2007_08 CP MNR Review Summary-IGxls - OZone provided by Ontario by taoyni


									  2007-08 Caribou Final Forest Contingency Plan - MNR Review Summary                                                                                                                                                Sept. 27, 2006

Number       Reviewer   Binder    Page     Line             Topic                                                  Comment                                            Response
                        Number   Number   Number

         1 Cathy          1        iii             List of Exceptions &      A) page iii deviation new text: re „non-achievement of 80/20 standard‟ as per         -done
           Cavalier                                Deviations                comments on another area of draft contingency plan, there is no „80/20 standard‟
                                                                             in the guide, so need to revise wording e.g. don‟t need to reference that at all,
                                                                             since requirement is correctly listed after title of guide; requirement is that 80%
                                                                             planned clearcuts should be <260 ha; this is not saying there cannot be more than
                                                                             80% as using 80/20 implies B) refers to section 4.3.1, but correct section is

         2 Cathy          1        1       41-42   Background                refers to the old timber management tourism guide, which was replaced by                 -done
           Cavalier                                                          'Management Guidelines for Forestry and Resource-Based Tourism' as referred
                                                                             to on page 33; the new guide specifically refers to supporting RSAs (it is noted
                                                                             this was missed in review of draft contingency plan submission)

         3 Cathy          1        33              New Guides                A) page 33 has a new heading „New Guides‟ which was not there before – the          -done
           Cavalier                                                          Old growth policy & definitions documents are not „forest management guides‟
                                                                             as per comments on draft contingency plan, so need to revise heading B) also
                                                                             lines 3-5 would need editing as below is not just about guides C) it is unclear why
                                                                             old growth…is listed if not applicable – e.g. clearly indicate these documents have
                                                                             come out since the last plan, but they were not applied because are strategic, etc,

         4 Cathy          1        79       17     Natural Disturbance        re „inability to meet the 80/20 standard‟ - same comment as for page iii                -done
           Cavalier                                Pattern Emulation
         5 Cathy          1        82       17     Planned Clearcuts         A) line 17 refers to section 4.3.2 but the correct section is B) also as per     -done
           Cavalier                                                          comments above, there is no 80/20 clearcut rule in the NDPE Guide

         6 Cathy          1        92      3-15                              re monitoring of exception from previous plan; this section really belongs in            -done
           Cavalier                                                          section; while the exception occurred in the last plan, it is still monitoring
                                                                             of an exception to an AOC prescription; putting it at the start is confusing when
                                                                             there is also section

         7 Cathy          1        82       3      Monitoring & Assessment „2002-20022‟ FMP should be „2002-2022‟                                                     -wrong page number…assuming it is page 92. -done
         8 Chris          1                        FMP-18, FMP-19 & FMP- FMP-19 needs to use the total of the „utilized‟ row from FMP-18, as does FMP-                -As per telephone conversation with CES on Oct 14'06,
           Schaefer                                24                    24. Currently it does not and in discussions (pg 83) it looks like Ce should have            FMP-18 is correct as is, FMP-19 Part B volumes will be
                                                                         been shown as unutilized in FMP-19/24. Text reference to the results of FMP-                 changed to match "utilized" volumes in FMP-18, and
                                                                         19 on page 83, ln 38 may need to be updated if Ce is not utilized (these numbers             FMP-24 volunes are corrrect as is. Text will be revised as
                                                                         assume include Ce). Also, the text regarding FMP-24 may need to be adjusted                  required to match tables. -done
                                                                         (pg 90), and the reporting of areas/volumes in Section 4.8 (pg 95).

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2007-08 Caribou Final Forest Contingency Plan - MNR Review Summary                                                                                                                                    Sept. 27, 2006

      9 Chris         1                                              With the new Social Economic content in the FMP – suggest you may want to          -prefer not to use these as there is no appendix available
        Schaefer                                                     also include the Demographic Profiles in a supporting SupDoc to the plan. This     to incude them in and they are really not necessary.
                                                                     is only a suggestion since it was not covered in the CP proposal.

     10 Chris         1        45       24-25                        Remove (clarify???) this new sentence regarding Wabakimi Park.                     -done
     11 Chris         1        82        3-4    Wood Utilization     Text is now inconsistent with the new text on page 83, ln 44-49. Either mill       -done
        Schaefer                                                     demand exists for the hardwood for the (one-year) period of this plan or it does
                                                                     not? FMP-18 shows full utilization of both hardwood species, and FMP-19
                                                                     outlines the planned utilization by mill.

