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Comments on the factual accuracy and science-based information of the draft report of the World Resources Institute / Global Forest Watch Canada entitled Canada's Forests in the Year 2000

General comments

The report generally has an alarmist air about it which does not support GFW's upfront statements in which say they adhere to "transparency", are "non-partisan" and are a "non-advocacy" organization. In other words, the report does not support the organization's stated objectives. Readers of this report will have no alternative but to conclude that GFW is of the activist mindset.

2. This impression of alarmism stems from a variety of elements within the report. First, there seems to be an over abundant use of descriptive phrases and adjectives. These occurrences are so frequent that it is not practical to list them all. The writers should carefully reexamine their use of such descriptives and eliminate things like A... industry commonly contravening codes and laws.....(pg. 2)", A...roads, enough to cross Canada more than 7 times." (pg. 4), ... in light of these extensive developments....(pg. 5)", etc. For the most part, these descriptives are not included in referenced quotes so can therefore only be attributed to GFW's opinions. GFW could benefit itself, and support its stated objectives of providing unbiased information by providing text without the gratuitous use of these (negatively-connotated) descriptives.

3. The reader is confronted with GFW's Key Findings right up front (which is appropriate) however, these key findings are all negative with the only exception being the last point. Clearly, there are some positive aspects of forestry in Canada which can be discussed and could be used to balance these seemingly negative key findings. For example, GFW could mention Canada's National Forest Strategy up front, or the success of our Model Forests Program, or our Criteria & Indicators initiative progress, or the industries that have changed their practices to the extent that they have attained (or are very close to attaining) certification, or the increase in new protected areas, or the globally-recognized consensus-building approach to decision-making Canada takes, or our internationally-recognized progress toward sustainable forest management, or the First Nations Forestry Program, or the National Forest Science and Technology Network, and so on. This up-front, negative key findings immediately sets the alarmist tone for the remainder of the report and is virtually impossible to shake.

4. The entire GFW report is in need of a complete rethink and rewrite. I don't feel it is within our (CFS's) mandate to provide revised or new text for this report, except where outright errors are evident. But again, the referenced fragments that are presented and which fall within the purview of CFS are, for the most part, not incorrect, perhaps just badly chosen and presented out of context. GFW has the task now of deciding whether they wish to present an objective report.

The report appears to be very thorough in terms of the information used. It appears well referenced and, even though we did not verify every single one, our sense is that they are likely factually correct. Our discGFWort is not with the facts used but rather the way they are portrayed as well as what is not included. As a report that purports to capture the state of Canada's forests, the focus is entirely what is wrong, giving the reader the impression that nothing is right! The persistent use of the word "control" in the context of forest leases to forest companies belies the reality that governments in Canada retain control and exercise that through policy and legislation. It is these policies that provide access for the multitude of users of the forest that is not reflected in the broad scale maps (eg: Figure 16) that exclude parks, large lakes, wildlife management areas, remote tourism reserves, protected areas, modified management areas, etc. The real picture of Canada's forests is one of transition from a largely unpopulated expanse of endless trees of 100 years ago, to one of managed diversity that will support the economic, environmental and social expectations of over 30.0 million people with no recipe book to follow.

Although referenced statements are used throughout the report, they are misused in many instances. One cannot dispute the statements GFW has included (since they are referenced) but what GFW has done is taken a mish-mash of statements (all referenced), left out the preceding or following contextual statements that were often part of the original discussion, and then joined these pieces together to weave a frequently skewed message. The data are accurate. Most are from published sources. There has been some new analysis of remote sensing data to characterize Canada's forests and changes from historic condition (e.g., the level of forest conversion described in the section on p. 6, "Are Canada's forests at risk?")

While the report provides a reasonable assessment of Canada's forests, some of the conclusions are based on inconsistent data comparisons, or incomplete information. It actually adds new information, and does not just rehash old information. It also provides good detailed technical summaries on the analyses carried out.

