Black Sturgeon Forest And - Spruce River Forest 2006-2011 Independent Forest Audits Management Unit Action Plan - Ontario.ca

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Black Sturgeon Forest
              And
       Spruce River Forest
2006-2011 Independent Forest Audits

         Management Unit
           Action Plan

                                      1
INTRODUCTION

In September-October, 2011, Independent Forest Audits (IFAs) were conducted on the Black Sturgeon
Forest and Spruce River Forest by ArborVitae Environmental Services Ltd. for the period April 1, 2006
to March 31, 2011. The final printed audit reports were received May 2, 2012 and the action plan is
due July 1, 2012.

One combined action plan has been prepared for both IFA Reports since the Black Sturgeon Forest
(BSF) and Spruce River Forest (SRF) have been amalgamated into the Black Spruce Forest and many
audit recommendations are the same in both audit reports. The Black Spruce Forest 2011-2021 Forest
Management Plan (FMP) covers the new amalgamated management unit. MNR Thunder Bay District
is the administrative lead for the Black Spruce Forest.

The final audit report for the Black Sturgeon Forest includes 10 management unit recommendations
and the Spruce River Forest final audit report includes 8 management unit recommendations. Of those
audit recommendations 6 are the same in both audit reports and 2 are almost identical. Those
recommendations directed at corporate MNR will be addressed in the separate 2011 Provincial Action
Plan (BSF R#3, 4, 6, 7, 12, 14, 16, 18; SRF R#3, 4, 7, 8, 10, 13, 15). For each audit recommendation
this action plan outlines the actions required, responsibility, timelines, and method of tracking progress
of actions.

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RECOMMENDATIONS

Recommendation # 1 (BSF & SRF)
MNR shall provide a letter to the Company as soon as possible outlining MNR administrative
and reporting relationships related to the Black Spruce Forest.

Action Required:
1. The MNR Thunder Bay and Nipigon Districts will finalize its “Cross District Protocol – Thunder
   Bay / Nipigon – Forest Management Roles and Responsibilities” for the Black Spruce Forest and
   provide a copy to the Company.

Organization and Position Responsible:
1. MNR Thunder Bay District Manager (lead), Area Supervisor; MNR Nipigon District Manager, Area
Supervisor.

Deadline Date:
1. Completed April 5, 2012.

Method of Tracking Progress:
1. E-mail with document provided to Company.

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Recommendation # 2 (BSF & SRF)
(BSF) MNR District shall seek meetings with each of the First Nation and Métis organizations
with traditional areas in the Black Spruce Forest; discussions shall specifically address
opportunities for benefits from forest planning and forestry activities consistent with Term and
Condition 34.

(SRF) MNR District shall seek meetings with each of the First Nation and Métis communities
with traditional areas in the Black Spruce Forest; discussions shall specifically address
opportunities for benefits from forest planning and forestry activities consistent with Term and
Condition 34.

Actions Required:
1. MNR Thunder Bay and Nipigon Districts will continue to incorporate the matters referred to in the
audit recommendation as part of ongoing efforts including meetings to improve our relationship with
Aboriginal communities and organizations.

Organization and Position Responsible:
1. MNR Thunder Bay District Manager and MNR Nipigon District Manager.

Deadline Date:
1. Ongoing. The status report due 2 years after action plan approval will report efforts to date.

Method of Tracking Progress:
1. Condition 34 Annual Report, Status Report.

                                                                                                    6
Recommendation # 5 (BSF) & # 6 (SRF)
The Company shall specifically report on and discuss the planned versus actual harvest achieved
on the Black Spruce Forest, and the implications for the accuracy of the yield curves, in the Year
3 and Year 5 Annual Reports. The results of these assessments shall dictate any appropriate
planning response.

Action Required:
1. To the extent possible the actual harvest volume achieved, recorded in iTrees, will be compared to
   the planned harvest volumes annually and aggregated for discussion including the implications for
   accuracy of the FMP yield curves.

Organization and Position Responsible:
1. AbiBow Canada Inc. Planning Superintendent.

