

Partially met The objective target of having more than the 604 ha of the white spruce working group on site in 2011 than was present in 2006 is simple. Based on the inventory used for the 2011 FMP, the target was close (592 ha) to maintaining the 2006 level and an additional 85 ha or white spruce artificial regeneration projects are in place. The establishment of the white spruce regeneration projects confirms the intent to meet this target. It can be verified when these areas are assessed at FTG. The objective has not been met but progress is evident.

FD-7.3: Area of Yellow Birch working group in HD1 (ha).

Inconclusive There was less yellow birch working group (365 ha) in the assessment used for the 2011 FMP than there was identified in the 2006 FMP. The apparent decline has been attributed to inventory errors. Therefore, there is no evidence to support a positive assessment of achievement. However, as was the case with objectives FD 7.1, and 7.2, the area noted on the ground is small. The auditors anticipate new baseline levels may be set when the new inventory, scheduled for delivery in 2017, is in place. Prior to that

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it is not reasonable to place much weight on the data available. The auditors regard these three objectives as useful placeholders that cannot and should not be assessed until an updated inventory confirms current levels.

FD-8 Increase (from 2.2%, 2001) and maintain the area of old growth white and red pine communities to a minimum of 20% of total white and red pine forest area. Target is 20 years. White and red pine communities are defined as the area in the PW1, PW2, and PR1 forest units.

Inconclusive The indicator for this objective is the area of PW1, PW2 and PR1 in the late seral stage that have not received a regeneration cut. As noted in Table AR 14 “This was not assessed, as Plan Start was based on the incorrect FRI age. 2011 FMP old growth targets are based on the new forest units and Desirable Levels consisting of the calculated Landscape Guide Simulated Range of Natural Variation (SRNV) of the Old Growth classification for each forest unit.” Given that the starting point was incorrect, and the new objective in the 2011 FMP is based on changed forest units, no credible conclusion on objective achievement from the 2006 FMP can be confirmed. The comparable objective listed in the 2011 FMP will not be assessed until the beginning of Phase 1 planning for the 2021 FMP, which should benefit from a new inventory.

FD-9 Maintain representation of old growth forest in all even-aged forest units within the bounds of natural variation. Targets by forest unit according to onset age.

Inconclusive This objective identified indicators/targets for 12 forest units. As noted in Table FMP 14 of the Year 10 Annual Report,” This was not assessed, as Plan Start was based on the incorrect FRI age. 2011 FMP old growth targets are based on the new forest units and Desirable Levels consisting of the calculated Landscape Guide Simulated Range of Natural Variation (SRNV) of the Old Growth classification for each forest unit.” Given that the starting point was incorrect, and the new objective in the 2011 FMP is based on changed forest units, no credible conclusion on objective achievement from the 2006 FMP can be confirmed. The comparable objective listed in the 2011 FMP will not be assessed until the beginning of Phase 1 planning for the 2012 FMP, which should benefit from new inventory.

FD-10 Maintain landscape patterns within the bounds of natural variation while moving the frequency distribution of forest disturbance patch sizes towards the template for Site Districts 5E-10 and 5E-

FD-10.1: Frequency distribution of forest disturbance patch sizes (NDPEGTool Analysis).

Achieved The objective includes eight patch sizes and assigns area percentage target across the forest as targets. Notably, at the start of the 2006 FMP there were no areas in the 1,040-5,000 ha and 5,000 ha + patches. These would be relatively large openings on this forest and it seems very unlikely that the largest will ever be achieved failing a very large natural disturbance. All target area opening targets below 5,000 ha moved towards the identified desirable range. Progress in the 1,000-5,000 ha patch size was

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attributed to the 2009 blowdown. The objective has been met.

FD-10.2: Changes resulting from harvest and distinguished from natural development will be limited to less than 10% for spatial indices of landscape pattern (Patch Analyst Analysis).

Inconclusive This objective includes detailed targets that were not assessed at plan end. The assessment tool (Patch Analyst Analysis) has replaced the analysis of young forest patch size according to the Landscape Guide using the Ontario landscape tool. Meaningful assessment of this objective is not likely until the new FRI is delivered in 2017.

Socio-Economic Objectives (SE)

SE-1 Meet the anticipated demand for forest products by the forest industry today and in the future. The estimated demand for poplar and white birch totals approximately 166,000 m3/year, which cannot be achieved if long term objectives for a predictable, even wood flow are also to be achieved (objectives SE-2 and SE-3). In the development of the Selected Management Alternative, this target had to be modified to be the maximum volume attainable while meeting the even flow objectives.

Achieved

SE-1.1: Meet the industrial demand for white and red pine.

Achieved The target for this sub-objective was volume greater than 70,000 m3/yr. Table AR 8

shows red and white pine harvest volume for the 2006-2011 period averaged 58, 007 m

3. This amounted to 90% of the planned harvest for these species. The planned

volumes are scheduled to increase over the medium (2026) and long (2106) term. Table AR 14 notes these objectives have been met through the selection of the selected management alternative. The objective has been met.

