Bonjour à tous. Good afternoon, everyone. Thank you for the opportunity to provide our perspective as you conduct a study on the review of the federal Fisheries Act.

I am here today representing the Forest Products Association of Canada, or FPAC, which is the voice of Canada's wood, pulp, and paper producers nationally.

Forest product companies employ more than 230,000 Canadians in 200 rural communities from coast to coast. FPAC members sustainably manage approximately 90 million hectares of land in Canada. That's an area approximately twice the size of Sweden, or two and a half times the size of Germany.

Our member companies are responsible for 66% of certified forest lands in Canada. Our members manage forests in a manner that supports economic, environmental, and social sustainability, and we work closely with indigenous communities from coast to coast. Repeated surveys have shown that Canada's forest sector has the best environmental record in the world. In short, we take our environmental responsibilities very seriously.

I would like to highlight a number of mechanisms that could be used as modern safeguards for protecting fish and fish habitat in Canada, and these are relevant to the forest sector. These include the existing provincial regulatory context we operate under, forest certification, and the former DFO operational statements.

I will first expand on the provincial regulatory context for forestry activities.

The exact language and regulations within each province differ slightly, but consistently the forest sector develops long-term forest management plans that include many habitat and biodiversity objectives. We utilize stakeholder input and science-based approaches. Forest management plans are approved by the provincial governments, and companies employ both adaptive management and ecosystem-based management approaches.

Components of sustainable forest management also benefit and contribute to ecosystem services such as biodiversity more broadly, but also the health of fisheries, be they commercial, recreational, or aboriginal.

The forest sector has implemented best management practices, or BMPs, that take into account regionally appropriate science-based approaches for maintaining fish habitat. Often these have been developed with regional DFO staff, provincial governments, and internal forest company biologists and ecologists over the past decades. These forest management plans can refer to regionally relevant codes of practice such as the Foothills Stream Crossing Partnership in Alberta.

The second mechanism I'll speak to is third-party audited forest certification standards. These are widely implemented in Canada. As a requirement of FPAC membership, beginning in 2001, companies committed to certifying their forestry operations under one of three certification standards relevant in North America: the Canadian Standards Association, or CSA; the Sustainable Forestry Initiative, or SFI; and the Forest Stewardship Council, FSC. Canada is a world leader in this area with 43% of the total certified forests in the world.

One of the overarching and relevant requirements of certification is the requirement to conserve biological diversity, or biodiversity. Although the exact language differs among the three standards, there is a fundamental consistency in maintaining naturally occurring ecosystems and habitat for species at risk, as well as habitat with high conservation value. This is built into current forest management.

Additional relevant requirements within the certification standards speak to the protection of riparian areas, which are the areas adjacent to permanent waterways; the protection and maintenance of sites that are biologically or culturally significant; the use of ecosystem-based management approaches; and the development of long-term research and monitoring programs focused on biodiversity.

The last mechanism I would like to discuss is the DFO operational statements, which were also mentioned by Mr. Bloomer earlier.

FPAC was a participant and lead organization in the national resource industry association partnership with DFO during the years 2005 to 2008. This is when parties came together to develop and test operational statements.

The operational statements were an effective and efficient set of guidelines, as well as a notification and tracking system. They outlined science-based timing windows and appropriate mitigation measures for proponents to undertake low-risk activities, both providing outcome-based objectives for avoiding or mitigating any impacts to fish and fish habitat, but also allowing DFO staff to focus on more time-intensive reviews on activities that were deemed higher risk to fish and fish habitat.

The current fisheries protection program at DFO no longer uses the operational statements. FPAC would like to encourage the department to revisit the progress made in developing and implementing guidance for conducting low-risk activities. Forest company staff biologists as well as contractors found the operational statements very useful in providing clear guidance for and explanation of the types of activities, mitigation measures, and timing windows. They were regionally appropriate as well.

In particular, we are aware that DFO has seen a three-quarter reduction of offices with habitat management staff and an overall reduction in regional staff. This is why we encourage DFO to explore existing mechanisms that are robust and implemented widely across the sector to help achieve modern safeguards, but in a streamlined fashion and with high implementation viability.

I would also like to quickly point out elements of the 2012 amendments to the Fisheries Act that we would like to be considered for being maintained, moving forward. These include equivalency of regulatory regimes that are deemed to meet or beat provisions under the federal Fisheries Act—this allows for a one-window approach in jurisdictions and has the potential to reduce regulatory duplication—secondly, the ability to recognize externally developed standards, as appropriate, to guide activities in and near water; and lastly, enhanced partnership opportunities to ensure that agencies and organizations that are best placed to provide fisheries protection provisions are able to do so.

In summary, we encourage the committee and the minister to consider the capacity of DFO in implementing enforcement provisions and regulations as you consider potential changes. We caution against adding further reporting or administrative requirements for proponents without adequate DFO staff to review and monitor for broader, cumulative effects.

In the case of forestry, we see an opportunity to first look to existing mechanisms, as I've outlined, to act as modern safeguards, and then to potential codes of practice or such guidance documents as the operational statements, which could be utilized in a streamlined fashion without adding regulatory duplication.

Thank you again for the opportunity to provide feedback on this important topic. I would welcome your questions. Merci beaucoup.

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