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Paper Assoc. concerned about Ont. Gov.

September 6, 2007
Minister of Government Services
Whitney Block
4th Floor Suite 4320
99 Wellesley St W
Dear Minister Phillips,
On behalf of the members of the Ontario Forest Industries Association (OFIA), I am writing in response to yesterday’s media release under the heading McGuinty Government to Use More Environmentally Friendly Paper. The OFIA has several reservations with both the content of the policy announcement as well as the policy development process.
The OFIA does not oppose forest certification under the Forest Stewardship Council. To the contrary, we support all three internationally recognized and accepted certification standards that exist and are being used in Ontario – Canadian Standards Association (CSA), Sustainable Forestry Initiative (SFI) and Forest Stewardship Council (FSC). What we do not support is a government policy that appears to arbitrarily favour one acceptable business standard over another. What was the competitive process used by government that exclusively awarded a portion of the government’s business to one acceptable business standard only?
The selection of one acceptable business standard over others compromises the competitiveness of companies or processing facilities certified to those other business standards and directly contradicts commitments and positions previously expressed by the Minister of Natural Resources. The Minister, during an April 2004 Certification Watch conference announced his intent to have all Sustainable Forest Licenses (SFL) in Ontario certified. This announcement recognized and included all three certification systems outlined above and acknowledged that the forest industry of Ontario was already well down the path of certification. By promoting all three systems for Ontario and then subsequently offering a level of business exclusivity to only one standard, the government is jeopardizing the viability of existing mills, forestry operations and potential investment in Ontario.
Initial discussions within industry raise the question as to whether or not Ontario mills can supply the FSC certified paper products required for use by government under the constraints imposed by this new policy. Had we been consulted prior to the announcement, perhaps we could have worked with government to ensure a new paper procurement policy supported all Ontario forestry companies, related Ontario jobs, and sent a loud message to the world that Ontario has some of the best managed forests in the world and, therefore, the Government of Ontario would favour the purchase of its paper products needs from Ontario mills. As announced, the new paper procurement policy for the Government of Ontario excludes some Ontario producers from selling their world class certified product to their own government and sends the wrong message to the public.  
Finally, and perhaps most importantly, our members are also very concerned with the insinuation that our existing regulatory framework is not sustainable, and that supporting a given certification standard will “make our government more environmentally friendly”. This misguided statement undermines decades of effort from government and industry to ensure that we have one of the most environmentally stringent regulatory frameworks in the world (a fact reinforced in a report by Dr. Benjamin Cashore of Yale University). In fact, it is our adherence to a strong regulatory framework that has allowed companies in Ontario to become certified so readily in the first place. In Minister Ramsay’s own words at the April 2004 Certification Watch conference:
“I am proud of the very rigorous regulatory framework that Ontario has in place for sustainable forest management.  I believe it positions Ontario’s forest industry well to satisfy any legitimate certification standard, and we’re now seeing the success of the industry’s substantial efforts in this area.
I don’t believe that third party certification systems are a replacement for regulatory systems, but they can and do play a very significant role in verifying and communicating whether regulated systems are working.”
Why is the government abandoning this position?
The Government of Ontario should take great pride in our province’s sustainable forest management practices. Instead of a policy that could encourage buying paper products from jurisdictions outside of Ontario, the government should be championing our practices with the development of a policy that is committed to promoting and rewarding sustainable practices, regardless of their associated certification standard, in Ontario.
In closing, the OFIA welcomes the opportunity to work with government to put in place a fair and equitable procurement policy that recognizes Ontario’s world class forest management practices, acknowledges all three accepted business standards (CSA, FSC and SFI) and keeps Ontario families working.
With warmest regards,
Jamie Lim
President & CEO
Ontario Forest Industries Association

Hon. Dalton McGuinty, Premier of Ontario

Hon. Dalton McGuinty, Premier of Ontario
Ontario Forest Industries Association, OFIA website
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