SUBMISSION TO SASKATCHEWAN ENVIRONMENT
North Central Land Use Planning Process: Issues and Solutions
January 2005

The document below was submitted jointly by CPAWS Saskatchewan and The Saskatchewan Environmental Society, to Deputy Minister Stonehouse, Saskatchewan Environment.

CANADIAN PARKS & WILDERNESS SOCIETY (CPAWS)
SASKATCHEWAN ENVIRONMENTAL SOCIETY (SES)

NORTH CENTRAL LAND USE PLANNING PROCESS:
ISSUES & SOLUTIONS

January 2005

History

The North Central Land Use Regional Advisory Board Terms of Reference state:

The Regional Advisory Board will develop a land use plan, and recommend its implementation to the Minister of Saskatchewan Environment. This land use plan will be used to guide and regulate land use activities that impact land, water, air, renewable and non-renewable resources of the North Central land use area. An Ecosystem Based Management approach will be used to develop an integrated and ecologically sound plan to ensure sustainable ecological, social, cultural, and economic benefits for present and future generations.

Over the past four years, members of the Regional Advisory Board (RAB) for the North Central Land Use Planning Process (NCLUP) have been working together to develop an ecosystem-based land use plan. In addition to attending RAB meetings, a group of several RAB members and other local residents have worked with an independent consultant to gather more information about the character and condition of the ecosystems within the planning area. This group has tried to gain a better understanding of what is needed to maintain a healthy forest ecosystem in the region and to determine the economic viability and ecological sustainability of proposed forestry developments in the region. Important data has been collected and analyzed. New interpretive maps of the region have been developed.

On September 17 (2004) the consultant presented the maps and an overview of this analysis at a meeting of the Regional Advisory Board. The next day, Saskatchewan Environment cancelled future RAB meetings. This effectively removed the forum in which the public could meet to collectively discuss land use issues, provide and receive information, and ultimately, develop recommendations for land use and protection in the North Central region.

Issue

The North Central Land Use Planning Process is seriously flawed. The process has been characterized by barriers to effective citizen participation, a premature commitment to the expansion of industrial forestry, and the absence or exclusion of important information.

The government’s reluctance to vest the Regional Advisory Board with the authority, information and resources to do its job has made it difficult to make progress.

We have serious concerns, both about the integrity of the government’s public consultation process and about its ability to develop an ‘ecologically sound plan to ensure sustainable ecological, social, cultural, and economic benefits for present and future generations.’

Problems with the Land Use Planning Process

Barriers to Effective Citizen Participation

1. Failure to support our right to participate in the process.

When several representatives from local communities and representatives from provincial organizations expressed a common commitment to placing a priority on maintaining healthy ecosystems, one government spokesman (not from Saskatchewan Environment) stated that there were “too many environmentalists” on the Regional Advisory Board and challenged our right to participate in the process. In contrast, the local representatives on the Regional Advisory Board have welcomed our participation and invited us to work with them on the development of an ecosystem-based land use plan.

Our right to participate in the process was further challenged when the government decided to discontinue funding to cover our travel expenses to attend meetings. As a result groups such as CPAWS, SES, Canoe Saskatchewan, and the Saskatchewan Ecotourism Society have had to cover their own costs, or limit participation.

Rather than seeing environmental organizations as important resources with much to contribute to the development of an ecosystem-based plan, we have been shunted to the margins of the process. The government’s September 2004 decision to suspend any further meetings of the Regional Advisory Board in this fiscal year effectively closes off our participation in the development of the government land use plan.

2. Reluctance to share decision-making power.

Effective citizen participation in the land use planning process was hindered by participants’ fears that our involvement in the process would be co-opted and used to legitimate land use planning recommendations that did not reflect our own views. One of the major reasons it took months to develop Terms of Reference was because people sought assurances that we, as citizens, would clearly be able to state our own recommendations in a draft plan. We agreed to participate with the understanding that the government would respond to the citizens’ recommendations, giving an explanation for agreement or disagreement with the views of the Regional Advisory Board. While we recognize that the Minister is responsible for the decision to approve and implement a land use plan, and that the draft plan would be subject to interdepartmental, technical and public reviews, nevertheless we wanted the draft plan to be a true reflection of our recommendations and decisions.

The government’s responses to our concerns have been contradictory. On one hand, staff have assured participants that our voices and views would be fairly represented in the draft plan. On the other hand, the government has made unilateral decisions on a number of occasions that have called into question their willingness to let the members of the Regional Advisory Board develop a plan that truly reflects our own views. We have heard local people who have been active in meetings say repeatedly that they do not feel heard.

The government was unwilling to adhere to a Regional Advisory Board decision that set a meeting agenda to bring in an ecosystem-based planning consultant to discuss what we considered to be key information. Instead, government actions reflected a paternalistic attitude that they knew what we needed better then we did ourselves. As a result of this and other instances in which people felt that they were not being heard, several members of the Regional Advisory Board wrote to the Minister to express our concerns.

