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  • Engaging the mindustry

    David Broadland
    THE OVERWHELMING PHYSICAL PRESENCE of the logging industry in populated areas of BC is hard to escape: it takes place almost everywhere except built-up urban areas, agricultural land and BC’s small system of protected areas. And even though employment in the industry has dwindled to 50 percent of what it was 20 years ago, the area of BC that gets clearcut each year is growing. That’s because the average size of the trees being cut is getting smaller and smaller as younger and younger trees are logged. To keep volumes up and remain competitive in the international market for wood, more and more land gets clearcut as time goes on. This is, of course, is subject to year-to-year market fluctuations, but the general trend is toward a greater area being cut in a given period of time.
    As the area being cut each year increases and awareness of the problems created by clearcut logging grows in the public mind, the conflict over how publicly-owned forests are used is growing. One avenue through which that conflict gets expressed is in letters of complaint written to what some of us think of as the “mindustry.” Let me define that term.
    “Mindustry” is shorthand for the alliance of people who have an economic interest in maintaining the logging industry at the maximum possible size. It’s that maximization that provides those folks with the greatest degree of job security. Included in the alliance are, on the one hand, employees of the BC Ministry of Forests and, on the other, employees of the logging industry. By “logging industry,” we mean the industry that plans logging roads and cutblocks, builds the roads and cuts the trees down, trucks them to mills or export terminals, and then mills the logs into wood products or loads raw logs onto ships. The mindustry includes the folks who replant the clearcuts and the educators employed to train foresters, forestry technicians and equipment mechanics at educational institutions like UBC and BCIT. And it includes businesses that supply the industry with the equipment, supplies and services required to remove forests. That’s the mindustry.
    Every job in the mindustry is made more secure if the current level of logging is maintained. Any suggestion of significantly lowering that cut threatens the long-term job security of everyone in the mindustry, from government to industry to educational institutions. There is no other industry in BC that is so sensitive about its collective job security. That’s because there is no other industry that does so much physical damage to our life support systems.
    When a conflict arises over proposed logging on a specific area of Crown land, those opposed to the logging will often put their objections in written form and send them to the company proposing to do the logging, and/or to ministry employees. In neither case is anyone in a position of authority going to do anything more than write a polite letter in response, which basically will say: “Thank you for your input.”
    Ocassionally, a company will agree to postpone logging of a small area, but that logging is simply shifted to some other nearby area. The actual rate at which a company is cutting on an area-based tenure will only change based on market conditions and the company’s own needs. The company is required by the ministry to cut a certain volume within a certain timeframe.
    So the question arises: What is the point of complaining about proposed logging?
    The easiest answer is that if we remain silent, the government will understand that as consent. If we don’t speak out against the destructive use of the forest, then the company and Ministry of Forests will interpret that as tacit agreement with what they are doing. Since we don’t agree, we must express our disagreement.
    This project is advocating a significant reduction in the amount of logging done on the Discovery Islands, which goes far beyond objecting to the logging of specific cutblocks. We understand that the mindustry—the alliance of economic interests described above—will be opposed to this direction, perhaps vehemently. Writing to them and asking for their support would be futile. Yet engagement with government is essential since only government has the authority to change the status of publicly-owned land.
    Engaging with the rest of government—the Ministry of Environment, the Climate Change Secretariat, the Ministry of Tourism, the new Ministry of Land Stewardship, and so on—is where this project will need to take its powers of persuasion in order to be successful in reversing the ecological degradation, the immense release of forest carbon, the loss of carbon sequestration capacity, the increase in forest fire hazard and the suppression of forest-related employment that is occurring as a result of authority for management of island forests resting mainly in the hands of the mindustry.
    This project will keep a record of letters and other submissions from people and groups engaging with the mindustry and with other government agencies. If you have written about some aspect of forest management on the Discovery Islands, please send it to us and we will add it to that record (please include the reply you received).
    See the full record of engagement here.
    David Broadland
    Talking and negotiating in person with logging companies about where they cut and what they cut has little, if any, positive effect beyond minor adjustments to cutblock boundaries or the timing of when a forest stand is cut.
    That’s partly because oversight of BC’s logging industry shifted from a system of government regulation and operational oversight to a regime of professional reliance in 2003 when Gordon Campbell’s government gutted the BC Forest Service.
    That shift replaced much of the operational oversight that the Forest Service had performed with oversight conducted by professional foresters employed by logging companies.
    In effect, regulation and operational oversight of logging on publicly owned land was privatized.
    Gordon Campbell’s big idea was that it would be better for the foxes to guard the chickens. Over 20 years of experience with professional reliance in action has shown that this change was better only for industry.
    The experience of Sonora Islanders Tavish Campbell, Jodi Eriksson and Farlyn Campbell (no relation to the former premier) enduring repeated failures by TimberWest’s foresters to meet the company’s legal and ethical obligations under the Great Bear Rainforest Agreement highlight the overall failure of professional reliance to protect old forest on the Discovery Islands. The video below, created by the Sonora Island community, captures the gist of the problem—in painful detail.
    The lesson? Don’t expect that talking with private logging companies will have any real influence on what they do. At the very least, make sure that all your communications with logging company’s are in writing and copied to the district forester and your MLA. Otherwise, it’s just talk ’n log.
    Better still, join with other islanders and work together for greater conservation of forests on the Discovery Islands, including full protection for at least 30 percent of the Discovery Islands by 2030.
     
     
    David Broadland
    May 12, 2023
    I bring the following issues to the attention of North Island Natural Resource District Manager Lesley Fettes, copied to the licensee and the Forest Practices Board. Please include these comments in any record of public comments included in the proposed Woodlot Plan.
     
    [1] The woodlot’s allowable annual cut is based on a flawed timber supply analysis.
    The foundational management plan, which this tenure has been operating under since July 13, 2011, relies on a 2007 timber supply analysis performed for the Ministry of Forests by a private consultant, Econ Consulting. Econ referenced the 2004 Strathcona TSA timber supply review as the basis for some of the assumptions made in its analysis. Our own analysis shows that Econ overestimated the timber harvesting land base for this woodlot. The allowable annual cut (AAC) that was calculated for the woodlot is, therefore, too high.
    Econ’s map, included with its analysis, shows that other than some reduction for areas of bare rock that occur on steep terrain, it did not reduce the area available for logging due to areas made inoperable by steep slopes (>40 percent in several areas) and cliffs. These are found on the north side of the valley that runs from the north end of Clear Lake northeast to Okisollo Channel, the east side of Wolf Mountain, the east side of Wolf Lake, and on the north side of Mount Yeatman.
    Econ also failed to remove areas of lodgepole pine from the timber harvesting land base. Our review of the the Ministry of Forests’ Harvest Billing System record of logging on Quadra Island shows there is no commercial market for lodgepole pine. Moreover, sites on which lodgepole pine grow on Quadra Island have generally thin, poor soils where—if logging did occur—trees would not grow back in a reasonable period of time. As was done in the timber supply review for the Strathcona Timber Supply Area (which Econ referenced in its analysis), Econ should have excluded 100 percent of the areas dominated by lodgepole pine from the timber harvesting land base.
    Below we itemize our determination of what we believe is a more realistic timber harvesting land base that should be used to calculate the AAC. Note that we have not excluded any area for wildlife tree retention areas (WTRAs), which, as you know, are legally required to cover 8 percent of the woodlot area. That 8 percent would be covered by the legally required riparian retention areas, the legally required visual quality retention area on Okisollo Channel, inoperable areas, low productivity areas, swamp and areas of lodgepole pine.
    We note that in choosing discretionary areas to set aside as WTRAs, the licensee has left unprotected many areas of old forest that aren’t in a legally required riparian zone. Instead, the licensee has chosen areas—including stands of lodgepole pine—at the tops of mountains that would, in any case, be difficult and costly to build roads to and log. The licensee’s discretionary WTRAs seem designed to have the least positive impact on biodiversity conservation and the least negative impact on AAC.
    Here is our calculation of the timber harvesting land base:
     
    Total area of Woodlot 2031 = 715 hectares
     
    Non-forested area (lakes, wetlands) = 38.3 ha
    Bare rock = 7.4 ha
    Existing roads, trails and landings = 30.3 ha             
    Total Forest Management Land Base = 639 ha
     
    Reductions
    Inoperable areas = 19.5 ha
    Problem forest types (Lodgepole pine) = 91.9 ha
    Low productivity sites (not including Lodgepole Pine) = 13.6 ha
    Lakeshore riparian areas = 6.4 ha
    Stream riparian areas = 3.3 ha
    Swamp areas = 1.5 ha
    Area where VQO is “retention” = 4.5 ha                                                 
    Total of reductions to the Forest Management Land Base: 140.7 ha
     
    Timber Harvesting Land Base (Forest Management Land Base minus reductions) = 498.3 ha.
     
    Any areas where two or more reduction types overlap have been netted down.
    See the map and spreadsheet on this page for more details on the reductions that should have been made.
    A timber harvesting land base of 498.3 hectares is 7 percent less than Econ estimated.
    We estimate that a more appropriate AAC would be at least 7 percent lower than the AAC used since 2011.
    Note that the above analysis of the timber harvesting land base does not include any areas of old forest in the woodlot except those that happen to occur in lakeshore riparian reserves. We will come back to the old forest issue later in this submission.
     
    [2] The tenure holder has been logging at a rate much greater than the inflated AAC set out in the management plan.
    Records from the Ministry of Forests’ Harvest Billing System show that over the 12 years from the beginning of 2011 to the end of 2022, the licensee’s cut amounted to 42,426.86 cubic metres. So over those 12 years, the cut averaged 3536 cubic metres per year.
    The allowable annual cut committed to by the licensee in its Woodlot Plan was 2890 cubic metres per year.
    The average annual cut, then, exceeded the allowable annual cut by 646 cubic metres per year. In other words, it was 22.3 percent higher than the AAC to which the ministry and the licensee agreed. It would take 2.7 years of no logging (starting in 2023) for the licensee to get back to the rate of cut it agreed to in 2011.
    Combined with Econ’s 7 percent over-estimation of the area available for logging as outlined in [1] above, this has resulted in an over-cut of approximately 30 percent per year over 12 years.
    Logging in this woodlot should be halted until the cut control is back on track and a more reliable timber supply review is conducted, including the use of drone technology and ground-truthing for identifying old forest and other areas of the woodlot that should be excluded from the timber harvesting land base.
     
    [3] This license is subject to an active complaint to the Forest Practices Board regarding logging of old forest in 2019.
    Until this complaint has been investigated by the Forest Practices Board, and its findings made public, review of this licence’s proposed woodlot plan should be postponed.
    The licensee cut 3 hectares of old forest in 2019, which we believe was contrary to written promises made in the licensee’s legally binding 2011 Woodlot Plan. The licensee’s plan had stipulated that even “scattered small patches of existing old forest” not specifically identified in the Woodlot Plan would be retained.
    We refer you to the complaint made to the Forest Practices Board for more details about the complaint.
    We note here that an earlier complaint related to this same logging was made to the Forest Practices Board. The Board found, based on one or more interviews with the licensee, that only 10 old trees had been cut and that they had been cut in order to build a road or for safety reasons.
    The licensee apparently failed to inform Board investigators that just down the road, it had, in fact, logged at least 35 old-growth trees from a 3-hectare cutblock (19-02).
    In July 2022, the licensee refused to answer our questions about how many trees greater than 250 years of age had been logged in cutblock 19-02.
    In the Spring 2022 edition of The Woodland Almanac, the licensee wrote: “Here is a photo of myself with a few of the 17 old growth Fd vets we retained in a 3 ha cut block on our WL. These Fd vets survived a 1920’s wildfire and were scattered in a second growth stand. We retained a majority of the scattered Fd vets because it’s the right thing to do. They’re beautiful.”
    Cutblock 19-02 had, in fact, contained at least 55 old-growth fir and cedar vets before roadbuilding and logging occurred. The licensee did not tell the truth to the readers of The Woodland Almanac when she claimed “We retained a majority of the scattered Fd vets…”
    In the context of the licensee’s application to the ministry to amend and renew its plan, we would point out that the licensee chose not to abide by its 2011 plan when it cut old forest in cutblock 19-02, and then, when that was revealed, attempted to hide the fact that it had logged old forest.
    We therefore question whether the licensee can be trusted to abide by the proposed woodlot plan—or any future woodlot plan.
     
