FSC-Watch

An independent observer of the Forest Stewartship Council

SmartWood and Tembec: into the 'black hole' of disinformationTags: Canada, Certifier conflict of interest, Rainforest Alliance SmartWood

FSC-Watch earlier reported on the certification of more areas of Tembec's vast logging operations in Canada, making it the largest of all FSC certified companies and no doubt earning it's certifier, SmartWood, substantial fees. David Nickarz, a forest activist in Winnipeg, has been challenging Rainforest Alliance over this certificate. Other forest activists that have questioned SmartWood (there are many of them) will understand what David means by the 'black hole' of disinformation that he refers to in the blog article below, which describes his experiences in 'complaining' to SmartWood.

We follow this article with the actual correspondence between Nickarz and SmartWood. It provides interesting insights into how SmartWood and other certifiers create these 'black holes' that suck energy and time out of forest campaigners.

It is yet another indication of how, under Heiko Liedeker, FSC has lost the support of many forest conservationists worldwide, and is now seen as 'part of the problem', not 'part of the solution'.

Tembec's Green Laundering Corporation Responds

Tembec has paid Smartwood to certify its forestry operations as 'green' and 'well-managed', and they got every penny's worth. On October 11, 2007 Tembec was certified under the Forest Stewardship Council (FSC) by Smartwood. They held and open house for their 2008-09 logging plans and let everyone know about it.

After spending 17 years as a forest activist, I was naturally skeptical. True to form, Tembec confirmed every fear. Vince Keenan, divisional forester for the Tembec mill in Pine Falls, took me aside and showed me how he was going to cut down half of the lowland Black Spruce on his 9000 square kilometer logging area. Black Spruce is the majority species needed to feed their aging newsprint mill.

After frantically scribbling down my concerns with their plan on several of the 'questions and concerns' papers left on the tables, I went home and contacted the company responsible for this green-washing.

Smartwood is a company that is paid to certify logging companies under the FSC principles. I knew I was in for a ride down the techno-babble black hole when Alex Boursier, Regional Manager of Smartwood informed me that he was treating my concerns as a formal complaint under FSC complaints and appeals process.

For those of you who are not familiar with the black hole, it's when a company wants to obscure and confuse an issue they respond with several pages of technical and double-speak. It's designed to bore you out of your skull and hopefully you will just go away and let them destroy the planet. FSC and Smartwood has now become another layer of obstacles for conservationists to overcome in their efforts to protect forests.

I made it known that I was not to be treated with a 'process' and that I wanted answers to my very real and pressing concerns regarding Tembec's logging operations.

Smartwood's five page response was very telling.

Apparently clear cut logging is an acceptable practice for managing the Boreal Forest. Logging in Provincial Parks does not contravene FSC standards - and he backs that up by citing other atypical uses of Manitoba's parks such as mining and hydro-electric development. I am to assume that FSC supports mining and hydro developments in Manitoba's Provincial Parks?

Logging is still allowed in the habitat of the endangered Owl Lake Woodland Caribou herd. My questions about herbicide spraying were not answered.

The worst of his response was in about Tembec's efforts to weaken guidelines that protect wildlife. Tembec has been in contravention of the Wildlife Guidelines several times over the past years. Manitoba Conservation has overlooked several of these violations until citizens started seeing them - and making noise. After that, Tembec started to complain that the guidelines were 'not clear or flexible'.

One example is the line-of-site across a clear cut must not exceed 400 meters. This already weak rule is to allow for deer to escape from predators out in an open clear cut. The 400 meters allows for a maximum of 200 meters to the nearest cover. Tembec is trying to weaken this rule so that they can cut down more trees and make larger clear cuts. Quoted directly from Mr. Boursier's e-mail to me,

"Tembec has been discussing with MC the possibility of removing these conditions from the work permit as it will continue to generate non-compliances because of a lack of clarity and flexibility in the work permit condition interpretation and a lack of clarity in how the condition will be enforced. Stakeholder interviews indicated that they believed the line of sight requirement is clear and that Tembec is not following the rules. MC does afford some flexibility over the line of sight and wildlife guideline implementation. Despite the difficulty in the work permit 'line of sight' wording, the audit team feels that the concept has merit, and the compliance standard can be made more precise through discussion with MC, Tembec and stakeholder groups."