Deadline Date:
1. November 15, 2014 year 3 AR, November 15, 2016 AR.

Method of Tracking Progress:
1. Accepted Year 3 and Year 5 Annual reports.

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Recommendation # 5 (SRF)
MNR District and Company staff shall more fully utilize the FI portal to keep track of all
submissions (i.e. draft, draft final and final), MNR draft and final review comments, and final
approval for all ARs, AWSs, amendments and revisions to accurately define their status. This
may involve working with MNR Corporate to help resolve issues relating to tracking the various
submissions, MNR reviews and approval.

Action Required:
1. The audit report identified discrepancies in the number of FMP amendments in the Forest
   Information (FI) Portal compared to the actual number of FMP amendments. The requirements of
   the Forest Information Manual 2009, Forest Management Planning Technical Specifications
   Section 5.9 will be followed to address the recommendation:

   Only amendments that have been granted approval to proceed are required to be submitted to the FI
    Portal;
   The submission file will include the details required of the Tech Spec including written decision on
    granting of the amendment request, all files required of the amendment, amendments will be
    numbered sequentially for the 10-year period of the plan;
   Approved amendments will be submitted for viewing on the MNR website.

2. The audit report identified discrepancies in the number of AWS revisions in the Forest Information
   (FI) Portal compared to the actual number of AWS revisions. The requirements of the Forest
   Information Manual 2009, Forest Management Planning Technical Specifications Section 5.8 will
   be followed to address the recommendation:

   AWS changes include three types of information – AWS revisions (e.g. additions of new areas of
    operations from the approved FMP), appended documents (aerial pesticide project plans), and
    changes to values; these requirements will be reviewed to ensure that only AWS Revisions are
    submitted using the file naming convention for submitted information products AWSRV for AWS
    Revisions;
   Approved AWS revisions will be submitted for reviewing on the MNR website.

3. Regarding more fully utilizing the FI portal to track draft/draft final submissions and review
   comments:

The FI Portal is not designed to keep track of draft submissions and review comments. The FI Portal is
designed as a mailbox to submit information between the SFL and MNR. The Portal also maintains the
final official information that is used as the source of information for the public website where FMPs
and amendments, AWSs and revisions are posted. Therefore the FI Portal does not retain meta-data
pertaining to intermediate product submissions as only meta-data pertaining to final product
submissions are retained.

To track submissions and review milestones, the SFL and MNR District are required to archive emails
from the FI Portal that are auto-generated each time a submission is made (e.g. for amendments,
revisions, Annual Reports) and then sent to all members on a user-specified distribution list. Meta-data
for intermediate product submissions (e.g. draft AWSs, amendments, Annual Reports) are recorded in
these emails and are standardized as per the Forest Information Manual, i.e. the file name in the meta-
data provided clearly indicates what the product is and a date of when that product was submitted is
also provided. To ensure that Districts and SFL holders maintain sufficient records for auditing of
criteria 3.9 (amendments), 3.10 (AWSs) and 6.5 (Annual Reports), information was communicated to
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all planning teams during the FMP update training sessions in 2010. The SFL and MNR District will
also retain records of review comments and responses.

Organization and Position Responsible:
1. Amendment submissions through FI Portal AbiBow Canada Inc. Planning Superintendent;
submission of amendments for viewing on MNR website MNR Thunder Bay District Management
Forester.
2. Revision submissions through FI portal AbiBow Canada Inc. Planning Superintendent; submission
of revisions for viewing on MNR website MNR Thunder Bay District Management Forester.
3. Archive auto-generated FI Portal submission emails, review comments and responses: Abibow
Canada Inc. Planning Superintendent and MNR Thunder Bay District Management Forester.

Deadline Date:
1. Ongoing during implementation of 2011-2021 FMP (beginning April 1, 2011).
2. Ongoing during implementation of 2011-2021 FMP AWSs (beginning April 1, 2011).
3. Ongoing beginning April 1, 2011.

Method of Tracking Progress:
1. All approved 2011-2021 FMP amendments in FI Portal as per stated action.
2. All approved AWS revisions in FI Portal as per stated action.
3. Archive of auto-generated FI Portal submissions for draft, draft final, final amendments, revisions,
Annual Reports. Records of review comments and responses.

