Domtar Pineland FM audit 06
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Domtar Pineland FM audit 06

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Certified by: SmartWood Headquarters 65 Millet St. Suite 201 Richmond, VT 05477 USA Forest Management Tel: 802-434-5491 Fax: 802-434-3116 www.smartwood.org 2006 Annual audit Contact person: Jon Jickling jjickling@smartwood.org Report for: The Pineland Forest, Certification Audit Performed by: Managed by Domtar Inc SmartWood Canada REgion 215 Nortre-Dame de l'lle #3 in Tel: 819-772-5740 Fax: 819-772-5740 Ontario, Canada Contact person: Alexandre Boursier Email: aboursier@ra.org (in the vicinity of Foleyet and Gogama) SW-FM/COC-1599 Certificate Code: Dec. 5-Dec. 7, 2006 Audit Dates: thMarch 5 2007 Report Finalized: Chris Wedeles, Nick Auditors: Baggs, Phil Shantz Keith Ley Operation Contact ACCREDITED 100 Old Nairn Road, Address: FSC-ACC-004 Nairn Centre, Ontario © 1996 Forest Stewardship Council A.C. P0M 2L0 FM-06 Oct 2005 TABLE OF CONTENTS 1. AUDIT PROCESS ..................................................................................................................................3 1.1. AUDITORS AND QUALIFICATIONS: ................................................................................................................. 3 1.2. AUDIT SCHEDULE.......................................................................................................................................... 4 1.3. SAMPLING METHODOLOGY: ..................... ...

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   Certified b :  SmartWood Headquarters 65 Millet St. Suite 201 Richmond, VT 05477 USA Tel: 802-434-5491 Fax: 802-434-3116 www.smartwood.org Contact person: Jon Jickling jjickling@smartwood.org         Certification Audit Performed by:            SmartWood Canada REgion 215 Nortre-Dame de l'lle #3 Tel: 819-772-5740 Fax: 819-772-5740 Contact person: Alexandre Boursier Email: aboursier@ra.org         
  ACCREDITED FSC-ACC-004  © 1996 Forest Stewardship Council A.C.          FM-06 Oct 2005
       
    
 
    
Forest Management 2006 Annual audit Report for:
The Pineland Forest, Managed by Domtar Inc in Ontario, Canada (in the vicinity of Foleyet and Gogama) Certificate Code:COC/MF-WS9 59-1     Audit Dates:Dec. 5-Dec. 7, 2006 Report Finalized:March 5th2007  Auditors:Chris Wedeles, Nick Baggs, Phil Shantz   Operation ContactKeith Ley Address:100 Old Nairn Road, Nairn Centre, Ontario P0M 2L0   
 
TABLE OF CONTENTS   1. P TIDUA........................SS..ROCE........................................3................................................................ 1.1. AUDITORS AND QUALIFICATIONS:................................................................................................................. 3 1.2. AUDIT SCHEDULE.......................................................................................................................................... 4 1.3. SAMPLING METHODOLOGY:.......................................................................................................................... 4 1.4. STAKEHOLDER CONSULTATION PROCESS.................................................................................................... 5 1.5. CHANGES TOSTANDARDS(IF APPLICABLE)................................................................................................. 5 2. AUDIT FINDINGS AND RESULTS ........................................................................................................5 2.1. CHANGES IN THE FOREST MANAGEMENT OF THEFMO............................................................................... 5 2.2. STAKEHOLDER ISSUES................................................................................................................................. 6 2.3. COMPLIANCE WITH APPLICABLE CORRECTIVE ACTIONS............................................................................... 8 2.4. NEW CORRECTIVE ACTIONS ISSUED AS A RESULT OF THIS AUDIT............................................................. 27 2.5. AUDIT OBSERVATIONS................................................................................................................................ 28 2.6. NOTES FOR FUTURE AUDIT......................................................................................................................... 28 2.7. AUDIT DECISION.......................................................................................................................................... 28 APPENDIX I: List of visited sites (confidential) ...........................................................................................29 APPENDIX II: List of stakeholders consulted (confidential) ........................................................................30 APPENDIX III: Criterion-level evaluation of compliance (confidential)........................................................32 APPENDIX IV: Chain of Custody Compliance (confidential) ......................................................................34 APPENDIX V: SmartWood Database Update Form ...................................................................................36  
 
Standard Conversions  1 acre = 0.405 hectares 1 foot = 0.3048 Meters 1 mile 1.60934 Kilometers =  1 mbf = 5.1 m3 1 cord = 2.55 m3  1 Gallon (US) = 3.78541 Liters   
