My Request to the Minister of the Environment

September 18, 2008

Agatha Garcia-Wright
Director,
Environmental Assessments and Approvals
Ministry of the Environment
12A Floor2 St Clair Ave W
Toronto ON M4V1L5 Phone: 416-314-7288 Fax: 416-314-8452
Email: agatha.garciawright@ontario.ca

Re: The Ogoki Forest Management Plan – Review of the MNR Response dated August 27, 2008

Dear Ms Garcia-Wright:

Citing published peer reviewed studies; I have analyzed and compared the recommendations of recognized scientific authorities with the response provided by the MNR. The results are alarming. This narrative raises serious doubts to the viability and credibility of the MNR`s plan, the ability of their FMP predictive modelling tool (SFMM) to provide a realistic natural benchmark, and the reasonableness of their management strategy.

The most disturbing element of the Ogoki FMP is their strategy which relies on convincing the reader that historical fire suppression has played a significant role in shaping the mature age class of the Ogoki forest as it appears today. Unsubstantiated and vague in this area, the MNR`s response exaggerates this activity to justify their proposed ``re-design`` of the forest which will include everything from wide-scale species conversion to a 60% loss of caribou habitat. My research explores this fire suppression `myth`` in considerable detail. The scientific community unanimously recognize climate change (The Little Ice Age) as the cooling trend responsible for tree longevity up to 1900 AD. (We have living proof of this in Ogoki today with lowland spruce trees well over 300 years of age.) After that - studies citing specific burn rates, frequencies, and precise return intervals are clouded with a degree of controversy – it is a modelling problem. As Cummings states: ``What is needed is a sound model of periodic area burned that directly includes the effects of fire weather and fire suppression. No such model exists.`` Finally, the MNR`s assertion that postwar fire suppression was a driving force in Ogoki in the last 50 years is unsubstantiated given the fact there are no actual fire statistics available after 1974 in north western Ontario and any reliance on FRI for fire scars of live trees is biased to aerial photography interpretation and the actual sampling of oldest stands in the FRI. Given the weighting fire suppression has been assigned in the outcome of the Ogoki FMP, this ambiguity provides the MOE with most compelling reason to move forward with an Independent Environmental Assessment.

Spurious assurances based on faulty modelling tool predictions abound in this FMP. The value of the SFMM lies in it’s ability to accurately predict the natural benchmark. This benchmark determines the degree of `fall out` and so called tolerance levels for inevitable habitat destruction. Wildlife species such as the Martin, Eastern Cougar, Woodpecker, Eagle and Caribou– all of these species habitat have or will be destroyed by logging. The MNR try to assure us the degree of destruction is within an acceptable range, as determined by the SFMM`s natural benchmark (expressed as a % above or below the benchmark). The devil is in the details, but to summarize:

- The SFMM is a non-spatial modelling tool. This is not `best science` rather this is all the MNR is currently capable of. Studies contained in this report from two independent scientists (Cummings and Didion) confirm spatial modelling is not only being done, it is mandatory to accurately represent the forest as it is today, and how it will look 20-40 and 200 years from now.

- Data: The SFMM is further compromised by biased and unproven assumptions of fire suppression which skew the managed fire cycle projections; inaccurate FRI (Forest Inventory) is the source data for this tool, inaccuracies in FRI result in erroneous representation of the current and future habitat of the caribou based on ecosites

- Ecosite assumptions negatively affect caribou habitat projections: The SFMM is responsible for supplying habitat projections for a number of wildlife species including winter habitat projections for caribou. Ecosite data is not surprisingly derived from the FRI.

The Forest Management Planning Manual defines ecosite as “an ecological landscape unit (ranging in resolution from thousands to hundreds of hectares) comprised of relatively uniform geology, parent materials, soils, topography, and hydrology, occupied by a consistent complex of successional-related vegetation conditions”. Ecosites are mathematical polygons designed to represent current and future caribou habitat. What is blatantly contradictory in this forest plan is the fact the MNR acknowledges balsam, cedar or larch are not considered preferred habitat by caribou yet the entire model was built on assumptions based on two eco-sites 19 and 21 which contain exactly that. ( The wildlife habitat units used (Supplementary Documentation 6.6, Tab 16 in the Ogoki Forest FMP) identified Lowland spruce as preferred habitat (all seral stages) for caribou).

Ecosite 19 and Ecosite 21 which are described by the FMP as follows :
The general description of ES19 is that it is dominated by trembling aspen (poplar), white birch and balsam fir, with occasional occurrences of white and black spruce. The hardwood component exceeds 50% of the canopy, with variable species occupying the shrub- and herb-rich understory. The general description for ES21 is that it is dominated by balsam fir, white and black spruce, with mixtures of aspen and white birch. The conifer component exceeds 50% of the canopy, with an understory typically shrub- and herb-poor with abundant feathermoss. (I have not included other characteristics for these two ecosites relative to soil types, drainage, parent materials, mode of deposition or typical understory species.)

How can the MNR even begin to make assurances on caribou habitat when they concede their own data assumptions are derived from ecosites that caribou cannot thrive in. This is absurd.

- Subjectivity: the tools inability to predict accurate and meaningful fire cycles to represent the entire range and age class of the forest result in reliance on subjective calculations by the individual forester. There is no ``acid test`` performed by the MNR to confirm or deny the results yet we are to believe the manual ``matching`` of SFMM outputs to spatial inventory geo-mapped data is reliable. This is mathematically impossible and no such assurance can be given.

I find it interesting to note within the MNR`s response is a statement that they have adopted best practices (``used appropriate, ecologically-based natural benchmark fire cycles, based on the best science available, and best practices in modelling techniques``). An organization cannot promulgate best practices without conducting an objective industry wide benchmarking of strategy, methods and theories against other national and international scientists engaged in the study of boreal eco-system management. Why then is there a need for a `disclaimer` - a carefully worded escape clause which states ` based on our understanding of the dynamic nature of the boreal forest`. Have the MNR now conceded that the plan was built based on their limited experience (10 years in Ogoki). In any case, the question remains: what exactly is their understanding, what data or research has been referenced to support this claim, and what scientist outside of the MNR (and their own guidelines) and any other government affiliated extraction based industry would endorse this plan and this model as ``best practice``. My own research in four short days has found five independent peer reviewed scientific studies that collectively challenge this plans ecological `theory`` not to mention the issues raised by MNR staff and Auditor as documented in the 2005 Audit.

I ask the MOE to review this narrative carefully and implore the Director at a bare minimum impose restrictions should the harvest be allowed to proceed in the form of a 3rd party scientific panel review before more damage is done and the destruction of a vital ecosystem is allowed. A list of issues below is followed by some additional recommendations on the last page of this report.

Thank you.

RESEARCH FINDINGS:

The below noted study (Bergeron et at) was compiled with data from 1874 to 1974 (it does not capture fire activities past that date). It examines a number of ecozones, the number of data collection points is unknown (to me) but the sampling area for the Northwestern Ecozone appears to be large at 24,000 km2 (1km² = 100 ha) or 2,400,000 ha. Put into perspective, this is roughly twice the size of the Ogoki Forest Management Unit.

The study’s main point: If current and simulated future fire frequencies using 2 and 3 × CO2 scenarios are lower than the historical fire frequency, forest management could potentially be used to recreate the forest age structure of fire-controlled pre-industrial landscapes.

At a high level, based on the studies methodology, Northern Quebec and Northern Ontario show the most significant changes to their location in a 3 × CO2 scenario which is close to the biodiversity (1-to-1 line) constraint line and the 1% yield constraint line as described in the conceptual model (Fig. 2).

In summary, the logic provided thus far in this study at a statistical level suggests Ogoki is a candidate for forest management using a shorter rotation cycle. In simple language, the theory put forth is that because there are less fires now that historically, adopting a “managed” fire cycle with fire suppression will result in the forest getting much older (since it won`t be burnt to the ground naturally), but that will be offset by humans harvesting it, creating young forest in it’s place.

Upon review of the MNR’s response, I believe it is fair to conclude the MNR have extrapolated those aspects of the study’s approach that favour their business proposal, to justify shorter rotation cycles in the Ogoki 2008-2018 FMP.
The paper: Past, Current and Future Fire Frequency in the Canadian Boreal Forest: Implications for Sustainable Forest Management, Yves Bergeron, Mike Flannigan, Sylvie Gauthier, Alain Leduc, and Patrick Lefort is a Canadian study – URL link below.



