• NLFIA

NLFIA response to WERAC | A Home for Nature: Protected Areas Plan for the Island of Newfoundland


The NL Forest Industry Association (NLFIA) welcomes the opportunity to comment on your recently released document titled: A Home for Nature: Protected Areas Plan for the Island of Newfoundland. We commend the Wilderness and Ecological Reserves Advisory Council (WERAC) for its effort to bring this initiative forward and recognize both its genesis, its long-term development, and its significance to our province, and beyond.


Given the importance of the forest industry to the well-being of our citizens, NLFIA strongly supports a collaborative approach to help finalize proposed boundaries and deliver a final plan that can meet national and international protected area targets. We trust the final protected areas framework can ensure the long-term viability of natural systems and can assist in improving future forest governance. We take this opportunity to provide a contemporary context of the forest sector and offer several recommendations for reaching protected areas targets taking into account the importance of the forest resource to our industry and to the economy of the province.


The historical significance of the forest resource to the people of Newfoundland and Labrador (NL) has been long recognized. For countless generations, our citizens have relied on forest resources and forest-related industries for their existence, livelihood, and way of life. Importantly, the future of NL’s forest industries depends on the long-term health and sustainability of our forest resources. Consistent with aspirations of WERAC, there is also a growing awareness within, and external to, the forest sector of the many goods and services offered by forest ecosystems, most notably, production of lumber and newsprint, domestic and industrial energy, agricultural bedding, sequestration of carbon, regulation of the quality and quantity of water, provision of residential and recreational amenities, and protection of biota.


To this end, the NLFIA continues to work with its partners to foster the growth and competitiveness of the sector. Notably, incorporating protected areas into sustainable forest management strategies represents an important objective of NLFIA. Our Association represents 96 percent of the province's commercial forest resource production. Valued at $383 million annually and providing direct and indirect employment to over 5,000 people, the sector contributes significantly to the rural economy of NL. Established in 2017, the Association's founding members believe collaboration and partnerships are key to strengthening, growing and transforming the forest industry in the province.


In our review of your Protected Areas Plan, we provide the following comments for consideration:

  • Protected areas (PAs) are key for biodiversity conservation, but NLFIA has concerns that the proposed boundaries, with their concomitant reduction in annual allowable cut (AAC), will have serious impacts on current and future economic opportunities within the forest sector. In selected areas, these boundaries generate unequal access to potential benefits of the forest resource, and in turn, exacerbate job losses. Further reductions in AAC will be highly detrimental to the sector and to the province’s economy, particularly to rural NL. There is every reason to avoid such impact given the province, with its current debt load, will be further challenged in a post-COVID economy.

  • Conservation of our land base and our natural areas is vital to the long-term health of our industry. Although the establishment of protected areas is one way to achieve this, it is not the only way. Given the renewable nature of our industry, and the fact that in NL forests are managed on 160-year rotations, we contend a more balanced approach is necessary. For example, there is opportunity to augment protected area policy with other policy instruments. Moreover, combinations of strategies require decisions on trade-offs, making it important to develop more holistic management strategies where both synergies and trade-offs are considered. Other approaches can provide for continuity of ecosystem structure, function, and species composition and support the integration of environmental, economic, and cultural values.

  • Canada is recognized as a leader in sustainable forest management and resource stewardship. Forest management decisions and activities are founded on science-based research and established planning processes. In NL, the provincial government is responsible for regulating and managing our forest resources and NLFIA members work with government to ensure Our Forests are protected and managed responsibly. The Province’s Environmental Management System is registered to the ISO 14001:2015 standard and provides a framework for forest management activities on crown land. In addition, Corner Brook Pulp and Paper Ltd. is certified to a sustainable forest management standard and a fiber sourcing standard which require validation from third parties to ensure management of the resource is being carried out responsibly and considers all stakeholder values, including protected areas.

