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Canadian Forest Service

Comments on Canada's Forests at a Crossroads: An Assessment in the Year 2000

Anthony C. Janetos
World Resources Institute
10 G Street
Washington, D.C. 20002
USA

Dear Dr. Janetos:

My staff has revised the Global Forest Watch Canada's report entitled Canada's Forests at a Crossroads: An assessment in the Year 2000.

From a Natural Resources Canada, Canadian Forest Service perspective, the GFW Canada report is mostly accurate and well documented. For the most part, the statements in the report are substantiated. However, I would like to forward my comments on some elements of the report that does not reflect Canada's achievements, namely:

  • the role of Canada's forests in mitigating climate change;

  • job and wages;

  • Canada's performance regarding biological diversity;

  • First Nations forestry program; and,

  • National and Provincial Legislation.

The attached annexe summarizes our comments regarding the above-mentioned issues. I would appreciate it if these comments can be posted on your web site along with our initial input as discussed between our respective officials.

I am looking forward to continue working cooperatively with the World Resources Institute on issues of international interest.

Sincerely,
Original signed by

Jacques Carette
Director General
Policy, Planning and International Affairs

NATURAL RESOURCES CANADA
CANADIAN FOREST SERVICE

Canada's Forests at a Crossroads: An Assessment in the Year 2000
an Initiative of the World Resources Institute

KEY FINDINGS

Note error on page 11: A52 percent of forests are managed as logging tenures." Actually, 28% of Canada's forests are considered managed under some form of tenure agreement. Of Canada's 417 million hectares of forest, 234 million hectares are considered "commercially productive". Of this 234 million hectares, 119 million hectares are "managed". This 119 million hectares translates into 28% of the total forest area (not 52%).

SECTION 2. INDICATORS OF FOREST CONDITION AND CHANGE

Forest Condition

Box 3 - the role of Canada's forests in mitigating climate change

Paragraphs 2 and 3 are misleading. While the first statement is correct (i.e., it is unclear whether Canada's forests are a sink or a source), the two estimates provided by GFW to prove their point are not, in fact, comparable. The estimate for Canada's forests submitted to the UNFCCC greenhouse gas inventory is for CO2 emissions/removals related to anthropogenic activities, i.e., this includes only the "managed forest" and excludes wildfires. On the other hand, the estimates that they cite based on the carbon budget modelling work done by CFS scientists are for the entire forest, and include noncommercial forest areas as well as emissions from wildfire. The data presented are correct, but the reasons for the differences between them are not given, and the inference is, therefore, that the Canadian government in its submission to the UNFCCC (that shows Canada's forests as a net sink) was not using the data of its own scientists that show Canada's forests as a net source.

SECTION 3. THE FOREST INDUSTRY

The Economic Value of the Forest Industry

Indicator 1: The Economic Value and Indicator 2: Global Export Ranking

Apart from the incorrect dollar value conversions from Canadian to US dollars (i.e., the GFW Canada report seems to be using an incorrect annual average exchange rate that underestimates the true values in US dollars), all of the statistical information on the economic value of the forest industry and the global export ranking is accurate.

Indicator 10: Jobs and Wages

Indicator 10 describes the level of forest sector employment, earnings, forest-dependent communities, and the ratio of jobs per harvested timber (often used as an employment intensity indicator).

The GFW Canada data and statements on the levels of employment and forest-dependent communities are accurate and consistent with NRCan and Statistics Canada assessments. As for the information presented on employment earnings, which is accurate, there are errors in their analysis that result in inaccurate comparisons between the forest industry and average Canadian earnings. For example, the GFW Canada report draws comparisons of earnings from two different sources, PricewaterhouseCoopers and Statistics Canada. Statistics Canada reports Canada's average earnings less benefits; however, the PricewaterhouseCoopers forest industry earnings includes wages plus benefits. Comparing these two very different estimates results in an inconsistent assessment. Statistics Canada reports average earnings in the forest industry on a consistent basis with average Canadian earnings. NRCan identified this inconsistency during the external review process of the draft report.