SE-1.2: Meet the industrial demand for tolerant hardwoods.

Achieved Planned harvest levels for tolerant hardwoods total 55m3/yr in the 2006 -2011 FMP fall

within the volumes specified in the selected management alternative. The medium and long term projections both exceed the targeted volume of >52,000 m

3/yr. Actual

harvest reported in the 2006 -2011 period was 24,000m3/yr. The objective is being

met.

SE-1.3: Maximize polar and white birch volume over the next ten years while meeting other harvest objectives.

Achieved Table AR 14 notes that the hard target for this objective is >100,000 m3/yr. This was

achieved in the last three plans where white birch and poplar harvest averaged 116m

3/yr. The planned harvest in the 2006-2011 FMP declines to 108,000m

3/yr and

then to 82,000m3/yr in the long term. The short term target has been met and the long

term objective has fallen within the selected management alternative, which meets the stated conditions of the objective to maximize within other harvest objectives.

SE-2 Achieved The objective has been achieved as near as the data available allows. The long term

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Ensure a long-term predictable supply of forest products to the industry that minimizes fluctuations in volume harvested for the three main species groupings to <=10% between forest management plan terms (i.e., white and red pine, poplar and white birch, tolerant hardwoods).

forecast shows harvest volumes will be available as targeted, a condition of the selected management alternative. The auditors have concerns about the accuracy of the modelled forecast over the long term but accept that the near term projections, which are more reliable, meet the objectives.

SE-3 Minimize fluctuations in area harvested between planning terms

Achieved The objective has been achieved as near as the data available allows. The long term forecast shows harvest volumes will be available as targeted, a condition of the selected management alternative. The auditors have concerns about the accuracy of the modelled forecast over the long term, but accept that the near term projections, which are more reliable, meet the objectives.

SE-4 Fully utilize the forecast harvest volume made available

Partially Achieved

The desirable level of achievement, which seems consistent with the stated objective, is 100% utilization. The stated target is >75%. Actual harvest has averaged 74% of planned levels since 1990. It is clear this varies according to market demand. The auditors noted a tendency to leave more residuals than required on shelterwood and clear cut sites. They have recommended that this volume in particular be fully utilized.

Objectives for Other Values Dependent on Forest Cover (OV)

OV-1 Maintain habitats (non-spatial habitat estimated using the SFMM) for all indigenous wildlife. The Selected Management Alternative was predicated on maintaining the twenty selected wildlife habitats above the lower bound of natural variation. Maintaining the twenty selected habitats will ensure that the habitats of most other species are also maintained.

Partially Achieved

There are 20 individual species tracked as indicators on this objective. The habitats for 16 of these are above the minimum desirable level and four fall below that level, as of the 2011 assessment. The four falling below the stated minimum threshold were all attributed to FRI stand age corrections or the blowdown event of 2006. The medium and long term projections show available habitat levels as being above the minimum threshold levels.

OV-4 Objectives for the provision of white-tailed deer habitat (quantitative and qualitative components).

Achieved All of the measurable indicators of achievement of the objective are trending towards targets.

OV-5 Objectives for the provision of moose habitat.

Partially Achieved

The 2011 analysis indicates the targets have not been met but analysis was done using an updated assessment tool which meant the results from the 2006 and 2011 assessments are not comparable. The average weighted moose-carrying capacity is 90% of the target.

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OV-6 Objectives for the provision of red-shouldered hawk habitat.

Not Achieved

The 2011 analysis indicates the targets have not been met but analysis was done using an updated assessment tool which meant the results from the 2006 and 2011 assessments are not comparable. The target area is 14,110 ha. The estimated actual area in 2011 was 5,297 ha.

OV-7 Objectives for the provision of pileated woodpecker habitat.

Achieved The 2011 analysis indicates the targets have not been met but analysis was done using an updated assessment tool which meant the results from the 2006 and 2011 assessments are not comparable. The estimate of preferred habitat in 2011 was 136,297 ha, which exceed the stated objective target of 84,804 ha.

OV-8 Objective for the provision of habitat for ruffed grouse (non-spatial habitat estimated using the SFMM).

Achieved The current non-spatial estimate of preferred habitat for ruffed grouse (22,285 ha) exceeds the 2011 target but is short of the medium term target of 34,958 ha. The trend is in the right direction as the starting level in 2006 was 18,625 ha.

OV-9 Objective for the provision of habitat for white-throated sparrow (non-spatial habitat estimated using the SFMM).

Partially Achieved

The long term target (42,765 ha) has not been met. The 2011 estimated area is 28,800 ha vs. 24,266 ha at the start of the 2006 FMP. The 2011 achievement is just short of the 2011 target, but the trend is viewed as being strongly in the right direction.

Silviculture Objectives (SI)

SI-1 To ensure every forest stand harvested on the Ottawa Valley Forest is renewed, and tended as required, by the most appropriate and cost effective methods to achieve the desired future forest condition.