    [4] The language in the draft proposed woodlot plan regarding conservation of old forest is unclear.
    A 2021 Forest Practices Board investigation into logging of old trees determined that in its 2011 Woodlot Plan the licensee had committed to retain all existing old forest in the woodlot. This is our interpretation of the 2011 plan as well. However, the proposed plan has been reworded in such a way that it appears that old forest could now be logged.
    The change in language in the proposed Woodlot Plan, when compared with the language in the original 2011 Woodlot Plan, suggests the licensee does not acknowledge the need to conserve all remaining old forest on the woodlot and/or may not have a reliable understanding of how much and where old forest remains on the woodlot.
    The licensee now proposes to commit to “maintaining or creating stand structures and forest attributes associated with mature and old forests, subject to the targets in the” Vancouver Island Land Use Plan Higher Level Plan Order.
    The “target” for old forest in Special Management Zone 19 (SMZ 19) is “greater than 9 percent” of the timber harvesting land base in the woodlot, which, as noted above, is approximately 498.3 hectares. That “9 percent” target would equate to 45 hectares of old forest.
    The Discovery Islands Forest Conservation Project has conducted a drone survey of woodlot 2031 and we estimate there are approximately 75 hectares of old forest, or forest containing significant concentrations of old trees, on the woodlot, that need to be conserved.
    Thus the licensee’s commitment—if our interpretation of it is correct—would allow it to log approximately 30 hectares of old forest.
    This is an issue that the Ministry of Forests must resolve in favour of protecting the remaining old forest on Quadra Island. The provincial Old Growth Strategic Review Panel recommended a moratorium on logging of old forest in any landscape unit in which old forest constituted less than 10 percent of the forested area of the landscape unit. On Quadra Island, it has fallen to approximately 4 percent, creating a high risk of biodiversity loss.
    The ministry created this problem, following completion of the Vancouver Island Land Use Plan, by failing to create legal old growth management areas on Quadra Island before it established 11 woodlot licences in SMZ 19. Now the ministry needs to find a solution that does not involve further logging of old forest.
    The licensee’s stated commitment to meet the seral stage distribution targets for SMZ 19 is at odds with the licensee’s description of its proposed “Wildlife Tree Retention Strategy” which states: “Biodiversity Reserves (Brs): retaining the existing old growth stands (>250 years, as per the Timber Supply Analysis Report (2007) in the W2031 Management Plan)…”
    This passage seems to imply that the licensee intends to conserve only existing old growth stands that were identified in the flawed 2007 timber supply analysis. That analysis, using an outdated methodology, identified only 15.1 hectares of old forest. That estimate does not come close to reflecting the reality on the ground. The licensee’s proposed approach does not meet the need to conserve all existing old forest—whether the licensee is aware of its existence or not. We are happy to share our mapping of old forest with the licensee. (See the map near the bottom of this page.)
     
    [5] The proposed plan appears to contain conflicting commitments.
    The licensee’s apparent new commitment to meet the seral stage distribution targets established for Special Management Zone 19 is incompatible with the licensee’s stated intention (recently confirmed in an email) of logging at a rate of 2890 cubic metres per year.
    As noted above, on page 5 of the proposed Woodlot Plan, the licensee states, “The Order indicates the following Resource Management Zone (RMZ) Objectives for SMZ 19, and the woodlot licensee commits to the strategies indicated: Objective 1: Sustain forest ecosystem structure and function by: maintaining or creating stand structures and forest attributes associated with mature and old forests, subject to the targets of the Order;”
    Our interpretation of this section of the Woodlot Plan is that the licensee is agreeing to manage the woodlot subject to the targets of the Vancouver Island Land Use Plan’s Higher Level Plan Order (HLPO) for Special Management Zone 19. Those targets are “greater than 9 percent” of the area of the woodlot is to be covered in old forest and “greater than 25 percent” is to be covered in mature forest. Those are the targets implied by the HLPO.
    This is not possible given the stated allowable annual cut of 2890 cubic metres.
    By definition, “mature” implies forest containing trees greater than 80 years old. “Old” implies forest containing trees older than 250 years of age.
    Let’s leave aside the apparent commitment to maintain at least 25 percent of the woodlot as “mature” forest cover and look at just the impact the old forest target would have on the licensee’s AAC.
    Above in [1], we estimated the timber harvesting land base to be 498.3 hectares.
    The areal extent of old forest that is needed to meet the target for SMZ 19 (>9 percent of THLB) is 44.8 hectares.
    We estimate that 3.5 hectares of old forest would be included by the riparian reserves around Hummingbird Lake and Wolf Lake.
    That would reduce the additional area of old forest needed to meet the old forest target for SMZ 19 to 41.3 ha.
    That, in turn, would reduce the THLB to 457 hectares.
    Given the mean annual increment used by the woodlot’s management plan (5.07 cubic metres/hectare/year), we calculate that the AAC for the woodlot under the commitments outlined above would be approximately 2300 cubic metres per year.
    But the licensee has said it also intends to apply an AAC of 2890 cubic metres/year. That level of cut is clearly incompatible with conservation of even 41.3 hectares of additional old forest, let alone the full 75 hectares of existing old forest.
     
    [6] The licensee has failed to properly assess and characterize forest types in the woodlot and can’t be relied on to identify old forest.
    An FOI for communications between the licensee and the Ministry of Forests showed that in 2019 the licensee mischaracterized the forest type in proposed cutblock 19-02 when applying for approval to commence logging in the cutblock.
    In a February 2019 email to the Ministry of Forests’ approving authority, the licensee stated that the forest in proposed cutblock 19-02 “has a vigorous second-growth HwFd(Cw) overstory with a sparse understory. There are scattered Fd and Cw vets in the block, as well as evidence of fire…”
    In fact, the 3.0-hectare stand had approximately 55 healthy old-growth Douglas fir and redcedar veterans in it before roadbuilding and logging occurred. The oldest live trees were in the neighbourhood of 400 years of age. The stand contained numerous standing snags and abundant woody debris on the forest floor. The area met the requirements for “old forest” as designated by the Forest Attribute Score (FAS) for the Great Bear Rainforest Order.
    The density of veteran overstory trees was about 18 stems per hectare. The density of snags was 5 or more per hectare. There was moderate vertical canopy differentiation and an abundance of course woody debris on the forest floor. The area had been lightly burned, likely in 1925. This combination of attributes would have given the stand a score of at least 6 on the FAS scale, and designation as “old forest”.
    The licensee’s failure to properly and professionally assess the true nature of the plant community in cutblock 19-02 should disqualify the licensee from seeking further cutblock approvals without first obtaining a confirmation of forest type from an independent registered professional forester or a forester from the ministry’s district office.
     
    [7] The licensee has not followed through with commitments made in its first woodlot plan and therefore can’t be trusted to do so in the future.
    In its draft 2011 Woodlot Plan, the licensee had stated that harvesting would be modified—meaning not clearcut—in “Areas adjacent to park boundaries, to maintain the integrity of the boundaries. Appropriate methods will be decided concurrent with development, and may include a 25m modified harvest buffer where practical”.
    In a public comment about the draft plan, a Quadra Island resident expressed concern that “park boundaries are protected from blowdown.”
    In a written response to that comment, the licensee stated: “Decisions regarding harvesting adjacent to parks will be made in discussion with BC Parks staff.”
    The records released under an FOI for the communications between the licensee and BC Parks for the years 2014 to 2020 shows that the licensee never undertook such discussions. The licensee did contact BC Parks in 2014 regarding the advisability of installing a gate to block public access to the area. But the records provided by BC Parks don’t include a single instance where the licensee, over those seven years, engaged in “discussion with BC Parks staff” regarding the licensee’s plans to clearcut six blocks right to the boundaries of Octopus Islands Provincial Park and Small Inlet Provincial Park. Moreover, the licensee apparently didn’t deem it to be “practical” to include the hinted-at “25m modified harvest buffer” in any of those six cutblocks.
    Again, these circumstances speak to the issue of whether the licensee can be trusted to follow through with the commitments it makes.
     
    [8] The 60-year rotation period adapted by the licensee will result in a significant loss in the carbon sequestration capacity of the forest in the woodlot area.
    The management plan, which is foundational to the Woodlot Plan, states that the AAC is based on a 60-year rotation period. Econ estimated the average site index for the woodlot area at 20 (metres).
    According to Ministry of Forests’ growth and yield curves for Douglas fir growing on land with a site index of 20, such a short rotation period would result in an approximately 90-percent loss in the carbon sequestration capacity of the forested area of Woodlot 2031 compared with a more natural rotation period of 300 years. Since Canada has declared a climate emergency, it seems foolish for the provincial government to allow such a predictable loss of the ability of BC forests to mitigate climate instability and global heating.
     

    Five 60-year rotations on Woodlot 2031 (light green)—compared with a single rotation period of 300 years (dark green)—would result in 90 percent less overall carbon sequestration over a 300-year period.
     
     
    [9] There is no economic justification for allowing a continued over-cut in the woodlot.
    Over the past 10 years, this woodlot has provided, on average, the equivalent of less than one full-time equivalent job per year. Over that same period, the average stumpage received by the Province from this tenure has been $1.84 per cubic metre, while the average stumpage paid in BC has been $18.33. Most of the trees cut on Quadra Island have been exported as raw logs, which provide no milling or value-added jobs. There is no justifiable socio-economic rationale for allowing this tenure to overcut its ministry-approved AAC by 22.3 percent over that time.
     
    [10] This area should be considered for inclusion in the province’s uplift of protected area to 30 percent by 2030.
    Current official provincial government policy is to expand the level of protected area in BC to 30 percent by 2030, a shorter timeframe than is being considered for the renewal period for this licence. Currently, only about 18 percent of Quadra Island is protected by any form of conservation measure. There are no legal OGMAs anywhere on the island.
    Since this tenure lies between 3 different provincial parks, contains 2 significant lakes and has, on a percentage basis, the greatest concentration of old forest in the Crown forested area of Quadra Island, it is one of the most likely areas to be involved in a future increase of protected land on the island.
    Continued logging in this area—especially at the inflated rate that has occurred under the current licensee—will only increase the inevitable restoration costs. The cost of buying back the license now, including the small amount of stumpage that would be forfeited by the Province over the next 10 years, would be much less than the cost of required restoration work and buying back the license in 2030.
     
