Spanish River Forest Plan, 2020-2030


Spanish Forest

2020-2030 Forest Management Plan

Comment Sheet

Andy Thomson

104 Bessborough Dr.,

Toronto, ON, M4G 3J1

Part 1

  1. Values: There are many cultural/historic values I would like to add and will locate them on the accompanying maps you provided. They are a combination of Indigenous and logging sites that should be recognized such as: former site of Hudson’s Bay post on Maggie’s (Kingston) Island on Lake Pogamasing (Big Pog), Native cemetery on Graveyard Bay on Big Pog, and Wye village alongside CP tracks east of present Sheahan station. An archeology student and resident of Big Pog, Tara Ward, conducted a study of the lake for her undergraduate thesis and found various sites that contained evidence Indigenous tools. For further values see:
  2.  Concerns about road control: Given that two camps in the north end of Pog Lake experienced theft as a result of road access a few years ago, it is essential that the Pog road is more carefully controlled.  Geoff Mason has discussed the options to better restrict access to their camps at the north end of Pog which I support. The camp owners on Little Pog are also concerned.

Action Requested – i) Can you report on what will be done differently to prevent outsiders from using these roads? Will we be notified when these roads will be opened, monitored and closed?

  1. Protecting historic and existing trails/portages: I will add a couple portage routes (Big Pog to Pejeke and Pejeke to Little Pog) that are presently part of the proposed harvest area close to Pog Lake and the creek (called Pogamasing River on maps) that flows from Little Pog into Big Pog. This is an historic trail that was first used by First Nations inhabitants and continued to be used in the fur trade to link the HBC post on Pogamasing (the island across from the Landing) to all the inland lakes (Pejeke, Little Pog, Dennie, Gilden, Sinaminda, Dusty, Mozhabong, Indian and Biscotasing). After the fur trading post closed in 1888, logging companies based on Big Pog or their headquarters at the railroad, used it to access the inland lakes such as Little Pog and Sinaminda where pine logging continued from 1890 to 1940. After WW II, tourist operators used the trails to access their inland posts on Little Pog and Little Squirrel. As well many canoe tripping operators (the author included ) used this trail to access the inland lakes so reach the headwater of the Spanish River. It is still used today by various canoe tripping camps and is listed as one of the Top 50 Canoe Routes of Ontario by Kevin Callan (Top 50 Canoe Routes of Ontario, 2011, Firefly Books).

Action Requested – ii) To protect these trails I would request the harvested area to be moved to protect the portages as I will indicate on an accompanying map.

  1. The available information is more than adequate to understand all the issues surrounding the ten-year plan. The maps were excellent and once I got the gist of how to find the ones I needed were most helpful.
  2. Concerns and comments.                                                                                               A) Use of herbicide glyphosate

At section 8.4.1 of the 2010-2020 plan, the plan noted its target to reduce herbicide use by 5%. The 2010-2020 plan noted that the area of aerial tending was in keeping with the target to reduce herbicides insinuating without a doubt that this 5% decrease target was for an aggregate decrease in the use of herbicides throughout the Management Area of 5%. Was this result met? Please provide information as summarized for all years of operations of the 2010-2020 plan as submitted within the Management Unit’s Annual Reports for any use of Pesticides as required under Part E Section 2.2.4 of the Forest Management Planning Manual.

The target as set out at page 98 of the proposed plan (2020-2030) states: “Decrease or maintain within 5% of the proportion of herbicide use per hectare of renewal activity.” Please clarify what this means. A plain reading suggests that this would be complied with even if herbicide use increases by 5%. Further, by changing the metric from decreasing pesticide use in the 2010-2020 plan on a whole to “per hectare” in the 2020-2030 plan, if the total tending area increases this clearly could lead to an increase rather than a reduction in herbicide use. How is this loosening of the target for reducing herbicides consistent with the principles of the Crown Forest Sustainability Act? While the proposed herbicides may have federal approval, that does not mean that such products have zero adverse effects. The 2010-2020 plan’s objective to reduce overall pesticide use by 5% was plainly adopted to pursue the sustainability objectives of the Act. Yet, the proposed 2020-2030 seeks to reverse course and will allow more not less herbicide application. Surely over time operators will be able to use herbicides more, not less efficiently – indeed the judicious use of herbicides is Management Objective #11 – the 2020-2030 plan’s implementation of this objective in allowing more herbicide is clearly inconsistent with this objective.

Where will signage be posted when herbicide (or any pesticide) applications will be applied in the areas around Pogamasing Lake as required by Part D Section 5.0 of the Manual?

Further concerns of spraying glyphosate  Although this is an anecdotal observation, I have noticed a sharp decrease the song-bird population at my camp over the past ten years. Whereas I used to see 10-12 species of small birds I rarely see any birds at my feeder or around my camp. I would like to learn more about what research has been done to accept the chemical glyphosate and its broader impact on bird and aquatic life. Its link to cancer is also suggested. If there is research to support its use I’d like to read it. Otherwise I’m left with information that bans its usage:

A second concern with using this herbicide is that it prohibits the growth of broad leaf trees, such as poplar and birch. Encouraging only coniferous trees to grow also creates  a forest that is more susceptible to forest fires as broad-leaf trees are known to inhibit and even stop forest fires. (

A question: What are the long-term implications for the Spanish Forest if only coniferous trees are supported and broad-leafed trees are suppressed? What research supports this limited choice of forest species? Some scientists are questioning the consequences of using it on other forms of life in the forest. (

Action Requested – 

iii) Report of whether a 5% reduction in the use of glyphosate in the 2010 – 2020 plan was achieved

iv) Will there be an increase or decrease in the use of glyphosate in the 2020-2030 plan? If there is an increase, what is the justification for more?

v) Notification to area residents when the area will be sprayed with glyphosate

vi) Can you provide me, and others, with the scientist’s report that supports the usage of  glyphosate on the Spanish Forest which details:                                                                                     a) the impact of the herbicide on all forms of life and                                                                   b) research on the impact of killing broad-leaf trees and its impact on forest fires?

  1. B) Compliance

Although the intentions and plans expressed in the Spanish River Forest plans are well laid out, not all implementation actions are done as proscribed by the plan. So the issue of compliance and how it is addressed is important. What are the common non-compliant issues? How responsible are companies in reporting non-compliance issues? Is there a record the public can see? Who are the repeat offenders and what happens to them?

A secondary issue from this regards the replanting of harvested forest. A recent article in the Globe and Mail – – highlighted another concern for me: given that we have had ten years of harvesting in the Spanish Forest, can you provide evidence to show that re-growth is happening in at least the earlier harvested sections? What follow-up from the MNR is being done?

One way locals could help in this matter is to have reporting of logging in a local area with notification to concerned citizens who can them monitor harvesting, use of roads, spraying, etc.

Action Requested

vii) A report on the types of non-compliance issues that were reported in the 2010-2020 period and how these incidences resulted in better compliance. Were there any consequences to repeat offenders?

viii) A report on the extent of the reforestation in the Spanish Forest for the 2010-2020 plan