Achieved Three of 10 targets for subobjectives have not been met as low harvest levels reduced the area needing regeneration treatments. Regeneration levels were largely consistent with harvest levels, with the exception of scarification treatments. Scarification was not completed unless site conditions warranted. The silvicultural effort is keeping pace with harvest levels.

QUALITATIVE OBJECTIVES

Forest Diversity Objectives (FD)

FD-11 Increase the representation of old growth conditions in managed uneven-aged stands.

Achieved A variety of strategies has been used by OVFI to maintain or increase old growth attributes in uneven-aged stands.

FD-12 Protect critical or sensitive habitats of featured species within managed forest stands.

Achieved Critical and sensitive habitat has been protected through use of site-specific AOCs.

FD-13 Maintain the diversity of tree species and

Achieved The renewal program is entirely dependent on natural renewal of existing species or artificial renewal of existing species using seed of local provenance.

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structural elements within managed stands.

FD-14 Identify and protect sensitive forest sites (Protection Forest).

Achieved Sensitive sites were protected using a variety of operational measures.

FD-15 Protect known populations and individual trees of species that are uncommon or at the extremes of their range (i.e., butternut, bitternut hickory, white oak, red spruce, red cedar) or of species at risk status (butternut).

Achieved A moratorium was placed on the harvest of butternut. White oak, red spruce, and red cedar were reserved from harvest.

FD-16 Maintain the genetic diversity of the common tree species of the management unit.

Achieved The renewal program is entirely dependent on natural renewal of existing species or artificial renewal of existing species using seed of local provenance.

Socio-Economic Objectives (SE)

SE-5 Improve the proportion of high value species and products, particularly white pine, red pine, and tolerant hardwood sawlogs over time.

Inconclusive Since the target was only set in 2006, FTG surveys have not been completed that would support meaningful assessment of this objective. The target is trend related rather than a specific volume or area. Modeling projections indicate an increase over the medium to long term.

SE-6 Identify and implement ways of achieving more equal participation by Algonquin First Nation communities in the benefits provided through forest management planning.

Achieved/ Ongoing

Discussions with Algonquin First Nations communities have been ongoing since plan implementation and continue as part of land claim discussions.

SE-7 Provide opportunities for the public to harvest personal use fuelwood from logging residues.

Achieved Harvested areas accessible to the public for fuelwood collection have been identified in the AWSs. Fuelwood permits totalled 3,267 m

3.

SE-8 Develop and manage the use and abandonment of forest access roads and water crossings that meet the needs of the forest industry, ensures public safety, and minimizes risk to the environment.

Achieved Roads have been constructed in accordance with the Environmental Guidelines for Access Roads and Water Crossings, as verified through compliance inspection reports. Roads no longer required for forest management purposes have been decommissioned in accordance with the relevant road use management strategies. Access controls and abandonment strategies consistent with the Madawaska Highlands Land Use Plan and OLL Enhanced Management Areas have been applied where required. The roads

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travelled by the audit team were in good repair.

SE-9 To manage the forest cover to provide and protect recreation and tourism values.

Achieved Known tourism and recreation resource values were identified and considered in the planning and implementation of forest management activities. Annual work schedule map products are provided to resource-based tourism facilities who requested this information. Forest operation prescriptions were prepared giving consideration to aesthetics along roads in major tourist routes.

SE-10 To manage forest cover for the protection and enhancement of fish habitat, contributing to the health of fish populations, and their sustained use for food, employment and recreation

Achieved Achieved through the implementation of approved AOC prescriptions for known and discovered fisheries values.

SE-11 To manage forest cover for the protection and enhancement of wildlife habitat, contributing to the health of wildlife populations and their sustained use for food, employment, hunting and viewing.

Achieved Achieved through the implementation of approved AOC prescriptions for known and discovered wildlife values and through the implementation of stand level prescriptions for wildlife habitat and biodiversity.

SE-12 Education, Demonstration, and Research

SE-12.1: Encourage and facilitate outdoor and environmental education opportunities in the Ottawa Valley Forest in order to promote the concept of sustainable forests.

Achieved Staff of OVFI have generally spent two days per summer with each of the Stewardship Rangers, Algonquin Earth Walkers, and Junior Rangers. One student took the opportunity to participate in training during the term of the FMP. Staff of OVFI regularly participate in information and training sessions with the LCAC.

SE-12.2: Make forest environments available for research and technology development related to developing the science and practice of sustainable forestry, and for monitoring ecosystem health.

Achieved Support of new monitoring and research projects on the unit including a project to assess and monitor planted oak acorn survival and performance versus that of planted seedlings, and a project to assess residual tree damage and damage to regeneration in a shelterwood final removal cut. Other research projects included assessment of regeneration survey methods and exceptions monitoring programs. It was also ensured that known, short and long-term research and environmental monitoring plots or study areas were identified and considered in the forest management planning process, including the development of AOC prescriptions for research plots such as established growth and yield plots, and permanent growth plots.

SE-12.3: Participate with Algonquin First Nation Achieved Staff of OVFI were made available to participate in field trips and tours to explain forest management principles and practices, including direct participation with the Algonquin

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communities in developing forestry awareness and in training First Nation forest technicians, foresters, and forest operators.