In recognition of the origins on the vast majority of Canada's forests, there should be stronger emphasis on the disturbance regimes and the role they play----fire, insects, disease and harvestBand their inter relationships.

The view of history presented has an editorial edge to it that seems to place the blame for all and any forest problems on harvesting. Historically the first clear cutters were settlers making way for farms , which made way for settlements and towns. The implication that forest management cannot be sustained in the boreal forest because Canada Land Inventory (CLI) said so is not acceptable. I suspect that the same CLI would propose limited capacity for certain species of wildlife on these areas that are in fact being managed to sustain certain wildlife. Therefore, a legitimate criticism might be the lack of a national ecosystem classification system, but drawing conclusions from CLI does not present an accurate picture.

10. The report does not take into account program activities being pursued by the Waswanipi Model Forest, which tries to find solutions to balance forest harvesting and the traditional usage by the Cree community.

There is little positive recognition of the progress being made by industry in taking on responsibilities and costs for sustainable forest management and the myriad of regulation that governs its activity.

Key Findings B bullet 4: the conclusion that "remnant forests that continue to be lost are some of the most endangered in Canada and home to many of Canada's endangered species" is not supported by any data or analysis in the report.

Some conclusions are based on flawed or inaccurate data, such as Key Findings B bullet 7 and bullet 13 (see Appendix 1).

14. Incomplete and/or inconsistent data sources are used in a number of places (Appendix 1, information description #6, #13 and #14).

Industry data on the value of forest products, employment trends and jobs per harvest is from PriceWaterhouseCoopers information instead of Statistics Canada and thereby underestimates the benefits from Canada's forest sector (Appendix 1, information description #4, #5, #9, #10, and #11; and Appendix 2).

Conclusions drawn from comparing data from different sources of information are misleading (Appendix 1, information description #3 and #12).

Some of the information for Canada's forest land base is drawn from Canada forest Inventory (CanFI), and some is from the Canada Land Cover Map interpretation and overlays carried out by GFW and CCRS. In some cases (e.g., p. 18, Who controls Canada's Forests?), the percentages of ownership refer to the CanFI forest land base of 417.6 million ha, not the 422 million ha used by GFW.

The Indicator sheet 5 for Figure 5 (Ecological Limitations to Commercial Forestry in Canada) is missing (or rather, the wrong one is supplied). The one supplied is identical to Indicator Sheet 7 (for Figure 16).

Specific Comments

What is the extent of logging in Canada?

The major problem with this section is the implication that the entire cumulative area of logging in Canada has resulted in an equal area of non-stocked forest land. Most of that area has, of course, been regenerated over the years. There is an element of double and triple counting in statements such as "Three provinces have logged a substantial portion of their productive forest land over the 22 year period: New Brunswick logged one-third; ..." Especially in the Maritimes, sites are revisited to harvest different species. The net effect is a significantly smaller area subjected to logging in any given multi-year period. Unfortunately, the data available to us do not permit a more exact account of the extent of logging.

Are Canada's forests regenerating adequately?

CFS has updated data available on the status of regeneration for the period 1975B1997. These data indicate that the accumulated backlog of understocked cutovers peaked in 1992 at almost 2.7 million ha. By 1997, the accumulated area of understocked cutovers had been reduced to just under 2.4 million ha. These data will be published in the C&I 2000 report.The data presented in Figure 12 were taken from "The State of Canada=s Forests 1997B1998."

Legislation in Alberta also requires that every cutblock (i.e., every "logged area") is surveyed after a prescribed number of years to confirm its regeneration status.

What is happening to wildlife?

This section could stand some reorganization. The subsection on Forest Birds is mostly devoted to a discussion of fragmentation, with references to fish and mammals, but not birds. There is also a typographic error in the period "19966-1979" in this section.

Has Canada protected its forests?