The Burn rates are complied in the table below, North western Ontario is identified as #11:


Looking beyond the statistics, the study acknowledges there are serious limitations and concerns about applying this modelling approach to the boreal.

ISSUE #1: CLEAR-CUTTING IS UNABLE TO EMULATE OVERMATURE AND OLD GROWTH BOREAL FORESTS

Bergeron’s study notes the following serious concerns that come with the statistical generalizations and assertions stated (above) as it relates to the strategy of clear cutting to recreate pre-industrialized areas of forest:

- “Understanding of the fire regimes that characterize the boreal forest is still fragmentary, and it is inappropriate to generalize from regional studies to the entire boreal zone. This lack of understanding has often led to false generalizations. For example, clearcutting has been justified for use throughout the boreal forest based on the assumption that the fire regime is characterized by the presence of large, frequent and severe fires that produced even-aged stands. In fact, it has become increasingly evident that a short fire cycle applies only partially to the boreal forest and that the situation is regionally more complex (10).
- “There are, however, important limitations to the use of clearcut systems for this purpose. Clearcutting and fire are obviously not the same process (38) and a careful examination of their respective effects on pattern and processes should help define clearcutting guidelines (39, 40). Moreover, clearcutting is unable to emulate overmature and old growth forests that composed a large part of our natural forests. Development of alternative silvicultural systems for the boreal forests is an urgent task to accomplish.
- “Reported historical fire frequencies are in most cases less than 1% (implying a 100 year forest rotation) (Fig. 2), which means that a large proportion of the pre-industrial landscape was composed of forests older than the 100-year commercial forest rotation. This figure is even higher if you consider that fire is a random process while forest management is not: With 1% burn rates, 37% of the stands are in fact older than 100 years in a landscape subject only to fires, while no stands are older than 100 years in a fully regulated managed landscape (37)”
- Note: The historical burn rate of north western Ontario is cited as 0.4615.
Forest age structure as indicator of boreal forest sustainability under alternative management and fire regimes: A landscape level sensitivity analysis
M. Didion∗,1, M.-J. Fortin1,2, A. Fall1

The above study makes several interesting points that coincide with the concerns Bergeron raised (above) namely:

``Natural disturbance processes are inherent to forest ecosystems`and will persist despite fire suppression efforts. Within the scope of our simulations, this research shows that the combined effects of harvesting in the presence of wildfire disturbance are different from the sum of the individual effects.
``That is, not only do fires and harvesting produce dramatically different effects on the age-class structure of a landscape, their effects combine to accelerate loss of late seral stands, and fire exacerbates the effect of harvesting even at fire cycles substantially longer than historic levels.``

In simple layperson`s language this statement says fire will persist in the boreal in spite of any suppression attempts, and can be expected to burn old growth. Therefore, in addition to the inevitable loss of some old growth stands through fire, and in spite of any attempts at suppression, harvesting will take what is left.

These points are expanded in more detail in Issue No. 3

ISSUE #2: Fire suppression is not responsible for changes in Fire Frequencies in Northwestern Ontario

Based on the MNR’s response, the MNR plan attempts to justify their business proposal with shorter managed fire cycle allocations using an unsubstantiated assertion that the forest is “unnaturally” old because of human intervention.

The MNR refers to the ``naturally suppressed` state of the forest in several sections of the response, below I quote their response to Question 3 (caribou habitat loss) where they justify a 60% habitat loss as reasonable and `natural` with the following assertion:

``In the absence of fire suppression, much of the landscape would be younger, large patches of fire originated tree species. As such, a natural variation of 30-60% of the landscape is expected to be in suitable condition at any time, which also means that approximately 40-70% of the forest is expected to be in a non-suitable condition for caribou. Therefore, the 40-60% management objective in the 2008 Ogoki FMP is consistent with the expected bounds of natural variation, based on our understanding of the natural dynamic of the boreal forest.``

This statement is highly contentious. The destruction of wild-life habitat and the inevitable extirpation of caribou along with all other species at risk is justified here with the fabrication of a myth. Yes, there are scientific studies to support the assertion that the fire cycle frequency within Northern Ontario has changed in the last 100 – 150 years but the reasons for the shift in frequency are not due to fire suppression, rather, two possible scenarios can be put forth.


SCENARIO ONE: THE FREQUENCY HAS (AND WILL CONTINUE TO BE) AFFECTED BY CLIMATE CHANGE.

As noted in Bergerons paper:

“The observed shift from short fire cycles in the past to longer cycles over the last 50 years is probably due to a combination of climate changes and better fire protection. Many studies from the Canadian boreal forest report a general decrease in fire frequency since the mid-19th century (10, 23, 24). As most of the forest was still unexploited at that time, it is very likely that the decrease in fire frequency was driven by changes in climate. In north western Quebec, the decrease in fire frequency was related to a reduction in the frequency of drought events since the end of the Little Ice Age (25). It is hypothesized that the warming that started at the end of the Little Ice Age is associated with an important change in the circulation of global air masses (26, 27).”

Cummings expands on this with the following:

``A general cooling trend since then was interrupted by the Medieval Warm Period (AD 800–1200). The so-called Little Ice Age followed (AD 1450–1900), but temperature have warmed slightly since (summarised from Campbell,1999).``

Low land spruce lives upward of 300- 400 years in the Ogoki forest and is prevalent today. It persists in spite of fire because fire does not burn all stands equally and in spite of what the MNR would have us believe it is important to include the location of trees (not just how many) when establishing the natural benchmark and fire return interval because (for example) spruce thrive in cold, wet, humid conditions which typify close proximity to lakes. Cummings expands on this in his study with the following comments (he qualifies the size of lake will affect the fire return interval):

``Consider a patch of forest on the shore of a very long lake, broad enough that fire can not cross. All else being equal, the fire return interval for that patch should be twice as long as that of an equivalent patch far from any fire break, because the effective source area for fires capable of burning the lakeshore patch is only one half that of the forest interior patch.``

North western Ontario is characterized by short, wet summers and long, cold dry winters. Although severe thunderstorm activity is not unusual, lightening is not a primary source of fire activity because with lightening, comes rain.

Below are extrapolations from the MNR`s response. I will cite the page number if the reader wishes to go back and refer to the comment within a larger context. I have some serious concerns regarding the validity of these statements and have added my comments.

PROPONENT:

Page 31: ``It is wise not to overestimate the success of fire suppression in the future. The 2008-2018 Ogoki FMP used lower rates for the managed fire cycles than were used in the previous plan, as noted in table 2, section 6.6, tab 13 of the Analysis Package. By doing so, the planning team effectively built some insurance into the managed fire cycle estimates.``

MY COMMENT:

The managed fire cycles that were used in the previous plan were derived from Northeastern Ontario. The 2005 Audit noted this along with the following concerns:

A key parameter in the benchmark run is the natural fire return time. The natural fire return time can be thought of as how often one place on the Forest can be expected to burn in the absence of fire suppression.

For the Ogoki Forest, the natural fire cycles used were those suggested by the MNR for the Northeast region, rather than the Northwest region as it was felt that these better reflected the climatic and moisture conditions on the forest.
These estimates of fire return times are considerably shorter than rates suggested for the Ogoki Forest and Northeast region in recent MNR publications10 11, which identified natural fire cycles from 362 to 852 years.

If that is the case, then the natural fire return time reported in the MNR publications may be erroneous. Greater fire suppression would result in longer fire times, and so the natural fire return time may not be in the range of 362-852 years as suggested in the MNR publications. Furthermore, some MNR staff have identified problems with the data used in the publications (i.e. missing fires). This would similarly have the effect of producing estimates of longer fire return times.

Notwithstanding the serious concerns raised by the auditor and the MNR`s own staff, in Bergeron`s study, the CURRENT BURN RATE in North eastern ecozones 12, 13, are near identical to north western Ontario.

http://ambio.allenpress.com/perlserv/?request=display-figures&name=i0044-7447-33-6-356-f01

http://ambio.allenpress.com/perlserv/?request=display-figures&name=i0044-7447-33-6-356-t01

Ecozone Past Burn rate Current Burn Rate
11 North western Ontario 1.92 0.4615
12 .58 0.0456
13 .72 0.0322
14 1.40 0.006
15 .90 0.03
17 .79 0.11

If the MNR checked the available scientific data, the MNR would have to know that fire burns NOW at the same rate in north eastern Ontario as in north western Ontario . Wouldn’t it be more logical to at least concede if you were going to check what the last plan did and make a statement that implies the comparison of the two, the longer fire cycles used in the previous plan should be at a bare minimum be used in the 2008-2018.

