CPAWS Comments on the Government
North Central (draft) Land Use Plan
(January 2006)

	North Central Land Use Plan Area

As its name implies, the North Central land use planning area (NCLUP) is located in north-central Saskatchewan. Its southern border lies near the town of La Ronge. Its northern border lies close to Key Lake. The planning area is large --- 3.2 million hectares --- and encompasses the traditional territories of the Lac La Ronge Woodland Cree Nation.

The area straddles a large section of the Churchill River and lies within two major eco-zones: the Boreal Plain and the Boreal Shield. The majority of land is rugged Canadian Shield, characterized by beautiful scenery, rocky outcrops, a high density of water, thin nutrient-poor soils, a cold climate, short growing season, and a complexity of ever-changing topography and plant life. The most common disturbance in the forest is death (of plants, animals and micro-organisms). The most dramatic disturbance is wild fire.

Most of this forest landscape is in excellent ecological condition. For those who live there or have visited the region, they know of its wild and beautiful character. Local people depend on the forest for many things including water, food, medicines, building materials, artistic inspiration and spiritual renewal.

Draft Plan Content

The government's current draft plan is a weak document. In spite of statements about using good science and ecosystem-based planning principles, this is not an ecosystem-based plan and it is not based on good science. It is better-described as an economic development plan, designed in large part, to meet the needs of the mining and forestry industries without addressing the long-term needs of the forest ecosystem.

It is unlikely that the plan will achieve one of its purported goals: to maintain a healthy environment. There is little substance in the plan's strategies to address the sensitivities of this fragile landscape. The zoning structure is poorly designed from an ecological perspective.

Three zones provide the foundation for the government's draft plan. Roughly 90% of the area is open to industrial development.

	Draft Land Use Plan Zoning Map (Saskatchewan Environment 2006)

1. Protected Zone (lime green) : About 11% is proposed for protection. The large site in the northeast corner (Pink Lake) lies directly over a 'low mineral potential' zone in the region.

2. Sensitive Zone (pale green) : About 31% of the planning area is in this zone. In spite of it's title, these lands are open to commercial logging, mining, road building, etc. This zone includes the Churchill River.

According to the government plan, developers will have to demonstrate to government's satisfaction that development will not conflict with other management developments, or with the protection of identified values. These 'developments' and 'identified values' are not clearly defined, leaving the reader with little understanding of what this means, or how it will be achieved.

3. Management Zone (peach and pale yellow) : The rest of the region, about 56%, is zoned for intensive resource extraction and development (timber harvesting, mining, etc).

Note: The dark green areas lie outside of the planning area. The brown is the La Ronge Corridor plan area (a plan nestled within the NCLUP).

Major Issues

The draft plan fails to consider the fragile and sensitive nature of this boreal region. Traditional knowledge and scientific planning principles necessary to address the ecological needs of the region, have not been integrated into the plan. Extensive ecological information complete with recommendations, were supplied to the planning table, but have largely been ignored.

Major problems with the draft plan include:

1. The government plan is not balanced.
Four years of research shows this forest landscape to be particularly fragile and sensitive to un-natural impacts. Almost 90% of the land base however, is open to industrial developments known to impact ecosystems. This risks...

• widespread ecological damage to this fragile and easily damaged landscape. Mistakes will likely be long-lasting.
• erosion of many current and potential economic endeavours in the region, including tourism, fishing, trapping and hunting.
• erosion of the recreational values in the region.
• erosion of the social and cultural fabric of the human communities in the region.

2. The proposed protected areas (ecological reserves) are not good choices.
The Pink Lake site is appreciably large, but the site was chosen for its low mineral potential, low forestry potential and an analysis of rocks, soils and topography (enduring features). From a science perspective

• not enough of this fragile landscape is protected from industrial development.
• the sites are not interconnected and do not provide for safe, unimpaired, seasonal movements of wildlife across the landscape.
• the sites do not protect rare or sensitive places.
• the sites are not designed to protect species at risk (e.g. woodland caribou).
• the sites do not provide adequate spaces to ensure that the forest's natural disturbance patterns are maintained throughout the region.
• the proposed sites do not encompass a representative array of terrestrial and aquatic habitats in the region, important to preserving the web of life in the forest.

3. Ecologically important and highly valued places like the Churchill River, Foster Lakes/River system and the Paul River system are zoned for commercial development (industrial logging and mining).
In so doing, the significance of these waterways to the overall functioning of the forest and to the ongoing economic, cultural and recreational pursuits of citizens are not considered or addressed.

4. The plan incorrectly assumes that mining and commercial logging are appropriate activities in most of the planning area.