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1. AUDIT PROCESS  
 
 
1.1. Auditors and qualifications:   Chris Wedelesfe bldlia wi is iclas epigtsoiol he ting iniz C –ishr relationship between forest management and wildlife ecology. Chris has been a professional consultant since 1986 and for the last ten years has been a partner in ArborVitae Environmental Services Ltd. In his consulting career Chris has worked on forest-related projects in every province in Canada. Chris has led or participated in approximately 35 audits and assessments of the management of tenured forest areas in Canada. Other recent relevant experience includes: being a technical writer in the development of the FSC National Boreal Standard (NBS), participating in a project to assess the wood-supply and ecological effects of the NBS, co-authoring comprehensive technical reports dealing with effects of forest management on songbirds, old growth management, and effects of roads in managed forests in Canada. Chris is currently working on a document related to the ecological effects of boreal forest fragmentation.  Phil Shantz Phil Shantz is registered professional planner, auditor and – socio-economist who has specialized in resource management projects across Northern Ontario. Since 2000, Phil has led or participated in approximately 25 forestry audits in Canada and the US, where he is responsible for socio-economic, public and aboriginal components. This included being part of the team that field tested the Draft FSC Ontario Boreal Standard and the assessment of the wood supply, biodiversity and community socio-economic effects of the National Boreal Standard. Phil has also led some of the largest resource economic studies in Northern Ontario and is currently managing a variety of environmental assessments of hydro-electric projects throughout the North. Phil is a shareholder and member of the environmental assessment and auditing groups at SENES Consultants Limited. ƒ Nick Baggs, R.P.F is a forest management consultant. – Forester. Nick specializing in policy review, audit and prescription services. He has worked in forest management planning and operations since 1982. He is also experienced in the development of various certification and other assessment standards in Ontario and British Columbia. Audit-related projects include two reviews of the Independent Forest Audit (IFA) Process in Ontario (2001 & 2006), IFA preparation and audit assignments on twenty Ontario forests, ISO 14001 internal EMS audits and update of the Ontario Forest Industries Association Code of Forest Practices. Nick completed the SmartWood Lead Assessor training course in 2001 and has since
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1.2.
1.3.
participated in six SmartWood FSC certification assessments (one as lead auditor) and ten annual audits in Ontario.   Audit schedule  Date Location /main Main activities sites November 20 – 22 Pineland Forest Interview with company staff and First Area Nations representatives (PS) Nov. 27-Dec. 1 Auditors’ offices Review of documents, scheduling of interviews, preparation of materials (CW, NB) Dec. 5 Travel Travel to Timmins (CW) Dec. 6 Field Inspection Truck-based tour, field inspection of approx. 12 sites on the forest – on-going harvest, road construction, water crossings, riparian areas, road condition (CW) Dec. 7 Timmins Interviews with company staff Dec. 8 – Feb.14 Auditor’s offices Follow-up with company staff, report writing Total number of person days used for the audit: 13.5 total Level of Effort (1 day of field work and 12.5 days of research, report writing, review and approval)    Sampling methodology:  One member of the audit team spent one day in the field in this annual audit. This reflects the fact that only one Condition (now called CARs, or Corrective Action Requests) required field observation. That was Condition 6.3h, related to water crossings. In addition, other sites were inspected to provide due-diligence for the audit process, to inspect areas operated by one particular contractor, and to inspect how new harvest procedures were being implemented by the company. Considerable time and expense is required to visit any significant number of field sites. This expenditure was not warranted to verify compliance with the other Conditions, or to address most of the Notes from the Auditors.  FMU or Rationale for selection Site audited Block 201, Access Road Inspection of a cross-drainage culvert Block 201, Mixedwood Inspection of a recently-conducted harvest using feller-buncher, Forest Unit processor for in-bush delimbing, and forwarder. Block 201, Access Road Inspection of a culvert installation on a previously un-documented stream Block 201, Conifer Forest Inspection of site impact on forwarder trail, discussion with Unit machine operator (through translation provided by C. D’Amours) Block 201, Access Road Inspection of on-going road construction Block 21, Access Road Inspection of recently-replaced culvert, draining a swampy area)