Not only does Smartwood take money to certify Tembec under FSC principles, but they are actively supporting Tembec's efforts to weaken the laws that protect wildlife, and in clear opposition from stakeholders. Logging companies like Tembec have a new ally in their efforts to destroy our forests, and it's the Forest Stewardship Council.

Mr. Boursier's response finished with insults to my intelligence. After denying me and others the preconditions for Tembec's certification, he wrote "We are very proud of the transparency of our process." He also apologized for not getting back to me within the timeframe of the certification and that they had ignored my concerns from as far back as 2005.

My response to his e-mail was finished within three hours. I really let him have it. If I could have yelled in an e-mail, I would have.

This also brings up a more pressing issue for the conservation movement. Greenpeace, World Wildlife Fund and the Rainforest Action network are a few of the groups that support FSC. They need to pull out of the process altogether. FSC condones the destruction of old growth forests, pesticide use, logging in parks and, now lobbies to weaken existing laws.

I must give credit to the Rainforest Action Network for posting the debate about FSC on their website. They talk about reforming FSC, which I strongly disagree with, but at least they are talking about it.

I strongly believe that FSC has been completely co-opted by the logging industry. Conservation measures are watered down and made meaningless by qualified language. Conservation groups must now pull out of the FSC process because they are lending legitimacy to this dead effort. There have already been efforts to lobby Greenpeace and Rainforest Action Network to do something to improve FSC. We have already come to the day that we have to lobby large conservation groups to protect forests on a grass-roots level.

What a sad day.

Letter to Alain Boursier, Canada Regional Manager, SmartWood Program

Nov 5th

Mr. Boursier,

First of all, your process is not open and transparent. I asked for Tembec's preconditions on August 29th and you told me that they were unavailable. You also admit that you did not address my concerns from as far back as 2005, and that those concerns should have been addressed during the time frame of certification.

I would like to be provided with a copy of all of my e-mails to Smartwood.

How is it that you are proud of the transparency of your process? You managed to hide the preconditions from me and others to avoid any conflict. Is it FSC practice to withhold preconditions from the public until certification is issued? What possible motive could this serve other than to protect the company applying for certification?

How much is Tembec paying you to certify them? I want to know exactly how much money Tembec pays your company, including dates and amounts.

I also want to know when and how Tembec plans to start advertising their FSC certification to consumers.

I want to know how much post consumer recycled content is in paper coming from the Tembec mill in Pine Falls. Do they still use all the recycled content for their markets in the United States? How much PCR content is in paper sold in Canada?

What are they going to tell customers like the Winnipeg Free Press?

Regarding old growth logging. Why is it that the levels of old growth are twice the level indicated in the PIC analysis? If the PIC analysis is so accurate, then why just double them? This was what Vince Keenan told me they did with the PIC numbers at the October 11th meeting.

Tembec has been actively lobbying Manitoba Conservation to remove the line-of-site requirements from work permits? Are you serious? You think that it is appropriate to take the view that the wording is not clear, when it clearly is? You also take this view in clear opposition to stakeholders. This puts you in clear conflict as to your role in certification. Is it your role to hold the company accountable to local laws or is it your role to help the company change those laws when they aren't convenient?

What is your role as a certifier?

The line-of-site requirement is clear and Tembec is not following the rules. The only reason why they want it changed is because they are being called on it when Manitoba Conservation doesn't do its job, and citizens have to do it for them. You said as much in your response.

Why are you supporting Tembec's questionable claim that the requirements are not clear and flexible?

