October 15, 2020

Corrine Arthur,
Regional Planning Forester,
Ministry of Natural Resources and Forestry

Dear Ms. Arthur,

Please find the Jack’s Lake Association’s (JLA) response to seek Resolution of Issues in the review of the Bancroft-Minden Forest Company (BMFC) 2021-2031 Forest Management Plan (FMP). In our submission, continued logging activities as contemplated in the 2021-2031 FMP will have significant negative environmental impacts on Jack’s lake itself and its surrounding area, outweighing the comparatively minor economic and employment impact of such activities. There should be a moratorium on any further logging activities until the significant and important issues raised below are adequately addressed and resolved.

BACKGROUND

Jack’s Lake is situated in an ecologically unique area.  It is located in a transition area between the Canadian Shield and the Southern Ontario lowlands in an area known as “The Land Between”. Jack’s  Lake is a headwater lake in the Trent-Severn system.  The quality and quantity of water in the lake is dependent on a series of wetlands which surround the lake.  Two of these wetlands have been inventoried according to provincial standards and found to be “Provincially Significant.”  It is clear from a very recent Species at Risk Assessment referred to below that the other wetlands surrounding the lake are also provincially significant and would be designated as such if formally evaluated.  Much of the area in question falls within the boundaries of the Peterborough Crown Game Preserve. 

The lake supports a diversity of fishes including coldwater (lake trout and lake herring), coolwater (walleye and muskellunge) and warmwater (largemouth bass, smallmouth bass, black crappie and panfish) species.  The ecological significance of the Jack’s Lake area has been recognized by Ontario Nature which considered it as one of the top three areas in Ontario, of more than 30 identified, requiring protection.  Letters of support for protection of this unique area have been provided by several interest groups including Ontario Nature, The Land Between, Muskies Canada and Peterborough Field Naturalists.

As you are aware, the JLA engaged in the past Issues Resolution Process for the 2011-2021 FMP in order to protect all of the unique features of Jack’s Lake:

* An essential habitat to many species of mammals, birds, reptiles, amphibians, fish, and numerous threatened and endangered species

* Crown Game Preserve which provides an active wildlife corridor

* Designated Trout Lake Status

* Headwater lake in the Kawartha Lakes, fed by Provincially Significant Wetland complex which feeds fresh water to the Trent System Waterway and the Kawartha Lakes, to Lake Ontario

* Other wetlands within Jack’s Lake would most likely be deemed Provincially Significant if evaluated (Paul Heaven, Wildlife Biologist)

* Curve Lake First Nation sacred ground, archeological sites and trap lines

* Situated within the boundaries of a “ribbon of sensitive land” known as “The Land Between”-this ecosystem is one of the most biodiverse in the world.

* Jack’s Lake is a significant reservoir lake for the Trent Severn Waterway. It is well known that mature forests act like a sponge releasing water slowly as opposed to a cut forest that results in flashy export of water. More thought about hydrology and forestry is essential and becoming more critical as summer droughts become more common. This lake is one of the most important in supplying water when needed in Peterborough.

The JLA Environment Committee who participated in the past Issues Resolution Process are the same team members who will engage in this new FMP: Neill Lanz, Steven Kerr, Dr. David Lean, Denyse Martial, Gary Girvan.

One of the two areas proposed to be logged in this new FMP (2021-2031) was previously evaluated in the 2011-2021 FMP. This area is to the immediate south of Jack’s Lake and around Little Jack’s Lake. This forest was already subject to an Individual Environmental Assessment by the Ministry of the Environment and Climate change (MOECC) at that time, due to the JLA’s appeal to the MOECC. Therefore, the appeal decision imposed then on the FMP should apply to the new FMP as follows:

* A 300 metre setback from Little Jack’s river due to Federal Crown Parkland designation of several acres from the Jack’s Lake Dam and south to Little Jack’s Lake
* 30 metre setback from Little Jack’s Lake
* 90 metre setback from all surrounding wetlands
* Any River crossing by forestry equipment to be south of Little Jack’s Lake
* Any River crossing (bridge) must be removed after logging is completed

A second area, newly proposed in the 2021-2031 FMP, lies close to the shores of Jack’s Lake accessible from the Narrows Point Road.