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Block 21 Mixedwood Forest Inspection of on-going harvesting operation using feller-buncher Unit and processor. Discussion with processor operator. Block 21, Mixedwood Forest Inspection of road construction and wood piles Unit Block 21, Access Road Inspection of recently-replaced culvert Block 21, Access Road Inspection of recently-replaced culvert   1.4. Stakeholder consultation process  The audit focused on interviews with Domtar staff, staff of contractors, and review of documents. The team also interviewed representatives of First Nations, environmental NGOs, local stakeholders and staff of the Ontario Ministry of Natural Resources.  Stakeholder t e Number f Number of osta (NGO, government, local stakeholders keholders inhabitant etc.) informed prcoovnisdiunltge idn opru t  NGO 2 2 First Nations 9 4 Local Stakeholders 2 2 Government 4 3  1.5. Changes to Standards (if applicable) The standard used for this annual audit was the Forest Stewardship Council (FSC) Canada Working Group National Boreal Standard (NBS, Version 3, November 2004). The FSC Board accredited the National Boreal Standard in August 2004.   This is the same standard used in the assessment in 2004. No changes have occurred. 
2. AUDIT FINDINGS AND RESULTS 2.1. Changes in the forest management of the FMO  As is outlined in the Assessment Report, the original assessment for the Forest was undertaken when it existed as the Pineland-Martel Forest. During the period when the assessment report was being written, tenure and management responsibility for the Martel portion of the Forest was transferred to Tembec Inc. As a result, the assessment report was revised so that it addressed only the Pineland portion of the former Pineland-Martel Forest. Several Conditions in the original assessment relate to undertaking/completing analyses only for the Pineland portion of the Forest, as they were originally done for the Pineland-Martel Forest. An example is Condition 6.3f, which relates to core forest areas.  Another significant change since the assessment is the approval of a new Forest Management Plan (FMP), which came into effect on May 5, 2006. The original
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2.2.
assessment was undertaken using the 2001 FMP as the main planning context. Several of the Conditions identified in the assessment reference issues to be addressed in the 2006 FMP.   In terms of in-bush operations a notable change has occurred in that all harvesting and movement of wood from the stump to roadside is undertaken using in-bush delimbing and forwarders. In a typical operation of this sort, trees are felled using a feller-buncher, a processor then delimbs and processes the trees in the bush, and a forwarder is used to transport the logs to roadside. This is notably different from most previous operations as this type of processing creates no roadside slash piles, and as forwarders can move wood further than can the previously-used skidders, there is a need for less tertiary road construction. All of these effects (i.e. leaving slash in the bush, no roadside slash piles, and reduced amount of road) are ecologically preferable compared to previous operations.  One of the major complications for Domtar at present is the lack of a market for the OSB quality poplar and birch on the Pineland Forest. Grant Forest Products, which has an OSB mill in Timmins has the commitment to OSB quality poplar and birch on the forest. Historically, while Grant’s has had the commitment to the birch, the company has never taken any volumes of significance. More recently, Grant’s has idled their mill and locked out their workers and is not accepting any wood from the Pineland Forest (the loggers on the Pineland Forest are contractors to Domtar). There are no other available markets in Ontario for the OSB wood. This situation creates several problems for Domtar. The first is that the veneer portion of the poplar log is still committed to and in demand from Norbord Industries in Cochrane. Therefore the harvest of poplar is still necessary. Second, the overall demand for wood harvested is reduced resulting in less work than desired for the Domtar contractors. This can often create financial problems for them. Third, Domtar has made some investments in roads to blocks to access the poplar but now of which there is no demand. All of these are challenging aspects of management for Domtar.  Stakeholder issues  The Chair of the Local Citizens Committee (LCC) spoke highly of Domtar’s work with the general public, First Nations and the LCC. In his view Domtar always makes excellent efforts to address the concerns and interests of the public. The LCC was fully supportive of the new 2006-2026 Forest Management Plan. The LCC is of the opinion that the MNR is not involved enough and should take more responsibility. The Chair of the LCC did indicate that while most members of the public do not outright oppose the use of herbicidal spraying, many retain reservations about its use and impacts.  Following the MNR approval of the 2006-2026 Forest Management Plan, four requests for Individual Environmental Assessment (EA) were made. One of the requests from a tourist operator was withdrawn fairly shortly after the request was made and appeared to be based on uncertain information. The second request,