  • As part of the forest management planning process, the Forestry Act requires an overarching, 10-year Sustainable Forest Management Strategy. Ecosystem management and forest protection are critical components of this strategy and this process enables stakeholders to provide input and respond to concerns respecting the local environmental effects of forestry activity. This input often results in numerous restrictions including, but not limited to, other resource uses such as agriculture, mining, protective interests including wildlife, endangered species, tourism, view scape protection, outfitting operations, traditional and indigenous land areas, municipal land use, cottage areas, protected water supplies, and recreation.

  • In recent decades, the forest management planning process has cumulatively reduced the productive forest available to industry, from approximately 36 percent of the island’s total landbase to 20 percent. Furthermore, 83 percent of this productive area has some form of additional restrictions placed upon it. The continuous cumulative erosion of the forest industry’s landbase over the past 20 years has resulted in an annual 26 percent reduction of available softwood fiber. It is imperative to understand that further constraints on the productive landbase will jeopardize current industries. Moreover, it will threaten future potential offered by an emerging bioeconomy in the province.

  • The sector is also gravely concerned with the impending spruce budworm infestation and the further reduction in inventory levels. The 1970’s outbreak resulted in 90 percent of productive forests of the Island being impacted with an estimated loss of 5,100,000 cubic metres. Quebec alone has suffered moderate to severe defoliation on over 7 million hectares since 2006 and we are on the precipice of another such infestation.

  • NLFIA and the Department of Fisheries, Forestry and Agriculture (FFA) are currently completing a wood supply validation project where initial findings indicate significant variances in the inventory available for harvest. The validation and accuracy of any inventory, protected or otherwise, is critical data in determining sustainability and viability of all users. Again, fiscal constraints have not allowed the province to invest in more reliable inventory technologies such as LiDAR that allow for greater identification and accuracy, critical to forest management regimes.

  • A key action of the recent provincial sector work plan, The Way Forward on Forestry, is to increase industry’s timber allocations and harvest levels by 20 percent. As the sector invests and transitions from a traditional pulp focused inventory to an inventory needed to support new innovative products, industry is gravely concerned that meeting targets will not be possible with any further decreases in the productive land base. In addition, any decrease in AAC will require a substantial increase and investment in intensive forest management (i.e. silviculture and forest protection). Going forward, the capability to grow more product on less land will be critical. However, in recent years, provincial fiscal constraints have caused forest renewal and protection budgets to plummet. Consequently, little to no funding has gone into site preparation, pre-commercial thinning and tree improvement. We as industry feel this will have a significant negative impact on future inventory levels and long-term sustainability.

  • Simply designating an area as “Protected” does not ensure a forest or ecosystem will remain in its current condition or continue to represent the values for which it was originally protected. Threats of forest pests like spruce budworm, blowdown from excessive winds and increased fire risk from a warming climate are issues that require management. It is noteworthy that national parks, as representatives of natural areas, allow prescribed burning and planting in an effort to re-establish forests that had been disturbed and not naturally regenerated. As an industry, we find a contradiction in the fact that this proposed protective plan will accommodate the potential for economic non-renewable deforestation activities, however, disqualifies renewable forestry practices.

  • Finally, over the years, the NL forest industry has compromised willingly, but in some cases unknowingly, to the accumulation of existing restrictions. Historically, areas proposed by WERAC through the Natural Areas System Plan process were voluntarily avoided by industry and removed from the protective land base with little or no negotiation. However, these final areas are vastly greater than anything previously presented. It has also come to the attention of NLFIA members that the areas have once again been removed, prior to the public release of this document and without industry consultation. After 25 years, if this is to be the FINAL Protected Areas Plan, then NLFIA members find it extremely disappointing and unacceptable that WERAC assumes industry will simply agree.

As stewards of the forest, our member companies are committed to the sustainable use of Our Forests. Sustainable forest management provides for the long-term health of forests while providing social and economic benefits for our residents. We can no longer support the additional erosion of our productive land base and future inventory. We trust WERAC will welcome our input and will collaborate with NLFIA to ensure the final plan provides for sustainable forest management and improved forest governance.


Our FORESTS Our FUTURE


#OurForestsOurFuture #NLForests