• research data and analyses collected for the planning process indicates that most of the planning area is unsuitable for commercial logging, both ecologically and economically.
• the mining industry is given unfettered access to all lands of interest to them, regardless of social, cultural, ecological or other economic values in the region.

5. The draft plan relies too heavily on an assortment of management tools to care for the ecosystem .
While management tools like forestry guidelines, forest management plans and environmental impact assessments have an important role, heavy reliance on them for 90% of this area is problematic for a several reasons...

• Significant knowledge-gaps about complex ecosystems: As new information becomes available, accepted techniques used today, quickly become outdated policies of yesterday . Heavy reliance on these ever-changing human methods is dangerous simply because of human knowledge gaps and inabilities to successfully manage complex ecosystems. This is a primary reason for well-chosen networks of protected areas that can provide balance and act as buffers or 'ecological insurance packages' to help maintain a healthy forest.
• Limited baseline data upon which to make decisions: Management objectives are being set with limited or no baseline information on which to measure objectives. As noted, prescriptions for things like forest regeneration, disease control, etc are very dissimilar to natural ecosystem-functions. Many of these prescriptions are being developed with limited knowledge of forest functioning.
• Strong human biases to manage for maximum resource extraction instead of ecosystem health: Existing and upcoming provincial standards and guidelines for forestry are not 'ecosystem-based' because the bias is to manage for fibre production, not maintain natural forest functioning. This is evidenced in new standards currently being developed. For example, proposed management criteria for mistletoe (witches broom) are calling for widespread removal of mistletoe to remove/reduce 'diseased' trees in the commercially harvested forest. Mistletoe is an important part of the forest ecosystem, providing important habitat for different wildlife.
• Inherent limitations with Environmental Impact Assessments: Once an environmental impacts assessments (EIA) is underway, the development project is almost certain to go ahead. In other words, the assessments look at how to minimize and/or mitigate impacts, not if the project should actually go ahead in the first place. Moreover, EIA processes typically apply to large projects only. Many small developments are usually not required to do an EIA.
• Lack of public funds to enforce the rules: Saskatchewan's Environment department is so short-staffed and under-funded, enforcement is and will be a huge problem to oversee compliance in forestry and mining operations.
• The ecologically sensitive nature of this region: Mistakes will be long-lasting.

6. Cumulative impacts from an array of potential developments are not addressed in the draft plan.
Government argues that forest management plans and environmental impact assessments will take care of the forest. Item #5 above discusses some of the problems with this position. In addition, there is nothing in this land use plan to address environmental problems due to cumulative damages that can occur from an array of activities and developments in the area.

The Positives in the Government Plan

The draft land use plan has some good things to offer:

• The plan does a good job of acknowledging the importance of these lands to the northern people, especially the Lac La Ronge Indian Band
• The plan correctly recognizes the need for local employment
• The plan explains that the land use plan is needed before the Band can move ahead with obtaining a Forest Management Agreement
• The plan calls for some good research projects (e.g. effects of disturbance, human development and climate change on watersheds)
• The plan calls for an inventory of sites that are important to the production of non-timber forest products
• The plan calls for incorporating traditional and local knowledge into wildlife management strategies, setting hunting seasons and species limits
• The plan calls for identifying critical wildlife habitat and areas of specific concern
• The plan suggests that the provincial woodland caribou recovery team should identify the NCLUP area as high priority
• The plan calls for continued development of training and employment-related partnerships between industry and the Band and local communities
• The plan calls for better education regarding outdoor recreation ethics and in particular, waste management.

A Vision for Better Planning

CPAWS and others worked together to gather and assemble best-available information to help produce a good land use plan. We envision a plan that is premised on good information, cautious land use zoning, careful decision-making and modern planning techniques. Our objectives are to ensure maintenance of the region's ecological integrity, indigenous culture, recreation opportunities and sustainable economic development. This work continues

Our Information is documented in the Uskiy Puhco report entitled Towards Ecosystem-based Conservation Planning in the North Central Land Use Plan Area (May 25, 2005). It provides extensive background information about the planning area, data analysis, land use recommendations and a vision for what should be considered in developing a good land use plan. A Summary of this report is available as well.

LEARN MORE:

Towards Ecosystem-based Conservation Planning in the NCLUP Read the Uskiy Puhco research report prepared for the North Central land use planning process. Full Report Summary Report

A Vision for Better Planning in the NCLUP Read more about CPAWS's vision for the North Central land use planning area. Learn about major research findings, a proposed zoning structure for the planning area and recommendations for future planning.