Thank you very much for the opportunity to appear before the committee.
As you said, I represent the Canadian Association of Forest Owners. About 92% of the forest land in Canada is publicly owned; the other 8% is privately owned and totals about 25 million hectares. A hectare is roughly 100 metres by 100 metres, or two football fields side by side, just to give you a scale. Of this 25 million hectares, 20 million is owned by 450,000 woodlot owners, whose average property size is about 40 hectares. The other five million is owned by companies like J.D. Irving, Wagner forest products, Acadian Timber, Island Timberlands, TimberWest, and other large industrial forest landowners. These are mainly the companies that make up the Canadian Association of Forest Owners, or CAFO.
CAFO members also manage 15 million hectares of public land. CAFO works closely with woodlot owners and farmers, and we share many of the same issues and challenges with these other rural landowners. All CAFO members are certified to one or several forest certification systems, and all are subject to the same regulations you see on public land: protection of water supply, fish and wildlife habitat, soil conservation, and other requirements. There's a legal requirement to reforest, and landowners are subject to penalties, audits, and public reporting.
Private forest lands make up 13% of the managed forests of Canada. They're located in some of the most productive sites in the country and are very well managed. As a result, this 13% of managed forests produces 18% of the forest products of Canada, contributes $7 billion to our GDP, and supports 80,000 jobs in rural Canada.
Private forests are also very productive in terms of wildlife and fish habitat. As a result they tend to attract the attention of wildlife and fisheries managers looking to protect habitat, and set aside portions of the forest to maintain critical habitat and ensure the recovery of species at risk. Forest owners fully support and spend millions on habitat management and protection, and are willing to work with governments to enhance protection.
The challenge arises when officials come onto private lands, sometimes without notice or approval, and begin to identify habitat. Once habitat is identified, it places a de facto restriction on what the owner can do with or near that habitat, reducing flexibility and options on their own land.
CAFO members seek to work with government to identify habitat and develop ways to protect it. They're willing to share the information they have about their lands. They want to avoid situations where they must set aside large areas to protect habitat regardless of the health of populations either on their land or elsewhere, despite the fact that it's private land where owners are trying to operate businesses and maintain the value of their asset.
CAFO members want government to adopt a two-step policy when identifying critical habitat. Step one would be to first identify habitat on public land and then, if necessary and with the knowledge and consent of the owner, identify habitat on private land. This approach ensures the involvement and support of landowners. It builds a relationship whereby the landowner is willing to share the extensive knowledge and information they have about their land without the fear that sharing that information will result in even more restrictions being placed on them.
CAFO has begun discussions with Environment Canada to develop conservation agreements under the Species at Risk Act. The idea is to recognize the efforts landowners already make to protect habitat, and avoid penalizing owners by adding further restrictions or imposing fines if mistakes happen and habitat is inadvertently damaged or species are harmed. Such agreements would be subject to annual, external, third-party audits under forest certification schemes. For forest owners, this would add a great deal of certainty to their business. For government, it would give them the assurance that habitat is being protected, while the audit function ensures that the work is being done and that any necessary corrective actions are identified and carried out in a timely manner.
The challenge we face with these agreements is that landowners manage habitat across the land base, not habitat for species A or species B. For government, the Species at Risk Act requires that if a species is identified as being at risk, a recovery strategy is required and very specific measures and actions are developed. This results in several actions for several species all on the same land base. This quickly becomes complicated, very expensive, and very difficult to measure in terms of success or failure. Our preferred approach would be to manage the land base, protect habitat, and verify that protection through annual audits.
I want to raise log exports on behalf of CAFO members with the B.C. Private Forest Landowners Association. This is a B.C.-only issue, but it seriously restricts their ability to conduct business. Log exports are subject to a surplus test in B.C.; in other words, logs can only be exported if they are surplus to domestic needs. This requirement makes logs available at a lower domestic price and affects the ability of the owners to assure foreign buyers of the volume, species, quality, and timing of the logs that they wish to purchase. There’s a large surplus of logs available to the domestic market, but this requirement remains in place. We would not consider a restriction on the export of raw wheat and a lower price for wheat producers in order to subsidize the domestic bread industry.
The softwood lumber agreement is coming up for renewal very shortly. The price of lumber affects the price of logs, and CAFO members are interested in providing their perspective in the softwood lumber agreement negotiations. CAFO is seeking recognition for private property rights and a distinction between public land and private land. We are looking to work with government, develop arrangements that are in the best interests of wildlife, and provide assurances that landowners will not be penalized for providing information about their land. Owners in B.C. are seeking to have restrictions on log exports removed and to participate in softwood lumber discussions.
All of these arrangements that I’ve described will provide certainty for business and allow forest owners to invest in their land, grow higher-value products, and generate further economic activity across the country.
Thank you.