Earth Walkers. Ottawa Valley Forest Inc. supported training initiatives and continuous learning of Aboriginal forest workers by holding tree marking workshops and operator training workshops that were attended by representatives of the Algonquin First Nation. Participation will increase as the Land Claim negotiations continue.

SE-13 Ensure significant features of cultural heritage are considered and protected from any impact from forest management activities.

Achieved Known and predicted potential cultural heritage areas were identified and considered in the development of the forest management plan. Prescriptions for AOCs were developed and implemented for known and High Potential cultural heritage sites. It was also ensured that additional First Nation values from the native background information reports and other identified use areas (berry picking sites, cedar and fuelwood gathering areas) were considered during plan preparation and implementation.

Objectives for Other Values Dependent on Forest Cover (OV)

OV-2 Manage forest cover and forest management activities for the protection and enhancement of water quality and fish habitat.

Achieved Approved AOC prescriptions for known and discovered fisheries values were implemented. Verification of the proper implementation of prescribed AOCs was done through tree-marking audits and forest operations compliance inspections. Pre-harvest surveys for unknown values were conducted by OMNR and OVFI reported new values to OMNR when encountered.

OV-3 Manage forest cover and forest management activities for the protection of provincially and locally significant wetlands.

Achieved Approved AOC prescriptions for known and discovered wetland values were implemented. Verification of the proper implementation of prescribed AOCs was done through tree marking audits and forest operations compliance inspections. Pre-harvest surveys for unknown values were conducted by OMNR and OVFI reported new values to OMNR when encountered.

OV-4.1 Optimize the availability/balance of deer habitats spatially and through time.

Achieved Achieved by strategically locating harvest cuts spatially across deer range to improve browse, create early successional forest and edges, and retain critical thermal cover in deer yards as needed based on landscape habitat modelling. Timber harvest using practices such as clearcutting small patches, shelterwood cutting, or selection cutting that together produce diverse habitat and forest edges within deer range.

OV-4.2: Improve and maintain summer habitats for deer in the Ottawa Valley Forest

Achieved The qualitative components to this objective have been achieved and include: ensuring that early successional forests are distributed throughout deer summer range by strategically locating allocation areas and harvesting approximately equal areas of clearcut forest units in each plan term based on appropriate rotation ages; Managing known and discovered OR1 stands according to the SGRs to promote crown expansion and increased mast production; retaining a minimum of 8 mast trees/ha and using native forage species when seeding landings and water crossings for erosion control. Implementation of these strategies has been verified through tree marking audits and forest operations inspections.

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OV-4.3: Improve and maintain wintering habitats for deer in the Ottawa Valley Forest.

Achieved The following strategies were applied: shifting harvest effort in each deer yard towards approximately equal five-year levels based on the amount of each forest unit present, stages of management present, and suitable rotation ages based on silvicultural and other objectives (e.g., old growth); managing average allocation block size so that the number of individual harvest areas in each deer yard is maximized; ensuring that key deer yard habitats are connected by maintaining suitable conifer cover along major deer travel corridors and over bedding areas, and by retaining access cover patches within harvested areas of the managed deer yards; and improving the identification and protection of major travel corridors within deer yards.

OV-5.2: Maintain and protect special moose habitat features such as calving sites and aquatic feeding areas.

Achieved Approved AOC prescriptions for known and discovered special moose habitat values were implemented. Verification of the proper implementation of prescribed AOCs was done through tree-marking audits and forest operations compliance inspections.

OV-6.2: Retain and protect special habitat features in forest stands that are essential to red-shouldered hawk breeding success.

Achieved Approved AOC prescriptions for known and discovered habitat values were Implemented. Verification of the proper implementation of prescribed AOCs was done through tree marking audits and forest operations compliance inspections. Pre-harvest surveys (Spring hawk surveys) for unknown values were conducted by OMNR and OVFI reported new values to OMNR when encountered.

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Appendix 3 – Compliance with Contractual Obligations

Licence Condition Licence Holder Performance

Payment of Forestry Futures and Ontario Crown charges

OVFI’s payments are up to date as of March 31, 2013.

Wood supply commitments, memoranda-of-agreement, sharing arrangements, special conditions

Appendix E shows the SFL is directed to provide Grant Forest Products and its successor received volumes. Mill shutdowns and reduced demand explain the lack of delivered volume.

Preparation of FMP, AWS and annual reports; abiding by the FMP, and all other requirements of the FMPM and CFSA

Preparation of the FMP, AWS, and annual reports were completed in accordance with the requirements of the FMPM. Compliance reports with negative findings were consistently submitted within the required timeframes.

Conduct inventories, surveys, tests and studies; provision and collection of information in accordance with the Forest Information Manual

OVFI has met the requirements of the Forest Information Manual.

Wasteful practices not to be committed The auditors did not observe wasteful practices other than those reported in compliance reports. In general, harvest sites were clean of industrial garbage and utilization was very good.