     12 Chris         1        83       44-49   Wood Utilization     This new text is a significant departure from the draft plan text, and contradicts -done
        Schaefer,                                                    the approach taken in the 2002 FMP (pg 141). The avoidance strategy
        Glen                                                         component is OK, but needs to be more clearly defined as to the actual intent
        Hooper, &                                                    (must state the % hardwood component where the avoidance would be
        Tara Pettit                                                  triggered). Bowater plans have in the past, set a 40% limit as a threshold for
                                                                     avoidance in stands containing species that were less marketable prior to
                                                                     requesting harvest approval, with the intent to hold them until later in the plan
                                                                     period (when markets hopefully improved) or declared Surplus. If cut, the 40%
                                                                     hardwood in the stand would still need to be harvested and utilized in accordance
                                                                     with the FMP standards (exclusive of snags and residual requirements) and
                                                                     brought to market (not at roadside either). (The caribou plan clearly articulates
                                                                     adherence to the scaling manual for utilization on pg 148).

     13 Chris         1        83       44-49   Wood Utilization     Continued...In addition, some plans have also addressed patchy stands where the -done
        Schaefer,                                                    hardwood components of the stands could be flagged out, so as to ensure that
        Glen                                                         these portions of the stands were not accessed for the other species and retained
        Hooper, &                                                    until markets improved. However, since this plan is only for 1 year very little
        Tara Pettit                                                  time actually exists to enable a market shift.  The phrase „cannot be avoided‟ is
                                                                     questioned as it can always be avoided, as is the „second pass harvest‟ since a
                                                                     second pass in subsequent years would need to be built into the 2008 FMP. Has
                                                                     this been done (Eligible? Optional blocks? Preferred blocks? Second Pass?). This
                                                                     entire text block needs to be reviewed, the intent confirmed and clearly
                                                                     articulated … while keeping to the strategic direction in the current FMP (see
                                                                     page 141 section of current plan). Full utilization of those stands with <40
                                                                     hardwood is fully expected (minus the residual stem requirements set in the FMP).

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2007-08 Caribou Final Forest Contingency Plan - MNR Review Summary                                                                                                                                              Sept. 27, 2006

     14 Glen Hooper   1        83       44-49   Wood Utilization     If the stand is dominated by conifer, this is not acceptable for meeting the        -done
                                                                     strategic direction of the Plan, since the entire SFL is in caribou habitat and
                                                                     continuous range. The strategic direction of the plan is to ensure the DFFC in
                                                                     conifer-dominated blocks is put back through silviculture. To lose land area to
                                                                     conversion to hardwood dominated or mixedwood stands is contrary to the
                                                                     strategic direction, and is not sustainable. If the stand is dominated by hardwood,
                                                                     then the stands are already not suitable habitat, and so these are not the issue of
                                                                     this required alteration (i.e. no problem). The issue is the conifer-dominated
                                                                     blocks. Leaving a conifer-dominated stand with significant amounts of standing
                                                                     hardwood and not applying an appropriate silvicultural treatment introduces too
                                                                     much of a risk to future silvicultural success due to the hardwood suckering and
                                                                     seeding that will occur, and change in soil herbaceous layers and humus form.

     15 Glen Hooper   1        83       44-49   Wood Utilization     Continued...Second pass harvesting delayed by several years will cause these        -done
                                                                     habitat sites to be permanently lost for the next rotation, and possibly two
                                                                     rotations, i.e. a permanent loss of caribou habitat and a negative impact on
                                                                     surrounding habitat through predator-prey interactions. The statement: “In the
                                                                     event that hardwood markets develop” , is stating that these might never be
                                                                     harvested with second pass, and thus not receive the appropriate silvicultural
                                                                     treatment. Harvesting in the Caribou Forest displaces caribou, so in order to be
                                                                     sustainable, the habitat must be returned block by block as it is harvested. This
                                                                     section must be revised. Text should be added saying that live birch left for snags
                                                                     should be stubbed to remove the seed producing top.

     16 Chris         1        88        23                          Text restricts aggregate pits to „areas within 500 meters of existing roads within an   Make sure that text states "Aggregate pits may be established
        Schaefer                                                     area of operation‟.  I have provided the policy via e-mail, and note that this text     within: a primary or branch road corridor (500 or 1000m wide)
                                                                     may have incorrectly combined two specific exemption requirements. Please               shown on the operations map in both the FMP and AWS or, an
                                                                     confirm the intent, and ensure the text is as intended.                                 area of operations that is shown on the operations map in both the
                                                                                                                                                             FMP and AWS or, an operational road corridor shown in the
                                                                                                                                                             AWS or, a planned aggregate extraction area (located within 500m
                                                                                                                                                             of an existing road) that is shown on the FMP and AWS
                                                                                                                                                             operations maps" This is straight from the Sept 27, 2006 training
                                                                                                                                                             booklet. -done

