The Ontario Internal Audit Division (OIAD) reviewed the Independent Forest Audit (IFA) regulation (319/20) for the ministry.

Ontario has a comprehensive and robust forest policy framework. The forest policy framework is an interconnected system of laws, regulations, and policies (for example, manuals, forest guides) based on science, continual improvement, and public and Indigenous engagement and consultation. The IFA process is an integral part of Ontario’s sustainable forest policy framework. Audits help demonstrate that Ontario’s forests are being managed sustainably and continue to provide benefits for current and future generations.

The ministry appreciates and acknowledges OIAD’s report, including the identified advisory considerations. The considerations align with the ministry’s knowledge of potential areas for improvement in the IFA process. The ministry appreciates the effort of OIAD and the contributors to OIAD’s review to support continuous improvement of the IFA process. The ministry is committed to continuous improvement of the IFA process and will continue to strive for the efficient and effective delivery of independent forest audits across the province’s managed forests.

The ministry is required to review Ontario Regulation 319/20: Independent Forest Audits every 10 years, with the last review being completed in 2013. The Environmental Registry of Ontario Posting ERO bulletin #019-5315 and email/letter notifications for the review occurred on August 15, 2022. The OIAD conducted the review for the ministry and wrote the report dated June 2023.

The Ministry is initiating a redevelopment of the Independent Forest Audit Process and Protocol (IFAPP) in 2024 for the 2025 Independent Forest Audits. As part of the redevelopment, the ministry will review the considerations from OIAD and propose updates, as necessary, to address. The proposed revised IFAPP will be available for Indigenous communities, public, and stakeholder review and comment through the Environmental Registry of Ontario.

The list of considerations and the ministry’s actions are:

OIAD Consideration 1

The Ministry should consider reviewing the current roles and responsibilities of the ministry and Forestry Futures Trust Committee (FFTC), as defined in both the IFAPP and Terms of Reference (TOR), with a view to minimizing any overlaps and reducing the administrative burden of the IFA process, while at the same time, ensuring alignment with objectives.

Ministry Action

Complete. The ministry and FFTC reviewed the roles and responsibilities in the FFTC Terms of Reference and the IFAPP in January 2024. The review focused on adding clarity and minimizing overlap between the ministry and FFTC while ensuring to align with the Regulation’s objectives.

OIAD Consideration 2

Once the review of the roles and responsibilities has been undertaken, the Ministry should consider revising both the IFAPP and the TOR to reflect the updates to the roles and responsibilities and ensure alignment between the two documents.

Ministry Action

The ministry and FFTC have drafted an update to the roles and responsibilities in the FFTC’s Terms of Reference. The new update will be proposed for inclusion in the IFAPP for 2025 audits to align the two documents.

OIAD Consideration 3

The Ministry should consider resuming local in-person community meetings to facilitate the ability for First Nations and Métis groups to provide input into the process, given COVID-19 measures are no longer mandatory.

Ministry Action

The current IFAPP encourages in person meetings (page 24) to support input into the audit process. The ministry will emphasize the importance of in-person meetings at auditor training sessions for 2024 audits (scheduled for April 2024).

OIAD Consideration 4

The Ministry should consider developing a Management Unit (MU) risk assessment template to standardize completion of risk assessments and facilitate review to ensure the process was appropriately followed.

Ministry Action

The ministry is updating the IFAPP for the 2025 audits. The development of a risk assessment template for auditors to use to document the completion of risk assessments and support reviews will be considered as part of the update.

OIAD Consideration 5

The Ministry should consider developing a process to periodically review the classification of the mandatory and optional audit procedures.

Ministry Action

The ministry is updating the IFAPP for the 2025 audits and the classification of mandatory and optional audit procedures will be reviewed during the update. The review will ensure that the classification of the mandatory and optional audit procedures align with the 10-year audit review cycle, or more frequently as updates are made to the forest policy framework.

OIAD Consideration 6

The Ministry should consider enhancing the IFA process by aligning the IFAPP audit procedures to the objectives of the Regulation to enable determination of the extent of work that is required to be performed to achieve each of the regulatory IFA objectives.

Ministry Action

The identification of opportunities to align the audit procedures in the IFAPP with objectives of the IFA Regulation will be considered as part of the 2025 IFAPP update.

OIAD Consideration 7

The Ministry should consider reviewing the audit procedures within the IFAPP to support the specific sections of the requirements of the Regulation using a risk-based approach that ensures appropriate procedures are included to facilitate the conduct of audits in an effective manner.

Ministry Action

The ministry is updating the IFAPP for the 2025 audits. A review of the audit procedures will be considered as part of the 2025 IFAPP update.

OIAD Consideration 8

The Ministry should review the Annual Reports process to ensure submission quality and timeliness.