We have the following concerns with the continued and cumulative impact of logging around our lake:

ISSUES REQUIRING RESOLUTION  

1)  Increased Mercury Mobilization Due to Logging

The relationship between logging and mercury export is relatively well-known. The JLA has consulted with Dr. David Lean, Lean Environmental, a world-renowned expert in Eco-Toxicology, PH.D. Zoology and formerly Director of Eco-Toxicology at the University of Ottawa. Dr. Lean identified serious concerns regarding the increased mercury output which would occur as a result of logging activities. Dr. Lean has investigated this relationship with funding from the Centre of Excellence for Sustainable Forestry. Jack’s Lake fish already have consumption restrictions due to elevated levels of mercury. There is evidence that elevated mercury levels are already resulting in reproductive failures in biota including walleye and common loons. Dr. Lean is of the opinion that continued logging around Jack’s Lake would contribute to higher levels of export of mercury in the coming years. From work in Hubbard Brook, aluminum and iron export is also enhanced with logging.

We look forward to seeing the most recent data collected by MOECP for the Guide to Eating Sport Fish in Ontario. This is a valuable long term data set that becomes even more important as years pass. We predict that we will see increased mercury in sport fish in McCoy Bay as a result of previous logging and indeed increased mercury in years to come. Monitoring of mercury export in streams should be an integral part of this logging operation. Similar work has been conducted in many provinces in Canada as well as similar locations in Scandinavia. In all cases enhanced mercury export is correlated with logging. 

The Stand and Site Guide, utilized by the MNRF, acknowledges its incapacity to effectively evaluate the impact of logging with regard to mercury mobilization. In fact, The Stand and Site Guide identifies “Key Uncertainties” (page 165) “There are many pieces of direction in the guide for which there is uncertainty associated with the outcome of their application. Unfortunately, there are insufficient resources to address all of these uncertainties…within the context provided by direction in the Landscape Guide, will the course filter direction in Section 3.2.2, in concert with the fine filter direction in Section 4, retain sufficient residual forest within catchments to ensure that hydrological effects resulting from forest management operations:

     i) do not exceed those observed in naturally disturbed catchments and
     ii) do not exceed acceptable levels for specific parameters (e.g., methyl mercury)?”

A Stakeholder Advisory Team was established by the MNRF to enable the revision of the Forest Management Guide for Conserving Biodiversity at the Stand and Site Scales in order to address these “Key Uncertainties”.  In 2018 the Stakeholder Advisory Team was put on hold thus serious uncertainties remain. The Federation of Ontario Cottager’s Association (FOCA), which represents the social, economic and environmental interests of 500+ lake associations was disappointed by the collapse of this  opportunity for key stakeholders to have input into the resolution of key uncertainties, including
 “seeing revisions to water setbacks, and considerations about mercury release”.   In our submission, no further logging activity should occur in the vicinity of Jack’s Lake or Little Jack’s Lake until stakeholder input has been received with respect to these uncertainties and they have been resolved satisfactorily.

2) Increased Risk of Forest Fires

The position of MNRF on the relationship between logging and forest fires is not consistent with the scientific body of information. The position of MNRF is that with proper Silviculture techniques, fire is less of a problem. However, the scientific literature has the opposite view. Simply put, a mature forest with a closed canopy has a higher relative humidity even on very hot and dry summer days. A cut forest on the other hand is dry and along with the dead limbs of cut trees provides the ideal place for forest fires to start. The Stand and Site guide does not adequately reflect the recent and growing scientific evidence on this issue.

3) Species at Risk

In May 2020 the province proposed extending an exemption to the Endangered Species Act for forestry. This exemption was intended to “avoid additional regulatory burden and economic strain on the forestry sector”. This legislation threatens the delicate Jack’s Lake ecosystem.

Evidence of the value of wildlife to the Jack’s Lake community can be seen in the 2020 Atlas of almost 4,000 records submitted by Jack’s Lake residents and coordinated by Steven Kerr (JLA Director of Environment). This Atlas demonstrates that the Jack’s Lake area supports more than 30 species at risk (designated both federally and provincially). 

In 2019, the JLA hired Wildlife Biologist, Paul Heaven, to conduct a Species at Risk Evaluation on our lake in which he identified 26 Species at Risk.