This section draws heavily on the recently released WWF Canada report, "Canada's Commitment to Forest Protected Areas", which is also well formulated and draws on data not accessible to CFS. This is also true of Figure 14, "How much of Canada's forested natural regions have been protected?" No problems with these.

Are First Nations Benefitting from Forest Developments?

Regarding the statement made on page 15, it is important to note that percentage of aboriginals working in the forest industry is to be applauded, compared to the early 1980's/1990's. The percentage will likely increase in the future.

Concerning the statement on page 16, that aboriginals have few tenures in Canada, it should be referred to "few forest land tenures". In addition, it also should be noted that partnerships between Aboriginals and forest industry is increasing.

Are First Nations Treaties Being Respected and Implemented?

For Treaty 6 area, which cuts across Saskatchewan and Alberta, discussions began in 1998 to reach a shared interpretation of the original treaty, as a step towards renewing the Treaty relationship between Treaty 6 Nations and the Crown.

Have Land Claims Been Settled in Forest Areas?

Suggested additions, as a second paragraph.: "A final agreement has been reached in 1999 with the Nisga'a nation, in British Columbia, on the terms of a Treaty. Enabling legislation to ratify the Treaty is now before the federal Parliament. Currently, 51 First Nations representing 70% of the First Nation population in British Columbia are negotiating treaty terms with government. Of these, three are in the early stages, ten are negotiating framework agreements, thirty-seven are negotiating agreements-in-principle, and one, the Sechelt, is negotiating a final agreement". (Source: NRCan, Canadian Forest Service: State of Canada's Forests 1998-1999)

Will Court Decisions on Aboriginal Rights Affect Canada's Forests?

Among the list of four court decisions, I suggest deleting reference to the Paul decision (1997), as it was overturned by the Court of Appeal; and it was effectively subsumed by the Marshall decision (1999), that is already in the list.

The coverage of Saskatchewan doesn't really do justice to a number of changes that they have recently made in terms of providing economic development opportunities to aboriginal people.

Who Controls Canada's Forests?

Responsibility for management of natural resources on much of the 23% of forest land under federal "jurisdiction" has been transferred to the territorial governments, with devolution to the Yukon Territory to be finalized in the near future.

The point made in this section is very allusive. On one hand GFW Canada seems to be critical of the reduction in numbers of sawmills, which presumably reflects increased productivity and efficiency, while overall production has increased at a rate of only 0.5%/yr. Is this merely a background "fact"or is there some implied criticism?

What is happening to forest jobs in Canada?

As stated in the 1998-1999 State of Canada Forests report, the number of workers in the forest sector has increased for the seventh consecutive year since the 1991 recession, reaching a 10-year high. Employment in the paper and allied industries sector increased in 1998, recouping the jobs lost during the two previous years. The forest sector has not returned to pre-recession employment levels. Logging industry and forestry services employment levels tend to fluctuate from year to year; the losses in one year often regained in the following year, with the result that the number of jobs in these sectors was the same in 1998 as it was 10 years ago. The past decade has seen employment gains in the wood industry more than offset losses in the paper and allied industries, for a total increase of 26,000 jobs in the forest sector. Direct and indirect employment in the forest sector accounted for 1 in every 16 jobs in Canada in 1998.

Is Canada Honouring its Forest Commitments?

This section does not adequately balance Canada's progress towards its commitments with the negatively-toned deficiencies GFW decided to highlight. Example: the first bullet in the "Reforms" section Cthe 1992 and 1998 Forest Accords go far, far beyond "...committing the entire country to changing its forest policies." And the second bullet C the two most recent NFSs are much more than described in the GFW report. What about the "national vision" aspects? the consensus-based approach to their development? the 42 signatories? etc.

The way the bullet is written it leaves the distinct impression that Canada had abysmal forest management policies and practices that were only somewhat adjusted (and under protest) as a result of the NFS; and that the Canadian forest community have begrudgingly moved from no public involvement in decision making to merely symbolic participation.