Ministry Action

Complete. The ministry reviewed the requirements in the Forest Management Planning Manual in 2023, including the annual reporting process, as part of the Forest Manuals Revision project. The Forest Management Planning Manual continues to provide the opportunity for the ministry to review annual reports and requires the forest manager to respond on how any ministry comments were addressed.

The ministry will continue to communicate the annual report submission and review process to forest practitioners during planned policy transfer and training activities that support rollout of the forest manuals targeted for implementation starting July 1, 2024.

OIAD Consideration 9

The Ministry should consider adding a statement to the Natural Resources Information Portal (NRIP) hosting the Annual Reports that this information is supplied by the forest manager with no Ministry review or approval.

Ministry Action

The ministry is identifying updates and enhancements to NRIP to support the proposed forest manuals targeted for implementation starting July 1, 2024. The ministry will consider communications related to annual reports as part of these updates and enhancements.

OIAD Consideration 10

The Ministry should consider investigating the factors which are causing discrepancies in the differences in Silviculture Effectiveness Monitoring (SEM) reporting and develop the required policies and technical direction to support making the audits more effective.

Ministry Action

The ministry is working on providing additional direction to ensure forest managers across Ontario can successfully implement the Forest Management Planning Manual and Forest Operations and Silviculture Manual’s silviculture policy requirements in the development and implementation of FMPs. Regeneration monitoring direction is being considered to provide for consistent silviculture policy implementation. The objective is to ensure confidence in the regeneration monitoring information used as the basis for FMP modelling and the determination of sustainability and public reporting.

OIAD Consideration 11

The Ministry should consider updating the IFAPP to require that findings be more risk- based through consideration of impacts that are more systemic in nature.

Ministry Action

A risk-based focus through consideration of impacts that are more systemic in nature will be considered as part of the 2025 IFAPP update.

OIAD Consideration 12

The Ministry should consider revising the time allotted for auditors to prepare the draft version of audit report Appendix 1 (technical findings).

Ministry’s Action

The time needed to prepare the draft version of the audit report will be considered as part of the 2025 IFAPP update.

OIAD Consideration 13

The Ministry should consider instituting a process which requires timely development of action plans in response to corporate findings raised in IFA reports. To facilitate transparency and accountability of the follow-up process, such action plans should be publicly reported and include the actions to be taken, responsible party, and timeframe for implementation.

Ministry Action

Complete. As outlined in the IFAPP, corporate findings are also assessed within the action plan developed for each management unit. The action specifies that corporate or policy level findings are considered as part of the regular corporate work planning and policy review cycle. The results of consideration of corporate findings are reflected in policy reviews and revisions. Policy processes involve Indigenous community, public and stakeholder consultation.

OIAD Consideration 14

The Ministry should consider developing a periodic process to review findings across all IFA audits and identify systemic issues that need to be corporately addressed.

Ministry Action

Complete. A process exists to identify trends based on findings in IFAs. The IFAPP identifies a role for the FFTC is “providing periodic commentary on audit findings and/or making recommendations to the ministry”. Additionally, the ministry maintains a database of audit findings to support identification of common issues, trends in audit findings, and identification of systemic issues.

OIAD Consideration 15

The Ministry should consider developing a process to track corporate actions and validate both the corporate and forest managers’ completed actions.

Ministry Action

Complete. In 2020, the Forest Management Planning Manual (FMPM) was revised to include tracking of actions assigned under an action plan developed in accordance with the applicable IFA into management unit annual reports. Also, proposed revisions to the FMPM (for 2024) clarify that where applicable "all" actions assigned under an action plan will be discussed. As outlined in the IFAPP, corporate findings are also assessed within the action plan developed for each management unit. The action specifies that corporate or policy level findings are considered as part of the regular corporate work planning and policy review cycle. The results of consideration of corporate findings are reflected in policy reviews and revisions.

OIAD Consideration 16

With the move to the 10-year cycle, the Ministry should consider assessing the corresponding updates which may be required to the IFAPP as a result of the longer audit period.

Ministry Action

The ministry will consider experiences to date in implementing an extended period between audits and identify any supporting revisions as part of the 2025 IFAPP update.

Since implementation of the revised audit cycle is still in its early stages, the ministry will continue to evaluate and make improvements to the IFAPP based on these experiences on an annual basis. A comprehensive evaluation of implementation of the revised audit cycle will be considered as part of the next review of the IFA regulation.

OIAD Consideration 17

The Ministry should consider undertaking a comprehensive review of the impacts to the IFA process as more audits are being completed with longer timeframes to monitor and assess risks associated with the decision to move to the ten-year cycle.

Ministry Action

Since implementation of the revised audit cycle is still in its early stages, the ministry will continue to evaluate and make improvements to the IFAPP based on these experiences on an annual basis. A comprehensive evaluation of implementation of the revised audit cycle will be considered as part of the next review of the IFA regulation.