    [11] Recommendations
    For all of the reasons stated above, we recommend that:
    1. Approval of the proposed plan as written not be granted.
    2. The Campbell River district office not grant any cutting permits for this licence through 2023, 2024 and 2025 so as to, at the very least, get the licensee’s agreed upon allowable annual cut under control.
    3. In the meantime a more reliable timber supply review for the woodlot should be conducted, and
    4. That such a review also undertakes to determine, accurately, where there is existing old forest on the woodlot, and
    5. That the potential for this area to be added to BC’s protected areas system by 2030 be evaluated by the pertinent BC ministries.
     
    Sincerely,
    David Broadland, on behalf of the Discovery Islands Forest Conservation Project
    David Shipway
    Overview map of the Sunshine Coast Timber Supply Area
     
    To: Jillian Tougas, RPF, Resource Manager—Sunshine Coast Natural Resource District, and Forest Analysis Branch Office—Vancouver Forest Region

    By sheer luck, a friend told me last week he had discovered there was a Timber Supply Analysis ongoing in this Forest District, leading to a revised AAC, and with a Public Comment period ending on May 1st. This isn’t common local knowledge, almost a well-kept secret, so I spent some time finding more information about this important review, and have sifted through the two PDF documents available on the SCTSA webpage before writing this response. While there are some laudable conservation goals now in place for a small number of endangered species across this magnificent coastal landscape, and some progress in recognition of aboriginal rights and title, nothing that I read has changed my woodworker’s perspective that our public “working forests” are still in relatively rapid decline due to an adherence to unscientific Timber Management policy. 
    I have lived within the SCFD for the last 50 years, mostly on Cortes Island. In the 70s I worked with MacMillan Bloedel on survey crews, and later spent a few years in treeplanting all over the province. These jobs were both a heart-rending education in what gets compromised to maintain the excessive flow of timber in BC, with more cubic metres exported per job than anywhere else in the world. Since the early 80s I’ve been exploring this whole beautiful coastal region by boat, but mostly making a living building houses in the Discovery Islands, and doing a wide variety of professional woodwork. It is from experience gained in all of these activities that I make the following response to this timber supply review:
    1. The current methods of public notification and engagement with communities within the SCFD are inadequate. Printed papers are going extinct, and most people now get their information through digital means. Most communities now have websites where anyone, including government agents, can post notices and information, so residents are kept informed of policy matters that are of a more local concern. I suggest that the District and Regional staff responsible for public involvement must shift to a more modern and direct electronic notification of all communities within the SCFD, otherwise very few will know what’s happening. The wide spectrum of public feedback that you seek to guide policy will be tilted towards only those who are notified by the licensees with a direct economic interest in timber supply.
    Furthermore, the public really needs to see ALL the good ecosystem mapping of the SCFD in order to make informed comment in any public review, but the only map provided in this TSR is a tiny low-info map showing the boundary of this forest district, and even that mapped boundary is incorrect, since Lasqueti Island has migrated over to the Arrowsmith FD. Ecosystem mapping will show the public that the majority of land in the SCFD is composed of extremely steep slopes, bedrock and retreating glaciers. Good productive forest land in the SCFD is actually quite rare.
    2. As economically accessible old-growth in the THLB disappears, and further OG deferrals are implemented, there will be even more political pressure to harvest immature stands to maintain an overly optimistic AAC. I am already shocked by the young age of many current harvest areas, and would like to point out why this trend is an extremely bad idea.
    First, young trees of most coniferous species in this THLB are by volume nearly half sapwood. Sapwood has no longevity in wood products, as the sugars within it attract fungi and boring insects. I have noticed that fir plywood mills on the coast ignore this and use the sapwood to make veneers anyway. Considering that plywood is now very expensive, and is often the primary material holding buildings upright, it is rather disconcerting when the plywood erupts in black fungus before the building can be finished and protected. This does not bode well for the durability of modern wood-based housing, or for the forests that must then resupply replacement buildings sooner in the future. This is a classic Feedback Spiral of Diminishing Returns, and totally unsustainable and counter-productive to the propaganda of long term carbon sequestration in durable wood products.
    Second, the more frequent site disturbances created by shortened rotations also have a negative impact on biodiversity and carbon sequestration in forest soils. Many key nutrient inputs associated with older stands, such as arboreal lichens, do not have enough time to develop, so the soils and fertility within the THLB will become impoverished and tree growth will decline. This is another classic Feedback Spiral of Diminishing Returns, and totally unsustainable and counter-productive to timber supply, as well as the urgent need for all forests to perform as effective carbon sinks.
    3. The solution to the serious problems described in #2 is quite simple—let the second growth trees grow to genuine maturity!
    The productive land that I am fortunate to own has a stand of co-dominant Fir and Cedar that is now nearing 120 years of age. When I do harvest trees, usually one or two at a time, I count the rings and do a volume calculation on recent growth rates. To my amazement, I have discovered some trees have put on as much volume of wood in the last 40 years as they had in their first 80 years of life! And what is also important is that a lot of this doubling in volume is in the form of clear wood that has a much higher potential and monetary value in woodworking. There is more heartwood and less sapwood, and so more of the tree will endure for longer as human artifacts. This higher quality heartwood can become doors and windows, fine furniture or traditional boats. This lucrative potential would have been squandered if the whole stand had been clearcut at 80 years of age, when the immature trees had more sapwood and the heartwood full of large knots.
    So when I see that young stands are often harvested now at the age of 60, I just shake my head in despair—doesn’t anyone realize what has been stolen from their childrens’ future? The world has envied our historical bounty of structural Douglas Fir timber. We can do far better now than grind it all down into mere cubic metres of low quality fibre. But patience is required, as any good farmer or woodworker knows. Second growth stands will also start to acquire many old growth attributes by the age of 120, and thus contribute more viable habitat to replace what has been lost with the hasty liquidation of the low-elevation old growth forests on this coast.
    4. In my readings of fire risks described by Blackwell & Associates in recent Community Wildfire Prevention Plans, young homogenous plantation stands pose a higher fire risk than older more mature stands with less ladder fuels and greater structural diversity. It seems obvious that reducing the overall percentage area of contiguous young forest stands is a very positive wildfire mitigation strategy. Solution: reduce the rate of cut and focus on Quality, by growing more mature forests!
    I do hope you can agree that the very limited Timber Harvest Land Base in the Sunshine Coast Forest District must contribute to and maximize long term viable solutions to mitigate climate change, and at the same time support the threatened survival of a multi-generational regional value-added woodworking economy using high quality wood. This must be the future we aim for, and can only be accomplished by allowing the second and third growth forests to fully mature before harvest. Please therefore calculate a conservation-based AAC with these critical long range goals, duties and obligations in mind.
    Sincerely,

    David Shipway
    Windjammer Woodworking & Design
     
    Send your comment to: Jillian Tougas at engagesunshinecoastforestdistrict@gov.bc.ca
    and copy the Forest Analysis Branch at Forests.ForestAnalysisBranchOffice@gov.bc.ca
    David Broadland
    Had the land on the northeast side of Granite Bay on Quadra Island—logged by TimberWest in 2018-2020—been previously deleted from TFL 47?
     
    Lesley Fettes, District Manager
    Campbell River Natural Resources District
     
    Dear Ms Fettes,
    I am submitting this letter on behalf of the Discovery Islands Forest Conservation Project in response to your invitation for public comment on a proposed change to the visual quality objective for the area of District Lots 319 and 318 and adjacent Crown land on the east side of Granite Bay (referred to as “the area at issue” below).
    I have reviewed the background material your office provided, including the letter from the Forest Practices Board. Thank you for providing this material.
    I had earlier contacted your office about the lack of certainty regarding the status of the land at issue. I note that the Forest Practices Board stated in its letter that some land in the general area had been removed from the TFL to establish Small Inlet Marine Park, but government maps incorrectly showed the area of the complaint as part of the park.
    Based on our research, the Forest Practices Board is correct in stating that the area at issue is not in the park. But there is good reason to believe this area was deleted from TFL 47 by an Order in Council or by some other instrument. The Forest Practices Board does not provide a chain of custody history for the land at issue, and other documents show the land as having been deleted from the TFL.
    These documents include a map of areas deleted from TFL 47 in TimberWest’s 2012 Management plan #4. The map (below) from that document shows areas deleted in brown. It shows the area at issue had been deleted from the TFL previous to 2012. Management Plan #4 mentions several examples of deletions from the TFL over a period of more than a decade.
     

     
    Keep in mind, this is TimberWest’s own mapping of the TFL and it is difficult to fathom how or why the company would erroneously delete land from its TFL in its Management Plan.
    We also have obtained a map that was created by TimberWest that shows the area at issue as not in TFL 47. The map below shows TimberWest’s version of its timber harvesting land base (blue-grey areas), and the land at issue is not in the TFL. Again, it is hard to understand how TimberWest could make such a mistake. The map is correct in every other respect.
     

     
    In going through the record of deletions from TFL 47 from 1992 to 2010—as shown in the Ministry of Forests’ archive of TFL 47 management plans #1, #2, #3 and #4—it is evident that aproximately 8999 hectares were deleted, as enumerated below:
    1992: Instrument 9 (“takeback area”): 2980 hectares 1996: OIC 589 according to TimberWest MP #4: 3345 hectares* 2003: Forest Revitalization Act removal: 1236 hectares 2003: Instrument 16: 1438 hectares Total for these 4 deletions: 8999 hectares.
    (* For OIC 589, we used the numbers from the order except for Surge Narrows Provincial Park, for which we estimated 44 hectares are on Quadra Island.)
    To what category of Crown land were these deletions transferred? Four provincial parks absorbed 3345 hectares and eleven Woodlot Licence tenures were given 5469.5 hectares.
    The total for these two categories was 8814.5 hectares.
    So, of the 8999 hectares of deletions, we can only account for 8814.5 hectares.
    Where did the remaining 184.5 hectares go? We believe this is the land on the northeast side of Granite Bay. Note the nearly exact match of the areal extent of the land at issue compared to the missing 184.5 hectares.
    The small island to the west of Lot 319: 15.3 hectares Lot 319: 33.63 hectares Lot 318: 42.11 hectares Crown land between Lot 318 and the north-south boundary of Small Inlet Park: 92 hectares  Total for these 4 areas: about 183 hectares.
    Keep in mind that each of these areas is shown as being deleted from TFL 47 in TimberWest’s maps.
    We are aware of no other forest-based tenure on Quadra Island that has been created during this period (1996-2003) that could account for the missing 184.5 hectares.
    TimberWest’s maps that show the area at issue had been deleted from the TFL, plus our accounting of the area of the deletions, and the areas of the new tenures created by those deletions, create serious doubt in our minds that the area at issue is still in TFL 47.
    Since the area at issue is not within the current legal boundaries of Small Inlet Park, it would appear this land should be classified as vacant Crown land. It likely was intended as a protected area, but fell through the cracks. In 2001, TimberWest expected to give up 751 hectares to Small Inlet Park. In the end, only 487 hectares of TFL were shifted to the park (see page 20 of this document). This would explain why the area was mapped in the 2007 GAR order as being a park or protected area.
    I asked Cody Gold in your office if he would look into this issue; Cody wrote back and stated, “I’ve conducted a brief review of our records and unfortunately, I was unable to find an explanation regarding the TimberWest Management Plan. I would encourage you to reach out to TimberWest/Mosaic to see if they can assist. If Mosaic are unable find an explanation in their records, there is also the option to submit an FOI request.”
    Since there was no possibility of obtaining records through an FOI by the March 31 deadline for comments, I asked TimberWest for their input.
    In particular, I asked TimberWest’s Operations Planner Gary Lawson for an explanation for why his company’s own maps showed the area at issue had been deleted from the TFL, yet it was now logging in that area. Management Plan #4 states that it was prepared for Lawson, so he seemed the best person to provide insight about why the maps in that plan showed the area at issue had been deleted from the TFL.
     