As noted in Issue No1, lower rates means cutting will proceed earlier in shorter rotations and as noted in the pages following this, the gap between old growth and young forest will widen with more and more young trees until the actual forest is depleted and the natural dynamic of the boreal is lost forever. I fail to see how this is a positive step forward – it is most definitely a step backwards.

The Thesis: The Effect of Season of Fire on Post-fire Legacies in Northwestern Ontario Red Pine (Pinus resinosa) Mixedwoods by Brett D. Woodman, 2005 is a thesis presented to the University of Waterloo in fulfilment of the thesis requirement for the degree of Master of Environmental Studies.

http://uwspace.uwaterloo.ca/bitstream/10012/969/1/bwoodman2005.pdf

Its focus is Quetico PP which is 160 km northwest of Thunder Bay. The details of fire suppression activities contained in this thesis suggest a number of things, which, taken together with the above statements by Bergeron et al, refute the MNR’s assertion that fire suppression has been a driving force in Ogoki and has resulted in an “older than natural” forest.

The paper concedes it is true that post 1950, with the advance of aerial water bombers and modern suppression methods that do not rely on road access, forests in Canada have been artificially influenced by suppression, however, the paper goes one step further to explain that the emphasis has been in two major areas:
- Areas of undertaking (managed forests) which are located south of the 51 parallel
- Protected areas (such as Quetico).

Ogoki is just above the 51 parallel, and has very limited reserves primarily located along the Albany River which were introduced as part of the Living Legacy exercise - a recent land allocation strategy finalized by the Ontario Government in the 1990s. The Ogoki Forest management unit is almost exclusively crown land.

Further, promulgations contained in this thesis that fire frequencies have increased 100+ fold from historical burn rates due to fire suppression are (a) specific to Quetico PP and (b) dated to the 1970s. This coincides with the same period of study cited by Bergeon above (1874-1974), and suggests to me that scientific studies and empirical knowledge of Northwestern Ontario are limited to data captured in the decades on or before 1974 because the northwestern area of the province remained largely undeveloped frontier.

It`s important to note 1974 is almost 40 years ago and the MNR`s response cites fire suppression activities took place in the last 50 years. Where exactly did these statistics come from. Their own staff concede the fire database is not accurate, their FRI inventory is incomplete and 20 years out of date (presuming they used fire scars on live trees to establish points) and two published papers cited in this narrative refer to data collected up to an including 1974 – it stops there. Another source: http://www.jstor.org/pss/2426178 reprinted in full below reinforces the complete lack of fire history reporting in the last 50 years in NW Ontario

Furthermore, as the thesis acknowledges, the 1950’s post-war approach to forest management has subsequently evolved with increased knowledge, such that in the 1990’s fires were not only allowed to burn, prescribed burns were encouraged and routinely performed in northwestern Ontario.

The Thesis states:

“In recent decades, there have been numerous initiatives to re-introduce fire in the landscape. These initiatives have focused on re-establishing fire as a natural ecological process and minimizing hazards to people and infrastructure. Prescribed burns are employed in the southern boreal forest of northwest Ontario, Canada, as a method of re-instating fire in this fire-dependent landscape. They are also used to manage fuel loads associated with tree mortality from defoliating insects and from blow-downs, as well as in-site preparation following harvest. The natural fire season in boreal Canada typically runs from April through September and is most often characterized by stand replacing fires. However, prescribed burns in northwestern Ontario are mostly scheduled for October when fire crews and equipment are available and fire hazard is reduced.”

“In a fire-adapted landscape such as northwestern Ontario, resource managers are
obliged to accept that some fire is not only inevitable but also desirable in terms of maintaining ecosystem processes``

The 2000 audited cited a large (thousands of ha) fire in Ogoki that the MNR allowed to continue without intervention or suppression in the 1990s for this very reason. Outside of the facts, there are some other practical considerations to fire suppression:

Fire fighting is expensive - a fire can range 10s of thousands of hectares and prior to 1998 the forest was not logged, was roadless and unprotected. Along with access limitations, are resource and visibility limitations that would allow small fires within a large forest to go undetected. Until logging was introduced in Ogoki in 1998, small fires would be undetectable. In short, there was very little reason to suppress unless fires burned unless they pose a risk to urban development. Greenstone is a microcosm for Northern Ontario. Sprawling across 2,780 square kilometers, this municipality is the largest incorporated town in Canada, larger than several countries yet host to less than 6,000 people. The population is sparsely located well OUTSIDE OF OGOKI across thousands of hectares and spending millions to protect a forest unless there is a risk to human life would not be cost effective.

Bergeron sums up these practical considerations with the following statement:

``However, fire suppression has its limitations, and it is more and more recognized that it is not really efficient in large tracts of natural forest where access is limited, and when fire season conditions are particularly severe.``

This narrative would not be complete without acknowledging another very real possibly – the actual burn rates reported historically have been reported incorrectly because of modelling flaws.

SCENARIO TWO: HISTORIC BURN RATES ARE MISLEADING DUE TO STASTICAL MODELLING ERRORS

The importance of calculating the correct fire return interval is discussed in Issue No 4 of this narrative since this also impacts the MNR`s predictive modelling capabilities (SFMM). For now it`s enough to state Science has evolved and we now know that fire is highly variable, rate of burn and what actually burns is based on ignition and spread and predicting fire cycles with non-spatial modelling tools is highly inaccurate.

As Cummings states:
``Many studies of forest age-structure that have concluded that the fire return interval changed at some point during the 19th century are compromised by (the fire modelling method used). The point is not that fire the return interval has never changed, but that much of the published evidence for such changes appears to be seriously flawed.``

He further explains:
Thus, these data do not necessarily prove that fire return intervals changed, only that the number of fires per unit time (of unknown size and spread over an unknown area) changed. This probably translates into changes in fire return interval, but what these changes were is hard to quantify.

Note: The changes in frequency documented by Clark (1990a) are inferred from peaks in the pattern of deposition of sedimentary charcoal. Paleoecology: as used here, is the study of Holocene communities through analysis of pollen, arthropods exoskeletons, plankton and charcoal fossilised (usually) in lake sediments.


ISSUE #3: ECOSYSTEM FOREST MANAGEMENT RECOGNIZES AN AGE CLASS CONSTRAINT IS CRUCIAL IN FMP MODELLING TO ESTABLISH A NATURAL BENCHMARK THAT ACCURATELY REFLECTS THE TRUE AGE RANGE OF THE FOREST

I note that in response to the MOE`s question No 15 (How is the forest age determined? Where are the old stands of forest? What scientific method is used to measure the age of the forest and inventory? Will age structure of the forest be compromised?) , the MNR`s response was:

Pg 35 MNR Reponse states:

``Concerning MOE’s question as to whether the age class structure will be compromised, the answer is that age classes will be re-distributed by design, through the implementation of the management strategy of the FMP. The current age class structure is unnatural (disproportionately mature to old), primarily a function of moderately successful fire suppression efforts that have been made since the 1960s and the absence of any timber harvest operations prior to 1998. As has been discussed in other answers, there is a gap in the current age class distribution, from approximately 20 to 60 years of age.``

Now that the `fire suppression post 1960`` myth has been debunked, it is clear the MNR`s use of managed fire cycles used in the SFMM is inherently flawed and, additionally the true age of the forest has not been represented in their benchmarking exercise. In addition to the above, the SFMM fails to include a hard constraint for age class. I discussed aspects of this in my initial request for bump up April 8, 2008 referencing the below noted paper and the FRI inventory.

Paper: Forest age structure as indicator of boreal forest sustainability under alternative management and fire regimes: A landscape level sensitivity analysis
M. Didion∗,1, M.-J. Fortin1,2, A. Fall1

This paper was then emailed in pdf format to the MOE for distribution to the Proponent Sept 12, 2008 .

I would like to summarize the salient points of that paper and how the paper`s findings support the importance of using age class as a hard constraint in forest modelling:.