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also from a tourist operator was resolved through a Business-to-Business agreement.    The last two requests are from the same individual representing two different parties or groups. The first request from the individual is on behalf of his family’s tourist operation. The second request from the individual appears to be on behalf of a large number of individuals but this is unclear and is technically questionable as a request for an individual EA is to come from a single individual. The substance of the two requests are different to some extent but share most of the same common themes.  The main concern articulated in both requests is the application of herbicides and its potential impacts.The individual is concerned that herbicides have negative effects on environmental quality including detrimental effects on wildlife. In turn, the individual is concerned that these possible impacts negatively effect local tourism operations and wildlife resources harvested by Aboriginal and non-Aboriginal people. The individual also expresses concern over the impacts of forest operations on remote tourism lakes. The individual also raises some concerns over the provision of forest management plan information and consultation, although reference is made to another company on another forest, which is not applicable to the Pineland.  The requests for individual environmental assessment are currently being examined by the Ministry of the Environment and the decision on whether or not to grant one, is at the sole discretion of the Minister of the Environment. As due process is being followed, both Domtar and the MNR cannot be faulted for how the request has been handled.  It should be noted that the records indicate that this concern was not raised until extremely late in the Forest Management Planning process, thereby limiting the options and time to address the concerns, through other processes such as the FMP’s Issue Resolution Process. However, the individual does not reside locally for most of the calendar year The nature of the concerns (to use herbicide versus not) is such that it is very possible that a solution satisfactory to all parties could not be worked out through the FMP’s Issue Resolution mechanism.  Without making a judgement on the elevation request, it is important to note that not using herbicides has several significant implications, the first of which would be silvicultural effectiveness and the conversion of forests that were historically conifer dominated to more mixed wood stands. Options to aerial spraying would include more manual spraying which has health and safety and cost implications as well as effectiveness problems.  It is important to note that while only one individual requested the environmental assessment, consultation with both the LCC and the Chapleau Metis Council have demonstrated reservations about herbicide use. Interviews demonstrated that these organizations and stakeholders fully support the industry but remain concerned
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about this one aspect of forest management. In using approved herbicides for regeneration and carrying out their application in accordance with the appropriate guidelines, Domtar is not only operating fully within the CFSA, but moreover is ensuring FMP objectives are met. The concerns raised by the individual have been handled with all due process. Nevertheless, public concerns about aerial spraying will likely remain and the company will be continually challenged in dealing with this concern.  It is also important to note that the concerns of the individual are very much directed at the Ministry of Natural Resources. The individual is concerned that the MNR is not a good arbiter of forest management decisions and that the concerns of the forest industry outweigh those of tourist operations. In particular, the individual is concerned that guidelines utilized by the Ministry with respect to herbicidal use are out of date and that remote tourism operations and their economic viability are not protected. It is expected that the Decision on the EA referral will address the former concern. With respect to how Domtar has worked with the tourism operator, auditors found that there is nothing that Domtar has done that is not consistent with the NBS.  2.3. Compliance with applicable corrective actions  The section below describes the activities of the certificate holder to address each applicable corrective action issued during the FMA assessment. For each Condition a finding is presented along with a description of its current status using the following categories. Failure to meet Conditions will result in noncompliances being upgraded from minor to major noncompliances with compliance required within 3 months or face suspension or termination of the SmartWood certificate. The following classification is used to indicate the status of the Conditions:  Condition Status Explanation Categories Certified operation has successfully Closedmet the Condition and addressed the underlying noncompliance. Certified operation has not met the Condition; underlying noncompliance Open  becomes ais still present. Condition Major CAR with a 3 month deadline for compliance  In addition, the team reviewed six Notes for Future Annual Audits recorded in the 2005 Assessment Report. The teams’ response to these Notes is also briefly described below.  