Am I considered a stakeholder in this process? I want the requirements of work permits to be more stringent. It's Tembec's job to follow the laws of the land, and it's not yours to undermine them.

Thank you for confirming that clear cut logging is an acceptable practice under FSC Boreal Standards. I find it hard to believe that no stakeholder brought up clear cut logging as a concern.

Thank you for also confirming that logging in Provincial Parks is an acceptable practice under FSC standards. It would also appear that the FSC standards support the practices of mining and hydro-electric developments in provincial parks. Can someone from FSC please confirm this?

Does FSC support the use of herbicides? Tembec plans to use herbicides on their clear cuts and has not indicated any intention of stopping. Does Tembec have a plan to phase out herbicide use? If not, then why not?

If FSC defers to Manitoba Conservation with regards to logging in parks, herbicide use, clear cutting, endangered species habitat and enforcing wildlife guidelines, then what good is Smartwood? Even if Tembec breaks the law, you take their side. It's no wonder, since they are paying you to certify them.

Is it not true that Smartwood is just a well-paid rubber stamp to greenwash Tembec's operations? Why should a stakeholder such as myself consider your involvement anything else? I'm serious--why?

What have you told me that Tembec hasn't told me before? What have you told me that any other logging company hasn't told anyone concerned with conservation?

You are an embarrassment and an insult to the conservation movement. We work for years trying to get this company to follow the basic laws of this land and you support them in their efforts to undermine them. FSC was once a hope for better logging practices and it's companies like Smartwood that have ruined and debased every effort in that direction.

Whenever I see the FSC logo on any product, I will be sure to tell everyone that it is a fraudulent scam. How dare you waste my time. How dare you sit there and tell me that you are proud of your process. How dare you tell me that logging in an endangered species habitat is 'Tembec doing the right thing for Caribou'.

Not only were my concerns not addressed, several new ones have come up. I want answers to all the above questions.

David Nickarz

SmartWood's letter to David Nickarz is available here: SmartWoodresposnetoDavidNIckarzcomplaintNov52007.pdf

Comments

Here is some media coverage of the Tembec certification in Manitoba. A small rural newspaper did a story.

http://www.lacdubonnetleader.com/News/351391.html

David and others,

Our team has attempted to respond to you, but in your responses you have consistently ignored the information provided, actually been insulting to our staff. At no time did our staff attempt, in any way, to provide information to you in an insulting fashion. Also, it appears from your comments that you have not read the various Public Summaries already provided on our website, the list of CARs, etc. For example on our website, which you appear to have visited, there is a Public Summary section that includes summaries of the various audits, including description of the pre-conditions and the auditing associated with them. Why would we keep such pre-conditions private before full certification? Because there are other parties, including First Nations, other stakeholders, etc. which we have promised confidentiality to. This may not satisfy you, and we may just disagree. But that is why. Such information IS on our website now and available through the summaries - which, based on my own review of other certification systems, go far beyond the information provided by any other certification system (in forestry, Fair Trade, organic or otherwise).

Following are comments on your specific comments.