The studies goal:

``One goal of our research was to examine the hypothesis of compensatory effects where Harvesting replaces mortality from natural disturbance in conjunction with suppression (MacLean, 1990; Carleton and MacLellan, 1994; Bergeron et al.,1998; Aber et al., 2000; Harvey et al., 2002). ``

To evaluate this, they created two different fire models employing both top down and bottom up modelling routines, and 3 different harvest models – in the latter one model was `status quo` and two ``alternative strategies` were introduced – one had a `hard constraint` introduced on age class and the other had a ``soft constraint` which meant retention of age class was secondary to harvest quota (ie what the MNR does today).

The studies findings:

Within the parameter space of our sensitivity analysis, we found that harvest rate, fire return interval and management strategy were the most significant parameters affecting stand age-class distribution across the landscape..

One result common to all analyses was that the stand age class distribution experienced large changes from initial conditions, although trends to reach steady state dynamics differed according to the combination of harvesting and fire parameters. Compared to initial conditions, the area of early-seral forest increases significantly in all cases with harvesting (Fig. 6).

The interaction of harvesting and fire leads to significant changes in age structure relative to initial conditions (Figs. 4–7). In particular, the cumulative effect of harvesting and fire results in significant changes to the area of mature and old forest (Figs. 4–7).

Because using a hard constraint implies potentially reduced timber targets, effective implementation of such a measure requires a shift in forest management from a constant yield policy to a more flexible approach.

``The difference in strategy relates primarily to what happens when the harvest target and age-class target conflict.

``Sustainable forest management should thus strive to maintain an age structure within the historic range of the forest (Hansen et al., 1991; Landres et al., 1999). Applying constraints on harvesting of old forest presented the most significant difference in the simulated alternative management strategies. In general, only the Burton hard strategy maintained a significant amount of stands older than the minimum harvest age because it was designed to do so with an explicit management constraint. The Burton soft strategy, which applied the age-class target as an objective not a constraint, produced an age-class structure similar to the Status Quo strategy because when old forest was limited due to interactions between management and fire, it was harvested to achieve timber yield targets.

Conclusions:

Didion states: ``It is therefore important to be clear about the targeted age-class range in a management approach with a hard constraint, and whether the oldest stands are open for lengthened rotations or for preservation. Ecosystem based forest management must examine the significance of the entire possible age-class range for the forest community.

``The Status Quo and Burton soft strategies produced a more uniform age-class distribution typical for industrial forestry defined by harvest rotation length. Only at harvest rates lower than 0.75% did these strategies maintain significant amounts of forest older than the minimum harvest age. This implies that achieving a target age-class distribution likely requires precedence over meeting the harvest target, emphasizing the need for strong forest policies if ecological values are to be maintained.`

``As can be expected, at higher fire frequency (shorter fire return interval) the disturbance effect increases (Fig. 8). Status Quo and Burton soft maintain a forest age structure similar to natural conditions and a constant timber yield (in terms of area harvested) only at long fire return intervals of 250 years and a harvesting rate of 0.65%. An increase in fire frequency leads to a decrease in mature and old forest in favour of early seral forest and to a decrease in timber yield.

Conclusion: Natural disturbance processes are inherent to forest ecosystems and will persist despite fire suppression efforts. Within the scope of our simulations, this research shows that the combined effects of harvesting in the presence of wildfire disturbance are different from the sum of the individual effects. That is, not only do fires and harvesting produce dramatically different effects on the age-class structure of a landscape, their effects combine to accelerate loss of late seral stands, and fire exacerbates the effect of harvesting even at fire cycles substantially longer than historic levels. This held whether fire was modelled as a top-down or bottom-up process.


Conclusion: In spite of the assertions made by the MNR consideration of age class as a constraint has a considerable impact on fire cycle outcomes as does the chosen fire return interval. A different model that allows for the cumulative differences between fire and harvest plus age class as a constraint must be developed.

ISSUE No 4: FIRE CYCLES DO NOT CONSIDER SPATIAL AND TEMPORAL VARIABILITY IN FIRE INTENSITY

MNR Response: (Page 31)
`
``In summary, there is no such thing as a “correct” managed fire cycle, but that said, it is not a modeling problem.``

On the contrary, IT IS A MODELLING PROBLEM.

The lexicon of forest management is confusing. References to burn rates, fire cycles, return rates gets blurred.

Definitions:

Fire Return Interval: Is the expected time between fires on a given patch of forest

Fire Cycle: The amount of time required to burn an area equal to the entire forest. In general, over the period of a fire cycle, some area will burn more than once, some not at all.

As noted in my bump-up Cummings stated:

``The important distinction is that a fire cycle applies to a landscape or region, while a fire return interval applies to a point or small patch. Under some strong independence and homogeneity assumptions, these parameters have the same value.``
``Although the boreal forest in Canada is superficially very similar from Newfoundland to the Yukon, it is in fact highly variable. The same or similar communities of tree species are found under quite different conditions of climate, topography, soil and disturbance regime. These factors interact in ways we are only beginning to understand. However, one major insight is emerging: the common perception of the boreal forest as a “fire dominated ecosystem” is somewhat misleading. This description is sometimes interpreted to mean that the boreal forest is subject to a fairly uniform and high rate of disturbance by large fires. The reality is more complex. Fire is highly variable in both time and space, responding both to effectively random climatic factors and to patterns In consequence, no simple model of fire’s impact on the forest (for example, a mean annual rate of burn) is adequate.
``Imagine a homogeneous forest composed of many small patches, all of the same size. All that we know about any particular patch is its age in years, which is defined as the time since the last fire. If we assume that 1) each patch has a constant probability p of burning in a given year and 2) patches burn independently, then the well known negative exponential forest-age structure emerges from the model. The assumption that p is constant implies that the total area burnt changes little from year to year. Note that in this simplest form of the model, p does not depend on the age of a patch: stands have the same probability of burning, no matter how old they are.
``Under these assumptions, the fire return interval (a patch attribute) and the fire cycle (a landscape attribute) are the same, and both are given by the inverse of p, the probability of burning per unit time. Thus if p is 0.01 per year (or 1%), then 1% of the forest should be expected to burn annually, and the fire return interval and the fire cycle are both 100 yr.
The MNR`s plan have made those homogeneity assumptions in the use of their SFMM tool – the fire return interval and the fire cycle is the same with the only variation being certain blocks have been given a different value for p – depending on their managed forest cycles applied to various blocks. They confirm this with the statement:
``It is important to appreciate that, in SFMM, the natural benchmark burns statistically evenly from all the age classes, from all over the management unit. ``

The weightings are used no doubt factors to weight for fibre quota dependant on class. Class is a consideration to meet fibre objectives – not to meet the needs of the eco-system.

Cummings final conclusions:

``In the boreal mixedwood, fires do not burn all stand types equally. See Cumming (in press) for details. ``…burn rates and mean fire return intervals differ by an order of magnitude between stand types.

``I conclude that there is overwhelming observational, empirical and theoretical evidence that fire spread probabilities differ markedly among forest types in the boreal mixedwood. These differences must translate into different fire return intervals. However, the fire return interval for a particular patch will depend at least as much on the composition of the forest landscape in which it is embedded as on characteristics of the patch itself.

Cummings explains in detail several reasons – not the least of which is wind and temperature and precipitation. He states:

``Rapid fluctuations of wind velocity, diurnal variation in relative humidity, and diurnal or longer period variation in temperature and precipitation all produce variation in intensity over time. This temporal variability appear as spatial variation in fire severity, because fire growth occurs in time. The two sources of variation must clearly interact. For example, a fire front encountering an aspen stand at 1500h would be more intense than if it encountered the same stand at 0300h the next day, because the temperature (and probably wind speed) would be lower and relative humidity would be higher. The interaction of spatial and temporal variability in factors controlling fire intensity has not been adequately considered.

``In my opinion, both factors are required to understand the substantial variation in fire return interval between forest stand types in the boreal mixedwood.``


MNR Response:

SFMM is a modeling tool that, by design, statistically burns the forest non-spatially, at a constant rate, burning all age classes evenly, every year.


MNR Response: However, in the Strategic Forest Management Model (SFMM) which was used by the Ogoki Forest FMP planning team, forest stands burn on a regular time interval regardless of age. Also, as has been pointed out in # 13, once managed fire cycles get well beyond the natural life cycles of the relatively short lived boreal forest trees, the actual number chosen becomes less and less significant in the model (there is little difference in model behaviour between 300 and 600 year fire cycles). In modeling science, the technique used is to find the cycles which represent meaningful changes to model behaviour that are thought to be close to reality.

