Protected Aresa Association
of Newfoundland and Labrador
St. John's, NL A1C 5M3 Canada
Phone: (709) 726 - 2603
Fax: (709) 726 - 2764
paa@nf.aibn.com
www.paanl.org

Hon. Clyde Jackman
Minister of Environment and Conservation
Confederation Building

August 28^th, 2007

Dear Hon. Clyde Jackman,

Protected Areas Association understands that commercial loggers are about to acquire a permit to begin logging south of Hall's Gullies and immediately north of the proposed Ripple Pond Ecological Reserve. We would like to remind the minister that this area is under discussion, and boundaries have not been approved by any public process. In fact, WERAC has been requested to consider extension of the boundary of this study area to include the Fox Marsh (Hall's Gullies) site. We also understand that scientists from Memorial University have asked you to protect this entire area in order to preserve the distribution of rare species: red crossbills and Boreal Felt Lichen.

In addition to a substantial population of Erioderma pedicellatum currently listed under your Endangered Species Act, the extremely rare species Erioderma Mollissimum has been reported in the south side of Hall's Gullies. We understand that the mitigation proposed by Department of Natural Resources, Forestry Division, includes logging "around" trees containing Boreal Felt Lichen. We know of no scientific studies to support these proposed measures. Such a mitigation would not protect the Erioderma Mollissimum habitat - only individual thalli, which would then have no expansion or growth habitat. This would be tantamount to protecting the five trees (a theoretical number) containing red crossbill nests, and cutting all the others. Such an important concentration of globally-rare tree lichens should not be subjected to trial-and-error invasive management.

The Ripple Pond Ecological Reserve study area has already suffered from clear-cutting and road development in the area south of the Clam River. Salmon spawning on the Colinet River was affected by silting-this river has only reopened to angling this year. This is just one example of edge effects already noticeable in this study area. Representing the smallest and most threatened of all the province's ecoregions, this ecological reserve study area needs to be expanded, not further compromised. The lichen is only an indicator species of a whole ecosystem that is in danger. This ecosystem is the last hold-out for the lynx on the Avalon Peninsula. If we can't protect the lichen, how can we protect the lynx, and other wildlife ranging in this forest?

If the Department of Natural Resources (DNR) is going to approach the Natural Areas Systems Plan in this way, it renders the public process useless. We see little value in discussing land that is available only because there are no other features left worth protecting. In a meeting on April 30 with your Assistant Deputy Minister Basil Cleary and Mike Cahill, we expressed our dismay with a seriously-flawed public planning process. Instituted by the DNR to generate a "sustainable" District 1 (Avalon) Five-Year Forest Management Plan, this process has created a plan that is unsustainable and threatens to decimate a once-renewable resource. We recommend that your Government implement an ecosystem-based planning process as promised in the 2003 Sustainable Forest Strategy document. As we expressed in our April meeting: A fundamental principal of ecosystem-based planning is to decide what to protect before allocating what will be harvested.

Protected Areas Association considers the Avalon Boreal Forest Ecoregion itself endangered; it needs emergency protection. At the very least, the current study area should be given provisional status under the Wilderness and Ecological Reserves Act by the end of 2007. At the same time, the proposal to extend the north-western arm of the reserve-the Ripple Pond forest portion-northward to include Hall's Gullies should be studied. Scientists tell us that any more negative effects in this area will be irreversible. If we are going to preserve any part of this small forest the time to act is now. With more compromises there is not going to be a fully representative example of the unique Avalon Boreal Fog Forest to conserve.

Minister Jackman, Protected Areas Association would like to see you use your ministerial discretion as defined by the Environmental Assessment Act and Endangered Species Act to do three things:

1. Immediately put in place an emergency status review on Erioderma       Mollissimum.
2. Immediately begin work on advancing the Ripple Pond Ecological Reserve      study area to Provisional protection status.
3. Delay any decisions on logging in this area of Fox Marsh (Hall's Gullies) until a      more thorough and scientific audit is undertaken - including an analysis of the      value of extending Ripple Pond ecological reserve northward to include this      important area.



Sincerely,


Laura Jackson                Jennifer Morgan
Executive Director          Associate Director

Cc: Kathy Dunderdale, Minister of Natural Resources

MAP: Ripple Pond Boundary Revised  

Protected Areas Association of Newfoundland and Labrador
Box 1027, Stn. C, St. John's, NL A1C 5M3 Phone: (709) 726-2603 Fax: (709) 726 - 2764 paa@nf.aibn.com
Under the Distinguished Patronage of
His Honour the Honourable Edward Roberts, QC, ONL, Lieutenant Governor of Newfoundland and Labrador,
and Christopher Pratt, C.C.

It is horrifying that we have to fight our own government to save the environment.
~Ansel Adams