    TimberWest has logged in the area at issue almost to the boundary of Small Inlet Provincial Park
     
    Lawson responded to my query with the following explanation: “The area you mentioned is part of TFL 47. An area had been removed from the TFL to make the Small Inlet Park in the late 1990’s. At the time of the writing of the TFL Management Plan #4 it was mistakenly assumed that this area had been included in the removal from the TFL and added to the park. It had not. This area continues to be managed as part of TFL 47. The official maps of TFL, attached, clearly shows this.”
    Lawson included a map which showed the area in question as not being in TFL 47. However the map also showed several areas that are definitely not in TFL 47 as also being in TFL 47. This included several parcels of private property along Granite Bay Road and also District Lot 488. The latter has been in Woodlot 2032 and Woodlot 1969 for over a decade, yet Lawson’s “official” map of TFL 47  did not show this change—or the private property.
    Lawson did not respond to a request for legal, documentary evidence about the status of the land at issue. 
    I understand that all you really want from the public are comments on the designation of a visual quality objective of “retention” for this area. Given the murky circumstances outlined above, however, I would suggest this area should continue having a “preservation” status. Until such time as the ministry can explain the issues raised here, we suggest that the small island to the west of Lot 319 also be given “preservation” status, not “partial retention” as it now stands. This island lies at the entrance to a provincial marine park and should not be logged.
    Any plans TimberWest might have to damage this area further should not be approved by the Ministry of Forests until such time as a definitive explanation is provided to the public regarding TimberWest’s map of deletions. Also, the ministry needs to provide a credible explanation for why the area of the deletions from TFL 47 do not match the area of the new and expanded woodlots and provincial parks. Lastly, the ministry needs to provide an exact timeline for the deletions and how that land was redistributed.
    With Premier Eby’s announcement of expanding protected areas to 30 percent of land and water in BC by 2030, this area would be ideal for a protected area expansion, subject to First Nations’ approval.
     
    The land at issue includes the island in the centre of the image below and the land behind it.

    David Broadland
    Submitted by the Discovery Islands Forest Conservation Project April 4, 2023
     

    Logging of a rare stand of old forest at Hummingbird Lake on Quadra Island. The top photo was taken during logging in 2019; the bottom photo was taken from the same point in 2020.
     
    Summary
    1. Old forest on Quadra Island has reached a critically low level (~4 percent).
    2. The Vancouver Island Land Use Plan created Special Management Zone 19 (SMZ 19) in 2000 to ensure conservation of biodiversity associated with old and mature forest on Quadra Island.
    3. The failure to complete landscape level planning has left Quadra Island without any spatially-designated old growth management areas, putting all remaining old forest at greater risk of being logged or degraded.
    4. Establishing 11 woodlot tenures in SMZ 19 after it had been created effectively undid the land use planning provisions related to conservation of old forest on 5470 hectares in the zone.
    5. TimberWest is degrading small patches of old forest in its TFL 47 on Quadra Island, both inside and outside SMZ 19.
    6. TimberWest has no effective strategy for meeting the old seral stage targets implied by the VILUP Higher Level Plan Order. If those targets were included in TimberWest’s planning, it would have very little room left to log on Quadra Island.
    7. TimberWest is not abiding by the strategies recommended by the Vancouver Island Summary Land Use Plan for managing concentrations of veteran trees in its tenure.
    8. TimberWest’s strategy for sustaining forest ecosystem structure and function within cutblocks is ineffective because it doesn’t retain forest within cutblocks.
    9. Woodlot 2031 is logging old forest despite stating in its woodlot plan that it would retain existing old forest, even “scattered small patches of old forest”.
    10. Woodlot 2032 is logging old forest for roads and degrading old forest by removing trees 250 years of age and younger. Substantive changes made to its woodlot plan in 2019 illustrate how old forest reserves in a woodlot can be changed without any notice being given to the ministry or the public.
    11. We respectfully request that the Forest Practices Board investigate these matters.
     
    The lay of the land: 11 woodlot licence tenures and a TFL crammed in a special management zone on a small island

     
    TimberWest/Mosaic map of SMZ 19 (pink boundary) and age classes of forest cover on Quadra Island

     
    Introduction
    The failure to implement landscape level planning on Quadra Island after the Vancouver Island Land Use Plan established Special Management Zone 19 in 2000, coupled with the awarding or expansion of 11 woodlots inside the special management zone, has left rare stands and small patches of old forest open to logging. Since the area of old forest on Quadra Island is now down to about 4 percent of the Crown forested land base, risk of biodiversity loss is extremely high and getting worse. Urgent action by government is necessary to conserve all remaining old forest to protect biodiversity and other values.
     
    The problem
    [1] In July 2022, the Forest Practices Board released its investigation report, “Government Enforcement of Old Tree Harvesting on a Quadra Woodlot.” The report contained factual errors about how many trees were removed and why they were removed. The Discovery Islands Forest Conservation Project reported on those errors.
    [2] After we published our report, Forest Practices Board Director of Investigations Chris Oman wrote to us and suggested, “If you have concerns about whether the harvesting of other trees complied with [Forest and Range Practices Act], you are welcome to file a complaint with the Board.”
    [3] This submission is, in part, our project’s response to that suggestion. But rather than focussing our complaint on just the question of whether or not the Compliance & Enforcement Branch and Forest Practices Board had failed to thoroughly investigate the logging of old forest that had occurred at Hummingbird Lake on Quadra Island—that logging being just a symptom of a larger problem—we provide below a detailed description of the underlying circumstances that have allowed continued logging of old forest on Quadra Island, including at Hummingbird Lake.
    [4] The Discovery Islands Forest Conservation Project is conducting ongoing surveys of old forest on each island in the Discovery Islands group. On Quadra Island we have so far identified approximately 176 widely dispersed fragments of old forest that in area total 655 hectares. As mentioned above, that amounts to approximately 4 percent of the current Crown forested land base.
    [5] The low level of old forest on Quadra Island has been blamed on fires that occurred in 1919, 1921, 1922, 1924 and 1925. But this is only partly true. Logging began in the 1880s and by 1925 much of Quadra’s old forest had been logged. That history in no way excuses continued logging of the remaining old forest. Instead, the critically low level of old forest should have guided the Ministry of Forests to more urgently consider the need to protect all that remains.
    [6] Unfortunately, the cutting of productive old forest continues. This loss is occurring for two main reasons:
    [7] First, because of the absence of landscape level planning—promised 23 years ago but never delivered—no legal old growth management areas (OGMAs) have been established on the approximately 11,000-hectare Quadra Island portion of TFL 47.
    [8] Second, 11 different woodlot licences were located on Quadra Island on 5,470 hectares of Special Management Zone 19 ( (SMZ 19) after the zone had been established by the Vancouver Island Land Use Plan (VILUP) in 2000. Since the Forest and Range Practices Act does not require woodlot licensees to meet the seral stage objectives established by the VILUP, old forest can be legally logged within those 5,470 hectares unless a licensee’s woodlot plan stipulates that it won’t log old forest.
    [9] One of the errors made in the report mentioned above at [1] reflects an assumption made by Forest Practices Board investigators that Quadra Island had undergone landscape level planning, and that management of old forest on the island was governed by a landscape level plan.
    [10] The Board’s report included a map of the “Quadra Landscape Unit” and this statement: “For the Quadra landscape unit (Figure 1), which covers the woodlot licence and tree farm licence 47, this means that the holder of the tree farm licence addresses the legal requirements to manage old-growth forests under their forest stewardship plan. Again, the woodlot licensee is exempt from following government’s objectives for the retention of old-growth forests.”
    [11] The assumption by the Forest Practices Board that landscape level planning had occurred is understandable. Landscape level planning for Quadra Island was given “high priority” in 2000 when the VILUP designated approximately 15,800 hectares of the island as SMZ 19. But, for unknown reasons, that planning never occurred. The “Quadra Landscape Unit” exists only as a line drawn around the island on a map.
    [12] We would also note that the Forest Practices Board, in carrying out its investigation, may have been under the impression that Quadra Island hosted only one Woodlot Licence tenure. The report mentioned only one. But, as noted above, there are 11, each of which, as the Board put it, “is exempt from following government’s objectives for the retention of old-growth forests.”
    [13] Although woodlots are required to reserve 8 percent of their area as “wildlife tree retention areas”, in practice this requirement produces little certainty that remaining areas of old forest will be protected, as we will show below.
    [14] Moreover, in the absence of landscape level planning, TimberWest, the tenure holder of TFL 47, has defaulted to the position that old forest in its portion of SMZ 19 is subject only to the 2004 Order Establishing Provincial Non-Spatial Old Growth Objectives. That order puts the old forest retention target for the CWH biogeoclimatic zone, natural disturbance interval type 2 (Quadra Island) at “>9 percent”. TimberWest handles remaining concentrations of old trees by leaving trees older than 250 years of age but logging all the younger trees between them (more on this later).
    [15] When the result in [13] is combined with the result in [14], a very different outcome for SMZ 19 than was intended by the VILUP has been produced. Based on aerial and ground surveys of old forest conducted by the Discovery Islands Forest Conservation Project over the past five years, we estimate the current extent of old forest to be at about 4 percent of the Crown forested area, and falling. This is highly problematic for conservation of biodiversity on Quadra Island and represents a failure of government to abide by its own land use planning.
    [16] In a 2021 Forest Practices Board investigation of a complaint about logging in Special Management Zone 13 in the Nahmint Valley, the Board criticized BC Timber Sales for failing to meet the obligations imposed by the VILUP. In that case, the Board stated: “The public needs to be confident that objectives established in land use plans will actually be carried through and implemented in forestry operations.”
    [17] Below, we will first outline what the intended outcome for old forest in SMZ 19 was. We will then address the question of whether TimberWest has advanced a credible strategy for old forest management in SMZ 19 and whether it is carrying through with that strategy. Finally, we will provide detailed examples of how old forest loss is occurring in both Block 12 of TFL 47 and two of the woodlots in SMZ 19.
     
    What outcome was intended for seral stage distribution in SMZ 19?
    [18] First, the intended management objective for distribution of old seral stage forest was to be at least 9 percent of the SMZ’s “contributing area”. The Vancouver Island Summary Land Use Plan defined that as the “timber harvesting land base” (THLB). To the extent that there wasn’t enough old forest to meet that target, mature forest suitable for old forest recruitment would need to be identified. Second, the intended objective for mature seral stage distribution in SMZ 19 was for at least 25 percent of the zone’s “contributing area” (again, defined as the “timber harvesting land base”) to be “mature”.
    [19] How were these intentions to be carried out in practice? First, the VILUP was to be followed by landscape level planning. As you know, landscape level planning was designed to establish spatially-designated old growth management areas (legal OGMAs) and non-legal OGMAs that could be located in protected areas. The provincial government created legal OGMAs for the purpose of conserving the biological diversity associated with old forests.
    [20] If landscape level planning had been conducted for Quadra Island, legal OGMAs and non-legal OGMAs would have been established for the entire Crown forested land base on the island. We estimate there would be approximately 1280 hectares of legal OGMAs associated with SMZ 19, and about 160 hectares of legal OGMAs associated with the area of Crown forest not in SMZ 19. Instead, no legal OGMAs have been created and all remaining old forest and concentrations of veteran trees not in protected areas are at risk of being logged or being exposed to logging.
    [21] It should be noted that the 8 to 9 percent targets for old forest mentioned throughout this submission are from 1990s-era forest management understanding. Those targets should be much higher now given the new science-based understanding about stand-replacing disturbance intervals for Quadra Island. In 2000, that interval was thought to be about 200 years. It is now estimated to be about 700 years. To keep the risk of biodiversity loss due to logging at a “low” level, at least 49 percent of the Crown forest base on Quadra Island should be old forest. So the 8 to 9 percent old forest targets mentioned throughout this submission are wholly inadequate to keep the risk of biodiversity loss to a manageable level.
     