The Jack’s Lake community is very ecologically minded and its members participate in several projects on an ongoing basis.  These have included:

* Ontario Turtle Tally (since 2014)
* Canada Lakes Loon Survey (since 1982)
* Invasive Species Monitoring
* Benthic Biomonitoring
* Atlas of Jack’s Lake Fauna (almost 4,000 individual records)
* Lake Partner Program (since 1996)
* Muskellunge Genetics Study (since 2019)
* Petroglyphs Butterfly Survey (since 1999)
* Petroglyphs Christmas Bird Count (since 1986)
* Western Chorus Frog Monitoring Program
* Kawartha Lakes Water Quality Study (since 2017)

The Stand and Site Guide is woefully inadequate to protect these Species at Risk. In studying the 2011-2021 FMP, we see that the only protection offered to the wide variety of Endangered Species is the leaving behind of some hollow standing dead trees. Undoubtedly, loss of habitat in such a fragile environment is of significant concern to the Jack’s Lake community.

In our submission, logging activity should cease in the area of Jack’s Lake and Little Jack’s lake in order to best preserve the habitat for Endangered Species as identified by Paul Heaven in his evaluation.

4) Water Quality – Altered Runoff

Many lakes in the North Kawartha and Haliburton regions are managed to provide a reliable source of water for the Trent-Severn Waterway (TSW).  Natural undisturbed forests retain a more consistent supply of water throughout the year. Clearly, the impacts of logging activities must be considered for future watershed management, flow volume (see above) as well as water quality. The water inflows to the lake from a cut forest become more colored with higher levels of dissolved organic carbon and levels of the nutrients phosphorus and nitrogen are also higher leading to increased eutrophication. We are considering repeating the Species at Risk study to show the damage caused by the recent past logging activities. The rare and endangered species are important for the reestablishment of healthy diverse populations. The trivial financial benefits of logging should be compared to the value of the mature forest. In the past, only one side of the cost benefit equation has been considered. 

5) Invasive, Non-native Species

Logging activity threatens to introduce invasive species into the existing healthy forest. Mitigation strategies, monitoring and enforcement have not been identified in the FMP satisfactorily. There are many pathways for this to occur. One is that trucks which take away timber have also worked in other areas so the potential for cross contamination is present.

6) Impact of Logging Activities Within Close Proximity to Ontario Cottagers and Tourism

There are approximately 580 full time and seasonal residences on Jack’s Lake with cumulative property values conservatively estimated in excess of 4-500 million dollars,  contributing approximately 70% and 80% to the tax base of the Municipalities of Havelock-Belmont-Methuen and North Kawartha respectively. The economic viability of the town of Apsley is directly related to expenditures made by residents on Jack’s Lake, including the thousands of people who benefit from the residing in or visiting the lake community.  Cottage country must be managed carefully to ensure that social and economic benefits are sustained in the future.  Continued logging is incompatible with and in too close proximity to this lake community.  Its negative effects on the environment and the community completely outweigh the economic benefit of employing a very small number of loggers.

The Federation of Ontario Cottager’s Association (FOCA) has stated that “forest covers almost 2/3 of the province of Ontario, and close to 90% of those forests are publicly owned, known as “Crown lands”. According to the province, 44% of these Crown lands are managed forests, which are subject to the Crown Forest Sustainability Act of 1994”. Easy accessibility to forests due to roadways established and maintained by cottagers should not be exploited by the logging industry at the burden of the local lake community and environment.

The Narrows Point Road Association, which has 154 members is registering their objection to logging based on the following concerns: Safety; Road Damage; Impact on Residents (Noise, Visual); Impact on Environment; Impact on Water Quality. 

THE JLA’s PROPOSED RESOLUTION OF ISSUES

At a meeting December 6th, 2019, with Jesse Van Allen, District Manager, MNRF Bancroft District office, the JLA Environment Committee provided a copy of Paul Heaven’s Species at Risk Evaluation which was added to the MNRF database for future reference to inform any decisions that would impact the Jack’s Lake environment.

The JLA recommends that there be a conference that brings together scientists from both sides to bring out all of the information that is essential to make an informed decision on the future of logging and the relationship to downstream water quality and the true value of a mature forest.

The Jack’s Lake Association is requesting a moratorium on any continued logging around Jack’s Lake, including Little Jack’s lake, as the solution to resolve all of the above issues.

Please confirm receipt of this email.

Regards,
Jack’s Lake Association Environment Committee