Ontario’s forests play an important role in world ecosystems. Our province is also home to about 17 per cent of Canada’s boreal forest, and 2.5 per cent of the global boreal forest. Many of the province’s 30,000 known species live within forested areas and every year millions of the world’s migratory birds use Ontario’s forests.

Approximately 80 per cent of the province’s forests are Crown lands managed by the provincial government. Over 35 per cent of this area is within the Area of the Undertaking (AOU), the region of Ontario where commercial timber harvesting actively occurs. The Ministry of Natural Resources (MNR) is responsible for sustainable forest management and the conservation of biodiversity, while the Ministry of Northern Development, Mines and Forestry (MNDMF) is responsible for the business and economic aspects of forestry.

Before forests are commercially harvested in Ontario, a forest management plan (FMP) must be developed and approved by MNR. Plan development is guided by four regulated MNR manuals. By the late 1990s, a collection of over 30 forestry management guides provided additional direction on dealing with finer scale, specific issues. In 1999, the ministry initiated a review of the province’s forestry guides. MNR decided to consolidate down to five guides, including the Forest Management Guide for Conserving Biodiversity at the Stand and Site Scales (the “Stand and Site Guide” or “guide”).

The purpose of the guide is to provide direction on planning and conducting forest operations at the stand and site level (i.e., tens of square metres to hundreds of square kilometres) so that “forest biodiversity will be conserved and Ontario’s forests will remain healthy and sustainable.”

Major issues addressed through direction in the guide include:

• stand composition, pattern and structure to allow for a variety of wildlife habitats;
• ecological function of aquatic systems and shoreline riparian zones;
• forestry activities in the ranges of particular forest species, such as moose, deer, and birds; and
• forestry activities in habitats of species at risk.

The Stand and Site Guide also includes direction for soil and water conservation, salvage and biofibre harvest, and road and water crossing construction. MNR staff are required to follow direction in the Stand and Site Guide when preparing 10-year FMPs that come into effect on or after April 1, 2011.

The Stand and Site Guide: Key Issues

Residual Forest

Residual forest is retained during forestry operations to provide wildlife habitat, particularly for species that inhabit older forest. However, the Stand and Site Guide’s definition for residual only requires a stand to be 35 years or older. The average age of forests in Ontario’s AOU in 2006 was 82 years old. MNR’s background and rationale document for the Stand and Site Guide suggests that residual forest will approximate older forests in its ecological function. However, the ministry admitted, “the response of wildlife communities to this direction has not been rigorously tested” and has indicated this will be a research priority. Therefore, the implication of this direction is currently unclear.

Wildlife Trees

MNR defines wildlife trees as “trees retained during forest operations with the intent to provide structure and features beneficial to wildlife in general, and for specific species, groups or communities.” Specific trees may be set aside for a particular purpose; for example, cavity trees provide habitat for bird and other animal species. While previous policy focused on the value of stubs to emulate forests after natural disturbances, the new guide is more explicit in recognizing the value of different types of wildlife trees, allowing protection of specific habitat and food sources. Nevertheless, the overall numbers of wildlife trees required for retention remain similar.

Shoreline Harvesting

The Stand and Site Guide outlines a conceptual shift in terms of shoreline cutting. In contrast to previous policy, direction in this guide not only permits, but also explicitly encourages, management in shoreline areas (Table 1). The ministry’s overarching rationale for the changes to shoreline harvest – from restriction to encouragement – relates to perceived ecological benefits. MNR notes where scientific evidence was not available that some components of shoreline AOC direction were “based largely on expert advice or inductive inference.” Harvesting will also be allowable in and around designated Provincially Significant Wetlands (PSWs) when MNR determines that forestry operations will not result in the loss of significant ecological functions or features.

Previous research has shown that shoreline cutting can be detrimental to aquatic and riparian systems. Much of this concern is related to increased runoff: increased concentrations of nutrients and sediments flowing into the water body can impair water quality and affect fish habitat and other aquatic biota. Although MNR has identified these biodiversity-related issues as key uncertainties in Stand and Site Guide direction, the ministry does not consider them of high priority for monitoring; MNR maintains that current research addresses these concerns. MNR will investigate how new direction emulates natural disturbances for some catchment-scale hydrological functions, such as increased release of methyl mercury into water bodies.

Habitat Protection

Although harming threatened and endangered species is prohibited in Ontario, the level of habitat protection currently provided for species on the Species at Risk in Ontario (SARO) list under the Endangered Species Act, 2007 (ESA) is variable. The Stand and Site Guide provides direction on specific considerations for habitats of many of the 59 species at risk within the AOU, although protection varies from species to species. Stand and Site Guide prescriptions may be especially important to species such as plants, reptiles and invertebrates which do not receive habitat protection under any other legislation. For some species, however, habitat protections afforded through the Stand and Site Guide may not be implemented by the time the ESA’s habitat protections come into effect.