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Apart from general discussions with Domtar regarding progress to meet the Conditions which extend beyond Year 1, the team did not review Conditions other than those which were targeted at Year 1 Conditions. 
  Condition #: 1.1 Reference Standard #: 1.1 Non-compliance: The assessment found that there were a sufficient number of compliance issues Major Minor to warrant effort in understanding their root causes. The assessment determined there is a need to develop more effective mechanisms to identify both legislative and EMS non-compliances, determine the root cause, assign appropriate corrective actions, and track their progress and completion.  Corrective Action Request: By the end of Year 1 of certification, Domtar shall improve the mechanisms in their Environmental Management System (EMS) to identify legislative and EMS non-compliances, determine the root cause, assign appropriate corrective actions, and track their progress and completion. Timeline for Compliance: Year 1  Audit findings: Revision of the Domtar EMS Incident Form to include a section on preventative action should help to facilitate the performance of root cause analysis and the assignment of appropriate corrective actions. Although all non-compliances (NC) and significant non-compliances (SNC) must be addressed within the EMS, the requirement to fill out incident reports has not been extended to all EMS NCs and thus remains a requirement only for EMS SNCs. As such, it is imperative that contractors develop corrective actions in response to SOP audits and submit action plans within 10 days of receiving the final audit findings as required by SOP-5. It is also imperative that audit results are clearly identified and discussed at regular EMS performance review meetings and that the Domtar representative follow up to ensure that approved action plans have been implemented and completed as required.  As concluded in the original assessment, the Domtar Inc. Forest Resources Group North-east Ontario EMS framework provides an excellent platform for the continuous improvement of forest operations. In order to monitor the effectiveness of its EMS, Domtar annually retains the services of an external consultant to perform internal audits of its Northeastern Ontario Operations. These audits covered the full range of EMS elements including structure and responsibility; training awareness and competence; communication; operational controls; monitoring and measurement; non-conformance, checking and corrective action; records, internal audit; management review; and a cross-section of field activities including field compliance, and the training and competency of contractors and field personnel.  In the 2005 assessment, numerous positive findings were cited but a great number of continual improvement and symptomatic findings were also noted. These included findings that: a) not all locations were following up with SOP audit findings and status of action plan completion; b) not all action items were being tracked through to completion; c) not all contractor operations were generating corrective and preventative action plans in response to SOP audit findings within the prescribed 10 day period; d) many action plans created in response to SOP audit findings were only corrective rather than preventative; and e) some action plans did not include target dates. Most importantly, however, was a systemic repeat finding that numerous action plan target dates had been exceeded and deadline dates were not revised when extensions were necessary. As a result, the Audit Team made several recommendations calling for improved mechanisms to develop, communicate, implement and track the completion of action plans, noting that clear lines of responsibility and accountability were required in
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order to do so effectively.  The 2006 audit; however, showed the situation to be greatly improved with no specific findings related to Monitoring and Measurement or the Evaluation of Compliance. Although there were findings related to Non-Conformity, Corrective Action and Preventative Action, these appear to have largely resulted from confusion with “multiple” action plans (e.g., some corrective and preventative actions were not correctly tracked) and the lack of process for recording the results of corrective and preventative actions taken and reviewing the effectiveness of such actions. In order to address these identified shortcomings, Domtar is currently developing an EMS database to track non-conformances and generate customized ad-hoc reports showing the status of corrective and preventative actions. It is anticipated this work will be completed early in 2007. As such, the audit team is satisfied that Domtar is making the structural changes necessary to act upon the recommendations made in the internal EMS audit report and satisfy the intent of this corrective action request.  The only item of concern; however, is the planned reduction in the number of SOP audits from three to two annually for each contractor. Although this will certainly suffice for the most reliable contractors, it remains to be seen if this will be sufficient to foster the improved implementation of SOPs by those poor performer(s) noted in the original assessment. Accordingly, the company may wish to employ some form of risk-based determination of audit frequency so that good performers are rewarded with fewer audits while poor performers are subject to a higher frequency of audits. Status: closed Follow-up Action:  Observation 1/06 Domtar should consider employing a risk-based determination of audit frequency.   