Therefore, in the modeling world it is virtually impossible to ever match line outputs between a totally non-spatial natural benchmark and a spatially constrained managed scenario, because the proportion of disturbance amongst age classes is distinctly different. Not only is matching almost impossible, but it is also not desirable from a management point of view, because management is spatial - it has to be for caribou. That statistical difference between the two scenarios presented in the 2008-18 FMP is relatively close. It is also not an accident, since one of the underlying principles of forest management is to keep the forest relatively close to a natural forest condition. Strategic spatial planning and non-spatial constraint modeling all contributed to this outcome.

The above statements raise some serious concerns:


(1) Age class is a consideration – not a constraint. `Therefore, the SFMM does not limit harvest by age of forest –in simple language if there is a persistence of old growth (as there is now) then the harvest quotas set by the SFMM will over-ride age class and eliminate old stands regardless of `consideration`. Age class is considered only as a weighting for fibre quotas.
(2) The behaviour of the managed fire cycles: the fact the model is not intelligent enough (or designed properly) to distinguish between 300 and 600 year cycles is an admission of the subjectivity of this process and the fact the MNR currently lacks the sophistication, knowledge and expertise to model accurately for the specialized needs of the boreal. As previously stated by Didion: ``As can be expected, at higher fire frequency (shorter fire return interval) the disturbance effect increases (Fig. 8).``. The `behaviour` at higher fire cycles does matter – subjective evaluation by a forester is not an acceptable replacement.
(3) I find the words ``two scenarios presented in the 2008-18 FM is relatively close`` an indication of nothing – coincidence perhaps and nothing more. The subjectivity of the SFMM gives no assurance that the application of non-spatial ``inventory`` over-laid on spatial caribou habitat means anything – two wrongs don`t make a right. As Cummings explains:

``Huggard and Arsenault (1999) show by example how totally spurious changes in the fire return interval can be generated by random sampling error. In addition, very old stands may be under-represented in sample age structures because the progressive loss of indicators makes their true ages difficult to measure. Finney (1995) shows that this censoring of very old stands can produce spurious changes in the reverse cumulative age distribution, which may be interpreted as evidence for shorter fire return intervals having prevailed in the past.``

The above raises another point noted in my bump-up the issue of the FRI Inventory. This is addressed in Issue No 5

Finally, what has not been said explicitly by the MNR is that although the model behaviour does not predict a different outcome between 300 and 600 years, the outcome of the forest through `redesign`` (MNR QUOTE: Concerning MOE’s question as to whether the age class structure will be compromised, the answer is that age classes will be re-distributed by design, (pg 34)) will mean a species shift – specifically, spruce will be replaced by a younger jack pine forest with poplar and (due to suppression) balsam fir.

This raises the potential of catastrophic and irreparable consequences of Species conversion and the exacerbation of climate change as a result of harvesting – both these issues were cited in my original bump up request of April 8, 2008 but neither have been addressed in the MNR`s response. I have re-visited these in Issue No 6.

ISSUE NO 5: FRI INVENTORY BIAS SFMM RESULTS

As previously stated in my bump up:
The difficulty is, the forest age structure is usually also unknown, so it must be estimated first. This is usually done by sampling a number of patches, and determining their time-since-fire by aging some of the standing trees.
Heather Farrer (nee Blackwell), Regional Forester of the Geraldton MNR provided this response to my inquiry on how tree age was determined in Ogoki:
In 1988, the MNR conducted a Forest Resources Inventory (FRI) on the Ogoki and Nakina North Forest. This project included field sample plots that, in addition to collecting species compositions, collected representative age and height data on dominant tree species within individual stands. These “calibration plots” were scattered throughout the forest in a wide variety of stand conditions and were utilized by qualified aerial photo interpreters to assign representative stand characteristics to every stand across the entire forest. At later dates, further ground truthing has occurred in select areas as required by any number of non-FRI related projects. A new FRI is currently scheduled for the Ogoki (tentatively) in 2009. This three-year process will result in a relatively accurate update to the current condition (including age) of the forest.
Cummings states:
``There are difficulties with this approach. The difficulty is, the forest age structure is usually also unknown, so it must be estimated first. This is usually done by sampling a number of patches, and determining their time-since-fire by aging some of the standing trees.
``It depends crucially on adequate sampling of the oldest stands, and on unbiased estimates of their ages. However, such stands are rare, and may be systematically under-sampled (Finney 1995). In addition, the usual indicators of time-since-fire are the original cohort of trees, which are eventually lost from the site (Fox 1989).
``The case if much worse when forest inventory data is used to estimate an age structure, as has been done by Van Wagner (1978) and Murphy (1985). The fact that very old stands are absent from forest inventories is not evidence that none exist. At best, it is evidence that they are not detectable from aerial photography. Forest inventories are biased against the detection of old stands, because ages are determined from tree heights. It is invalid to estimate fire parameters from forest inventories alone (Cumming et al. 2000)

The 2005 Audit acknowledges these risks as follows:
, and possible errors in the forest inventory. When short fire return times are modelled, relatively little old forest remains since most areas burn before they can become old. Longer fire return times result in more old forest. This is an important point for the Ogoki plan, as the targets for old forest are an important component of the forest’s ecology for woodland caribou and several other wildlife species.

There is considerable uncertainty surrounding the natural fire return time on the Ogoki Forest, and there is not a concordance of opinion amongst qualified MNR staff on this topic. (The Audit Team interviewed several MNR scientists and experts on this topic.)

ISSUE NO 6: Forest `redesign`` will result in accelerated species conversion which will be further exaserbated by climate change resulting in a loss of productivity

As noted on page 13 of this narrative, the MNR concede their management strategy will result in a younger, jack pine and poplar dominated landscape at the expense of spruce. Lowland spruce predominates (60%) Ogoki today. The cold wet weather keeps it there.

As explained in more detail in my original bump up:
Forestry practices and fire suppression in the boreal forest are, in fact, driving the change in species composition. The information presented in the [MNR's] report that details the increase in poplar and decrease in spruce over a five year period is a microcom of the larger shift in the boreal away from spruce and pine forest, towards forests of white birch, aspen and balsam fir. Cutting practices simplify forest diversity, resulting in a loss of mixed forest, and the conversion of coniferous and mixed forests to deciduous forests."(4) (Page 7)
"Research in the boreal forest in Ontario has indicated that "...the observed increase in shade intolerant hardwoods at the expense of conifers...has been attributed to increased application of mechanical clear-cutting practices in the province's boreal region over the past 50 years" and further, "the shift in species composition in the boreal region from coniferous to deciduous species may be directly attributed to clearcut harvesting, either because of differences in post-clear-cutting and post-fire successional trajectories, changes in stand age distributions, or both"(5)
Please refer back to my April 8, 2008 submission for more details. This species conversion will have devastating consequences and will accelerate climate change. Again, referring back to my original bump-up:
“Canada’s boreal forest builds soil, filters water, captures carbon and produces oxygen. While difficult to monetize the value of such life-giving functions, these life-support services have been quantified as nearly $70 billion worth of life-support services for Canadians annually.”
``Boreal ecosystems contain relatively low numbers of species (approximately 100,000 in Canada) and their simple community structures make them vulnerable. Limited numbers of plant and animal species result in a lower information content (i.e. DNA) in an ecosystem. Efficiency is reduced if the information content of a system is reduced. Therefore, removing a few species from a boreal ecosystem that contains only hundreds of species may be more likely to degrade vital community and ecosystem functions than the removal of the same number of species from a tropical ecosystem that contains hundreds of thousands of taxa. The disappearance of only a few species has been shown to impair the proper functioning of food chains and biogeochemical functions in boreal lakes. Additionally lower biotic productivity of boreal ecosystems increase their recovery time following disturbance.
``There are three main areas that will be impacted by climate change: “changes in forest distribution and composition”; “increased frequency of forest disturbances”; and “changes in forest productivity”. The distribution of tree species is dictated by temperature, amount of precipitation and length of the growing season. So as the climate changes we are likely to see changes in species composition and distribution.
“Most models predict increasing temperatures; they don’t see a decrease in temperatures. One model for 2040 projects that summer maximum temperatures will increase over the northwestern part of the province and that the winter minimum temperatures will increase significantly over this same area.”
“With a warmer climate we are likely to see more natural disturbances like insects, forest fires and extreme climatic events. As the forest become more degraded or stressed, the more vulnerable they are to insects. As the temperature warms, there will be an invasion of southern insect species into those areas such as the Mountain Pine Beetle.”
Regarding the impacts that climate change will have on forestry the study notes:
“With increased CO2 levels there will be an increase in photosynthesis, and in turn, an increase in tree growth. If conditions become wetter and drier, then there will be decreased productivity and increased forest fires and decreased forest cover.”
“What we are most likely to see happen to the distribution of tree species? We are going to see a range shit northwards by some species, like white birch and black spruce, and those areas will be replaced by species common to the south, like red oak. There will also be a decrease in the growth and competitiveness of tree species that can not keep pace with the changing climate. The forest will degrade and eventually lead to a change in the “wood supply, forest type and wildlife habitat”.