Natural disturbance and salvage SFL conditions must be followed

The license conditions regarding natural disturbance and salvage harvesting were followed.

Protection of the licence area from pest damage, participation in pest control programs

No pest management programs were completed on this Forest.

Withdrawals from licence area No areas were withdrawn from this Forest during this audit term.

Audit action plan and status report The action plan dealt with each of the recommendations targeted at the OMNR District of the OVFI from the previous independent forest audit that were directed to OVFI. The auditors note that the action plan did not address recommendations addressed to Regional or Corporate OMNR. As reflected in Recommendation 11 of this report, it is evident that the OMNR Corporate and Regional response to Recommendation 7 from the last IFA (MNR Region and/or Corporate MNR must take steps to resolve the long standing controversy over the implementation of the compliance program in the Pembroke District) was not effectively addressed.

Payment of forest renewal charges to Forest Renewal Trust

Payment of forest renewal charges to the Forest Renewal Trust met the required minimum balance as of March 31, for each of the five years within the scope of the audit.

Forest Renewal Trust eligible silviculture work Field inspections of the 2011-2012 work confirmed

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that the silvicultural operations were consistent with forest operations prescriptions and were eligible for reimbursement from the Trust fund. Maps and records were available and were consistent with invoices submitted. According to the report “Compliance with the Forest Renewal Trust Agreement for the period April 1, 2011 to March 31, 2012, (June 2013) the total actual cost of eligible silviculture work was $781,600.

Forest Renewal Trust forest renewal charge analysis

The renewal rates were reviewed and adjusted to ensure sufficient funds were available to meet the requirements of the silviculture program.

Forest Renewal Trust account minimum balance Payment of forest renewal charges to the Forest Renewal Trust met the required minimum balance in each year of the audit term.

Silviculture standards and assessment program Silvicultural standards were maintained at an acceptable level.

Aboriginal Opportunities A limited set of benefits were provided to Aboriginal peoples during the audit period. There are very active discussions taking place that should lead to more opportunities in the future.

Preparation of compliance plan Preparation of the compliance plan met the contractual obligations.

Internal compliance prevention/education program

The internal compliance program met contractual requirements.

Compliance inspections and reporting; compliance with compliance plan

Compliance inspections by OVFI were generally well done.

SFL forestry operations on mining claims Notices were provided to all mining claim holders with operations within the Ottawa Valley Forest.

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Appendix 4 – Audit Process The CFSA directs the Minister of Natural Resources to conduct a review of the Ottawa Valley Forest every five years to ensure that the licensee has complied with the terms and conditions of its license. Independent forest audits, as directed through the Independent Forest Audit Process and Protocol (2013) are conducted to support this direction. The Independent Forest Audit Process and Protocol (2013) details the scope and process requirements of an independent forest audit, and contains approximately 150 individual audit procedures. It states that the purpose of the audits is to:

• assess to what extent forest management planning activities comply with the Forest Management Planning Manual and the [Crown Forest Sustainability] Act;

• assess to what extent forest management planning activities comply with the Act and with the forest management plans, the manuals approved under the Act, and the applicable guides;

• assess the effectiveness of forest management activities in meeting the forest management objectives set out in the forest management plan, as measured in relation to the criteria established for the audit;

• compare the forest management activities carried out with those that were planned;

• assess the effectiveness of any action plans implemented to remedy shortcomings revealed by a previous audit; and

• review and assess a licensee's compliance with the terms and conditions of the forest resources license.

There are two key types of findings in an independent forest audit, recommendations and best practices. A recommendation provides direction to address a noted deficiency in the planning, implementation, or monitoring of forest operations. Recommendations can be directed towards the Company and/or at the appropriate administrative level of the OMNR. The auditee must address all recommendations in follow-up actions. If the audit team feels that an aspect of forest management is exceptional it may be identified as a best practice. The Independent Forest Audit Process and Protocol (2013) states that “Highly effective novel approaches to various aspects of forest management may represent best practices”. The auditors collected evidence through document review, interviews with staff and stakeholders, and physical inspection of field activities that occurred on the Ottawa Valley Forest between April 1, 2008 and March 31, 2013. The audit process began with a pre-audit and site selection meeting in Pembroke on April 9, 2013. The purpose of the meeting was for the lead auditor, the OVFI, and OMNR to discuss audit logistics and for the lead auditor to collect background information and documents for the audit. Following the meeting, an audit plan was finalized and distributed that outlined the audit schedule and identified the main contacts for the audit. From June 30 to September 20, the audit team reviewed documents describing forest management activities on the Ottawa Valley Forest. Interviews were held with a variety of