Condition #: 3.1b Reference Standard #: 3.1 Non-compliance: The assessment found that although Domtar has implemented several measures Major Minor intended to foster rapports with First Nations and develop business relations, efforts have been somewhat uneven across the interested First Nations. Corrective Action Request: By the end of Year 1 of certification, Domtar shall develop and begin to implement measures that will ensure more consistent performance in terms of working relationships with aboriginal peoples in their northeastern Ontario operations. Timeline for Compliance: Year 1  Audit findings: Since the original FSC assessment, Domtar has been active in working with local First Nations on the Pineland Forest. A First Nations Task Team was set up for the Chapleau area to provide input to planning for both the Pineland and the Superior-Martel Forests on the 2006 Forest Management Plans. This Task Team comprised of representatives from: Mattagami, Brunswick House, Chapleau Cree, Chapleau Ojibway, Michipicoten and Missinabie Cree First Nations provided an excellent forum for First Nation members to discuss and address First Nation interest and concerns. During interviews, representatives of First Nations, Domtar and MNR spoke positively about the work of the Task Team and about how relations with industry have improved over the years. MNR has access to funding to support the Task Team during the preparation of forest management plans, but that funding is complete once the Plan is approved, therefore there was a lack of funding to continue to support the Team past the FMP. Domtar has stepped forward with funding for some meetings to ensure the work of the Team can continue. Domtar has also fully participated in the meetings and views them as excellent opportunities
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to discuss First Nations issues across the board. All participants generally feel that a great deal of positive work was completed.  Along with support of the Task Team, Domtar has worked with First Nations on a variety of other projects and initiatives. The company continues to work closely with the Chapleau Area First Nations Task Team, even though Domtar’s main tenured areas are farther east. (When the Pineland-Martel Forest was split, Domtar’s tenured area shifted east (as the Pineland Forest is farther east than the Martel, which is centred around Chapleau). While all the First Nations on the Task Team except for the Missinabie Cree retain an interest in the Pineland Forest, it is not the forest that surrounds their Reserves.  Domtar has quite a close relationship with the Mattagami First Nation largely because they have overlapping interests in several Forests. Mattagami has strong interests and is located in very close proximity to the former Shiningtree portion of the Temiskaming, Spanish and Pineland Forests. Mattagami First Nation harvests wood for Domtar in close proximity to the Reserve. Domtar has supported Mattagami First Nation in its Community Resource Information Project and has provided donations to various projects in the community.  Domtar has also supported various projects and initiatives with other First Nations. With the Chapleau Cree, Domtar has provided support for the community’s interest in a cedar mill and has also provided financial and in-kind contributions for other projects. Similarly, Domtar has also supported a community initiative and has had a meeting regarding business opportunities with the Missinabie Cree.  Since the original assessment, Domtar has made good efforts at ensuring a more consistent working relationship with First Nations. The creation of the Chapleau Area Task Team is the primary vehicle in which the relationship Domtar has with First Nations can be fostered. The Audit team was pleased that Domtar has recognized the importance of the Task Team and has assisted in its continuation through financial support. The Audit team is concerned that positive initiative could be lost if the Task Team’s work is not perpetuated.  Based on the above evidence, the condition is closed.  Status: Closed Follow-up Action:None   Condition #: 3.3 Reference Standard #: 3.3 Non-compliance: The assessment found that while many sites of special cultural, ecological, Major Minor economic or religious significance to First Nations have been protected, there is concern that there are possibly a greater number of sites of interest that have not been identified. Corrective Action Request: By the end of Year 1 of certification, Domtar shall, in concert with the MNR and local First Nations, develop a strategy and ensure appropriate resources are available to carry out an aboriginal values collection exercise on the Pineland Forest to:  i. Ensure that these values are identified and protected in the operational forest management plans; and, ii. meet the definition of High Conservation Value Forests, identify theseWhere they values as HCV and include them in the HCVF report. 
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