Species listed as Special Concern on the SARO list do not receive any habitat protection under the ESA. For many of these species, direction in the Stand and Site guide will increase their overall habitat protection. For example, although the den sites of eastern wolf are protected under the Fish and Wildlife Conservation Act, 1997 (FWCA), the Stand and Site Guide provides additional protection for their rendezvous sites. It remains to be seen, however, whether future species of Special Concern will be included in updated versions of the guide.

The Stand and Site Guide provides specific guidance for protecting the habitat of 27 bird species. Although nests and eggs of most birds are protected from disturbance and/or destruction by either the federal Migratory Birds Convention Act, 1994 or the provincial Fish and Wildlife Conservation Act, 1997 the Stand and Site Guide provides additional protections for some species. Compared to previous direction, the buffers are larger for some species and smaller for others; while others are unchanged (Table 2).

Biofibre Harvest

The Stand and Site Guide includes limits on the removal of non-timber woody materials, noting that organic matter that is not part of a harvested tree must be left on site, and that “stumps and all below ground portions of a tree are not available for utilization as a forest product.”

The maintenance of biofibre on the forest floor after forestry operations is vital in preventing the depletion of soil nutrients. Although biofibre may be becoming a more desirable commodity as a renewable resource – for bioenergy, wood pellets and biochemicals – its excessive removal after timber harvest may have negative impacts on soil quality over the long term. The inclusion of limits on non-timber biomass removal in the Stand and Site Guide may be increasingly important as Ontario moves forward with encouraging the use of biofibre for fuel.

Effectiveness Monitoring

The final Stand and Site Guide contains only a brief overview of the types of effectiveness monitoring and methods that may be undertaken. The ministry states that its effectiveness monitoring program is based on “the principle of hypothesis-based monitoring,” with the underlying hypothesis that direction in the new guides are more effective than old direction, or no direction at all, when compared to biodiversity conservation in reference forests.

MNR will not be conducting full effectiveness monitoring for all aspects of direction in the guide. Instead, only key uncertainties will be subject to further research. Monitoring will compare Stand and Site Guide direction to controls in five study areas. Although comparisons with controlled experimental regions is a science-based, logical approach, this method may not reveal the diversity or breadth of issues within Stand and Site Guide direction, especially as guidelines require professional interpretation. The guide does not provide timelines for research and monitoring.

ECO Comment

The ECO is pleased that MNR has completed the Stand and Site Guide. MNR’s goal of streamlining and increasing public accessibility of the document is commendable and the ECO acknowledges the difficult work of consolidating over 20 documents into one guide. There are many positive aspects of the guide: for example, the ECO is pleased that MNR has addressed the issue of biofibre harvest in the final Stand and Site Guide, as was recommended in our 2008/2009 Annual Report. However, the process of developing and finalizing the guide has been lengthy and exceeded target completion dates. The ECO urges MNR to adhere to timelines in the future, particularly its required review of approved forestry guides every five years.

The new direction encouraging shoreline cutting was likely the most controversial aspect of the Stand and Site Guide, and some components were based on expert opinion rather than research findings. The ECO is, therefore, troubled that some key research questions related to shoreline cutting were given low priority for effectiveness monitoring by the ministry. Although the ministry’s current research may address some of these issues, ongoing monitoring is essential in determining how these changes in shoreline cuts will influence aquatic and riparian communities over the long term.

In the guide, MNR admits no “rigorous” tests have shown that residual forest is sufficient for wildlife habitat – although much of the guide is predicated on the fact that residual forest will “conserve” biodiversity. The ECO questions why this research remains incomplete, despite seven years spent preparing the Stand and Site Guide. Without research to show that residual forest provides for the ecological integrity of biological communities, MNR’s approach to forestry continues to be a “grand experiment” as the ECO noted in our 2001/2002 Annual Report.

MNR’s approach to treat “policies as hypotheses” may be a rapid and economical way to proceed. However, if monitoring programs are not thorough, well funded and completed in a timely manner, these “hypotheses” are not truly being tested, and are simply ill-informed and risky policy directions.

This is especially troubling for controversial directions, such as increased shoreline cutting and harvest around provincially significant wetlands. The ECO is concerned that there are no timelines for effectiveness monitoring, and is disappointed in the lack of information about monitoring provided in the Stand and Site Guide.

It is currently impossible to determine how effective this policy will be in conserving biodiversity during forestry practices. Before the implications of this guide can be measured, it will need to be incorporated into future FMPs, which in turn will be used to guide forest management on the ground. As a result, large-scale, practical results and compliance with this policy will not be available for evaluation for several years, through monitoring FMPs and independent forest audits. In ecological time frames, the benefits afforded to biodiversity conservation as a result of this guide will take much longer to observe.

Citing This Article:
Environmental Commissioner of Ontario. 2010. "Forest Management: Conserving Biodiversity at the Stand and Site Scale." Redefining Conservation, ECO Annual Report, 2009/10. Toronto, ON : Environmental Commissioner of Ontario. 70-4.Crown Forest Sustainability ActFish and Wildlife Conservation Act