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interested parties. Personnel from OMNR and OVFI were interviewed throughout the audit. Most of these interviews took place in person, but contact by phone and e-mail between the audit team, auditee, and the public was common. Field site visit locations were selected to evaluate harvest, renewal, tending/maintenance, FTG operations, AOCs, road construction and maintenance, site preparation, water crossings, wildlife management activities, and other areas of special interest. Sites that had multiple audit values (e.g., renewal and AOC) were preferentially selected. Field sites were also selected to ensure that evaluations of winter and summer operations were representative of actual operations and included representative sites for the operations of each of the overlapping licensees. On-site and field audit activities occurred between Sept 22 and 27, 2013. The audit team verified records and information systems at the OVFI and OMNR offices. The team split into two or three field crews at different times, each of which was accompanied by OVFI or OMNR staff. Sampling was completed through 14 person days of field inspections. Sampling continued until the auditors had viewed all of the selected sites and were satisfied that they had viewed enough sites to be confident in their assessment of field performance. Table 4.1 shows the total amount of each key activity that has occurred on the Ottawa Valley Forest during the audit period, total area of the sites visited, and the sample size as a percentage of the total area. The audit protocol requires the audit team to sample a minimum of 10% of the area treated during the audit period, and to increase the sample where higher risk activities were identified.

Table 4.1 Sampling Intensity for the Ottawa Valley Forest Audit by Operational Activity.

Activity Total Area through Audit Period (ha)

Audit Sample (%)

Clear Cut 3,799 23

Selection 1,294 29

Shelterwood 4,824 34

Stand Improve 3,325 31

Mechanical Site Prep 1,667 40

Chemical Site Prep 1,401 44

Tree Plant 2,441 23

Tending 3,704 20

Free To Grow 5,368 21

Total 27,803 27

AOC and Roads Inspections The auditors directly viewed implementation of prescribed protective measures for 91 values in the field, along with a sample of their documentation and compliance reports. Most of these

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observations are of AOCs, but there are some for values protected through Conditions on Regular Operations or other measures. By category: Water related - 55; Gates, boundaries or trails - 7; Confidential values - 5; Nest sites - 7; Archeological sites - 4; Deer habitat - 5; Land use permits or Madawaska Land Use Plan - 8. The audit team also travelled extensively on the road system in the Forest and observed operational road conditions on primary, branch, and operational roads. In 2006, the Government of Ontario developed a funding program (the Road Construction and Maintenance Agreement) to assist the forest industry in offsetting road construction and maintenance costs for roads meeting the program’s criteria. Throughout the audit term, OVFI qualified for assistance to maintain a number of primary and secondary (branch) roads and was reimbursed for maintenance costs as illustrated in the following table. Table 4.2 shows the funds expended and reimbursed through the program on the Ottawa Valley Forest landbase only.

Table 4.2 Road Expenditures on the Ottawa Valley Forest (2008-09 to 2012-13).

2008-09 2009-10 2010-11 2011-12 2012-13 Total

Actual cost of invoices for construction and maintenance work reimbursed

$913,838 $861,600 $952,858 $817,436 $795,901 $ 4,341,633

Actual total kilometers of road constructed

0 1.0 0 23.2 31.2 55.4

Actual number of crossings constructed

0 0 0 4 3 7

Actual total kilometres of maintenance work completed (km)

130.9 226.8 522.2 494.0 144.1 1,518.0

Actual number of crossings maintained 16 22 7 7 5 57

The auditors reviewed copies of invoices for construction and maintenance work that was conducted in 2008-09, 2010-11, and 2012-13. The audit team is satisfied that proper invoicing procedures and due care were exercised relative to the monies claimed under the roads maintenance program. Evidence in the field confirmed that the work was indeed carried out. The equipment and service rates paid to the licensees are based on 2006 rates obtained from the Ministry of Transportation. These rates remained unchanged throughout the audit period. It was evident from notes in OVFI files and interviews with OVFI staff that they closely scrutinized licensees’ invoices to ensure that they accurately reflected the work that was performed and supported the amounts being claimed.

Maintenance work included road and water crossing construction, bridge and culvert replacements and repairs, road base improvements, graveling, brushing, sign repairs, summer grading, and snow plowing. The auditors drove on the majority of the roads that had received

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funding and found ample evidence that the work for which the funding was provided had indeed been performed. The audit protocol requires tracking and assessment of a sample of sites treated in 2011/12 that were eligible for funding through the silvicultural trust fund. The summary of the area inspected is listed in Table 4.3. Table 4.3 Audit sample of areas treated in 2011/2012 that were eligible for funding though the silvicultural trust fund.

Treatment Total area treated

2011/12 (ha) Area inspected on audit (ha)

% sample

Site Preparation 662 262 40

Tree Plant 306 81 26

Tending 976 253 26

The auditor reviewed sites and confirmed that the treatment mapped, and charged to the trust fund was consistent with that observed on the ground. Risk Assessment The audit protocol allows the auditors to subsample procedures identified as low and medium risk in terms of contributions to the sustainability of the Forest. Given that the audit team reviewed the content, process, or outcome of each of these procedures in their assessment of those procedures deemed high risk, the auditors elected to audit all procedures pertinent to the Ottawa Valley Forest (Table 4.4). Table 4.4 Independent Forest Audit Procedures Audited by Risk Category.

