2024-05-10 Comments regarding proposed cutblocks and road segments on West Redonda Island

To: Jillian Tougas, RPF, Acting District Manager, Jillian.Tougas@gov.bc.ca

cc: To whom it may concern at A&A Trading, FOM@aatrading.com

Good afternoon Ms Tougas,

Under section 9 of the Forest Planning and Practices Regulation (FPPR), the objective set by government for wildlife and biodiversity at the landscape level is: “to the extent practicable, to design areas on which timber harvesting is to be carried out that resemble, both spatially and temporally, the patterns of natural disturbance that occur within the landscape”.

A&A Trading’s forest stewardship plan states that its strategy for meeting this objective is: “When constructing a road or harvesting timber under this FSP, the Holder undertakes to comply with section 64 and 65 of FPPR.”

Section 64’s intention is to limit the size of an individual cutblock, in this case to 40 hectares. Section 65’s intention is to ensure that new cutblocks are only located near to adjacent cutblocks when the regrowth in those cutblocks has reached a height of at least 3 metres. Neither of these regulations address the objective of ensuring that timber harvesting resembles, “both spatially and temporally, the patterns of natural disturbance that occur within the landscape.”

The Discovery Islands Forest Conservation Project has determined (see our analysis below) that issuance of cutting permits for A&A Trading’s proposed cutblocks and road segments as shown in FOM #1352 would be contrary to the provisions of section 9 of the Forest Planning and Practices Regulation and so would negatively impact “the management and conservation of forest resources”.

Under the newly amended Forest Act (see section 3.1 of the Forest Statutes Amendment Act, 2003), the minister (or his/her designate, in this case the Sunshine Coast Natural Resource District Manager) may refuse to issue a cutting permit in such circumstances. Since the proposed cutblocks and road segments would clearly not be in accordance with newly amended section 9 of FPPR, we request that you decline to issue cutting permits for cutblocks that would result in an area being logged that would be in excess of the requirements of section 9.

In our view, the plain meaning of section 9 of FPPR is that, on the scale of the Cortes Landscape Unit, in order to protect wildlife and biodiversity, logging must resemble (look like, be similiar to, be like) natural disturbance in terms of both the expected size of natural disturbances (“spatially”) and the expected return interval of those natural disturbances (“temporally”).

The common meaning of the word “practicable” is “capable of being put into practice or of being done or accomplished”. We believe the expression “to the extent practicable” is intended to recognize the inherent scientific complexity of determining the spatial and temporal dimensions of natural disturbances. In our view, “to the extent practicable” was not intended to be a limitation on the extent to which this objective could affect timber supply. The impact on timber supply of section 9 of FPPR was formerly controlled by the “unduly clause” attached to this objective, in conjunction with government policy that determined what “unduly” should mean with respect to timber supply. Removal of the unduly clause by government now implies that the objective set by government by section 9 is no longer conditional on its impact on timber supply.

Since this section 9 objective set by government was first introduced with FPPR, the scientific understanding of natural disturbances—including their spatial and temporal dimensions—has evolved.

According to the most recent science, which is included in the 2020 Standards for Assessing the Condition of Forest Biodiversity under British Columbia’s Cumulative Effects Framework (please see the table in Appendix 3 on page 52) the estimated minimum natural disturbance return interval for the CWHdm variant is about 700 years, and for CWHvm1 it is about 2000 years.

The cutblocks and road segments proposed by A&A Trading in FOM #1352 would be mainly within the CWHdm biogeoclimatic variant. A few of the proposed cutblocks would be in the CWHvm1 variant.

For A&A’s proposed logging on West Redonda Island to resemble natural disturbance on a temporal basis, then, a year’s logging must not exceed 1/700 of the area of productive forest in the CWHdm variant, or 1/2000 of the area of productive forest in the CWHvm1 variant of West Redonda Island’s productive forest.

Because we are uncertain of the extent of productive forest on West Redonda Island, the calculations below are based on estimates of the entire area of CWHdm and the entire area of CWHvm1 on the island. Our estimates, therefore, produce an estimated area greater than would be the case for just productive forest.

CWHdm

Estimated total area = 10,585 hectares

1/700 of total area = 15.1 hectares

CWHvm1

Estimated total area = 4432 hectares

1/2000 of total area = 2.1 hectares

If A&A Trading’s logging is to resemble natural disturbance at the landscape level then it can log no more than 15.1 hectares per year of CWHdm and 2.1 hectares per year of CWHvm1.

Its current proposal entails 171 hectares of cutblocks and approximately 19.5 hectares of roads. That area of logging would need to be spread out over approximately 11 years to spatially and temporally resemble natural disturbance. That estimate assumes that no other logging occurred on West Redonda Island during that time.

Since 2010 , a 15-year period, A&A Trading and others have logged 961 hectares of West Redonda Island. If those companies had been meeting the section 9 objective set be government as it is written today, those companies would have been able to log no more than 258 hectares in that 15-year period. That high level of over-cutting—3.7 times greater than the natural rate of disturbance—has had negative impacts on wildlife and biodiversity, but also on increased fire hazard, loss of carbon sequestration capacity and carbon emissions.

Please decline to issue any cutting permits that would result in the limits implied by the newly amended section 9 of FPPR being exceeded.

Sincerely,

David Broadland for the Discovery Islands Forest Conservation Project