    How will the seral stage targets for SMZ 19 be met?
    [22] In this section we will examine the question of whether TimberWest has responsibility for meeting the seral stage targets for all of SMZ 19. We include targets for both old and mature forest in this discussion since the VILUP implied targets for both of these seral stages in SMZ 19.
    [23] For clarity, we will note that the Vancouver Island Summary Land Use Plan described SMZ 19 as the land that “comprises all provincial Crown forest on Quadra Island outside of protected areas, excluding the northern portion (north of Small Inlet), as well as the southern, mostly private portion” (emphasis added).
    [24] Clearly, it was the intention of the planners that the protected areas on Quadra Island could not be used to meet the seral stage objectives for SMZ 19. Let’s briefly review what those objectives were, and where they came from.
    [25] The biodiversity emphasis option chosen for SMZ 19 by the Vancouver Island Summary Land Use Plan was “Intermediate.” According to the provincial Biodiversity Guidebook current at the time VILUP was ordered, the recommended target for distribution of seral stages for the “Intermediate” biodiversity emphasis option in Natural Disturbance Type 2 areas (Quadra Island) was as follows: Mature + old: >34 percent; Old: >9 percent; Mature: >25 percent.
    [26] When SMZ 19 was created in 2000, approximately 15,800 hectares of Quadra Island were in the zone and subject to the seral stage targets described above. The areal extent of the zone has not changed.
    [27] Did locating eleven woodlots in SMZ 19 mean that the targets for old and mature forest are no longer applicable? If that was the case, years of careful land use planning would have been undone by the ministry’s own ill-considered action of establishing woodlots in SMZ 19 before completing landscape level planning. We don’t believe anyone should settle for that outcome. Instead, we believe the responsibility for meeting the overall targets for the 15,800-hectare SMZ 19 has shifted, or should be shifted, to that portion of TimberWest’s TFL 47 that’s in the SMZ.
    [28] As noted above at [10], the Forest Practices Board found that “the holder of the tree farm licence addresses the legal requirements to manage old-growth forests under their forest stewardship plan.” The Board seemed to be implying that TimberWest had the sole responsibility for meeting the seral stage objectives set for SMZ 19 (and, indeed, the entire “Quadra landscape unit”).
    [29] Even if the Board did not mean that TimberWest has such a legal responsibility, Section 9 (Proportional Objectives) of the Forest and Range Practices Act gives the Minister of Forests the power to “establish targets, in specified proportions between or among the holders of forest stewardship plans, for sharing the responsibility to obtain results consistent with objectives set by government.”
    [30] In this case, to ensure the overall objectives for seral stage distribution in SMZ 19 are met, TimberWest should be given 100 percent of the share of “responsibility to obtain results consistent with objectives set by government.”
    [31] Such an approach would ensure the intentions of land use planning were carried through by government, and would satisfy the public interest highlighted by the Board in the Nahmint SMZ 13 case, namely that: “The public needs to be confident that objectives established in land use plans will actually be carried through and implemented in forestry operations.”
    [32] This would have important implications for TimberWest’s operations in SMZ 19. The table below summarizes TimberWest’s own assessment of the current age class distribution in its portion of SMZ 19. Note that the total for the centre column is 7084 hectares.
    [33] Since old plus mature forest needs to cover at least 34 percent of the forested area of TFL 47’s portion of SMZ 19, about 2408 hectares needs to be older than 80 years of age. By TimberWest’s own estimate, 3060 hectares currently meet that requirement. That leaves TimberWest with a buffer of 652 hectares within which it can log.
     

     
    [34] If TimberWest is responsible for meeting the full SMZ 19 target for old forest, however, it must also incorporate a reserve to cover at least 9 percent of the 5470 hectares covered by woodlot tenures, which are not required to meet seral stage objectives. That would add an additional 492 hectares to TimberWest’s old forest responsibilities, and would further reduce the area within which TimberWest could log to 160 hectares.
    [35] The strategies for meeting seral stage objectives that TimberWest has included in its successive forest stewardship plans suggest that it is aware of its responsibility to cover the full seral stage distribution obligations that arise from objectives 1.A and 1.B set by the VILUP Higher Level Plan Order for SMZ 19.
    [36] For example, in its 2022 forest stewardship plan, TimberWest’s stated strategy for objective 1.A was: “In concert with other harvesting licence holders operating in the Special Management Zone, the holder of this FSP will ensure that planned development and harvesting activities will not result in the proportion of mature forest area dropping below 25% in the FDU [forest development unit].”
    [37] Why would TimberWest’s strategy for meeting its own mature seral stage target involve looking outside of its own TFL boundaries for help to ensure its “harvesting activities will not result in the proportion of mature forest area dropping below 25% in the FDU”?
    [38] Although the language seems a bit jumbled, the principle at work is clear enough. TimberWest is responsible for ensuring that the overall target for the mature seral stage in SMZ 19 does not fall below 25 percent. Therefore it can count the area of mature forest in the woodlots to meet its legal requirement.
    [39] But this same principle must also apply to the >9 percent old seral stage target for SMZ 19. And since old forest covers only about 4 percent of SMZ 19—well below the target of at least 9 percent—TimberWest is responsible for managing for the missing 5 percent of old seral stage forest, too.
    [40] This is, however, a moving target. If additional old forest is logged in the woodlots, TimberWest would be required to set aside even more of TFL 47 to manage for the old seral stage target.
    [41] The Forest Practices Board seems to agree with this premise. In an investigation about logging of old forest in a woodlot on Quadra Island, as noted above at [8], the Forest Practices Board found that “the holder of the tree farm licence addresses the legal requirements to manage old-growth forests under their forest stewardship plan.”
    [42] As in the case of acting “in concert with other harvesting licence holders operating in the Special Management Zone” with regards to mature seral stage targets, TimberWest should be acting in concert with the woodlots regarding meeting SMZ 19 targets for old forest.
    [43] There is no evidence in the current woodlot plans of the 11 woodlot licensees that there is any planning “in concert” with TimberWest. And, as we will show below, at least two of the woodlots are logging old forest. Both of these circumstances suggest that TimberWest is not following through with its limited strategy to meet the seral stage distribution objectives that flow from the VILUP.
     
    TimberWest is not following the recommended strategy for managing old forest set out in the VILUP
    [44] Although TimberWest has committed in its forest stewardship plans to not log old forest in its portion of SMZ 19, it has logged small patches of old forest. In those cases it leaves the trees that are greater than 250 years of age but cuts away all younger trees between the old trees. This is not the strategy outlined for SMZ 19 by the VILUP.
    [45] The recommended strategy for protecting old forest on Quadra Island, as stated in the Vancouver Island Summary Land Use Plan was this:
    Objective: General Biodiversity Conservation Management
    Strategies: to the extent that old seral forest retention will be required within the contributing land base portions of the landscape unit, such retention should be concentrated within the SMZ-portion of the landscape unit; maintain existing old forest in the zone, as well as second growth with high portion of veteran trees; manage to replace old forest in the long term (>150 years) in accordance with old seral targets for intermediate BEO; focus old seral replacement in CWHxm2, concentrated along riparian areas and, where possible, adjacent to existing old seral forest; recruit old seral habitat blocks with higher priority on forest interior conditions than on old seral connectors; maintain harvest opportunity in second growth by identifying some old growth recruitment areas in early seral forest; recruit mature forest in the mid (>50 years) term, building gradually towards a mature seral target of 25%; actively create mature and old seral forest attributes through suitable management strategies, such as variable density thinning or partial cutting silvicultural systems.
    [46] We interpret the stated strategy—“maintain existing old forest in the zone, as well as second growth with high portion of veteran trees”—as meaning that concentrations of veteran trees should be left undisturbed.
    [47] However, TimberWest is not abiding by that strategy. Below are photographs of three such instances in TFL 47 in the special management zone.
    [48] We have been advised by forest ecologist Rachel Holt and forester Herb Hammond that such a practice does little to conserve the biodiversity associated with old forest, which is the basis for the above recommended strategy outlined in VILUP for SMZ 19.
    Three photos below: TimberWest leaves trees older than 250 years but logs everything around them.

     

     

     
    TimberWest’s strategy regarding Objective A.1.(b) is ineffective
    [49] Objective A. 1. (b) of the VILUP Higher Level Plan Order (HLPO) states: “Sustain forest ecosystem structure and function in SMZs, by… retaining within cutblocks, structural forest attributes and elements with important biodiversity functions…”
    [50] In its current forest stewardship plan, TimberWest states that it will comply with Objective A. 1. (b) of the VILUP HLPO by: “(1) Retaining wildlife trees as specified in Section 66 of the Forest Planning and Practices Regulation (FPPR)”.
    [51] Section 66 of FPPR states, in part: “(1) If an agreement holder completes harvesting in one or more cutblocks during any 12 month period beginning on April 1 of any calendar year, the holder must ensure that, at the end of that 12 month period, the total area covered by wildlife tree retention areas that relate to the cutblocks is a minimum of 7% of the total area of the cutblocks.”
    [52] TimberWest’s strategy for “retaining within cutblocks, structural forest attributes and elements with important biodiversity functions…” utilizes a “group retention” approach whereby the full annual 7 percent retention area is accounted for as an area, or areas, of unlogged forest somewhere on Quadra Island. This has two problems.
    [53] First, this approach defeats the intention of Objective A. 1. (b) of the VILUP HLPO. The order specifically uses the language “retaining within cutblocks…” and a footnote elaborates : “Within cutblocks: generally means non-contiguous with cutblock boundaries”. We take that to mean that retention areas should be like “islands” within cutblocks. Yet none of TimberWest’s wildlife tree retention areas occur within cutblocks.
    [54] Second, mapping of these retention areas on Quadra Island shows that they often end up being logged later or do not contain mature trees (see image below). Or inoperable areas where logging wouldn’t have occurred in any case are designated as stand-in wildlife tree retention areas. Neither of these approaches helps to “sustain forest ecosystem structure and function…within cutblocks…”
     

    Some of TimberWest’s mapped “wildlife tree retention areas” on Quadra Island (areas outlined in green with oblique lines through them) are areas that have been clearcut or do not contain mature trees (marked above with red dots). See more wildlife tree retention areas on Quadra here.
     
    [55] Moreover, Section 67 of FPPR states: “An agreement holder must not harvest timber from a wildlife tree retention area unless the trees on the net area to be reforested of the cutblock to which the wildlife tree retention area relates have developed attributes that are consistent with a mature seral condition.”
    [56] As noted above, in those cases where TimberWest leaves veteran Douglas fir trees as wildlife trees, it immediately removes the younger trees around them from the potential wildlife tree retention area, contrary to Section 67 of FPPR. The photos below are typical of TimberWest cutblocks on Quadra. All three are in the Long Lake area.
     