Furthermore, the statement "Logging generates over $15 billion in wages and benefits in 1998" is incorrect. The statement should have read "Canada's forest industry generates over $15 billion in wages and benefits in 1998." Logging accounts for a very small subset of the total industry earnings.

SECTION 4. COMMITMENTS AND LEGISLATION

International commitments

It is true that Canada is a Party to some 230 international agreements. However, the wording of the second sentence suggests that all or most of these agreements deal with forests which is inaccurate. The juxtaposition of the first and second sentence of the first paragraph is misleading.

While the number 230 may be accurate, it is important to note that it includes both binding and non-binding instruments. Forests, because of their omnipresence, may be of interest in a number of these agreements, but are not necessarily the key drivers. As indicated in paragraph 2.36 of the OAG's 1998 Report, < The subject of the largest number of our international agreements is fisheries and ocean issues...>. There are approximately 40 international arrangements, mechanisms and organizations that Canada belongs to, with both binding and non-binding provisions, of interest for forests.

Although it is a signatory to the CBD, nothing in the Text of the Convention creates obligations for Canada, or any other Party, < to protect its biological resources and respect Aboriginal rights > as stated in the WRI/GFW report. Such a statement is somewhat misleading because it needs to be examined within the appropriate context. As illustrated below, the objectives of the Convention are much broader than the restrictive description provided in the report.

Article 1 B Objectives

The objectives of this Convention, to be pursued in accordance with its relevant provision, are the conservation of biological diversity, the sustainable use of its components and the fair and equitable sharing of the benefits arising out of the utilization of genetic resources and by appropriate transfer of relevant technologies, taking into account all rights over those resources and technologies, and by appropriate funding.

Based on the above, the CBD is not dealing with < protection > but rather with < conservation, sustainable use and, fair and equitable sharing of benefits >. Implying that the CBD is concerned only with protection is not only misleading, it is inaccurate.

The CBD also calls upon Parties to < take into account all rights > but WRI /GFW fails to specify that this is in the context of national legislation. With specific regard to Article 8 (j), the CBD calls upon Parties to < respect, preserve and maintain knowledge, innovations and practices of indigenous and local communities >, subject to national legislation.

While it is recognized that numerous issues need to be addressed domestically with regard to aboriginal rights, further clarification by the courts is required with regard to such matters as the definition and scope of aboriginal rights. Other answers will likely come from international arrangements and mechanisms (both existing and future).

The report remains silent on a the contribution of the First Nations Forestry Program to advance traditional knowledge in the context of the CBD. A report, entitled Traditional Ecological Knowledge within the Government of Canada's First Nations Forestry Program was prepared in response to a request from the Biodiversity Convention Office of Environment Canada for case studies on the implementation of Article 8 (j) of the CBD. The report was tabled at the third meeting of the Intergovernmental Forum on Forests (IFF3) in May 1999.

Under the Convention, Parties are committed to meeting the Convention's objectives, as stipulated in Article 1 of the Convention. The fulfilment of these objectives is facilitated by implementing the provisions of the various articles of the Convention. In most cases, the wording calls for States to < as far as possible and as appropriate > carry out relevant actions.

Canada is indeed an active promoter of an international forest convention and is proud of its role in advancing the international dialogue on forests. There is, however, a statement that must be corrected in the WRI/GFW report, relating to the Costa Rica-Canada initiative (CRCI). While the CRCI was designed to support the work on Category III of the IFF, it was not designed nor conducted < to build global support for a forest convention >.

The CRCI was a neutral, transparent and participatory process designed to provide experts from all regions of the world the opportunity to hold technical discussions on the relative merits and options of future arrangements and mechanisms for the sustainable management of all types of forests. In that sense, it provided the IFF, and all participants to the CRCI regional and expert meetings, with a better understanding of the issues at hand. This improved understanding was, in Canada's view, a prerequisite for meaningful discussions within the IFF.

When looking at the implementation of global commitments, the WRI/GFW report states: Canada will not meet its commitment to curb greenhouse gas emissions.

