September 15, 2021
Courtenay Lewis
Canada Project International Program
Natural Resources Defense Council, Inc.
1152 15th Street, NW
Washington, D.C. 20005
Via email
Dear Ms. Lewis:
We reviewed the document you provided on Thursday, September 2, 2021, and are left puzzled as to why you and your colleagues continue to promote distortions and falsehoods about our company, while evading concerns raised in our previous correspondence.
On February 10 of this year, your colleague Andrew Wetzler wrote to us stating NRDC was “open to having discussions in good faith with any stakeholder who is interested in ensuring the protection of the boreal forest’s value to Indigenous Peoples, biodiversity and climate.” We responded to Mr. Wetzler in attempt to establish such a dialogue but received no reply before NRDC publicized misleading claims about our company.
In our response, we pointed out the many stakeholders – including trade associations, unions, First Nations, mayors and other representatives of boreal communities – who have expressed anger about how NRDC’s misinformation is “denigrating the work of sustainable forestry in Canada, and causing grave harm to local economies, communities and the people who live and work in the boreal.” That too went disregarded, and if NRDC recently visited those communities to engage with them, I am unaware of it.
Even when NRDC took part in a conference of forestry experts, including industry, government representatives and other stakeholders, your claims that harvested areas are not replanted were openly rebuked, not surprising since the assertion is so at odds with the facts on the ground.
The claims in your latest overture are gross oversimplifications of the facts, so we intend to set the record straight.
Our Work with Indigenous Peoples
Your latest inquiry repeats a misunderstanding about the concept of free, prior, and informed consent of Indigenous Peoples (FPIC). FPIC is not some certificate or piece of paper; it is serious work, requiring deep engagement and many years to develop. Our certifications and range of consultative relationships and business partnerships are a testament to the extensive work we have done in this area.
In 2013, Resolute developed an Indigenous Peoples Policy that outlines our commitment to building strong relationships, ensuring Indigenous Peoples are consulted in decisions impacting their communities, and developing shared economic prosperity. That means we provide equitable access to commercial opportunities and promote economic participation of Indigenous Peoples and business in the forest products sector. We also implemented Indigenous Procurement Policy Guidelines to further strengthen this commitment to Indigenous communities across Ontario and Quebec.
These commitments have led to ongoing consultative relationships and business partnerships with close to 40 Indigenous communities and organizations in Ontario and Quebec. For example, our Thunder Bay sawmill, located on Fort William First Nation land, employs approximately 250 workers, including 40 Indigenous employees, and was the first in Canada to work under regulations created by the First Nations Commercial and Industrial Development Act. Just two weeks ago, I was joined by Resolute’s president and CEO and other company Executives, as well as government officials, First Nations leaders, community representatives and business associates to celebrate our two decade-long collaboration and an additional investment of C$17.5 million in the sawmill.
Memorandums of agreement, including significant contracts for construction and transportation that have resulted in $50 million in economic opportunities for Indigenous communities, have been signed with the Fort William First Nation, Red Rock Indian Band, the Nigigoonsiminikanning, Kiashke Zaaging Anishinaabek, Lac des Mille Lacs, Seine River, Couchiching, Mitaanjigaming, Métis Nation of Ontario, and Whitesand First Nation. We also launched a youth employment and training program in partnership with Wabigoon First Nation.
Extensive records of these partnerships can be found on our website. Yet NRDC continues to repeat the myth that we do not consult with Indigenous Peoples in our operations.
Caribou Conservation
Your inquiry cites the federal government’s caribou habitat requirement threshold of 65 percent, but omits some key facts about this controversial subject. Significantly, this sort of threshold for undisturbed territory would lead to a significant reduction in harvesting operations, and therefore to devastating impacts on jobs and communities.
Since the publication of the Boreal Caribou Recovery Strategy in 2012 by Environment and Climate Change Canada (ECCC), a number of experts and studies have highlighted the shortcomings of a strategy that focuses only on a disturbance threshold. NRDC’s blind commitment to this approach also ignores many other important factors affecting caribou population dynamics, such as the effects of climate change, reduced food availability, parasite and disease transmission, nutritional deficiencies, disturbances caused by recreational activities such as snowmobiling, and caribou hunting.