In the tables at the back of the report, there is a Table 5 which is comprised of only 5 of the actual 6 Criteria in Canada's domestic C&I framework (Criterion 2 is missing). But nowhere in the body of the report, i.e. on page 21, is there a reference to Table 5. If the table is to be corrected and included in the report, it should be referenced somewhere around reference #133 in the text.

In the last bullet on page 21: the NRTEE is not a federal agency. It is an independent agency that the Prime Minister prompted into existence (read: federal leadership) to "play the role of catalyst in identifying, explaining and promoting, in all sectors of Canadian society and in all regions of Canada, principles and practices of sustainable development." GFW may wish to refer to NRTEE's web site for accurate information: www.nrtee-trnee.ca.

It should also be noted that provincial Premiers established provincial round tables on the environment and the economy.

Is the Federal government upholding its national responsibilities?

Concerning paragraph 5, there is no correlation as the report claims between staff reductions at Environment Canada and the department's activities of moving toward voluntary compliance of environmental laws.

Has Canada kept its global promises?

Although Canada is a signatory to the Convention on Biological Diversity, nothing in the Text of the Convention creates obligations for Canada, or any other Party, < to protect its biological resources and respect Aboriginal rights >. Such a statement is both misleading and inaccurate. As illustrated by the following, 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 provisions, 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.

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 may very well be a signatory to some 230 international agreements, but it is misleading to state that all these agreements are dealing directly and specifically with forests.

The statement < no independent assessment of Canada's ability or willingness to fulfill these agreements has yet been done > may be true but does not mean that nothing is being done in Canada. It is therefore somewhat misleading.

When looking at < five key agreements > the report is once again misleading:

_ Canada and other countries have recognized that targets orginally set for reducing greenhouse gas emissions will not be met. These same countries have, however, developed the Kyoto Protocol, in order to address this issue head-on. The report remains silent on the work and follow-up to Kyoto.

_ Canada is depicted as having < 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 Environement and Sustainable Development cited here. Morever, the nature and magnitude of actions undertaken by the various Canadian stakeholders does not necessarily require an overall strategy to be efficient and relevant.

_ The comment that < poor enforcement of national environmental laws may violate several international agreements including the North American Free Trade Agreement > is misleading. Firstly, Canada has committed to the effective enforcement of its environmental laws under the North American Agreement on Environmental Cooperation, not the North American Agreement on Free Trade. Secondly, the sentence is postulated as a possibility, not a fact, and it will remain hypothetical for as long as it is proven otherwise.

Furthermore, this excerpt is from the third report of the STANDING COMMITTEE ON ENVIRONMENT AND SUSTAINABLE DEVELOPMENT, entitled ENFORCING CANADA'S POLLUTION LAWS: THE PUBLIC INTEREST MUST COME FIRST!, issued in May 1998. The focus of this report is on the effectiveness of enforcing federal environmental laws (i.e., CEPA and the pollution prevention provision of the Fisheries Act). The report makes several recommendations to improve the enforcement of these statutes.

In addition, the footnote to this statement makes reference to 2 different submissions to the Standing Committee. One of the submissions (SEM-98-004) relates to the enforcement of the Fisheries Act and the need to ensure the protection of fish from the impact of mining in BC. The other reference SEM-97-001 relates to the enforcement of the Fisheries Act and the need to ensure the protections of fish in BC from the effects of hydro-electric dams.

GFW's "key finding" is that it is somewhat removed from the forest. Unfortunately, it is difficult to see how GFW establishes the link of this "key finding" back to forests.

_ Softwood Lumber Agreement. "The SWLA may violate the US National Environmental Policy Act. US environmentalists argue that the act promotes "intensive logging in Canada at higher than sustainable levels."

How and whether the SWLA violates US legislation is an issue for the US. The suggestion that the SWLA dictates the amount of the allowable cut is absurd. Trade is not a factor in the development of forest management regimes for Canada and has no effect on environmental policy or management practices in the Canadian forest sector.

