Some comments received did not result in changes to the proposal because they were not within the immediate scope of the proposal (e.g. review the status of the Blanding’s turtle as a species at risk) or potentially might result in increased risk to the species (e.g. remove restrictions on hauling within the Blanding’s turtle AOC).
The main changes to the proposal based on comments received are summarized below by broad themes:
General support for the proposal: Thirteen of the 14 submissions supported the proposed changes to the previous direction in the Stand & Site Guide. However, they generally suggested that the proposal did not go far enough to address the significant socio-economic impacts associated with implementation of the current direction, especially in light of perceptions that i) these species are more common and widespread than anticipated and ii) the species are frequently found in areas of past operations so forest operations appear to represent a low risk. One submission was opposed to changes in the current direction based on the perception that the changes would result in less protection for the species, were not supported by science, were ambiguous, and would be difficult to enforce. To address these comments changes were made to the proposal to make direction less ambiguous, provide some additional flexibility for the forest industry (when this could be done without increasing risk to the species), and provide some additional protection for the species when deemed necessary. To make the direction more enforceable, clarity was improved, clear objectives were provided, and more opportunity was provided for MNRF to specify locally appropriate (and enforceable) conditions on operations. The scientific basis for changes is outlined in the associated background and rationale document (available at www.ontario.ca/page/2016-revisions-forest-management-conserving-biodiversity-stand-and-site-scales).
More flexibility: Numerous submissions suggested there should be more opportunity for local MNRF and forest industry staff to develop local solutions to local problems. Where considered appropriate, revised direction identifies specific objectives, then permits MNRF to specify locally appropriate conditions on operations based on local experience and best available information and advice (examples of potential practices listed in the original posting have generally been removed).
Description of habitat: The description of habitat was simplified considerably to address concerns about clarity and ambiguity.
More flexibility in construction of new roads: Some additional flexibility was provided for the construction of new roads to address concerns about socio-economic impacts on forest operations (if they can be built in a manner that does not increase risk for the species). Specifically, new roads are permitted within 30 m of suitable summer habitat if they can be constructed using techniques that will avoid traffic-related mortality (based on MNRF conditions). In addition, new all-weather single-lane roads are permitted within 150 m of suitable summer habitat if built on clearly recognizable roadbeds that are dominated by vegetation no larger than shrubs and sapling-sized trees, do not occur in high risk locations, will be decommissioned or subject to access control measures following operations, and are built in a manner that restricts traffic speed/volume, road longevity, and the risk of traffic-related mortality (based on locally appropriate MNRF conditions).
More flexibility in use of landings: In the absence of reusable landings, piling and processing of wood on road rights-of-way is permitted if consistent with restrictions on corridor width and concerns about worker and public safety.
More flexibility in construction of new roads: Flexibility was provided for the construction of new roads to address concerns about socio-economic impacts on forest operations (if they can be built in a manner that does not increase risk for the species). Specifically, new single-lane roads are permitted within the AOC if built on clearly recognizable roadbeds that are dominated by vegetation that, if removed, would not significantly alter the suitability of the roadbed or surrounding forest as potential ginseng habitat (construction, maintenance, and use subject to locally appropriate MNRF conditions designed to protect ginseng plants, maintain habitat suitability, and limit access by illegal collectors).