     

     

     
    Logging of old forest in the woodlots
    [57] Between 2003 and 2011, after SMZ 19 had been created, nine new woodlots were established on Quadra Island in the special management zone, and the two pre-existing woodlots were expanded into the zone.
    [58] The rational course of events, after the establishment of SMZ 19, would have been to conduct landscape level planning, establish legal OGMAs—and only then establish Woodlot Licences.
    [59] Because of the differences in requirements for old forest retention in legal OGMAs as compared with Woodlot Licence tenures, there was a dramatic decline in the level of protection of remaining old forest in the area occupied by the woodlots.
    [60] While 18 percent of Quadra Island is in provincial parks, only a fraction of the remaining old forest is in those protected areas. And since no legal OGMAs have been created, much of the remaining old forest—which is mostly in TFL 47 and four of the 11 woodlots—is at risk. This worsens an already high risk of biodiversity loss.
    [61] One consequence of the Ministry of Forests’ lack of coordinated planning for old forest on Quadra Island is that it is still being logged. The Forest Practices Board’s 2022 investigation report involving Woodlot 2031 illustrates how and why this is happening: Ministry of Forests personnel have too few resources to be able to assess what’s on the ground, plan for conservation and then monitor the state of old forest on Quadra, and some woodlot tenure holders are taking advantage of that lack of attention.
    [62] In the text below, we will address the particulars of two different cases in which old forest has being logged on Quadra Island in spite of the high risk of biodiversity loss. Each case helps to illustrate the problems that have arisen due to the lack of implementation of landscape level planning.
     
    Logging of old forest in Woodlot 2031
    [63] With little or no resources for the Ministry of Forests to monitor what is being logged on woodlots, some Quadra Island woodlot tenure-holders are taking advantage of the situation and are logging old forest. Woodlot 2031 was established in 2011 and lies entirely within SMZ 19. The tenure is held by Okisollo Resources Ltd. Below is our account of logging of old forest in 2019 in Woodlot 2031:
    [64] The Discovery Islands Forest Conservation Project visited Hummingbird Lake with a drone in July 2018, one year before the logging took place. We returned again in July 2019 while the logging was taking place and a third time in June of 2020, after logging had been completed.
     

    Hummingbird Lake and surrounding forest in July 2018, as seen from a drone flying east.
     

    This photo taken in 2018 shows the approximate area of old forest (left side of photo) north of Hummingbird Lake that was logged in 2019.
     
    [65] On each visit, we photographed the area, both on the ground and using a drone for aerial views of the forest and lake. Over the past five years the Discovery Islands Forest Conservation Project has been surveying forests at dozens of locations on Quadra Island where it seems possible or likely that old-growth forest could be logged before it has been properly identified and reserved.
    [66] On our 2018 visit, we could find no stumps or other evidence that would indicate the forest on the north side of Hummingbird Lake had ever been logged. The BC government’s record of road building in the province shows the north side of Hummingbird Lake had never been roaded before Okisollo Resources began logging in 2014. A forest fire in 1925 had lightly burned through the area, leaving the old trees intact. About 5 years after that fire, hemlock began to grow back—naturally—in the shade of the remaining big trees.
    [67] All the evidence suggested that the north side of Hummingbird Lake was rare primary forest with big, old trees growing at a density that was at least equal to any other old forest we have surveyed on Quadra Island.
    [68] When we visited the logging operation in July 2019, roads had been built. There was a completed cutblock near the southwest corner of the lake where four old-growth Douglas firs still stood. Ten full-length tree trunks were lying beside the road into the second cutblock—all old-growth Douglas firs that had been removed to make way for the road.
     

    The new logging road built along the north side of Hummingbird Lake in July 2019.
     
    [69] In a second cutblock on the north side of the lake, smaller-diameter hemlock and fir were in the process of being machine-felled (photo below). There were numerous large, old-growth Douglas firs and a few old cedars standing amongst the younger trees. It was unclear whether the dozens of old firs would be left standing or be felled. We had never seen so many big trees in the middle of a Quadra Island logging operation.
     

     
    Above: Okisollo Resources’ logging of old forest north of Hummingbird Lake in July 2019.
    Below: The same view in 2020.
     

     
    [70] The project revisited the area in June 2020. Logging had been completed in the cutblock on the north side of Hummingbird Lake. Most of the old trees had been felled in both cutblocks. Along an edge of the northern cutblock, about 15 old vets still stood, testimony to the density of the grove that had just been cut.
     

    In 2020, a line of old-growth Douglas fir vets was left along the edge of Okisollo Resource’s clearcut on the north side of Hummingbird Lake.
     
    [71] We photographed the northern block where several large-diameter logs had been left beside the road. The growth rings of a recently live tree showed it had been 370 years old when it was cut. Several dead snags had also been cut and were stacked or scattered across the cutblock.
     

     
    Above: This Douglas fir had 370 annual growth rings.
    Below: A stump showed approximately 380 years of growth.
     

     
    [72] To determine how many old firs had been logged in the northern cutblock, the project searched for satellite images taken in mid-August 2019. The image below shows logging in progress in the second cutblock on August 15, 2019. At least 50 old-growth trees remained standing on this day. The smaller-diameter hemlock had all been cut, stacked and were being removed.
     

     
    [73] The satellite image below was taken a few weeks later. Of the 50 old-growth trees that had been standing in the cutblock (see photo above), only 15 remained.
     

     
    [74] The project’s photographs and notes, when combined with the satellite images, show that of approximately 64 old trees in the two cutblocks and the road, at least 49 were cut. The 3-hectare cutblock north of the lake had contained at least 55 live, old-growth trees and an unknown number of standing snags.
    [75] In 2021 a Quadra Island resident filed a complaint about this logging with the Compliance & Enforcement Branch. A complaint was then filed with the Forest Practices Board. The Forest Practices Board found that 10 old trees had been cut and “the old trees were not set aside from logging. The licensee removed the trees to build a road and for safety reasons.”
    [76] In response to questions sent by this project to Chantal Blumel, a registered professional forester and a principal of Okisollo Resources, Ms Blumel stated: “We removed some of the old trees during the harvest of the second growth stands, for safety and access purposes.”
    [77] There is no dispute that some old trees were removed for building logging roads. Above, we estimated that at least 10 had been removed because they were in the way of the road. But was “safety” actually an issue for the other 35-40 old trees that were logged? The Occupational Health and Safety Regulation of BC’s Workers Compensation Act states: “If work in a forestry operation will expose a worker to a dangerous tree, the tree must be removed.”
    [78] At the cutblock north of Hummingbird Lake, all of the younger, smaller-diameter trees had already been removed several days before approximately 35 larger old-growth Douglas firs were felled. That can be seen in the satellite images. Those old trees did not have to be logged for either “safety” or “access” purposes.
    [79] The original complaint by a Quadra Island resident was based on the belief that the 2001 Vancouver Island Land Use Plan prohibited logging of old forest in SMZ 19 on Quadra Island. In fact, it had been, until Woodlot 2031 was established in 2011.
    [80] Although section 52 (1) c of the Woodlot Planning and Practices Regulation requires woodlot license tenures to designate, in their woodlot plans, 8 percent of the area of the woodlot as “wildlife tree retention areas”, this designation does not have to be applied to actual areas of old forest. But in the case of Woodlot 2031, which contains several areas of old forest and concentrations of veteran trees, the licensee made written promises in its woodlot plan to retain existing old-growth stands.
    [81] The wording in the licensee’s woodlot plan regarding existing old forest had apparently made a strong impression on Forest Practices Board investigators.
    [82] The Board’s report stated: “In their [woodlot plan], they committed to setting aside all of the existing old-growth stands by designating them as wildlife tree retention areas.” In another section, the report stated, “the licensee chose to set aside the existing old-growth stands to provide wildlife habitat and conserve biodiversity even though it did not have to. The licensee did this in consideration of the community’s desire to protect old-growth forests on Quadra Island.” In the “Conclusions” section, the report stated “the woodlot licensee chose to set aside all of the existing old-growth forests because they recognized the community’s desire to protect the remaining old-growth forests on Quadra Island.”
    [83] The Board could have been referring to the section in the licensee’s legally binding woodlot plan on “Wildlife Tree Retention Strategy”, which stated: “The wildlife tree retention strategy for woodlot licence W2031 involves: retaining the existing old growth stands (>250 years) and recruiting around them to enlarge existing and future old growth forests…”
    [84] Or the Board might have been referring to the section in the legally binding woodlot plan that addressed “Areas where timber harvesting will be avoided”. That section contained this statement: “Retaining the existing old growth forests is key to maintaining the biodiversity values of forests in the CWHxm biogeoclimatic subzone. Maintaining these reserves, and recruiting around them to enlarge existing and future old growth forests is one of the strategies to meet the biodiversity objectives set out in the VILUP for SMZ 19.”
    [85] Whichever part, or parts, of Okisollo Resource’s woodlot plan the Board was referring to, it is clear that the strategy specified in the woodlot plan to retain existing old growth stands, and the stated strategy on how the licensee would conserve biodiversity, convinced the Board that Okisollo Resources “committed to setting aside all of the existing old-growth stands by designating them as wildlife tree retention areas.”
    [86] We believe the Board understood the plain meaning of the statements made in Okisollo Resources’ legally-binding 2011 woodlot plan, and that this meaning was also communicated to the approving authority and the local community when Okisollo Resources’ plan was put out for public comment in 2011.
    [87] Section 21(1) of the Forest and Range Practices Act states: “The holder of a forest stewardship plan or a woodlot licence plan must ensure that the intended results specified in the plan are achieved and the strategies described in the plan are carried out.”
    [88] The possibility that the owners of Okisollo Resources were not fully aware of where old-growth forest in the woodlot existed when they created their legally binding 2011 woodlot plan cannot be allowed to undo the commitments they made in writing to retain existing old forest. In any case, the licensee stated that even “scattered small patches of existing old forest” not specifically identified in the plan would be retained. We believe this commitment would apply to the area of old forest logged in 2019.
    [89] We are asking the Forest Practices Board to investigate Woodlot 2031’s logging of old forest in 2019, as described above, and to explain why that logging did not contravene the results and strategies stipulated in the tenure’s legally binding woodlot plan.
     
    Logging of old forest in Woodlot 2032
    [90] Woodlot 2032 was established in 2011 and lies entirely within SMZ 19. The tenure is held by Younger Brothers Holdings.
    [91] In 2019, Younger Brothers Holdings built logging roads through two areas of old forest the company had mapped in its 2011 woodlot plan as “old-growth” reserves. This logging would have been prohibited without a properly made amendment to the plan. The approximate boundaries of the reserves are shown in the image below:
     

     
    [92] To ascertain whether the Ministry of Forests had determined whether such an amendment to the legally binding 2011 woodlot plan had been properly made, an FOI was filed in late 2021 by the Discovery Islands Forest Conservation Project. The FOI requested all communications between the Ministry of Forests and the principals of Woodlot 2032—including the woodlot’s registered professional forester—back to the beginning of January 2017. The records released to us suggested—by the absence of any records relating to an amendment of the woodlot plan—that there had been no written communication between the woodlot tenure holders and the ministry about a major amendment of the woodlot plan.
    [93] Asked directly about this change, Younger Brothers’ forester provided the Discovery Islands Forest Conservation Project with a letter he told us was sent to the Campbell River District Manager in February 2019. The letter described changes to the 2011 plan that involved removing reserves of old forest above Discovery Passage (the areas outlined in green in the image above) and replacing those areas with an area of younger, sparser forest running up to the top of Darkwater Mountain (the area outlined in green in the image below). In the amendment, the replacement area and a pre-existing logging road were named the “Manzanita Mountain Recreation Area” and an old logging road was named the “Manzanita Mountain Trail.”
     