Is industry upholding forestry laws?

Regarding paragraph 3, while the comments are supportive of the AFPA's Forest Care Program, GFW would have to review all the companies in Alberta who are not part of ForestCare Program relative to those that are in order to determine just how more effective the standards of Forest Care members are relative to industry non members. The Alberta government and forest industry should be consulted on this matter.

Does Canada assess the environmental impact of projects in forests?

Paragraph 1 is incorrectly stated. Invocation of CEAA does not lead to assessment of logging operations. Indeed the recent court cases have confirmed this . . . that is, under CEAA the scope of project assessment does require the assessment of logging operations but simply the areas pertaining to federal interests. This paragraph must be deleted or revised in keeping with the above.

GFW second paragraph flows from the wrongly premised logic of the first paragraph and equally should be revised as Tolko is not indicative of any reluctance to invoke CEAA to assess logging operations. Admittedly there has been only one CEAA assessment of a bridge at this time but that will increase as more federal permits are issued triggering CEAA in keeping with the company's implementation of its forest management plans. Also, the last sentence of this para is inaccurate.

The Government of Canada has not opposed legal action to expand its assessments but has merely requested the courts to confirm interpretation and application of CEAA provisions respecting scope of project and assessment.

The last sentence of paragraph 3 regarding Manitoba's Future Forest Alliance, should be deleted as this is not true, the suit has been withdrawn.

Has Canada met its obligations to Aboriginals in the forest?

Regarding the first paragraph, I suggest relacing the second sentence Measuring progress ... with the following:

Measuring progress in this area however is difficult due to newly affirmed Aboriginal and Treaty rights (Supreme Court of Canada decisions in Delgamuukw (December 1997) and Marshall - (Fall 1999), different interpretations given to those decisions, and resulting differences of views on how those rights will be exercized.

Concerning the list of positive developments, I recommend to add :

i) third point, about cooperative management agreements in two of the territories, add: as part of land claims settlements.

ii) fourth point, about court decisions in B.C. and New Brunswick: the statement to the effect that these (unidentified) decisions "suggest that Aboriginal peoples have the right to log on Provincial crown land despite provincial legislation" is erroneous. It is also out of date given that Supreme Court of Canada decisions in Delgamuukw (December 1997) and Marshall (1999) together reaffirmed the existence of Aboriginal rights to lands and resources while recognizing that those rights have yet to be defined in practice, and issued guidance to governments and Aboriginals in their efforts to define the extent of those rights.

iii) the fifth point, refering to Saskatchewan's new forest management act, should be supplemented by the following sentence: In northern Saskatchewan, co-management agreements between lumber & paper producers and Aboriginal communities are common practice.

iv) penultimate paragraph - last sentence: beginning with "A 1999 Ontario study reported ..": suggest checking the reference to verify the scope of the study and to ascertain the basis for stating "some First Nations report that the situation has worsened".

5. last paragraph: Both sentences refering to the Senate sub-committee on the Boreal Forest are erroneous and misleading. The quotes "for the most part fallen on deaf ears" and "buck-pasing between the federal and provincial governments on this issue has been the order of the day" are attributed to the Senate sub-committee itself, whereas they are taken from the statements made by a P. Smith, appearing before the sub-committee on behalf of the National Aboriginal Forestry Association, on April 10 1997, as per the footnote in that report.

Annexes

On page 34, foot note # 90, the web site address should read: http://www.fnfp.gc.ca

On page 36, foot note # 134, the web site address should read: http://www.nrcan.gc.ca/cfs/proj/ppiab/sof/common/latest.shtml

Figure 15 - Aboriginal Treaties, Settlements and Land Claims and Major Industrial Developments

The delineation of area #10 includes the entire area claimed by the Cree, which extends much further north than the cationned "clearcut logging". The shaded area on the map should be reduced to reflect this.