ISSUE NO 7: Harvesting will result in the permanent loss of deadwood
Constraints on my time do not allow me to fully explore the impacts the harvest will have on the eco system.
In simple terms, boring a hole in a tree and calling it deadwood however isn`t going to cut it. It is not hyperbole to suggest economies of scale that provide a measly 25 trees per hectare are going to result in the permanent loss of an ecosystem and the overall loss of productivity of the entire FMU. It has already happened in Sweden – it can happen here. I`m particularly concerned with the MNR`s response that indicates slash and woody debris will be brought to roadside and removed. I question the financial motivations and a management strategy that is biased to short-term production gains as the expense of the longer term implications.

Below is some additional detail. I have included the pdf source document as an attachment.

Silviculture and dead wood
``Forest management has altered forest ecosystems in at least three ways: 1) the size, configuration and spatial distribution of different forest stand types has changed (Mladenoff et al., 1993); 2) the structural features of different forest types and the transition zones between them have changed (Angelstam, 1992); and 3) particular microhabitats, e.g. snags and decaying wood, have been lost (Esseen et al., 1992).

``Clear-cutting has large effects on a variety of organisms (Pawson et al., 2006). The surrounding forest communities often suffer from steep gradients between stands with different micro-climatic conditions and other edge effects (Chen et al., 1999). The loss of natural forests threatens the long-term persistence of many species that are confined to these habitats (Fahrig, 2003 and references therein).

``Dead wood is a key factor for biodiversity in boreal forests as it hosts a large number of polypores and other decomposing fungi, bryophytes, lichens and invertebrates (Siitonen, 2001). Large amounts of dead wood are also characteristic of old-growth boreal forests (Lämås & Fries, 1995; Ohlson et al., 1997; Linder & Östlund, 1998). The amount of dead wood is sometimes considered to be the main difference between managed and natural forests (Samuelsson & Ingelög, 1996).

``In Sweden, the managed forests with the largest amounts of dead wood are the oldest stands, which are mature for harvest (Siitonen, 2001). Following harvest, the amount of dead wood decreases significantly. Models suggest that the amount of dead wood decreases to 30 % of the preharvest amounts at the end of the first 100-year rotation and to six percent after the second (Spies & Cline 1988 in Hansen et al., 1991). In natural boreal forests, the amount of dead wood is greatest immediately following disturbances such as fires or windstorms (Uotila et al., 2001; Pedlar et al., 2002). Along with this is a high species diversity (Junninen et al., 2006).

``At the same time as more dead wood is being created and left in clearcuts, a new forestry practice is arising in Sweden and elsewhere, in which logging residues (slash) as well as cut stumps are being removed for biofuel. This is done with the aim of reducing the dependence on fossil fuels (Egnell, Liedholm & Lönnell,
2001). Most studies on biodiversity associated with dead wood have focused on coarse woody debris (diameter >20 cm) (Siitonen, 2001). An increasing number of studies have, however, showed that fine woody debris (diameter <10 cm) may support as many or more species as coarser debris when the same volumes are compared (Kruys & Jonsson, 1999; Nordén et al., 2004). Twigs and branches may be an important breeding substrate for saproxylic insects, likely because they become warmer earlier in the season and thereby promote insect activity (Edmonds & Eglitis, 1989; Jonsell, Weslien & Ehnström, 1998).

``On newly clear-cut sites, slash reduces wind velocity and affects temperature fluctuations both below and above ground (Proe, Griffiths & McKay, 2001). Slash contributes to structural heterogeneity at the stand level and, in doing so, may have both short- and long-term effects on the species richness and composition of ground-living beetles (Nittérus & Gunnarsson, 2006; Nittérus, Åström & Gunnarsson, 2007). Slash has also been shown to provide shelter for both small mammals and desiccation-sensitive bryophytes (Ecke, Löfgren & Sörlin, 2002; Åström et al., 2005).

Below is the MNR`s response:

Downed Woody Debris
Following harvest, logging slash and roadside chipping waste, brought or generated at roadside, may be left at roadside. The objective of slash management operations will be to increase the amount of available growing space for natural or artificial regeneration amongst roadside debris. Where possible, mechanical site preparation equipment will be used to reclaim this productive growing area.

Other roadside slash management activities, such as spreading, rowing, piling or burning may be employed to achieve this objective. At the time of plan development, slash management strategies were undergoing many changes on the Ogoki Forest and other SFL’s managed by Buchanan Forest Products Ltd. Provincial concerns regarding biomass utilization topped with widespread financial constraints began forcing the trials and adoption of alternative slash management methods. The actual methods employed will consider these concerns and such things as the quantity, type, depth, distribution of roadside debris and wildlife travel. (pg 33)



RECOMMENDATIONS

I preface the below recommendations with the strong urging that a collaborative discussion be allowed to take place that includes all requestors and the MOE. Here are some ideas:

1. 3rd party scientific review in the form of a nationally or internationally recognized panel of experts should preside – reviewing the strategy, the assumptions, the modelling language – in short EVERYTHING. The panel should include experts in modelling, caribou biologists, boreal eco system subject matter experts and scientists from abroad (Sweden for example) to provide a `lessons learned`` perspective, particularly in regards to the deadwood issue.
2. Investment in geo-spatial modelling tool to completely replace the current SFMM and the process methodology by which caribou habitat and mosaic is interpreted and designed. The MNR is constrained by disparate systems that require considerable manual rework and subjective evaluation – the SFMM, the caribou database, the FR inventory. The limitations in software are evident in their plan – the mosaic for example does not include calving lakes, migration routes or other critical habitat and ecological criteria.
3. The immediate and comprehensive update of Ecosite information and FR inventory.
4. Forester retraining and investment in eco-system based science training. The MNR background in southern Ontario does not qualify them as experts in the boreal.

My Bump up for Ogoki

Issue #1: Clear cutting as a method of forest extraction has historically and irrevocably changed the age class and composition of managed forests in Ontario.

"Research in the boreal forest in Ontario has indicated that "...the observed increase in shade intolerant hardwoods at the expense of conifers...has been attributed to increased application of mechanical clear-cutting practices in the province's boreal region over the past 50 years" and further, "the shift in species composition in the boreal region from coniferous to deciduous species may be directly attributed to clearcut harvesting, either because of differences in post-clear-cutting and post-fire successional trajectories, changes in stand age distributions, or both"(5)

Observe the conifer tree density in a burn then look at the conifer density in a standard clear cut. In a burn the high density of conifer growth will for the most part preclude competing species from growing in any significant numbers. The open patterned hand planting of an industrial clearcut will actively encourage competing species to grow and will require the application of chemical herbicides to eliminate them. The open pattern of the industrial replant will also not allow the progression toward the correct light and humidity conditions which are essential for the production of the lichen required to sustain caribou populations through the winter. In order to actively emulate a fire driven system, each stage of forest growth must be faithfully reproduced as closely as possible. Failure to allow each progressive stage of the natural cycle to occur (in an effort to artificially increase the rate of fibre growth), will result in an altered eco-system that will not sustain the life that previously inhabited the region. Early high density conifer growth and the subsequent process of naturally occurring thinning (a classic example of survival of the fittest) is key to recreating the classic, fully functioning mature boreal forest.

Recommendation #1: Suspend all forest operations in the Ogoki Forest pending an Environmental Assessment that would isolate the impacts timber harvesting has on species conversion separately from conversion due to natural causes. To fulfill this commitment, benchmarks should be established that map the pre-industrial state of the Ogoki forest and then indicators should be employed to ensure that species composition is maintained.

Recommendation #2: Improve silvicultural effectiveness by hand planting or better yet aerially seeding locations where tree densities are too low. Conifer density (not woody stem growth as is the currently used indicator) is a critical part of emulating the fire driven Jack Pine forest.