1) Tembec has been holding open houses for years. Just to be clear, the open house you attended was NOT a SmartWood open house, though we did conduct various, publicly announced (website, local papers, emails) open sessions during the audit process.
2) We have not seen any evidence that supports your contention that Tembec "was going to cut down half of the lowland Black Spruce" in the certified forest unit. If you have evidence otherwise, we would like to see it.
3) The FSC complaints and appeals process is what it is. We don't define it; we use it. I disagree with the assertion that the process is a black hole - "i.e. its when a company wants to obscure and confuse....". All FSC chambers (economic, social and environmental) have input into it, and it is not biased towards any particular interest.
4) The FSC certification process paralleled a process whereby 26,000 hectares of the Owl Lake "core caribou area" was set aside in a 50-year halt to logging in woodland caribou habitats on the east side of Lake Winnipeg. Facts do not support your contention that FSC certification is an obstacle for conservation.
5) Clearcutting is an even-aged forest management tool. We don't "support" clearcutting; we evaluate the implications on the ground of the approach and assess whether the approach to managing forests meets the FSC standards. If clearcutting means no wildlife values are considered, no retention, no thinking about corridors or forest "edge" or other key components of managing biodiversity from both a stand and landscape perspective - we would not certify it - FSC standards require a higher, more rigorous approach and other field observers and others from the conservation and biodiversity community generally have responded to us positively during this process (though of course they retain their right to confidentiality and to point out their own concerns re Pine Falls operations).
6) We specifically followed up on the allegation that Tembec was lobbying Manitoba Conservation to weaken the rule. Interviews with MC at multiple levels indicate this is not true. Tembec WAS pushing for clearer instructions and guidance and to use the "line of sight" instructions "more flexibly" to more effectively/productively manage biodiversity. You may interpret "flexibility" as a weakening; we don't. We expect operations to use the flexibility to actually be rigorous in terms of attaining better biodiversity outcomes (i.e. use the flexibility to get the highest biodiversity values) in natural systems.
7) At no time did we "ignore" your concerns. We did not give you the responses you wished for, because we were in the middle of an auditing and certification process getting inputs from over 100 different individuals and organizations. The certification process for Pine Falls began in 2001 and involved many trips to region and interactions with stakeholders, including public meetings, sensitive, private meetings with First Nations, government, NGOs and others. SW auditors had direct email interactions with you in August 2005, where we responded to your questions and concerns, and apparently you had direct communications with Tembec (which we strongly encourage). We have attempted to follow up with, though clearly you are not satisfied. But your lack of satisfaction is not due to a lack of effort or seriousness on our part. Maybe there is information you are looking at that we aren't, and we would certainly welcome access to it, as it would help the auditing process.
8) FSC does NOT "condone destruction of old growth forests, pesticide use, logging in parks...[or] weaken existing laws". As per communications to you from FSC Canada, FSC builds on government requirements and land use planning decisions by governments elected (for better or worse) by civil society in Canada. On the chemicals side, you should know that the Pine Falls approach on chemicals is in fact among the most rigorous I have ever seen. Total volumes of chemical used are low compared to the area being managed; the chemicals used meet FSC requirements, and application procedures very careful and highly, carefully targeted. The alternatives to using chemicals, which are used primarily to attain forest composition similar to natural forest conditions, in an ecosystem where First Nations, pests, climate change and many other factors have impact, are not good. One alternative might be the use of prescribed burns on a fairly large-scale, which of course brings with it other broad and deep social, environmental or community concerns.

Finally, as I have said in a separate email to Simon Counsel, candidate operations pay SmartWood to implement certification audits and assessments according to FSC standards, irrespective of the results. This can frustrate forest enterprises, since as in the case of Pine Falls, it required multiple audits over a 6 year period. But I am not aware of another workable model for implementing this activity (which is the same auditor service model followed under organic, Fair Trade, ISO and other certification models and all financial accounting). We are rigorously audited by the FSC, through ASI and the results of each specific accreditation audit is made public - again a feature that I am not aware exists in any other certification system. We believe the FSC system is rigorous. But we also think it can improve, and thus your continuing inputs actually can help us. We will extract constructive value from your comments.

Thank you,

Richard

Richard,

I express my frustration as I see fit. I am angry because efforts to strengthen protection for forests is being undermined on many fronts.

1. I know it wasn't a Smartwood open house. I guess that wasn't clear in my article.

2. This came from Vince Keenan of Tembec. He told me that the Pre-Industrial Condition of the FML was 22% lowland Black Spruce. Right now it is 43%. So, Tembec wants to 'manage' the FML to 22% from 43% in the next 25 years (or so). That's about half.

If you want the evidence then ask Vince Keenan. I don't have the open house materials that were presented.