Table 6 - Progress on National Canadian Commitments

CEAA - Assessment Box: The Auditor General (Commissioner of the Environment and sustainable Development) alledged comments re logging roads are not accurate. It would be appropriate to say: " Logging roads and pulp mills particularly are assessed. The former are undertaken under provincial Environmental Assessment (EA) regimes, the latter can be joint federal - provincial EAs or by one government or the other ". It would be appreciated if GFW could substantiate those instances where this is not the case.

On second point referring to uncertainty, there is no uncertainty about jurisdiction. Each level of government carries out its EA in keeping with roles and responsibility. Federal intrusion into provincial jurisdiction would not necessarily safeguard EA standard as GWF implies given that provinces have their expertise in their area of responsibility which the federal government does not have which is why Canada's EA duties are shared.

There are no marked EA deficiencies and GWF should substantiate those in support of their claim. 

Endangered Species Protection Act: GWF's claim of 15% growth in decline of species is inaccurate. This may be the case for all species across the world but not in Canada. This sentence should be deleted. Moreover, what are is being counted in species at risk: endangered, threatened, vulnerable, extirpated ? - need to substantiate. Moreover, decline in species is not always directly linked to habitat destruction as the report claims.

GWF's claim about earlier Endangered Species legislation is also incorrect. The legislation did protect habitat. The opposition of the 600 scientists should be explained in context . . . they objected that science decisions about species should be subjected to policy considerations by government. It is worth noting that many scientists also approved the government's earlier legislation.

Fisheries Act: The issue of funding enforcement is currently under review and expected to be strengthened as elements of the Fisheries Act is streamlined and delegated to the provinces which will result in savings due to their proximity to the fisheries landscape.

Canadian Council Ministers on the Environment (CCME): The commitment box should be rewritten, the objective of CCME is to promote coordination. The "impact on Forests Box" should also be re-written to substantiate which agreements affect forestry. As yet, there is no CCME monitoring agreement which is in process of development and about which I assume GWF is referring.

On the Assessment Box, GWF should note that CCME ministers met recently with 5 First Nation Organizations to discuss Protocol of Understanding on how First Nations will participate in environmental harmonization initiatives. On the issue of CCME failing to document evidence of overlap and duplication, this is currently being undertaken by the CCME to respond to concerns of select parties that want to see duplication as a means to ensure federal oversight. And finally, the CCME Accord and sub agreements, provide for a public \ stakeholders review after 2 years (January 2000 ) to assess performance. This should be mentioned.

Table 7. Progress on International Commitments

The header of the second column has nothing to do with < commitment >; it is rather the objective of the agreement listed in the first column.

With regard to CBD, the second column is grossly truncated and is therefore misleading. The CBD=s objective is much broader than indicated, and should be reworded as follows :

"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".

Response to Assessment section:

The report of the Commissioner of the Environment and Sustainable Development is now almost two years old. The follow-up to the Biodiversity Chapter will appear in the May 2000 report of the Commissioner. Federal implementation plans in response to the Canadian Biodiversity Strategy are nearing completion. Implementation plans have been completed for Wildlife, Protected Areas, Agriculture and Forestry. In fact the Canadian Forest Service was one of the first federal agencies to release its action plan entitled " Biodiversity in the Forest - The Canadian Forest Service Three Year Action Plan - Implementing the Canadian Biodiversity Strategy." This plan was published in 1997. The Canadian Forest Service also contributed to the implementation plans for Wildlife and Protected Areas.

A final report on Ecological Management, scheduled for release in the Spring will address cross-sectoral science and integrated planning. The federal government is currently developing a performance measurement framework for reporting on progress in implementing the Canadian Biodiversity Strategy. Canada is also one of eight countries working with the World Conservation Monitoring Centre to develop a framework for national reporting on implementation of the Convention. Canada has also shown leadership in advocating a more active role for Indigenous organizations and was recently commended by the Secretariat for work undertaken in Canada to engage Indigenous communities.

