August 3, 2017
Re: Urgent Need for Clear Process and Science-Based Outcomes to Support Caribou Recovery
On behalf of Canada’s leading forest products companies and the 230,000 people we employ in hundreds of communities across the country, I am sending you an urgent letter requesting that the federal government give serious thought to adjusting the procedures and timing of its Caribou Recovery Strategy to achieve a more balanced and sustainable way forward for all.
We believe that the current process could jeopardize thousands of jobs and the well-being of hundreds of communities all the while not achieving caribou recovery goals.
In some provinces, we believe the current federally mandated process is resulting in a situation where incomplete and ineffective caribou range plans are being developed and may cause unintended harm. We are asking today that the federal government take a step back and reconsider the processes associated with the recovery strategy in order to ensure that the most current science and socio-economic impacts are taken into account.
Unless the current approach is altered, the positive outcomes we are all seeking for caribou will not be realized and a number of sustainable forestry operations will be put at risk, along with the well-paying jobs they support across rural and northern Canada.
As you know, our sector prides itself in the positive environmental benefits we realize every day. Indeed, the detailed forest management plans that our companies develop and implement at the provincial level are built to support biodiversity, and our harvesting practices are tailored to meet the unique realities of each forest area.
It is with this deep experience that we reach out to you today, on an urgent basis.
Caribou recovery plans still incomplete; risky experiment putting thousands of jobs at risk
The caribou is an iconic species, and Canadians want to ensure that all reasonable measures are taken to help the species recover. Since caribou was designated as endangered, our industry has invested substantially in programs across the country to improve our collective understanding of why some herds are faltering. Believing that solutions must be science-driven, we have been directly supporting a range of initiatives in partnership with leading researchers, environmental groups and community partners over many years. These include collaring programs, maternal penning initiatives and numerous other research and operational efforts to support caribou populations across Canada.
Under the current federal action plan for caribou recovery, there is no clear and consistent mechanism to allow provinces to factor this extensive research into their plan development. Instead, provinces are being obliged to meet disturbance and buffer thresholds set out in the federal plan, which limits flexibility in local decision making and stands to, in many cases, unnecessarily prohibit access to vast tracts of the forest. If we continue down this road, we cannot promise that caribou populations will rebound. We do however know that the lives of tens of thousands of rural and northern Canadians will be impacted. In short, we believe the current process needs to be realigned for the benefit of all concerned.
In that regard, we believe it would be in the interests of all Canadians for the federal government to review the current process and adjust the factors being taken into account in the Caribou Recovery Strategy to include the most recent research and experience, as well as the socio-economic impacts of any proposed policy changes.
Complex web of factors at play
It is important to remember in the context of this policy development that human activity is but one in a complex web of factors contributing to overall forest health. It is critical that the government base caribou recovery decisions on a thorough scientific assessment of all causes of caribou decline, from human and natural disturbance to climate change, predation, pathogens and disease.
Recent research shows that factors beyond human and natural disturbance on the land are clearly impacting caribou populations in Canada. We have seen a reported increase in caribou populations in areas like Lac Saint-Jean, Québec that are deemed to have a relatively high level of disturbance. Another study in Northern Labrador shows that caribou populations there are significantly declining despite the fact that region has one of the lowest disturbance rates in Canada. Similar outcomes are being realized in Banff and Jasper National Parks where there is no industrial activity, yet falling caribou populations.
While we were encouraged to see the government refer to provincial caribou range plans as plans “which can be adopted over time” in its Summary of the Action Plan for the Woodland Caribou released last week, we remain concerned that a lack of clear direction from the federal government on the need to consider all contributing factors to caribou population decline is leading to incomplete and inaccurate planning at the provincial level.
Misinterpretation standing in the way of progress; long-term initiatives offer hope
One of the most worrisome points of contention is the federal direction regarding a 65/35 non-disturbance/disturbance threshold, which some provinces have interpreted as an absolute rather than as guidance that can be adapted to regional conditions. No two regions of this country are the exact same and the broad application of this model poses a challenge to the best local outcomes. Also, given that the economic consequences of this threshold are now better known, we strongly advise that this provision, which was based on dated modelling, be refined. Weeks ago, we presented to senior staff of the Canadian Wildlife Service our detailed rationale for why the 65/35 formula simply does not work everywhere. We respectfully request that flexibility be conveyed, and implemented, in its application at the provincial level.
We are fully committed to continuing our collaboration with provincial governments, forest communities, Indigenous partners and multi-interest groups to create effective, science-based caribou recovery plans that meet local conditions. And, we look forward to contributing to the National Boreal Caribou Knowledge Consortium being set up by the federal government.
THE FEDERAL GOVERNMENT MUST RETHINK RANGE PLAN DEADLINES IN CONJUNCTION WITH PROVINCES OR CONVENE A NATIONAL CONFERENCE TO CAREFULLY ASSESS CURRENT STATE OF RECOVERY STRATEGY AND POSSIBLE RISKS. IMPACT ASSESSMENTS ALSO NEEDED.
We hope the federal government will undertake an urgent review of the current process with a view to ensuring that the provinces do not move ahead with their caribou range plans with undue haste in an effort to meet the federally imposed deadlines. This could be addressed by the federal government rethinking the range plan deadlines in conjunction with provinces or possibly by convening a national conference to carefully assess the current state of the recovery strategy, any possible risks in the timing and the way forward.
More specifically, we ask that the federal government consider mandating impact assessments for all at-risk ranges and carefully weighing the costs and benefits before sanctioning provincial plans.
Without undervaluing the importance of the Caribou Recovery Strategy, we are hoping that the process can be re-examined to produce a balanced outcome that fully incorporates the latest research and recognizes the need to weigh all impacts, including those affecting the economy and thousands of Canadian workers. We sincerely hope that the federal government will give serious consideration to adjusting the current recovery strategy in an effort to avoid inflicting irreparable harm on our industry and the Canadian economy.
Jobs at risk if no clear process or balanced outcome
Ministers, our 230,000 forest and mill workers, the hundreds of thousands of indirect jobs, and the communities who rely on these sustainable, renewable resource jobs depend on us all working together to get this right.
I would be pleased to discuss further, at your earliest convenience.
Chief Executive Officer
Forest Products Association of Canada