After waiting several months, the information was finally presented to the Regional Advisory Board in September. However, instead of enabling the RAB to work with the information and incorporate the findings into a draft plan, the government chose to shut the RAB process down. It now appears that the draft plan will be written by Saskatchewan Environment staff with minimal participation by members of the Regional Advisory Board. We have been dismissed and the decisions regarding recommendations for the land use plan have been taken out of our hands. Having devoted countless hours to this process in good faith, we find this unacceptable.

Premature Commitment to Industrial Forestry

1. Proponents of expanded forestry operations lack important information

It appears that the government is planning for industrial forestry before an adequate forest inventory is complete. Reconnaissance level analysis does not provide adequate information about the quantity and quality of timber resource, much less the complexity of boreal ecosystems. There is a lack of adequate landscape analyses and a lack of information on harvesting and silviculture for Saskatchewan Shield ecosystems, which differs significantly from the Boreal Plain.

Important questions about forestry which were raised by local advisory boards have not been fully addressed. Saskatchewan Environment has not yet produced issue papers to address several key issues:

• How can you plan without an adequate forest inventory?
• What kind of harvesting and silviculture practices are sustainable and maintain biodiversity?
• How would forestry impact on wildlife in the region?
• What restrictions on forestry make sense in riparian areas?
• What do we know about reforestation after harvesting in this type of forest?

Concerns raised about potential environmental damage caused by industrial forestry practices have been met with assurances that environmental impact assessments are done and forest management practices are monitored and adapted as problems arise. While this is important, it does not preclude the need to address these questions when developing a land use plan.

We have not been presented with any convincing evidence that industrial forestry makes either ecological or economic sense in this region. To the contrary, we have evidence that suggests otherwise. We are not prepared to risk the health of forest ecosystems and the economic potential of other land uses, to gamble on a development that may be empty promises.

2. Early assurances are called into question.

We are concerned that government is planning for industrial forest licencing with Kitsaki/Zelensky; using forest management practice requirements as a substitute for ecosystem-based management.

The government made a commitment to expand forestry operations in northern Saskatchewan while at the same time assuring the RAB that no new allocations would be made until the RAB had made its recommendations, zones for various activities were identified, and a land use plan developed. Now the government appears to be proceeding toward developing a land use plan without the RAB’s input.

The government decision to expand forest fire protection also seems to indicate plans to suppress fire to protect commercial forestry interests across a wider area.

With the demise of the RAB, it appears that the proponents of expanded forestry operations are playing a greater role in the development of the land use plan. How are their interests kept in balance with other interests, and with overall plan goals?

Absence or Exclusion of Important Information

1. Need to synthesize information to make it accessible.

Throughout the planning process, citizens have asked for better information in order to make better decisions. The information needs for public participation cannot be met simply with boxes of background documents. The data need to be synthesized so that people understand available evidence and have a clear identification of knowledge gaps.

Requests for useful summaries of information to address some fundamental questions have been brushed aside with statements like “we don’t have time to learn all there is to know about forest ecosystems” or “we’ve got stacks of papers about this if you want to read them”. It is important not to dismiss or underestimate people's capacity to learn complex information to make informed decisions. Land use planning presents an opportunity to foster adult learning that should be encouraged rather than stifled. Instead of questions being brushed aside, they should be investigated and the information conveyed in clear language. There is a need to mobilize knowledge sources outside government to respond to citizen's questions and desire to learn.

2. Planning with Major Information Gaps

Efforts to synthesize evidence from scientific research should be coupled with greater efforts to ensure the inclusion of local voices and indigenous knowledge. Additional resources are needed to support work to bring the voices and concerns of those who are traditional occupants and users of the land to the forefront of the planning process. The knowledge of those who live closest to the land is absolutely essential to making wise decisions.

Ecosystem-based planning requires an assessment of what is needed to maintain the health and integrity of the ecosystem. We have tried to bring information that addresses this fundamental question to the table, but have been frustrated by the way that information and issues are dealt with in a fragmented way.

This fall we were presented with an analysis which offered a logical framework for ecosystem-based planning combined with locally relevant data. This could have been the basis for fruitful discussions and debates. Instead it was followed by a decision to suspend RAB discussions.

Major gaps have been identified in the following areas:

• timber inventory;
• analyses of character and condition of landscape;
• discussion on industry impacts on wildlife, ecosystem functioning, etc;
• lack of integration with endangered species work in province;
• science-based rationale for government-proposed RAN sites;
• discussions to understand what is needed to maintain viable populations of umbrella species, keystone species, indicator species;
• information to understand what linkages are needed to maintain connectivity across the landscape;
• information to understand economic viability/sustainability of forestry in the region.
• information to better understand the potential impact of industrial development on other land use opportunities in the region.

These gaps must be filled before planning decisions are made.

Next Steps to Deal with the Problems and Issues in the NCLUP

1. CPAWS and SES remain committed to working with people living in the North Central region to develop an ecosystem-based land use plan for the region. This plan will be based on the following:

• Good information stemming from best science and best traditional knowledge of the land.
• Cautious land use zoning and decision making, recognizing that the NCLUP ecosystem is fragile, that there is a lot humans don’t know about the ecosystem, and that there is much that we do know about impacts from industrial activities such as forestry, mining and roads, on the land.
• Modern planning techniques that mimic state of the art planning processes underway in other parts of Canada, the United States and South America (e.g. Yellowstone to Yukon). These modern processes include gathering good information and pursuing meaningful discussions and decision-making about human and ecological needs. Maintaining the long term health of the ecosystem is foundational to all planning decisions, and the needs of local people are always considered.
  