                                                                                                     9
Recommendation # 8 (BSF) & #9 (SRF)
The planning team for the next FMP (i.e. the 2021 FMP) shall calculate the managed fire return
time for the Forest using as much data as are available. The calculation shall reconcile the fire
return history on the Forest with that from the broader forest region

Action Required:
1. The Planning Team for the 2021-2031 FMP, with the support of Regional Advisors, will calculate a
   managed fire return time for the forest using as much appropriate data and scientific literature that
   is available and will consider a broader geographic context than just the management unit when
   considering and interpreting the available data. As well, any science package information
   developed to support the Landscape Guide development will be taken into consideration.

Organization and Position Responsible:
1. AbiBow Canada Inc. Planning Superintendent (lead), MNR Thunder Bay District Management
Forester, MNR Northwest Region Planning Analyst.

Deadline Date:
1. 2021-2031 FMP Analysis package by March 31, 2019, approved FMP by March 31, 2021.

Method of Tracking Progress:
1. Analysis package in approved 2021-2031 FMP.

                                                                                                     10
Recommendation # 9 (BSF) & #11 (SRF)
The Company shall ensure that harvest operators follow the requirements of the Stand and Site
Guide regarding residual wildlife tree retention.

Action Required:
1. All operators will be trained as to the requirements regarding residual wildlife tree prescriptions
   with-in the 2011 FMP. The Company has arranged for office and field training to be completed by
   the authors of the Stand and Site Guide.
2. Managing for Wildlife Trees in the Company Environmental Management System (EMS)
   documentation to be updated with the new Stand and Site Guide requirements in the 2011 FMP and
   sent to all operators.
3. The Forest Operations Inspection Program (FOIP) reports will be monitored with issues addressed
   as they arise and FOIP reports will be summarized for issues related to wildlife tree retention in the
   Annual Reports.

Organization and Position Responsible:
1. & 2. AbiBow Canada Inc. Planning Superintendent.
3. AbiBow Canada Inc. Operations Forester.

Deadline Date:
1. Completed. Training held, classroom March 9, 2011, field training May 9, 2012.
2. Completed. EMS updated – April 17, 2012 sent out to contractors.
3. Beginning with 2012-2013 AWS and ongoing annually.

Method of Tracking Progress:
1. Training records.
2. Updated EMS & record that was sent to contractors.
3. Compliance Summary in the Annual Reports.

                                                                                                      11
Recommendation #10 (BSF) & #12 (SRF)
The Company shall develop and implement measures to ensure the timely implementation of
silvicultural treatments, especially on rich, competitive sites and on mixedwood sites.

Action Required:
1. Review renewal status of harvested areas to identify any current areas with delays in
   implementation of renewal treatments. Where competitive mixedwood sites are not being left for
   natural assign “priority renewal” within the renewal tracking database to these sites to minimize
   delays in implementation of renewal activities.
2. Identify these areas as priority areas for renewal and schedule in AWS.
3. Implement treatments and report in annual report.

Organization and Position Responsible:
1. - 3. AbiBow Canada Inc. Renewal Superintendent.

Deadline Date:
1. November 15, 2012.
2. April 1, 2013.
3. November 15, 2014.

Method of Tracking Progress:
1. Record of review on file at AbiBow office.
2. AWS 2013-2014.
3. AR 2013-2014.

                                                                                                 12
Recommendation #11 (BSF)
MNR and the Company shall work together to assess reasons for the low rates of regeneration
success for hardwood forest units and implement appropriate actions to improve success rates in
the future.

Action Required:
1. The Company will review free-to-grow records and prepare a report documenting the rationale for
   former BW1 and PO1 forest unit area that was shown as not successfully regenerated in the 2006-
   2011 Annual Report AR-13 Summary of Assessment of Regeneration and Silvicultural Success.
   The report will include actions were appropriate to improve success rates. MNR will review the
   report and provide comments to the company for use in finalizing the report.
2. The Company will implement any actions noted within the report referred to in action 1 above.