3. Please forgive my apprehension about getting into another process. I've been fooled before and I don't want to waste my time. We're just going to have to disagree on this one.

4. The caribou issue is another whole problem. FSC is an obstacle for conservation because it's no better than what's happening 10 years ago.

5. Clear cutting is cutting every tree down in a given area. You support clear cutting because you certify companies that clear cut. Clear cutting is bad for the forest because it is a violent interruption of the forest cycle. Don't try to confuse the issue.

6. Flexibility means weakening in corporate-speak. Tembec asked to have these requirements removed from their work permits. That's not flexible at all, is it?

You say that you "expect operations to use the flexibility to actually be rigorous in terms of attaining better biodiversity outcomes (i.e. use the flexibility to get the highest biodiversity values) in natural systems."

Tembec wants to cut down as many trees as it can, while doing as little as they can to clean up the area. Tembec is certainly not interested in using flexibility to get the highest biodiversity values. They just want to cut down the trees to feed their mill without being charged with not following the already weak guidelines.

Specifically, the line-of-site requirement for clear cuts are mentioned in Smartwood's response to me.

"MC believes that it is a good guideline; however Tembec has been discussing with MC the possibility of removing
these conditions from the work permit as it will continue to generate non-compliances because of a lack of
clarity and flexibility in the work permit condition interpretation and a lack of clarity in how the condition will be enforced. Stakeholder interviews indicated that they believed the line of sight requirement is clear and that
Tembec is not following the rules. MC does afford some flexibility over the line of sight and wildlife guideline
implementation. Despite the difficulty in the work permit “line of sight” wording, the audit team feels that the concept has merit, and the compliance standard can be made more precise through discussion with MC, Tembec and stakeholder groups."

So, even though the guideline is clear, Tembec wants to remove it from their work permits. Stakeholders disagree and go so far as to say that the law is clear and that Tembec should follow the rules. SW takes the side of Tembec and feels that the requirement can be made "more precise".

That guideline is pretty simple--don't make a clear cut more than 400 meters wide in any direction so that deer can escape predators without having to go more than 200 meters in any direction. Pretty clear, although it needs to go further--but that's not the direction that SW wants to take.

Again, from SW's response to me;

"There were no line of sight non-compliances between 2002, and 2004; however the line of sight requirement was a guideline at the time, and consequently not strictly enforced by MC. In response to line of site issues by a stakeholder in the 2004 Shoe Lake block, MC began to rigorously enforce this work permit condition. Several stakeholders began to monitor the line of site issue on all Tembec harvest blocks. The Shoe Lake, Euclid Lake, and Maskwa blocks line of site compliance and a trespass into the Manigotagan River buffer were the main compliance issues raised during the audit. Interviews with MC after the field audit indicated that there was one additional buffer trespass which resulted in a verbal warning. MC has stated that there are numerous other non-compliances where Natural Resource Officers could have laid charges and didn’t."

Those stakeholders included me. We did not monitor every block that Tembec cut. We found some more illegal logging and tembec was charged.

So, Tembec is exposed as breaking conservation laws with regards to the size of their clear cuts. Citizens, including myself, call them on it and they are eventually charged. If a certifier was interested in upholding the laws of the land, then I would think they would tell Tembec to just follow the law as it is clearly written. Maybe that certifier could tell Tembec to do so, or they may not be certified. Instead, they take the side of deregulation.

So, if I try to lobby the province to enforce it's own rules, I have to fight government bureaucracy and lazy enforcement, corporate deregulation and a gutless certification corporation.

If you want a copy of Smartwood's response, then I can send it to you.

7. You have access to all the same information that I have! Ask Vince Keenan about the PIC analysis. Ask Alex Boursier about his statements about Tembec's efforts to undermine conservation laws. I'm not the one hiding anything.

So when can you provide me with the answers that I want? How much money has changed hands between Smartwood and Tembec? When is Tembec going to phase out the use of pesticides? How much post consumer recycle content does Tembec intend to advertise to it's buyers?