2. CPAWS, SES and community people will continue with research required for ecosystem-based planning. Extensive and valid research information has been collected and analyzed by the North Central communities and ENGOs over the past several years to provide best-available information for the planning process and to fulfill the requirements of the Terms of Reference for the NCLUP. This work is ongoing. The following is scheduled for 2005:

• Additional ecological data collection and analysis, with emphasis on obtaining and interpreting vegetation/landcover information;
• Additional collection of cultural and local information;
• Finalization of the economic analysis for timber management in the NCLUP region;
• Analysis of other economic opportunities in the NCLUP region, beyond mining and forestry, including solutions to develop solid community economies.

3. CPAWS, SES and community people will assemble an ecosystem-based plan for the North Central Region and share it with governments and other actively interested parties.

Our Proposal to Work with Government

As a result of the frustrations experienced by the RAB participants and the subsequent demise of that body, it appears that two distinct land use plans will be developed for the North Central region: one by the communities and NGOs and one by government. We recognize that there may well be significant differences between the plans, e.g. on zoning and allowable land uses. In order to progress we make the following suggestions:

1. We request information from government that will serve two purposes: a) enable us to ensure that as we prepare our plan we will be working from the fullest available data; b) help us understand the process and rationale being followed by SE in developing their plan.

We would like to obtain the following public information:

• Government’s vegetation/land cover data for the NCLUP region;
• Government’s ecosystem analysis (character and condition) of the NCLUP region;
• Government’s RAN analysis of the NCLUP region;
• Government’s understanding/analysis of ecological impacts from human activities such as forestry, mining, road and trail building, etc on different ecosystems in the NCLUP area;
• Government’s economic forestry analysis for the NCLUP region;
• Government’s economic benefits analysis of the different land uses for the NCLUP area;
• Government’s gap analysis of information needed to complete an ecosystem-based land use plan for the NCLUP region.

To help us understand what other government activities are under way for the North Central planning region, we would like clarification on the following:

• Who has government been meeting with since September 2004, to work towards development of a North Central land use plan? Communities? Industries? Other?
• What stage is the writing of the plan currently at?
• What activities does government have planned to complete their land use plan? How will it fit with the work that the communities and ENGOs are doing? What is government’s timetable?

We are interested in meeting with government to discuss technical aspects of planning, ecology, forestry, other economic opportunities, etc. We repeat an earlier request/offer to conduct a technical meeting with SE. As the communities’ consultant, Herb Hammond should attend the meeting, at government expense.

2. We wish to meet with government . a) to negotiate an improved public consultation process for examination of the two plans and the information on which they are based, and b) to discuss how working towards a final plan should proceed.

What is at risk here?

The information gathered and analyzed so far strongly suggests that widespread industrial forestry is a risky endeavor for the North Central region. This stems from both economic and ecological data results:

Economic
In light of the research that we have assembled thus far, it is our opinion that government would be foolish to rush into finalizing a land use plan that promotes industrial development and risks foreclosing on ecosystem health and smaller, community-based economic activities in the area.

With respect to forestry, the government runs the risk of raising expectations for long-term local employment that won’t materialize An interim analysis looking at likely trends in forestry operating costs and anecdotal information suggest that the timber resources in much of the NCLUP are not economically operable. The planning table has not been provided with any information to counter these findings. Government risks having ‘egg on their face” when they have to provide major subsidies to keep the logging company going to meet expectations for meaningful and long-term jobs.

Environmental
Without proper examination and consideration of important data, there is a risk of severe ecological damage to the ecosystem. Our interim analysis of the character and condition of the landscape suggests that industrial forestry could harm the land significantly. The land is fragile because of soil characteristics, topography, climate, and other landscape features. Large-scale, widespread logging activities risk damage ranging from irreversible deterioration of thin soils to loss of ecosystem diversity, including removal of rare, but ecologically important habitats.

Social/Cultural
If the Provincial Government does not review the current planning process and enter into discussions with communities and ENGOs, this will set a precedent of poor public consultation in land use planning. There is currently inadequate process for public input into the land use plan. A plan that will not be supported or embraced by local people and public interest groups could well result.

Loss of ecological integrity in the region risks loss of land for traditional indigenous use and forecloses opportunities for future generations.

What is needed?

• Good information
• Transparent discussions
• Credible process that respects input from participants
• Credible process that does not give preference to industrial needs
• An ecosystem-based plan that is supported by communities
• No incremental forest resource allocations or major timber harvesting permits or licenses until an ecosystem-based plan is in place.

Though this process has failed in its previous form, it is not impossible to fix. Collaborative, inclusive land use planning is occurring elsewhere.

LEARN MORE:

North Central Land Use Plan Information on the North Central Land Use planning process and CPAWS work.