Regulation and process from our industry's front line PDF

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Regulation and process from our industry’s front line
Speaking notes for a presentation to the Ontario Minister’s
Council on Forest Sector Competitiveness, January 25, 2005
Geoff Meakin, President
Meakin Forest Enterprises Inc.

There are two big obstacles to improving forest industry competitiveness: overregulation and lengthy process. The impact of these two factors costs substantial dollars in timing and effort with added frustration and stress on the operational front line staff.
Most costs from new regulations have been downloaded on the front line of the industry – the harvest contractor and the forest worker.
New regulations and processes for safety, environmental protection and forest management certification all add additional dollars to wood costs.
As professionals, we want to do it right but doing it right does cost more!
Why can’t we make some regulations more flexible and the process more simple and streamlined!? We could save a lot of dollars in our wood costs. It sounds like I am talking ‘in the weeds’ in much of this presentation but, again, action ‘in the weeds’ costs us dollars. We should be taking the enlightened examples of common sense shown by some MNR employees in dealing with regulations and use them to go by. Not the other way around!
A few years ago, a bridge went out on a 4 metre creek crossing. Our operation was low on fuel and there being a shallow ford 400 metres downstream we phoned the MNR for permission to use it. The area supervisor OK’d it realizing the need and realizing we would not abuse the situation. Not every supervisor would have. Mark one for common sense! This was an example of good management decision-making on the part of the MNR
Streamlining the process
With regards to dealing with the SFLs, it seems that routine issues now experience two levels of delay instead of one. Again, time costs money.
The SFL’s have guidelines to follow for the approval process and provided they follow those guidelines, they should have the freedom to make decisions without MNR involvement to further delay the process!
Is MNR reluctant to release ‘power’?
Why do pre-approved MNR bridge designs have to be sent to the region for OK? Why can it not be handled by the SFL and the local district office?
Why can’t the district approve the location with the Federal Fisheries and Oceans and that be the end of it!
Speaking about bridges
On the Batchawana River, the process for building a new bridge started in April 2003 with approvals in August 2004. That is 16 months! There were issues over the site, the type of cribs, timing restrictions, etc. The MNR got hung up on so many issues and the permit was held up until we succumbed!
Stream crossings
We understand why major crossings need to be identified ahead of time but why make all crossings to be identified two years ahead of time! It is simply not operationally doable. Here is a suggestion – do not pinpoint the exact possible crossing; give some flexibility by putting in options.
Why are we being asked now to remove water crossings that were placed earlier following proper process and technical specifications? This means extensive costs of moving equipment back to the locations. If you pull the bridges how do you get there to do your silviculture? And why after we have invested millions of dollars in reforestation do we cut off access?
Why does the MNR have to review all crossing locations regardless of size? Yet the SFL can approve culvert size up to 1 metre and the MNR after that. Would it not make sense for the SFL to approve both location and size of culvert up to
1 metre?
Planning for water crossings has become overly burdensome. This is regulation at its worst!
Is aggregate policy under review? And if so, by who? Some good movement has been made with aggregate problems by MNR personnel. For example: reverting all category 9 pits to category 14 except if ownership is in question and the inclusion of a 500 metre strip along all existing road in FMP’s for the purpose of category 14 pits.
Why can’t we have two levels of aggregate removal (gravel) one for commercial pits and one for forestry use and make the forestry one more user-friendly and cost-effective, because the forest industry roads become public the minute they are built. Think outside the ridged box! Maybe the Aggregate Resource Act needs changing? If so, let’s do it!
Land use permits
Regarding campsites, we are treated the same as a tourist trailer. We must either be inside the AWS area or else the 21-day rule applies! Many existing sites would be better suited instead of making new ones.
Last year with spring coming two weeks early and our operation pushing to finish a cut block, we requested a downpiling site to facilitate the forwarding. It took two weeks to get the land use permit!
My last blast
Over regulation and adhering to a strict process where everyone is covering their ‘you-know-what’ is leaving us on the front line, out on a limb, trying to get some common sense and economic need. This coupled with a condescending attitude of ‘don’t care - it is by the book or else’, is pushing us to do more of our harvest on private land.
In summary
The three pillars of sustainability are economic, social and ecological, it seems to me that the MNR has forgotten about the first two and that is why the industry is disappearing before our very eyes!
Wood for the forest industry is what is left over in the FMP process, once they have dealt with all the ecological requirements and other user’s needs. That is why the smart investment money is going west and small family-owned harvesting contractors and woods workers are choosing to retire as their children leave to pursue their dreams.
My three pillars of cost reduction from the operational front line are:
1. Regulations must be more realistic and flexible
2. Process must be streamlined
3. Attitude of MNR towards the forest industry must change
My challenge to all of us is, have we got the guts to do what we must to save our communities and our industry!
Summer 2005 • Vol. 9 #4
First printed in