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2007-08 Caribou Final Forest Contingency Plan - MNR Review Summary                                                                                                                                                     Sept. 27, 2006

     17 Chris         3                        Appendix 18                The "Areas of Operations‟ (AOO) as shown on map 8.1 are excessive                       AoO are not necessarily excessive given that they must incorporate
        Schaefer &                             (Management Plan           considering the amount of operations actually beign conducted during this plan.         harvest and R&T operating areas. Further discussion with Tara
        Tara Pettit                            Composite Maps)            The AOO shown in this CP are more reflective of what could be shown in the              and Chris Schefer in later September, 2006 resulted in the following
                                                                          2008 FMP. Given the availability of areas for operational roads and aggregate           acceptable approach to the AoO concerns: 1) The Dole Valley
                                                                          extraction not associated with actual operations (i.e. within unallocated timber        AoO will be removed as it is not required for a primary road. 2)
                                                                          etc.), the MNR cannot approve these AOO as shown. Note that a number of                 AoO text on p 88 will be revised to reflect the Exception Criteria
                                                                          these areas do not even have current or historical harvest, or any associated           in the revised Aggregate Resources of Ontario Provincial Standards
                                                                          renewal or tending activities. The AOO needs to be netted down to reflect actual        for Category 9 and 14 pits.
                                                                          oeprations (training messeages suggest using a 250m buffer). The Dole Valley
                                                                          AOO needs be be removed totally as an AOO is not required (road corridor
                                                                          suficiant). As operational corridors are still shown on the Map 8‟s, the
                                                                          relationship between these operational corridors and the AOO should be

     18 Chris         1        89        10                               The original text regarding conditions on operational roads has been omitted       -done
        Schaefer &                                                        from the final plan (20 m width of ROW through AOC‟s and 30 m ROW
        Tara Pettit                                                       through unallocated timber etc.). Please reinclude text referenced in the draft CP
                                                                          on pg 78 (ln 41-45).
     19 Tara Pettit   1        90        25    Revenue & Expenditures     Renewal Rates and the FMP-24 have been changed since the draft submission. -done
                                                                          The renewal rates used in the draft submission were the correct rates ($5.00 for
                                                                          conifer). Please correct. Although the planned silviculture program has not
                                                                          changed from the draft submission, the expenditures submitted in the final plan
                                                                          have been reduced. Please correct his error. The present costs depicted are not
                                                                          consistent with true silvicultural costs. What programs is Bowater not intending
                                                                          to complete under "other eligible activities".

     20 Cathy         1        93        3-5   Planned Clearcuts          if this is revised to something like as follows, then the text at page 92 referred to   -done
        Cavalier                                                          above could get added at the end of this section „There are no exceptions to
                                                                          forest management guides in AOC prescriptions in this contingency plan,
                                                                          therefore no exceptions monitoring programs are required for operations to be
                                                                          carried out in this contingency plan.‟

     21 Cathy         1        94        13                               line 13 refers to „draft Well Spaced Free Growing Assessment Manual‟ – this is    -done
        Cavalier                                                          no longer draft – it has been finalized as „Well spaced Free-growing Regeneration
                                                                          Assessment Procedure for Ontario NWSI Technical Manual TM-007 December

     22 Chris         2                        Appendix 1 (Contingency I agree that a signed approval of the CP proposal is not critical, but if it is desired -done
        Schaefer                               Plan Proposal)          I can provide a copy of the signed approval page for the CP proposal. In
                                                                       addition, I suggest that the inclusion of an update (addendum) be considered to
                                                                       outline changes to the schedule and the additional public review.

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2007-08 Caribou Final Forest Contingency Plan - MNR Review Summary                                                                                                                                                                 Sept. 27, 2006

     23 Chris          2                       Appendix 14 (Plan         The plan needs to include the actual PLRA and FLRA. (Not in the regional copy) -Tara to do
        Schaefer                               Review & Approval
     24 Chris          2                       Appendix 13 (Summary      Suggest that the district still consider placing copies of the actual newspaper and                 -Tara to do
        Schaefer                               of Public Consultation)   EBR notices in the district‟s copy (even if not placed in all copies).

     25 Chris          2                        Appendix 15 (Caribou    The preamble to the section of the appendix titled Marten Habitat Strategies (new -done
        Schaefer                               Habitat & Martin Habitat text) includes the phrase „however, from a compliance perspective will be
                                               Documentation)           accountable to the Marten Guideline‟.  This is incorrect as compliance is
                                                                        measured against the FMP (CP) and not the guide. Significant direction has been
                                                                        nicely build into the CP text outlining the requirements in this regard (pg 80-81)
                                                                        and these requirements must be followed. The SOP, on the other hand, can be
                                                                        treated and supplemental approaches/suggestions.