8. Yes, yes you do condone the destruction of old growth forests, logging in parks, pesticide use and weakening existing laws. You certainly don't condemn them. You lend your name and the names of conservation groups to a process that allows these things to happen and you give them a stamp of approval. The public thinks that this is all 'green' and 'well managed'.

It isn't and you say it is.

Why is there no effort to improve anything? You defend clear cutting, pesticide use and following the weak rules and weaker enforcement laid down by our duly elected governments. If FSC is supposed to be anything different than the usual, then why not ask for more?

If you have to spray a clear cut with chemical pesticides then you might want to question the way it's cut in the first place. You don't question that--you raise the spectre of massive forest fires. Thanks for being an industry lackey.

Are you really surprised that people are angry and frustrated with you? You put a green stamp on an operation like Tembec in Manitoba and you expect us to send you roses?

Mr. Nickarz,

It is unfortunate that you choose to include language which is disrespectful.

FYI, I have also received separate correspondence from you yesterday, by email, wherein you ask ASI if they are following up on X issues, without you indicating that in fact SmartWood has responded to those same issues you raise on this website. FYI, we are keeping ASI informed as to our responses to you, here and elsewhere, and we will continue to provide them evidence, through our audits and correspondence, for our findings.

In the following, I will restrict my responses to technical issues you raise and avoid repeating, as much as possible, information from previous responses. I am working closely with our staff and auditors on all responses and am aware of them all.

1) "The caribou issue is another whole problem. FSC is an obstacle for conservation because it's no better than what's happening 10 years ago." RESPONSE - As per my previous response, Tembec is working with other NGOs and respected scientists on caribou issues and our evidence clearly is not in line with your assessment of the situation. We will have to agree to disagree.

2) "Clear cutting is cutting every tree down in a given area. You support clear cutting because you certify companies that clear cut. Clear cutting is bad for the forest because it is a violent interruption of the forest cycle. Don't try to confuse the issue." RESPONSE - As stated before, we certify to the FSC standard for boreal forest management in Canada. Harvesting techniques must meet those requirements. Clear-cutting that meets FSC requirements does not mean cutting down every tree in a harvest unit.

3) "Flexibility means weakening in corporate-speak. Tembec asked to have these requirements removed from their work permits. That's not flexible at all, is it?" RESPONSE - As per our various documents and responses, we are following up on this issue with MC and Tembec through our audits. There is more work to be done on it, and we will be public on the audit follow up that is done.

4) "You say that you "expect operations to use the flexibility to actually be rigorous in terms of attaining better biodiversity outcomes (i.e. use the flexibility to get the highest biodiversity values) in natural systems.....Tembec wants to cut down as many trees as it can, while doing as little as they can to clean up the area. Tembec is certainly not interested in using flexibility to get the highest biodiversity values. They just want to cut down the trees to feed their mill without being charged with not following the already weak guidelines." RESPONSE - If auditing demonstrates that Tembec's actual operations result in your negative scenario, SmartWood will take action. Perhaps this is already clear to you from your perspective. Our field evidence and interviews with MC don't, at this time, indicate this. We welcome any site specific evidence in this regard, even if it is only from one site - this is still helpful.

I am on vacation now for Thanksgiving and, after further consultation, our team may have further clarifications next week on the issues you raise.

Regards,

Richard

Richard,

When you are disrespectful to the forests, you will get disrespectful language from forest defenders. I was actually holding back.

1. The Caribou issue is a whole other problem because Tembec is still logging in critical caribou habitat. They have come to an agreement with CPAWS regarding a large area to be set aside--but within that agreement are potential problems. One is that the boundaries of the area to be protected can be moved--both to accommodate migration and to log areas that have the big trees.

2. Don't give me that crap about forest units or FSC standards. Clear cutting is unacceptable in my books. Clear cutting means cutting down every single tree in a given area--I know how you people map and design clear cuts. Again, you are confusing the issue to cover up a bad practice.