Issue #2: There is no evidence that the proposed 48% of the forest will regenerate naturally as planned to meet the Ministry’s mandate to retain bio-diversity on Crown Land.

Clear Cutting means Saying Goodbye to Ontario's Old Growth Forests

The Ogoki forest in July of 2007 - Jack Pine and Spruce filled with beds of lichen and moss

"Old growth is the ultimate forest - it is where nature has taken it's course and the forest continues to grow"

The average lifespan of a tree species within the Ogoki Forest ranges between 90 and 300+ years. Black spruce living in lowland areas (swamps) can live well past 300 years - surviving wildfires, windstorms and disease; jack pine is considered a relatively short-lived conifer at 140 years. But old trees alone do not make old growth forests. Old growth forest develop when trees live long and die natural deaths, creating a diversity of structures, habitats and ecological conditions.

When a tree is converted to lumber, firewood, paper or other wood products, it is lost from the natural system. But when it dies a natural death in the forest, its body and influence lives on. This makes Ogoki unique from many other Ontario forests becuase Ogoki has only began a cycle of forest management in the last 10 years.

Old growth forests have many values:

• Habitats for forest species and wildlife communities
• Sources of habitat diversity
• Living examples of how natural forests work
• Sources of inspiration and heritage appreciation

But there value extends well beyond habitat for creatures such as the Woodland Caribou. Boreal forests in Canada including the Ogoki forest sustain human life on the planet .

“Canada’s boreal forest builds soil, filters water, captures carbon and produces oxygen. While difficult to monetize the value of such life-giving functions, these life-support services have been quantified as nearly $70 billion worth of life-support services for Canadians annually.”1

In southern Ontario, less than .07 percent of the land base is in stands older than 120 years. Old growth forest remnants are also at risk. Elements of old growth - dead trees, logs and soil diversity provide important ecological services and enrich the habitats for wildlife. But these remnants often do not survive standard logging activities. Boreal forests like Ogoki are particularly vunerable when industrialized activity predominates.

"Boreal ecosystems contain relatively low numbers of species (approximately 100,000 in Canada) and their simple community structures make them vulnerable. Limited numbers of plant and animal species result in a lower information content (i.e. DNA) in an ecosystem. Efficiency is reduced if the information content of a system is reduced. Therefore, removing a few species from a boreal ecosystem that contains only hundres of species may be more likely to degrade vital community and ecosystem functions than the removal of the same number of species from a tropical ecosystem that contains hundres of thousands of taxa. The disappearance of only a few species has been shown to impair the proper functioning of food chains and biogeochemical functions in boreal lakes. Additionally lower biotic productivity of boreal ecosystems increase their recovery time following disturbance."1

A dead tree in a forest opens up new worlds of forest life, first as a dead standing tree and then as a fallen log. Dead trees and fallen logs can easily last as long in the forest as when the green tree was "alive", sometimes longer. Large logs, for example, can last over 100 years on the ground floor before being completely reabsorbed into the eco system.

Dead dying and decaying trees provide habitat for animals such as osprey, woodpeckers, grouse and squirrels. Now imagine what the forest will look like after a clear cut of 10,000 ha...

"It all resembles modern warfare. First they send in the mechanized brigades. Then come the foot-soldiers. Aierial bombardment even has a role. The entire operation is dependent on some of the latest technologies. But the action isn't taking place in a dusty Persian Gulf desert. This campaign is being waged in Ontario's boreal forest, where the pine-scented stillness is usually disturbed only by the strident cry of the blue jay and the loon's gentle call.

The mechanized attack is led by diesel-powered machines called feller-forwarders that look like huge praying mantises. They rumble through dense stands of jack pine, their hydraulic cutting heads shearing off spindly trees and depositing them onto their backs. When fully loaded with tons of pulpwood, the machines groan back to the roadside landing where the trees are limbed and dumped onto waiting trucks for the long voyage to the mill. Every year the trip gets longer as the forest frontier recedes.

The infantry of industrial forestry consists of hundreds of little platoons of tree-planters deployed in the wake of the logging machines. Every spring this small army -- mostly college students from the south along with a few local natives and whites -- fans out across the north, packs stuffed with the tiny seedlings that, it is hoped, will transform the massive clear cuts into productive forests.

Later, small planes will fly over the new plantations, their specially-fitted nozzles releasing a fog of chemical herbicide that, it is hoped, will kill off unwanted hardwood competition and allow the cutover land to support a crop of the spruce and pine whose long, strong fibres have always been the basis for the success of Canada's single most important industry. One of the most popular herbicides among foresters is the old standby 2,4-D, a compound first developed when the US military was looking for more effective chemical weapons during World War II"2

The boreal forest is unlike any other in Ontario - the Ministry of Natural Resources has stipulated a specialized silviculture technique be employed. CLAAG (Careful logging around advanced Growth) is a harvest method that is used in low-land areas of the Ogoki forest where it is felt natural regeneration (as opposed to artificial) is optimal. That means the logging company does not replant - rather advanced growth and seedbeds provided by mother nature are relied upon for natural regeneration. The Ogoki forest plan for 2008-2018 will have 48% of the area naturally regenerated - 52% will be re-planted artificially by forest operations. The 48% figure does include some hardwood - the north west ecozone region where Ogoki sits has 25% of its area covered in wetlands. So it could be reasonably assumed 25% of the entire harvest operation will require CLAAG harvest technique.

The above photo is of the Ogoki Forest after a CLAAG harvest and was taken by the Audit team in 2000 . Should they all look like this? No - this is a clear example of what should not be done in a CLAAG harvest. The harvest has pretty much wiped out any hope of advanced growth taking off and with it any hope of reforestration. Artificial replanting will be necessary and assuming the licenseholder follows through - it will mean additional cost and effort. The factors affecting the rutting are cited in the auditors report (this is an independant environmental auditor who is hired by the forest operations to audit the license holder as set out by law in the Crown forest sustainability act - it must be done every 5 years). Primarily it boils down to operator error and the forest company choosing to log the forest when the ground is not frozen - imagine a winter thaw and the damage heavy machinery will have on wetlands . The auditor cites the other reason - cost. Buying high-floatation equipment is extemely expensive so the foresty operations rely on bringing in their regular machinery but cutting only when its frozen . Works fine unless you have a winter like last year where the temperatures were so mild. Or a cold winter with a sudden thaw.

The following silviculture standards must be adopted by the Ontario Government for boreal forests such as the Ogoki.

1. Diligently locate and document vital habitats and significant features. Updating NRVIS databases and Wildlife specific databases are critical.


2. Buffer zones (and animal travel corridors) left around water features and critical habitats are to be significant . 13 km buffers around caribou calving lakes, and any natural distribance (road, harvest block) should be mandatory.


3. Roads are to be located so as to avoid crossing navigable waterways and if they are absolutely required to do so, they should be designed to do so only once. Upon discontinuation of use they should be decommissioned, replanted and continued use should be agressively discouraged. Roads that cross known caribou migration corridors (like the Reckett road) must not be permitted - period.


4. When cutting operations begin they must be done utilizing equipment that leaves the smallest footprint possible on the land –the best floatation tires or other such devices should be mandatory on any piece of equipment that leaves the roadbed or landing areas.


5. All log preparation should be done in the field i.e. the tree is cut, topped, delimbed, cut to transportable size –all done exactly where it stood, then once a truckload is gathered, it is brought to the edge of the cut to be loaded onto a truck and hauled out. The current practice of cutting down the tree and transporting the entire tree to a landing, placing it into a pile where it is later topped and delimbed thereby creating huge slash-piles that are later burned, is a horrible practice that leaves an uneven distribution of the biomass (forest building nutrients) concentrated in one location. The current practice is also the cause of severe rutting of the forest floor because of the numerous trips required to bring small numbers of trees to the landing for further processing. By processing trees in situ the number of trips through the field is reduced thereby reducing rutting.


6. Burn it. With all the limbs and tops left in situ a burn over will open seed cones and begin the reforestation process. Because the seeds will not be dropped from their normal height, distribution will be uneven therefore another step is required.