The fact that Canada and most other nations did not meet the commitments made in Rio is hardly a new concept. In fact, Canada and other countries came to this realization a while ago and decided to take action. This led them to negotiate the Kyoto Protocol, in order to address the issue of greenhouse gas emissions head-on. The report remains silent on the Protocol and its follow-up.

On the domestic scene, Canada initiated the National Climate Change Process (NCCP) in early 1998. This broad, inclusive consultation process is designed to help Canada determine options for achieving the targets set in Kyoto. The report also remains silent on this Canadian initiative.

As for the fact that Canada will miss its stabilization target for the year 2000 by at least 11 percent, this is not news and has been known to Canadian authorities for a long time.

Canada has no overall strategy for implementing its Biological Diversity Strategy.

This comment does not recognize the work carried out by the federal and provincial governments since the publication of the report of the Commissioner of the Environment and Sustainable Development cited here.

The Canadian Biodiversity Strategy released by federal, provincial and territorial governments in 1995 points out that legislation is an important component of an overall approach to conserve biodiversity and ensure the sustainable use of biological resources. Federal, provincial and territorial governments have enacted numerous acts and regulations that affect biodiversity, including:

  • the Canada Wildlife Act and the provincial and territorial wildlife acts;

  • provincial endangered species acts;

  • the National Parks Act and provincial parks, wilderness and ecological reserves acts;

  • federal and provincial environmental protection acts;

  • the Migratory Birds Convention Act;

  • the Fisheries Act;

  • the Wild Animal and Plant Protection and Regulation of International and Interprovincial Trade Act;

  • the Oceans Act;

  • provincial forest acts;

  • the Environmental Assessment Act; and

  • provincial land use planning acts.

In some cases, municipalities protect biodiversity locally, primarily through the use of local planning and municipal zoning laws.

Moreover, Canada submitted its national report to the Secretariat. In fact, Canada was implementing the provisions of the CBD before it even existed. Action plans have been developed in forestry, wildlife, agriculture and protected areas. Aquatic biodiversity is currently being developed.

National and Provincial Legislation

Under the heading INITIATIVES, the authors made an error when discussing Canada=s National Forest Strategy. In the report, it is mentioned that the 1992 National Forest Strategy is the first strategy. In fact, Canada's first strategy was developed in 1981 and was entitled A Forest Sector Strategy for Canada, followed by a National Forest Sector Strategy for Canada's in 1987. Then, the 1992 and 1998 National Forest Strategies would be third and fourth.

Under the heading VOLUNTARY INITIATIVES, reference is made to two certification processes, i.e. CSA and FSC. The authors made reference to the number of hectares certified to FSC. Similar information should have been made for the CSA system. Actually, there are two forest companies that have their forestry operations CSA certified, corresponding to about 480,000 hectares of managed forests (250,000 hectares certified in May 1999 and 230,000 hectare certified in December 1999).

In addition, the report only provide criticisms about the CSA system. No criticisms are offered regarding FSC. Furthermore, the report forgot to mention that a number of companies have been certified under the International System Organization, i.e. ISO 14001 on forestry operations. It is important to note that closed to 12 millions of managed forests, or or 10% of managed forests, are currently certified ISO in Canada.

SECTION 5. CONCLUSION B DATA GAPS AND NEEDS

This section presents an account of the data challenges that any organization faces in compiling a report like this. GFW stresses that data costs impose real limitations to environmental reporting, particularly the high costs associated with government "cost-recovery" policies. The report includes a statement that government cost-recovery policies are now being questioned from within. It refers to a report by three CFS scientists, "Report on Spatial Data in the United States Government and Recommendations for Natural Resources Canada," available on the Pacific Forestry Centre Web site. The WRI/GFW Canada report does not acknowledge the high costs to public or private agencies of acquiring data through field work, remote sensing or other means.

APPENDIX 2. REVIEW PROCESS

The acknowledgement under Government should read as follows: Natural Resources Canada/Canadian Forest Service(Jacques Carette, Claude Léger).

The name of Peter Hall should be deleted since he is an employee of the Canadian Forest Service.

Under other Forestry and Ecology Experts, I would appreciate if the affiliation of Jim Ball should be specified instead of using "former CFS".

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