The following letter was sent to Minister of Natural Resources Denis Landry.
The 2014 Forestry Strategy will cause the supply of old-forest habitat to fall below the thresholds identified by your staff as necessary to maintain viability of populations of several species requiring old forests. There have been clear public statements to this effect by your staff in the past six months. Simply put, if old forest is converted to plantations on the scale envisaged by this Strategy, New Brunswick is very likely to lose species of wildlife that are native to this province.
The Forestry Strategy considers forests simply as sources of lumber and fibre. Yet your department also has responsibility for maintaining viable populations of native wildlife, as described in both the NB Wildlife Policy and the NB Biodiversity Strategy. The habitat goal of the former is to “ensure an amount, quality, and distribution of wildlife habitat … sufficient to maintain viable populations of all native species”; and a goal of the Biodiversity Strategy is to ensure that “healthy and resilient native ecosystems and viable populations of all native flora, fauna and other organisms are present and sustainable”. Neither of these goals will be achieved under this Forest Strategy.
Furthermore, the Crown Lands and Forests Act, 1982, Section 3(1) states that the “Minister is responsible for development, utilization, protection and integrated management of the resources of Crown Lands, including … (c) habitat for maintenance of fish and wildlife populations.” Thus the Strategy is in clear violation of not only the Wildlife and Biodiversity Policies, but also the very legislation authorizing how New Brunswick Crown forests are to be managed on behalf of the people of the province.
Modern forestry aspires to obtain “green” certification of its products to ensure access to increasingly environmentally-aware markets. Implementation of the 2014 Forestry Strategy puts this possibility at risk: Principle 6.6 of the Forest Stewardship Council (FSC, the leading certification authority) requires that forest organisations must “effectively maintain the continued existence of naturally occurring species … and prevent losses of biological diversity.” If New Brunswick not only allows but actively encourages industry to convert old mixed forest to conifer plantations on the scale envisaged, it jeopardises the possibility of obtaining FSC certification and will find access to markets increasingly difficult.
The proposed Forestry Strategy violates (1) the integrated management required by the Act, (2) the goals of the NB Wildlife Policy, (3) the habitat goals of the NB Biodiversity Strategy, and (4) key principles which must be followed to obtain certification of our forest products.
I respectfully urge you to fulfill the full range of duties of your Department by not pursuing this regressive and narrowly-focused Strategy, continuing instead to pursue the careful and balanced stewardship of the forests which New Brunswickers clearly treasure for their full range of values.
Dr. Tony Diamond is a research professor of wildlife ecology at the University of New Brunswick.