3. I'm sure you'll find a way to sugar coat the fact that Tembec is lobbying the provincial government to weaken the wildlife guidelines. I understand that this takes time.

4. Oh, please. Clear cut logging is only sustainable because there is more primary and old growth forests to cut down. Tembec has very little interest in regeneration or biodiversity. Manitoba Conservation (MC) couldn't find their ass with both hands. They are the only ones who care even less about how Tembec ruins the forest.

Specifically, conservationists like me had to find violations of the Wildlife Guidelines and that forced MC to enforce the law. They told us that they were ignoring the law until it became public.

If you like, I can quote Mr. Boursier's letter in this regard.


5. "Why would we keep such pre-conditions private before full certification? Because there are other parties, including First Nations, other stakeholders, etc. which we have promised confidentiality to. This may not satisfy you, and we may just disagree. "

One of the preconditions that you held back is regarding the work permit violations. Who's confidentiality was being protected by holding this one back?

My original statement stands, and is accurate. FSC condones the destruction of old growth forests, pesticide use, logging in parks and weaken existing laws. No amount of confusion or obfuscation, double-speak and techno-babble will change that basic fact.

FSC is not worth supporting. In fact, it's worth opposing, resisting and subverting.

Have a great vacation.

Dave Nickarz



I am a fourth year Ecology student at the University of Guelph. I have assisted with research in areas that have been logged by Tembec.

Richard: Why does Tembec choose to use herbicides instead of prescribed burns? I suppose they both have their drawbacks, but it seems to me prescibed burns might be the better option from an ecological perspective.

David: Disrespect does not solve problems. If you really were a forest activist, you would accept this as a step in the right direction and politely point out the areas that FSC certification may be improved. Also, clearcutting is not always such a horrible thing. I believe in group selection as the most natural way of logging, but clearcutting also simulates the natural forest cycle. Forests burn regularly and it is part of the natural system. Why else would Jack Pine evolve to have cones that open and disperse seed in the heat of fire? Clearcutting simulates this natural, regular, event. Clearcutting also allows shade-intolerant species to thrive. For some wildlife, such a moose and bears, clearcutting can allow regeneration of grasses, shrubs, and berries that are optimal foraging plants. So, my point is, clearcutting can be done in a sustainable manner.

Kaitlin,

If clear cutting is so good then why does it take 7 years for the nutrient variability to return to the soil, or even longer for deer mice to return to a clear cut site? Why does Global Forest Watch consider not only a clear cut not intact for 70 years, but 500 meters into the surrounding forest as well? The same goes for roads too.

Woodland Caribou need these forests to survive. I'm sure your analysis of clear cutting works on paper, but we're living in the real world--with real endangered species facing real threats.

I'm sure you've been taught to believe what the forest industry tells you, including how to be polite, but I've been in this for too long to be anything but assertive. Please don't tell me anything starting with "If you were really a forest activist..." That belittles us both.

Thanks

David Nickarz


Miccorrhyzal fungus; takes years to recover after a cut-over, compared to a burn site. Standing dead trees are not as plentiful in a clear cut site as compared to a fire. Standing dead trees are important habitat for cavity-nesting species of birds.

Marten need 90% of the Annual Allowable Cut to survive in their habitat. What company is going to leave 90% of their AAC for Marten?

Primary/Old Growth Boreal forest is being rapidly destroyed to make newsprint. How much of these forests do you think we have left? Our newsprint mill in Pine Falls (Tembec), which is FSC-certified, by the way, is getting only 1/3rd of their fibre from their massive Licence area. The rest is coming from all over Manitoba, hundreds of kilometers away because their logging is unsustainable.

And they just eliminated their Post Consumer Recycled content, increasing their forest destruction by more than 20%.

Their mill is too large to be fed by slow growing Boreal Forest.

David Nickarz

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