     
    [94] The letter stated that the new reserve area was “created to provide recreational opportunities (hiking trail established) and to provide protection for the rare Manzanita plant (arctostaphylos columbiana) which is observed in the area.”
    [95] Access to Darkwater Mountain (the name for the mountain used by Cape Mudge Forestry, which is operated by We Wai Kai First Nation) by old logging roads predates development of Woodlot 2032. Hairy Manzanita is not “rare.” It can be found in many high areas on Quadra Island and is NOT on the BC Red Blue List.
    [96] As mentioned above, the letter provided to us by Younger Brothers’ forester was not included by the Campbell River office of the Ministry of Forests in the record of communications between the Ministry of Forests and Younger Brothers that were obtained by FOI. Recently, the Discovery Islands Forest Conservation Project asked the Campbell River District Manager for an explanation for why the amendment letter had not been included in the FOI release. Subsequently, the District Stewardship Forester indicated to us that this letter could not be found at the District office and there was no record of a response from the District office to Younger Brother’s letter of amendment. Later, District Manager Lesley Fettes sent us an email which stated, in part: “I encourage you to report your concerns by making a ‘Report of Natural Resource Violation’ using the online form. This is government’s process to have potential non-compliances investigated.”
    [97] When we asked Younger Brothers’ forester for a copy of the email to the District notifying them of the 2019 amendment, the forester explained, “As this amendment was 3 years ago, I no longer have the email.”
    [98] When asked about the switching of reserves from an area of old forest to an area of younger trees, Younger Brothers’ forester stated that “Minor revisions to retention strategies are acceptable providing the total area under reserve is not reduced.”
    [99] But the Woodlot Licence Planning and Practices Regulation states that an amendment is only considered “minor” if it does not “decrease the nature or quality of wildlife trees or wildlife tree retention areas.” In this case, the amendment replaced areas of old forest containing some large trees with an area of mostly younger, sparser forest at the top of a rocky, dry hill where Hairy Manzanita was growing. We contend that this change constituted a decrease in the nature and quality of both individual wildlife trees and the wildlife retention area as a whole. Yet there is no record in the Campbell River District office that Younger Brothers’ forester even sought approval for this amendment. In other words, the amendment appears to be “wrongly made”.
     

    A view of the forest in one of the two 2011 wildlife tree retention areas that had roads built through them in 2019. This photo was taken from the road.
     
    [100] Under Section 22 (“Minor amendments wrongly made”) of the Woodlot Licence Planning and Practices Regulation, the forests minister may “declare the amendment to be without effect” and may “require the holder to suspend operations that are not authorized in the absence of the amendment”.
    [101] This is a serious matter. Under Section 52 (2) (“Wildlife tree retention”) of the Woodlot Licence Planning and Practices Regulation, “A woodlot licence holder must not cut, damage or remove wildlife trees or trees within a wildlife tree retention area except in accordance with the wildlife tree retention strategy prepared under section 11”.
    [102] Under Section 11 (c) (d) (e) (“Wildlife tree retention strategy required”) of the Woodlot Licence Planning and Practices Regulation, the strategy must include “the conditions under which individual wildlife trees may be removed” and “the conditions under which trees may be removed from within a wildlife tree retention area” and “how trees removed…will be replaced.” None of Woodlot 2032’s woodlot plans have included these required elements for its wildlife tree retention strategy.
    [103] Younger Brothers Holdings, by building roads through two wildlife tree retention areas that it had mapped in its approved 2011 woodlot plan (as mentioned above in [96]), has cut and damaged trees in what had been wildlife tree retention areas. Did the swapping of the areas of old forest with an area that Younger Brothers had not previously mapped as old forest constitute a “wrongly made” amendment?
    [104] Again, this is a serious matter. Under Section 90 (“Offences”) of the Woodlot Licence Planning and Practices Regulation, contravening Section 52 is “an offence and is liable, on conviction, to a fine not exceeding $500,000 or to imprisonment for not more than 2 years or to both”.
    [105] These circumstances illustrate how, over time, a woodlot tenure holder can unilaterally “amend” their woodlot plan and remove areas that they had previously established as an “old-growth reserve”. Without a motivated watchdog looking out for the public interest, no questions would be asked and stands of old forest—which are commercially more valuable—would be logged or degraded.
    [106] As per the district manager’s suggestion, the Discovery Islands Forest Conservation Project has filed a complaint with the Compliance and Enforcement Branch.
    [107] This woodlot contains one of the largest areas (16.5 hectares) of primary forest remaining on Quadra Island, including one of the old-forest reserves the tenure holder’s 2019 amendment removed from its wildlife tree retention reserve. According to the licensee’s draft plan, logging in this area is imminent (see photo on next page).
    [108] The tenure holder of Woodlot 2032 has committed to not cut any trees older than 250 years of age, as has become the practice on Quadra Island, but all other trees between those older trees can be logged. As mentioned above, we have been advised by a forest ecologist and a forester that this practice does not protect biodiversity.
    [109] Moreover, the Woodlot Planning and Practices Regulation does not allow any logging to occur in wildlife tree patches, so asserting that these patches only need trees that are 250 years and older to be viable at supporting species associated with old forest is not supported by the legislation applicable to woodlots.
     

    Foreground: Part of the area of old, mainly primary forest southwest of Darkwater Lake, which contains large, old trees—now a very rare ecosystem on Quadra Island. The small reserves in this area that the 2011 plan created have now been moved to the top of Darkwater Mountain (in background).
     
    [110] We request that the Forest Practices Board investigate whether Woodlot 2032’s amendment was properly made or not (we have filed a complaint with Compliance and Enforcement but have not heard from them as of April 4, 2023). We are also providing these details to assist the Board in understanding the ways by which remaining old forest on Quadra Island, already at a critically low level, will continue to disappear unless changes are made. Without change, antagonism in the community over this issue will continue to grow. As you know, land use planning and creation of SMZ 19 was intended to end such conflict.
    [111] If TimberWest does have the sole responsibility to ensure the full targets for old forest in SMZ 19 are met, perhaps a more effective arrangement for conserving old forest on Quadra Island would be for TimberWest to cooperate with the woodlots on a commercial basis that compensates the woodlots with work or wood in exchange for conserving old forest on their woodlots. If that’s not possible, what other solutions does the Board recommend?
     
    Conclusion
    [112] The extent of old forest on Quadra Island is currently at about 4 percent. TimberWest puts that number at 3.8 percent for that part of its tenure that is in SMZ 19. This situation poses what forest ecologists Dr. Karen Price and Dr. Rachel Holt and others have termed “high risk” for loss of ecological function, biodiversity and resilience.
    [113] The Old Growth Strategic Review Panel has called for an immediate pause to logging of old forest in landscape units with less than 10 percent of old forest remaining. (Although the “Quadra Landscape Unit” has no plan, its areal extent has been defined.)
    [114] Throughout BC, mapping of old-growth deferral areas has depended on the use of the Ministry of Forests’ Vegetation Resources Inventory (VRI). That mapping is notoriously inaccurate for locating actual old forest, and those deferrals on Quadra Island that have been mapped by the Technical Advisory Panel do not accurately reflect where old forest is on Quadra Island.
    [115] The Discovery Islands Forest Conservation Project has identified 176 fragments of old forest and concentrations of veteran trees that amount to approximately 655 hectares in areal extent. We are in the final stages of confirming these on the ground, and our mapping is ongoing
    [116] Given the circumstances outlined in this submission, we request that the Forest Practices Board determine the most practical approach to conserving the remaining old forest on Quadra Island given the existing legislation, regulations and land use planning.
     
    The Discovery Islands Forest Conservation Project is conducting its research on the unceded traditional territories of the Wei Wai Kai First Nation, Kwiakah First Nation, Homalco First Nation, Klahoose First Nation, the K’ómoks First Nation and the traditional territory of the Tla’amin Nation. It is our intention to work with these nations to increase the general level of settler knowledge about the land and our connection to it.
    Ralph Keller
    To:
    District Manager Leslie Fettes,
    Campbell River Forest District
    Dogwood St. 
    Campbell River BC  
    February 5, 2023
    Re: Younger Brothers Quadra Island Woodlot 2031 Woodlot Plan Renewal 
    Dear Ms. Fettes,
    It has been brought to our attention that Younger Brothers’ Woodlot 2031 on Quadra Island is renewing its license and that it plans to “trade” a section of old forest previously committed to protection for a section of forest that appears to be much younger, and which may have been in part, previously logged. Further, the new proposed forest reserve appears to be located on a drier rockier mountain side with lower ecological values.
    This proposed new site is dominated by a drier impoverished forest, not a suitable replacement for the original reserve. Further, if the objective is to protect Manzanita, according to the BC Conservation Data Centre: “This species is reasonably common within its range and not very threatened.” One reason Manzanita isn’t very threatened is because it is typically found on very dry sites with poor timber quality and seldom logged.
    As a citizen of BC, I am offended by this and other forest companies who claim to protect biological diversity by placing reserves on dry, steep mountain slopes instead of preserving wetter low elevation sites with high ecological values. If satellite imagery is correct, much of the proposed site contains trees of low timber value. This trade appears to be more about profit than protecting biological diversity.
    According to Cop 15, there is a global biological diversity crisis here and around the world.  If the government is serious about protecting biologically rich forests in BC, it needs to stop protecting steep mountain sides and focus on wetter, rich sites that are able to host a greater diversity of species. I’m sure you know there is a serious shortage of protected low elevation old forest sites along coastal BC.
    Finally, as owners of a Quadra Island wilderness lodge who have added millions of dollars in revenue to the local economy and employ 10 people full time seasonally, we are tired of being treated as voiceless bystanders while the forest industry runs roughshod over the landscape we depend on to survive. The original mandate for the BC Woodlot program was for small local licensees to work with surrounding communities to ensure local recreational, economic and ecological values were considered in forest management. I think many woodlot licensees have forgotten this. I believe it is your job to remind them of these obligations.   
    Please disallow this misrepresented forest swap by the owners of Woodlot 2031.  
     Sincerely,
    Ralph, Lannie & Albert Keller 
    Discovery Islands Lodge & Coast Mountain Expeditions
    Bonnie Brownstein
    Dear Dave Younger, John Marlow and District Manager Lesley Fettes:
    I live on Quadra Island and am writing on behalf of the Executive Committee of Sierra Quadra. This is my comment regarding the application for approval of a new Woodlot Licence Plan (WLP) for Woodlot Licence W2032. From what I have read, this application should not be accepted as it stands, but should be amended. We are actively hoping to avoid polarization because Dave and John are upstanding citizens of Quadra and we want an outcome that both protects old forest and supports Dave in making a living from his woodlot. 
    As you know, the 1925 fire that burned much of the forests on Quadra did not touch the area that is now Woodlot Licence W2032. For this reason there is genuine old forest left there worthy of protection.
    Let me summarize my concerns regarding old forest in Woodlot 2032:
    1. There are about 109 hectares of rare old forest (CWHxm2) remaining on the woodlot. The proposed plan shows only 20.5 hectares being in an “old forest reserve.” The initial plan (2011) showed 56 hectares of old forest reserves. Because the occurrence of old forest in this biogeoclimatic zone variant is now rare (on Quadra, but also in the entire BEC zone), all 109 hectares should be reserved as old forest. Instead, the plan would allow logging any tree younger than 250 years in 88.5 hectares of old forest (109-20.5 = 88.5). That logging would ruin that area of old forest as a biodiversity reserve.
    2. The Woodlot Planning and Practices Regulation does not allow any logging to occur in wildlife tree patches, so asserting that these patches only need trees that are 250 years and older to be viable at supporting wildlife is not supported by the legislation applicable to woodlots.
    3. Denuding the old forest of younger trees, standing snags and woody debris not only eliminates the potential of these areas of old forest for biodiversity conservation, it will make them more vulnerable to forest fire and wind throw
    4. The highly questionable amendment made in 2019 switched old forest reserves - long mapped as such by TimberWest - for an area that previously had not been mapped as old forest. Following that amendment, which was apparently not see by anyone at the Ministry of Forests (formerly FLNROD) Campbell River District office, logging of trees 250 years and older occurred when roads were built through two of these old forest reserves.
    5. Given this history, the pledge that no trees 250 years and older will be logged on the woodlot cannot be counted on. Based on the amendment made in 2019 which was not signed off on by the Campbell River District Office of FLNROD, it seems that your Woodlot Plan was unilaterally amended. Of course this is not usual procedure, but you can understand that trust will need to be rebuilt.
    I have read the proposal for the WLP for W2032 at www.quadraislandwoodlots.ca, plus all the correspondence about this in the Discovery Islander and the piece about this in the Discovery Islands Forest Conservation Project website https://www.discoveryislandsforestconservationproject.ca/
    I ask that Younger Brothers not be allowed to log the area of rare old primary forest that has already been flagged just west of Darkwater Lake. I also ask that Younger Brothers remove plans to log the area of W2032 that TimberWest previously mapped as “old forest” when it was part of TFL 47. I request that all other areas of remaining old forest in Woodlot 2032 be carefully identified, mapped and set aside from any plans for logging. This plan should not be approved until all these concerns have been addressed.
    Yours Sincerely,
    Bonnie Brownstein for Sierra Quadra
    David Broadland
    The Discovery Islands Forest Conservation Project submits the following observations about—and objections to—the renewal of Woodlot Licence 2032 and the proposed Woodlot Plan:
     