7. Hand plant or better yet aerially seed locations where tree densities are too low –conifer density (not woody stem growth as is the currently used indicator) is a critical part of emulating the fire driven jackpine forest. Observe the conifer tree density in a burn then look at the conifer density in a standard clear cut. In a burn the high density of conifer growth will for the most part preclude competing species from growing in any significant numbers. The open patterned hand planting of an industrial clearcut will actively encourage competing species to grow and will require the application of chemical herbicides to eliminate them. The open pattern of the industrial replant will also not allow the progression toward the correct light and humidity conditions which are essential for the production of the lichen required to sustain caribou populations through the winter. In order to actively emulate a fire driven system, each stage of forest growth must be faithfully reproduced as closely as possible. Failure to allow each progressive stage of the natural cycle to occur (in an effort to artificially increase the rate of fibre growth), will result in an altered eco-system that will not sustain the life that previously inhabited the region –especially the caribou, an indicator of the failure of current practices. Early high density conifer growth and the subsequent process of naturally occurring thinning (a classic example of survival of the fittest) is key to recreating the classic, fully functioning mature boreal forest.

1. The Boreal Below: Mining Issues and Activities in Canada’s Boreal Forest Region, December 2001
2. Jamie Swift has been following the changes in Canadian forestry for ten years. He is the author of "Cut & Run: The Assault on Canada's Forests" (Between The Lines, 1983).
3. Clear Cut Photo courtesy of http://creativecommons.org/licenses/by-sa/3.0/

Its not too Late! Write your Environmental Assessment TODAY!

The Ministry`s Plan for Ogoki - Summary

1. The Forest Management Plan for the Ogoki Forest will result in harvesting of timber through exceptionally large clearcuts (10,000 ha or more).

2. The plan further stipulates that to meet this objective, the plan assumes 100% silvicultural effectiveness although only 52% of the forest artifically regenerated. Nature will be asked to regenerate the remaining 48%.

3. A specialized harvesting prescription called Careful Logging around Advanced Growth (CLAGG) will be utilized in low land spruce areas to minimize soil disruption and the destruction of advanced growth. Natural regeneration (as opposed to artificial) is planned for these areas of harvest which represent about 25% of the total area harvested. The balance of natural regeneration will be in hardwood/mixed forest.

4. The Caribou Mosaic stipulates the rotation of harvesting will occur within a given block every 100 years - such that an area that is cut today will not be re-harvested for another 100 years. Three small blocks (F blocks) have been identified within the plan for harvesting beyond the 100 year rotation - rotations for these three blocks range from 120 to 160 years.

5. The MNR proposes landscape connectivity for caribou to migrate through will be maintained by providing forest in adjacent blocks to those that are currently being clear cut for a period of approximately 30 years. Their position is that habitat > 30 years of age (in general) supports current and future caribou habitat needs.

6. Fire cycles (fire return rates) are modelled in the 2008 plan between every 90 and 350 years yet the forest is being cut every 100 years (with the exception of 3 small F blocks cited above). So tree age will never exceed 100 years (assuming it survives any natural disturbance) and deadwood will be non-existant in 100 years time. The MNR acknowledges the average age of the forest will decrease.

7. The Reckett Road construction will continue. This road borders Wabakimi Provincial Park and crosses a major caribou migration corridor. Roads will also be built around every block.

8. Increased Moose Habitat will occur as caribou winter habitat is decreased. This will bring deer, moose and wolves which will in turn increase the risk of predation for caribou, increase the risk of caribou disease (parasites) and reduce suitable caribou habitat.

Paddling the Ogoki Forest

Morning Paddle on Marshall Lake

Crows. Whether they are cawing to greet the dawn at first light, or flying alongside my canoe as self-appointed sentinels to guard and guide me through this wild place, after five days of canoeing alone with two dogs in relative solitude, I realize I have come to not only expect - but to rely on their presence. Yet now, fully clothed and swimming alongside my canoe, one hand holding the line on the gunwale, the other pushing hard against the current in a sublime act of sacrifice designed to keep up all from drifting perilously back downstream, I can't hear anything except my dog's whining pleas for mercy and the sound of churning water as it forces its way past rocks and debris.

The Ogoki forest is 14+ hours or 750 miles by car from Toronto to the put-in at Marshall Lake, which can only be accessed via logging roads that run north-west off Highway 11, deep into the bush within the Township of Greenstone. Widely regarded as the Mecca for hunting and fishing, Greenstone is a microcosm for Northern Ontario. Sprawling across 2,780 square kilometers, this municipality is the largest incorporated town in Canada, larger than several countries yet host to less than 6,000 people. Although a hard-core mining and pulp and paper culture is still evident, with the Greenstone amalgamation in 2001 and a recently launched web portal in 2007, the north has clearly revitalized itself with a direct focus on tourism. In spite of the marketing and hype, canoeists seeking adventure in "shield country" are admittedly few and far between. But if the view of break-taking boreal landscape is what you yearn for, and solitude is your idea of a daily fix, the Marshall Lake Canoe route within the Ogoki forest is the drug that will take you to a place where magic begins.

Now as I scan the shoreline for a log or branch to hold on to, shoulder deep in "adventure", I must confess that onlookers would be justified to conclude this girl's gone wild! With sunglasses askew on my forehead, a torso soaked through to the bone, and hair gnarled with forest flotsam, it would seem the final stages of transmogrification were upon me. How ironic, that my wish for "magic" would be granted conditional to such comedic and grotesque distortions. Decorum gone, I refuse to be diminished by my situation, and in spite of my dogs' pleas to get back in the canoe where I belong, I continue my slog upstream against the current for another kilometer until finally, the water is calm and I can once again paddle safely to terra firma.

Whether you blame it on global warming or just the luck of the draw, with over 30 days of rainfall in the past 6 weeks, water levels in north-western Ontario have reached biblical proportions: an arc might have been a better choice! High water means fast water, and this makes paddling upstream impossible. Portaging through thick spruce, rock and blow-downs isn't an option, so it is walk, swim or battle my way back to the lake.

But decision-making is part of the drill, and the excitement of the boreal is it's wild and unpredictable nature. High winds on large lakes can keep you wind bound for days at a time, wildfires are not uncommon during the summer months and leaving a detailed trip plan with the Ministry of Natural Resources or the Geraldton OPP is well advised.

As I paddle my way back towards Marshall Lake, rain clouds loom dangerously low overhead and the temperature begins to drop. I need to get off the water and find shelter. Weary from my foray in the creek, I look along shore for a place to crash and am drawn to a low-lying rock ledge that juts out invitingly from a nest of conifers. Paddling closer, I'm thrilled at my choice. Cloistered within these 80+ year old pine and spruce are deep beds of lichen and moss. Lichens are not a single plant, but rather a complex group of plants that maintain a close association between a fungus and algae in a symbiotic relationship only nature could divine. Lichens are the primary food source of the Woodland Caribou, found only in old growth forests like Ogoki where the average tree is more than one hundred years old. In the harsh northern climate where vegetation is often scarce, lichens provide this prey animal with a much needed advantage for survival. Sadly, these majestic creatures and one of the most emblematic species of Canada's boreal wilderness are at risk of extinction in Ontario, where their range has dropped by about 50% in the last 100 years.

There is no question their biggest adversary now is logging. Since 1998, the Buchanan Group acting through its subsidiary Long Lake Forest Products has bee harvesting timber in the Ogoki Forest. The 20 year license issued by the Ministry of Natural Resources is now up for renewal. The current plan proposes harvesting via clear cut approximately 70,000 ha of Boreal Forest over the next 10 year period commencing April 2008. 70,000 ha is abou the size of the city of Ottawa! For a few moments I forget my beleagured shoulders and sit in silence, hoping to see any sign of Woodland Caribou. As I ponder the fate of the forest and the caribou, I wonder if it is a coincidence that the name Lichen means "dejection" and "solitude".

The next morning, I awake to a bright and sunny day. The rain has passed, and I am eager to get back on the water. Sleeping on a bed of lichen is an unparalleled experience in comfort. I am revitalized! I pack my gear and command the dogs to load. After taking a careful inventory to ensure I have left no trace, I look around one last time to fill my senses with the sight and smell of this idyllic place.

In my canoe paddling towards open water, I smile. The crows are back, announcing to the world my arrival. I feel comforted once again by the cacophony of beating wings and rhythmic cawing as my blade cuts through the water. Straining my eyes, I look through the dense canopy to see where these mythological messengers of spirit and creation and hiding. Too smart to be goaded into view, they remain in the shadows, safe from predators while they boldly continue to mock and chide me. It's going to be another great day!

The above trip to the Ogoki Forest was taken in July of 2007. For detailed route information check out the Canoeing and kayking section under the Culture & Recreation tab in the Greenstone portal at http://www.greenstone.ca/