Dog River Matawin Forest Local Citizen S Committee

Dog River Matawin Forest Local Citizen’s Committee c/o 435 James Street South, Thunder Bay, Ontario

February 11, 2002

Timber EA Renewal Project Ministry of Natural Resources Roberta Bondar Place 70 Foster Drive, Suite 400 Sault Ste. Marie, ON P6A 6V5

RE: MNR PROPOSALS FOR EXTENSION AND AMENDMENT OF THE ENVIRONMENTAL ASSESSMENT ACT APPROVAL FOR FOREST MANAGEMENT ACTIVITIES ON CROWN LANDS IN ONTARIO

Dear Sir or Madam:

On behalf of the Dog River Matawin Forest Local Citizen’s Committee, I have prepared this response to your call for comment as contained in the document, “A Paper for Public Review Concerning the Extension and Amendment of the Environmental Assessment Act Approval for Forest Management on Crown Lands in Ontario.”

At its meeting of Monday, February 4, 2002, the Dog River Matawin LCC discussed the aforementioned report and its contents. After considerable debate we agreed that we should make one comment to the MNR at this point in the application-for-renewal process.

There is a serious need to simplify Forest Management Plans.

We understand the FMPs are prepared in accordance with the FMPM which in turn is a reflection of the original EA Approval and subsequent implementation experience and scientific discovery. We understand that FMPs must meet the needs and expectations of a wide range of stakeholders, many of whom may have sophisticated assessment skills. Nevertheless, we find that the final product of the planning process is unnecessarily complex and voluminous.

We believe that the complexity and size of the FMP makes it unintelligible to the general public and even to planning experts charged with the responsibility for its preparation, interpretation and implementation. This opinion has been formed through our collective experience with the preparation of a new five-year FMP in our unit. This process was completed in early 2001, hence our experience is recent.

Dog River Matawin Forest LCC Page 1 Further, we believe that the physical size of the FMP helps to limit the public’s access to the document and ultimately to its use. Fifteen large binders makes it impossible to post FMPs on a website. Today, if a member of public wishes to examine those documents, prior arrangements must be made, physical space allocated and valuable staff time consumed. When documents are available only during office hours, this places a particular burden on members of the public who must regularly work for an employer during these same hours of the day.

We believe that every effort must be made to ensure that the objectives of EA be met through the planning process. However, we also believe that the resultant FMP must be accessible and available to everyone who has a stake in the future of Ontario’s forests, including planners, RPFs, biologists, MNR staff, politicians, members of LCCs, the Aboriginal Community as well as the general public.

As an example of the need for simplification we note the document that caused us to respond to your call for comment. After introducing an acronym, the report continues to use that same acronym throughout the report. Were there one or two acronyms, this would not compromise accessibility. However, we note that many acronyms were used extensively throughout the document:

 MNR  FMP  EBR  EA  T&C  FOSM  OLL  AOU  FIM  FMPM  CFSA  LCC

For a member of the public to use this document, the user must read the report in its entirety, and he or she must be particularly diligent to note the initial definition that is buried within the report at the first point of use. The report’s construction necessitates this approach.

Consistent use of well-defined terms is absolutely essential in effective communication. However, when documents are prepared, they must take into account the target reader (and in all cases involving Crown Lands…readers). In this case, a simple glossary of terms on the inside of either the front or back covers of the report would greatly enhance accessibility for its intended audience.

We provide the foregoing example simply to reinforce our comment.

A plan can only be effective when it can be read, understood and acted upon. We trust that this is a goal that both the Ministry of Natural Resources and that the Environmental Assessment Board share.

Yours sincerely,

K.R. Hartviksen

Ken R. Hartviksen

Dog River Matawin Forest LCC Page 2 Chair Dog River Matawin Forest LCC

Dog River Matawin Forest LCC Page 3