Procedures Audited, by Risk Category

Principle

Low Risk Medium Risk High Risk

Comments

Ap

plic

able

(#)

Sele

cte

d

(#)

% A

ud

ite

d

Ap

plic

able

(#)

Sele

cte

d

(#)

% A

ud

ite

d

Au

dit

ed

(#)

1. Commitment 2 2 100 2 2 100 100 All procedures were audited

2. Public Consultation & Aboriginal Involvement

6 6 100 6 6 100 100 All procedures were audited

3. Forest Management Planning

27 27 100 27 27 100 100 All procedures were audited

4. Plan Assessment and Implementation

6 6 100 6 6 100 100 All procedures were audited

5. System Support 2 2 100 2 2 100 100 All procedures were audited

6. Monitoring 4 4 100 4 4 100 100 All procedures were audited

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7. Achievement of Objectives and Forest Sustainability

5 5 100 5 5 100 100 All procedures were audited

8. Contractual Obligations

20 20 100 20 20 100 100 All procedures were audited

Totals 72 72 100 72 72 100 100

Summary of Consultation and Input into the Audit General Public: A survey was sent to 702 stakeholders on August 28, 2013 using the mailing list that the OMNR maintains for the Ottawa Valley Forest. The audit team received 54 responses to the survey by mail and four though phone conversations. Eighteen of the written surveys were received after the completion of the field audit. Additionally, invitations to comment on forest management on the Ottawa Valley Forest over the audit term were placed in daily newspapers and an on-line version of the same. The results of the surveys are noted below. Survey Results Number of Surveys Mailed = 702 Number of Surveys Returned with Responses = 54 How Would You Describe the Management of the Ottawa Valley Forest?

Excellent Adequate Inadequate Poor Do Not Know

No Comment

15 16 5 2 7

When you have asked OMNR any questions about their forest management did they response to your satisfaction?

Yes No No Comment

27 7 13

When you have asked OVFI any questions about their forest management did they response to your satisfaction?

Yes No No Comment

27 4 12

When you have made comments to OMNR about forest issues that you feel are important, did they respond in a reasonable time?

Yes No No Comment

24 6 13

When you have made comments to OVFI about forest issues that you feel are important, did they respond in a reasonable time?

Yes No No Comment

24 2 15

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Did OMNR explain how your comments were considered?

Yes No No Comment

18 11 14

Did OVFI explain how your comments were considered?

Yes No No Comment

21 6 16

Have you seen specific instances of forest management practices on the Forest that concerned you or impressed you?

Many A few None Do Not Know

Concerned 7 12 12 6

Impressed 12 15 6 8

Summary of Comments Relevant Comments - Operations

Visit all locations on your Audit

Cutting too close to our camp

Landings that aren’t properly cleaned up

Any FTG location won’t be! Many poor bridge/culvert installations. Areas high-graded and excessive road building.

Concerned about wood waste and oil spills on landings.

Cutting stayed well back of camps and lakes.

Jobber left a mess in one location with hung tops and slash. MNR made them come back.

After logging never clean up, people throw away garbage and other materials. We always try and clean up what we can.

Tending projects in general

Visit White Mountain – Round Lake, KM 7 Brent Road

Overall forest management is quite good, much better than 30 years ago.

Block 319 (too many trees left), Block 320 (Final removal)

Beechnut lake Road – new roads put in and then they were not ditched to reduce vehicle traffic. This increases risk of illegal game taking. If new roads were ditched it would still be accessible for ATV’s but not vehicles.

ATVs are causing considerable damage to forested areas.

Bisset Creek Road, Brent Road, Rat Tail Lake Road – use of blue paint only overcuts stands. Accelerated removal cuts in shelterwood are against silvicultural manual. Poor pine /sawlog utilization on Rat Tail Lake.

My general impression is that loggers follow the “beg forgiveness” principle and that penalties for transgressions are seen as a cost of doing business. I hope I am wrong. Damage to waterways prevented whenever possible. Logging roads are closed to let nature have a chance.

Our hunt camp has never seen a forestry job that has not been completed in a responsible manner

Practice of removing culverts and bridges unfair as new access very important. Often reduces access to longtime LUP.

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Relevant Comments – Planning and Sustainability

Forest access roads that are blocked off without any scientific or ecological data to justify

ESA is making it very difficult to have blocks ready for operations and to meet all aspects of compliance

MNR is not achieving a balanced approach to resource management. Managing for environmental interests and disregarding socio-economic ones.

Concerned that the ESA does not take into consideration regional differences regarding certain species.

Appalling lack of information – secrecy related to Algonquin Land Claim

There no one looking out for the general public’s interest. All of the people on their advisory board have a vested interest.

The Species at Risk Legislation is not scientifically based. The Area of Concern for turtles lacks all common sense.