     26 Steve Winsor   2                       Appendix 17 (Area of      AOC 30-2 states that “reserves will be maintained as mapped on a peninsula west DONE - revised AOC 30-2 wording to reflect current
                                               Concern Supplemental      of minis bay...” yet the red AOC designation does not match the same area as tourism agreements (previous wording in this AOC was
                                               Documentation)            mapped in the 2002-2022 FMP. Please ensure all tourism AOC‟s contain the not up-to-date) - mapping is correct
                                                                         proper delineation of the AOC boundaries.

     27 Steve Winsor   2                       Appendix 17 (Area of      AOC 18 (long term baitfish/water quality study area) is omitted from the DONE
                                               Concern Supplemental      Normandy OA, BM 564558. Please correct.
     28 Tara Pettit    2                       Appendix 17 (Area of      The dimensions of AOC 17.2 as referenced in the sup doc and FMP-14 is still AOC is as per MNR Growth and Yield expert. AOC has
                                               Concern Supplemental      incorrect. The dimensions of the AOC is "100 metre reserve from centre post of not been changed. Incorrect dimensions in the 2002 FMP
                                               Documentation)            plot". Due to previous mapping errors the original 2002 FMP sup doc wording is will be revised through an amendment.
                                                                         required (state 100m).

     29 Brad Everatt   2                       Appendix 9 (Compliance    RA # 38791 has only been partially addressed. To fully address this issue the                       -done
                                               Plan)                     following wording “and tree planting” needs to be added after the word site
                                                                         preparation in the last line of item 7.

     30 Brad Everatt   2                       Appendix 9 (Compliance    RA # 38809 has not been properly addressed. To properly address this issue the                      -waiting for John B to confirn acceptance (page already printed)
                                               Plan)                     present wording should be replaced with “Start Up – In order to ensure that the
                                                                         M.N.R. can set appropriate compliance inspection risk based targets in an accurate manner,
                                                                         notification of start up of any forest operations or activities will be provided to the MNR prior
                                                                         to their commencement. Notification will be conducted by the Bowater Field Representative or
                                                                         Qualified Overlapping Licensee Representative to the appropriate M.N.R. contact. The method
                                                                         of notification is specified in the Annual Compliance Schedule (Part 2).”

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2007-08 Caribou Final Forest Contingency Plan - MNR Review Summary                                                                                                                                     Sept. 27, 2006

     31 Chris          5-7                     Appendix 20 (Map 8.0   While not an issue on this CP (given intent to retain the existing mapping           As the reviewer notes, this comment is not for the 2007-
        Schaefer                               Areas Selected for     formats) I would suggest that the approach to identify the SGR‟s will need to be 08 Contingency Plan.
                                               Operations)            reviewed with regard to the new FMPM requirements for the development of the
                                                                      2008-2018 FMP.  As noted on A-57, ln 14, and B-25, ln 10 the SGR‟s are
                                                                      required to be identified on your map 8‟s for the operations selected for the first
                                                                      5-year term (harvest, renewal and tending). As a suggestion, it may be easiest to
                                                                      just include the SGR in the stand identifier itself (as with the FU‟s), avoiding the
                                                                      need for the printed stand listing on the individual maps

     32 Steve Winsor   5-7                     Appendix 20 (Map 8.0   Several water crossing have been identified for installation within areas that have TANA - please remove the water crossings listed
                                               Areas Selected for     all harvesting operations completed and only aerial herbicide ops proposed.
                                               Operations)            Examples of this would include WC#‟s 1-240, 1-241 & 1-289 within the
                                                                      Normandy OA. These water crossings need to be removed.

     33 Steve Winsor   5-7                     Appendix 20 (Map 8.0   There are examples of water crossings that are not approved to be installed. TANA - remove crossings listed
                                               Areas Selected for     Water crossing that have been dropped via amendments (ex Amendment #02-07-
                                               Operations)            41) have now resurfaced and are identified as planned water crossings to be
                                                                      installed during this contingency plan period. This was noted during the draft
                                                                      plan review and 90% of the crossings have been addressed within the final
                                                                      submission except for a few isolated occurrences. Ex BM 565557, WC# 1-308.
                                                                      After referring this issue with Jen Jones, it has been determined that the following
                                                                      water crossings need to be removed: 308, 267, 337, 326, 413, 263, 332.

     34 Steve Winsor   5-7                     Appendix 20 (Map 8.0   Roads that have been decommissioned are still identified as roads (drivable by      TANA - remove road in Normandy (see attached map)
                                               Areas Selected for     definition). An example is the Normandy north road network. Please correct.

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