Even in its 2020 Caribou Range Plan guidance, ECCC recognizes the complexity of factors affecting the caribou population dynamic in Canada:
“Habitat disturbance within a range needs to be managed by the responsible jurisdiction at a level that will allow for a local population to be self-sustaining. As there is variation in habitat and population conditions between boreal caribou local populations across their distribution, for some ranges it may be necessary to manage the range above the 65% undisturbed habitat threshold, while for other ranges [ . . . ] it may be possible to manage the range below the 65% undisturbed habitat threshold.” [Emphasis Ours]
That is because the disturbance-population relationship model was derived mainly from populations in western Canada that are confined to a specific area. There are many caribou populations in Ontario and Quebec to which this model does not seem to apply. Not to mention the fact that nearly 75% of the woodland caribou range distribution in both Ontario and Quebec is located north of the area where forestry activities are even permitted.
Implementation of caribou plans, monitoring and ongoing adaptive management is well advanced in both Ontario and Quebec. These provincial-led plans are reflective of the Federal Recovery Strategy and incorporate new science and knowledge. Since 2000, Resolute has been a leader in caribou conservation, working with experts and provincial governments to increase knowledge on caribou behavior and habitat utilization. This work has significantly contributed to the implementation of special regional caribou habitat management plans that have been integrated into harvest planning.
The Problem with the Concept of “Primary Forests”
Your question about sourcing from “primary forests” indicates a misunderstanding of the dynamics of the boreal forest, where fire is a major part of the lifecycle. The boreal forest is always in a process of natural regeneration. In Ontario and Quebec, where Resolute operates, ecosystem-based management mimics natural disturbances and results in greater long-term carbon storage than not harvesting would. Trees that are mature or over-mature are more vulnerable to being destroyed by natural disturbances like fire and insects. Climate change only increases these risks. Harvesting mature or over-mature trees reduces these risks significantly, creates the conditions necessary for regeneration and allows additional carbon to be stored within long-lived forest products like lumber and books. Then, as the forest regenerates (as required in Canada), the growing trees capture even more carbon.
Our Third-Party Certifications
Your inquiry also raises questions again about our FSC certifications but omits that Resolute remains one of the largest FSC certificate holders in North America. Your last report says that we have “approximately halved the area of FSC-certified forestland” but those decreases reflect a change in circumstances, including the company’s operational footprint, particularly due to a reduction of demand for newsprint. For example, we no longer operate the Iroquois Falls newsprint mill, and therefore no longer harvest in the Abitibi River Forest, which was a very large FSC certified area. We also reiterate that 100 percent of our managed woodlands are third-party certified to at least one internationally recognized forest management standard.
You also claim that that only a portion of our virgin wood fiber inputs are certified to either FSC, SFI, or PEFC certification. But this is based on a misunderstanding of our sourcing policies. Even if the wood fiber inputs do not come from our own certified managed forests, we ensure that 100 percent of our internal and external fiber is sourced in accordance with SFI fiber sourcing requirements, PEFC CoC due diligence requirements or the FSC Controlled Wood standard, and in some cases a combination of these standards. Every one of our Canadian operations are certified to all three of the aforementioned standards. This means we ensure all fiber we process meets minimum due diligence requirements related to risks of illegal logging and other important sustainability issues. This enables us to confirm that we have avoided timber and timber products from unacceptable sources. To maintain our certifications, Resolute takes appropriate steps to ensure that it, and the suppliers and woodlot owners we source from, all abide by a number of provincial, and federal regulations, as well as voluntary best management practices that protect important ecosystem elements, including water quality and habitat for endangered species.
For the lay reader, unaware of how the Canadian forest industry operates, facts like these are complicated and nuanced. But instead of seeking to truly understand how our forests are managed on the ground in Canada, NRDC writes from distant cities to patronize Canadians about how our forests should be run. As we have pointed out before, NRDC lacks the credibility of either a governmental authority, an internationally recognized third-party certification standard, or a well-respected scientific journal or academic institution, yet it seems dead set on lecturing Canadians about our forestry practices.
Unfortunately, we expect, despite our repeated responses to your claims, that your forthcoming report will contain numerous errors and distortions about our company and its practices. If that is the case, then you can expect that we will join the chorus of stakeholders to set the record straight.
Sincerely,
Seth Kursman
Vice President, Corporate Communications, Sustainability and Government Affairs