North American Agreement on Environmental Cooperation:

The GFW report has attributed statements made in a Parliamentary Standing Committee on the Environment and Sustainable Development Report (on a broad enforcement review) to the NAAEC, making incorrect conclusions about the Agreement's provisions.

Canada has committed to the effective enforcement of its environmental laws under the North American Agreement on Environmental Cooperation (not the North American Agreement on Free Trade). The process by which citizens can make citizen submissions to the Secretariat on enforcement matters under the Agreement (Article 14) in the event that they feel that a Party is failing to effectively enforce its environmental law is a way to inform Parties of the public's views on their performance. The Secretariat may then request a response from the Party named in the submission, including the preparation of a factual record.

To date, citizen submissions on enforcement of Canadian federal environmental legislation has only been made with respect to habitat provisions of the Fisheries Act. Under the NAAEC, the public does not render a judgement or deliver sanctions for <regulatory negligence>.

International Covenant on Economic, Social and Cultural Rights (1976)

Impacts on Forests, Eighty percent of Canada=s Aboriginal communities, not "people", are located in forested areas.

Assessment:

In 1998, a 5 year action plan titled "Gathering Strength - Canada's Aboriginal Action Plan" was released. It is designed to renew the relationship with the Aboriginal people of Canada with particular attention being paid to their unique needs and circumstances. The partnerships envisaged in this action plan are broadly based and provide for the inclusion of all Canadians, including various levels of government and the private sector. Attached to the plan is a budget of approximately one billion dollars.

Table 8 - Contravention in Alberta

Table 8 would benefit from explanations of some of the violations. In some cases, companies receive permission to depart from the forest management plan but fail to follow up with the paperwork to the government and are fined because there is no paper trail. GFW should consult the Manitoba Government and forest industry on this matter.

Fragmenting the forest of the Western Canadian Sedimentary Basin

The case study appears to draw heavily upon a recent detailed report from Alberta Environmental Protection that discussed the degree of intrusion of roads, seismic lines, pipelines, powerlines, etc. into Alberta's boreal forest. The text for this case study implies that a new "analysis of these linear access features was completed" as part of the present GFW report, and that GFW's analysis was "the first of its kind in Canada". This is clearly not the case. GFW appears to have done some additional analysis (e.g., for northeastern BC), and may also have replicated work done in the earlier study, but the Alberta Environmental Protection report clearly preceded the GFW report and addressed the same topic.

The Sunpine Forest Management Agreement Area, Grizzly Bear and Other Species

The primary discussion is on the impacts of fragmentation on grizzly bear, but at the end of the text there is reference to woodland caribou, wolves, bull trout, and forest birds. The conclusion that each "species" has unique biological requirements but "reacts adversely to increased access densities" cannot be generalized to all bird species, and should be restricted to that group of bird species that require forest interior habitat.

Restocking deficits in Saskatchewan

GFW should consult the Saskatchewan Government and forest industry on this matter.

Ontario case study on "fire disturbance and forest harvest policy

The associated text for an illustration of "clearcutting vs. fire" provides a reasonably balanced discussion of the pros and cons of many small versus few large clearcuts. However, it is somewhat limited from the perspective of "forest harvest policy". It does not address the scope for strip cuts, shelterwoods, patch cuts, and selection cuts, does not discuss the possibility of leaving residual groups of standing trees and snags in clearcuts (to mimic "fire skips" and leave habitat for cavity nesting species), and fails to note that forest fires can result in a natural "species conversion" (e.g., when a young, sexually immature conifer stand burns and is replaced by aspen, birch, hazel, etc.).

Appendix 2

Federal Data for Direct Forest Sector Employment in Canada & Job Coefficients

Source: Statistics Canada, Labour Force Survey and Canadian Forest Service

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