Organization and Position Responsible:
1. Abibow Canada Inc. Renewal Superintendent and MNR Thunder Bay District Management
Forester.
2. Abibow Canada Inc. Renewal Superintendent.

Deadline Date:
1. December 31, 2012.
2. Ongoing after finalization of report in action 1 (December 31, 2012).

Method of Tracking Progress:
1. Report on file at company and MNR.
2. The status report will identify any actions that were required and what was actually done based on
   company records; improved success rates as documented in future annual reports.

                                                                                                  13
Recommendation #13 (BSF)
The Company shall make best efforts to avoid leaving large amounts of hardwood residuals on
harvested areas, and to minimize the use of the two-pass harvest system.

Action Required:
1. When markets do not exist, the hardwood strategy in the 2011 FMP will be employed utilizing the
   avoidance strategy when ever possible and the increased residuals as the least desirable option.
2. An amendment to the 2011 FMP will be processed to bridge existing harvest areas from the 2006
   plan with excessive residuals for clean-up.

Organization and Position Responsible:
1. & 2. AbiBow Canada Inc. Planning Superintendent.

Deadline Date:
1. Ongoing beginning April 1, 2011.
2. Completed August 19, 2011.

Method of Tracking Progress:
1. AR summary of the utilization of the hardwood strategy.
2. Approved Amendment #9277.

                                                                                                 14
Recommendation #14 (SRF) & #15 (BSF)
R#14 SRF: The Company shall ensure that all compliance reports are submitted within the
timeframes prescribed in the Forest Information Manual and MNR policies. Furthermore, the
Company shall ensure that the descriptive information entered in the FOIP reports is of
sufficient quality to accurately describe the site conditions and circumstances that are the subject
of the report.

R#15 BSF: The Company shall ensure that all compliance reports are submitted within the
timeframes prescribed in the Forest Information Manual and MNR policies. Furthermore, the
Company shall ensure that the descriptive information entered in the FOIP reports accurately
describes the site conditions and circumstances that are the subject of the report

Action Required:
1. Weekly and monthly meetings will be held with contractors to ensure timelines in the 2011 FMP for
report submissions are being achieved.
2. Bi-monthly meetings with the Company and the MNR will be held to discuss compliance issues and
block status.
3. All certified inspectors to attend the spring 2012 MNR compliance update course to reinforce
content requirements for FOIP reports.

Organization and Position Responsible:
1. - 3. AbiBow Canada Inc. Operations Forester.

Deadline Date:
1. Ongoing Starting in May 2011.
2. Ongoing Starting in May 2011.
3. Completed March 15, 2012.

Method of Tracking Progress:
1. Minutes of meetings on file.
2. Minutes of meetings on file.
3. Attendance record of March 15, 2012 training.

                                                                                                 15
Recommendation #17 (BSF)
The Company and MNR shall produce the Action Plan and Status Report for this audit
according to the required timelines.

Actions Required:
1. AbiBow Canada Inc., MNR Thunder Bay District, NW Region and Forest Branch will develop an
   Action Plan production and review schedule beginning with the Draft Final Report to ensure the
   Action Plan is submitted prior to the deadline.
2. AbiBow Canada Inc., MNR Thunder Bay District and the NW Region will develop a Status Report
   production and review schedule prior to the deadline and develop, review, and submit the Status
   Report according to this schedule.

Organization and Position Responsible:
1. AbiBow Canada Inc., MNR Thunder Bay District Management Forester; MNR Northwest Region
   Forest Program Specialist, MNR Forests Branch Provincial Forest Evaluation & Reporting
   Forester.
2. AbiBow Canada Inc., MNR Thunder Bay District Management Forester; MNR Northwest Region
   Forest Program Specialist.

Deadline Date:
1. Completed April 4, 2012 and updated May 9, 2012 due to delay in receipt of final audit report.
2. Prior to Status Report due date as determined by MNR Forests Branch based on Action Plan
   approval.

Method of Tracking Progress:
1. Actual production/review schedule; submission of action plan by scheduled submission date.
2. Submission of status report by scheduled submission date.

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