Interesting Comments

NO wind turbines on crown forests

Strongly object to stopping logging in Algonquin Park

Have observed excessive clear-cutting of forests for agricultural purposes. Local Citizens’ Advisory Committee: The LCAC was established by the OMNR in accordance with the requirements of the FMPM. All LCAC members were interviewed during the course of the audit. During the audit period the LCAC membership contained a good balance of interests with representation from environmental organizations, recreation, forest industry (mills), local communities, cottager lease holders, cultural heritage interests, angler and hunters and the general public. There is currently no AOO representation on the LCAC although Algonquin leaders have been invited. Algonquin representatives have many opportunities to raise issues of importance and concern to Algonquins and, therefore, the LCAC may not be of high priority to them. Most of the members have been on the LCAC for a long period of time and are very knowledgeable about various aspects of the Ottawa Valley Forest and its management. The LCAC was heavily involved in the preparation of the 2011 FMP. Most of the members of the LCAC were very supportive of how forest management occurs in the Forest.

First Nations: Most of Ottawa Valley Forest is covered by an Aboriginal rights and title claim by the Algonquins of Ontario (AOO). Discussions and negotiations about the claim have been ongoing since the 1990s. The AOO is comprised of ten Algonquin communities: Mattawa/North Bay, Antoine, Whitney, Bonnechere, Greater Golden Lake, Ottawa, Pikwakanagan, Snimikobi (Ardoch), Kijicho Manito (Bancroft), and Shabot Obaadjiwan (Sharbot Lake). These communities are located throughout their traditional territory/claim area, which covers a large area of eastern Ontario. Collectively, the AOO has a unified approach to negotiating with the federal and provincial governments to reach a settlement of their land claim. During the audit, a member of the audit team met several of the Algonquin Negotiation Representatives and the AOO's forestry technician.

OMNR: The District Manager, Area Forester, Acting Area Supervisor, Area Biologist, Senior Technician, and Resource Technicians participated in the opening and closing meetings and all

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or part of the field audit. Regional OMNR staff attended the opening meeting, the closing meeting, and one field day. Main office OMNR staff attended the opening meeting and three days of the field audit and participated in the closing meetings via conference call.

OVFI: All staff from OVFI with responsibility for management of the Ottawa Valley Forest participated in the audit.

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Appendix 5 – List of Acronyms used

AOC Area of Concern AOO Algonquins of Ontario AWS Annual Work Schedule CFSA Crown Forest Sustainability Act CTC Critical Thermal Cover FMP Forest Management Plan FMPM Forest Management Planning Manual FOIP Forest Operations Inspection Program FOP Forest Operations Prescription FRI Forest Resource Inventory FTG Free-to-grow GIS Geographic Information System GPS Global Positioning System LCAC Local Citizens’ Advisory Committee MHLUP Madawaska Highlands Land Use Plan NRVIS Natural Resource Values Information System OFRL Overlapping Forest Resource Licensee OMNR Ontario Ministry of Natural Resources OVFI Ottawa Valley Forest Inc. PDAIP Preliminary Draft Agreement-In-Principle RPF Registered Professional Forester SGR Silviculture Ground Rule SAR Species at Risk SFL Sustainable Forest License SFMM Strategic Forest Management Model SSG Forest Management Guide for Conserving Biodiversity at the

Stand and Site Scales

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Appendix 6 – Audit Team Members and Qualifications Craig Howard, R.P.F., CEA (SFM) – Lead Auditor Education: B.Sc. Forestry, University of New Brunswick, 1983. Experience: 30 years’ experience in forestry, 16 years in private practice, 3 years in

the OMNR. Previous Audits: 26 Independent Forest Audits, 16 Sustainable Forest Initiative

verifications, 19 Forest Stewardship Council assessments. Mark Leschishin, R.P.F – Forester Education: B.Sc. Forestry, Lakehead University, 1978. Dip. For. Tech., 1974. Experience: 34 years experience in forestry in Ontario. Previous Audits: 30 Independent Forest Audits, one Forest Stewardship Council

assessment. Tom Clark – Ecologist Education: M.Sc., H.B.Sc. Experience: Forest ecologist and biologist with 32 years experience in habitat

ecology. Previous Audits: 31 Independent Forest Audits, and numerous Forest Stewardship

Council assessments and audits. Phil Shantz – Socio-economist Education: M.E.S, R.P.P. Experience: Registered professional planner with 20 years experience in forest

auditing/certification, resource and socio-economics, environmental assessment and public consultation.

Previous Audits: 18 Independent Forest Audits, 15 Forest Stewardship Council assessments.

Brian Callaghan, R.P.F. – Forest Management Planning Analyst Education: B.Sc.F., University of Toronto, 1982. Experience: 31 years experience in forestry in Ontario. Previous Audits: 28 Independent Forest Audits, 60 Sustainable Forest Initiative

verifications, 30 Forest Stewardship Council assessments.

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Appendix 7 – Trend Analysis - Year 10 Annual Report

YEAR TEN ANNUAL REPORT for the

Ottawa Valley Forest Plan Period 2006 to 2011

Ministry of Natural Resources Pembroke District, Southern Region Ottawa Valley Forest Inc.

for the year April 1, 2010 to March 31, 2011 This document can be found on the OMNR website: http://www.mnr.gov.on.ca/ Search: OMNR: Forestry: Forest Management Plan: Find a forest management plan: Forest Management Unit Ottawa Valley Forest 780: Annual Report 2010-2011: Annual report text