    A. The tenure holder appears to have wrongly amended its legally binding 2011 Woodlot Plan in 2019 and the Ministry of Forests has no written record of the amendment.
    (1) In 2019, Younger Brothers Holdings built logging roads through two areas of old forest the company had mapped in its 2011 Woodlot Plan as “old-growth reserves” in Woodlot 2032. This logging would have been prohibited without an approved amendment to the plan. The approximate boundaries of the reserves are shown as green lines in the image below:
     

    Old-growth reserves (outlined in green), established by the original 2011 Woodlot Plan, had roads built through them in 2019.
     
    (2) To determine whether the Ministry of Forests had given permission to Younger Brothers for this apparent amendment to the legally-binding 2011 Woodlot Plan, and if so, why, an FOI was filed in late 2021 by the Discovery Islands Forest Conservation Project. The FOI requested all communications between the Ministry of Forests and the principals of Woodlot 2032—including the woodlot’s registered professional forester—back to the beginning of January 2017. The records released to us suggested—by the absence of any records relating to an amendment of the Woodlot Plan—that there had been no written communication between the woodlot tenure holders and the ministry about an amendment of the Woodlot Plan.
    (3) Asked directly about this change, Younger Brothers’ forester recently provided the Discovery Islands Forest Conservation Project with a letter apparently sent to the Campbell River District Manager in February 2019. The letter described changes to the 2011 plan that involved removing reserves of old forest above Discovery Passage (the areas outlined in green in the image above) and replacing those areas with an area of much younger, sparser forest running up to the top of Darkwater Mountain (the area outlined in green in the image below). Some of the replacement area appears to have been logged in the past. In the amendment, the replacement area and a pre-existing logging road were named the “Manzanita Mountain Recreation Area” and the old logging road was named the “Manzanita Mountain Trail.”
     

    The replacement area (outlined in green) on Darkwater Mountain is mainly young forest, some of which has been previously logged
     
    (4) The letter stated that the new reserve area was “created to provide recreational opportunities (hiking trail established) and to provide protection for the rare Manzanita plant (arctostaphylos columbiana) which is observed in the area.”
    (5) Access to Darkwater Mountain (the name for the mountain used by Cape Mudge Forestry, which is operated by We Wai Kai First Nation) by old logging roads predates development of Woodlot 2032. Hairy Manzanita is not “rare.” It can be found in many high areas on Quadra Island and is NOT on the BC Red Blue List.
    (6) As mentioned above, the letter provided to us by Younger Brothers’ forester was not included by the Campbell River office of the Ministry of Forests in the record of communications between the the Ministry of Forests and Younger Brothers that were obtained by FOI. Recently, the Discovery Islands Forest Conservation Project asked the Campbell River District Manager for an explanation for why the amendment letter had not been included in the FOI release. Subsequently, the District Stewardship Forester indicated to us that this letter could not be found at the District office and there was no record of a response from the District office to Younger Brother’s letter of amendment. Later, District Manager Lesley Fettes sent an email which stated, in part: “I encourage you to report your concerns by making a ‘Report of Natural Resource Violation’ using the online form. This is government’s process to have potential non-compliances investigated.”
    (7) Younger Brothers’ forester, when asked for an email showing that he had sent the amendment to the District office, stated by email, “As this amendment was 3 years ago, I no longer have the email.”
    (8) When asked about the switching of reserves from an area of old forest to an area of much younger trees, Younger Brothers’ forester stated that “Minor revisions to retention strategies are acceptable providing the total area under reserve is not reduced.” The replacement area is virtually the same size as the two areas of old forest it replaces.
    (9) But the Woodlot Licence Planning and Practices Regulation states, in effect, that an amendment is only considered “minor” if it does not “decrease the nature or quality of wildlife trees or wildlife tree retention areas.” In this case, the amendment replaced areas of old forest with an area of mostly younger, sparser forest that appears to have been previously logged. And there is no record in the Campbell River District office that Younger Brothers’ forester sought approval for this amendment. In other words, the amendment appears to be “wrongly made”.
     

    A view of the forest in one of the two 2011 wildlife tree retention areas that had roads built through them in 2019. This photo was taken from the road.
     
    (10) Under Section 22 (“Minor amendments wrongly made”) of the Woodlot Licence Planning and Practices Regulation, the forests minister may “declare the amendment to be without effect” and may “require the holder to suspend operations that are not authorized in the absence of the amendment”.
    (11) This is a serious matter. Under Section 52 (2) (“Wildlife tree retention”) of the Woodlot Licence Planning and Practices Regulation, “A woodlot licence holder must not cut, damage or remove wildlife trees or trees within a wildlife tree retention area except in accordance with the wildlife tree retention strategy prepared under section 11”.
    (12) Under Section 11 (c) (d) (e) (“Wildlife tree retention strategy required”) of the Woodlot Licence Planning and Practices Regulation, the strategy must include “the conditions under which individual wildlife trees may be removed” and “the conditions under which trees may be removed from within a wildlife tree retention area” and “how trees removed…will be replaced.” None of Woodlot 2032’s Woodlot Plans have included these required elements for its wildlife tree retention strategy.
    (13) Younger Brothers Holdings, by building roads through two wildlife tree retention areas that it had mapped in its approved 2011 Woodlot Plan (as mentioned above in (1)), has cut and damaged trees in what had been wildlife tree retention areas. Did the swapping of the areas of old forest with an area that Younger Brothers had not previously mapped as old forest constitute a “wrongly made” amendment?
    (14) Again, this is a serious matter. Under Section 90 (“Offences”) of the Woodlot Licence Planning and Practices Regulation, contravening Section 52 is “an offence and is liable, on conviction, to a fine not exceeding $500,000 or to imprisonment for not more than 2 years or to both”.
    (15) As the Campbell River District office of the Ministry of Forests may have been negligent in its duty to properly file documents and/or determine whether the 2019 amendment was properly or wrongly made, that office should be kept at arms length from any determination of what has occurred.
    (16) A complaint has been filed with the Forest Practices Board. Until this matter is fully investigated by the Board, the woodlot licence holder should not be permitted to resume operations.
     

    A portion of the area of old, mainly primary forest southwest of Darkwater Lake, which contains large, old trees—now a very rare ecosystem on Quadra Island—that would be open to logging if the proposed Woodlot Plan is approved. The small reserves in this area that the 2011 plan created have now been moved to the top of Darkwater Mountain (in the centre background). Note the new logging road in the lower left corner.
     
    B. In any case, the proposed Woodlot Plan would be a significant step backward in terms of protection of old forest on Quadra Island.
    (17) The initial Woodlot Plan that was approved in 2011 was criticized by the Quadra community because it did not fully protect old forest in the woodlot. Since 2011, our understanding of the need to protect all remaining old forest on Quadra Island has grown. Yet the proposed plan would provide even less protection.
    (18) The 2011 Woodlot Plan identified 56 hectares of “Old Forest Reserves.” The proposed plan now identifies only 20.5 hectares of “Old Forest Reserve”. The Discovery Islands Forest Conservation Project estimates (using drone videography, satellite imagery and on-the-ground confirmation) that there are at least 109 hectares of old forest in this woodlot. That means only 20 percent of the old forest is acknowledged in the “Old Forest Reserve”. The other 80 percent is either not acknowledged in the proposed plan or has been moved into areas newly identified as “Inoperable.”
    (19) “Operability” is at the discretion of the tenure holder. For the identified “Inoperable” reserves containing old forest, there would be nothing to constrain the tenure holder from deciding later that they are, in fact, operable, and then removing all trees younger than 250 years of age in those areas.
    (20) Moreover, several areas that had been mapped as old forest in the 2011 plan are no longer identified in any way. This includes 45 hectares of old forest to the southwest of Darkwater Lake on the slope down to Discovery Passage. It also includes 14 hectares of old forest on the western side of Darkwater Mountain.
    (21) In the 2011 plan, these areas were either old-growth reserves, or areas of old forest where the tenure holder could “modify” the old forest. Each of these had been identified in that plan.
    (22) In the 2011 plan, for the areas that were to be “modified”, all trees older than 250 years of age were to be retained—unless they posed a danger to worker safety as all the other trees in between the old trees were logged. Forest ecologist Rachel Holt and forester Herb Hammond have advised that his approach would completely defeat the purpose of protecting old forest, which is to conserve biodiversity. Old forest always consists of old trees and an understory of younger trees and plants, not just trees greater than 250 years of age.
    (23) Furthermore, as mentioned above at (11), under Section 52 (2) of the Woodlot Planning and Practices Regulation, no logging is allowed in wildlife tree patches, so asserting that logging old forest and leaving only the trees 250 years and older supports biodiversity conservation is not supported by the legislation applicable to woodlots.
    (24) In the nearby Sayward Landcape Unit, no logging—not even single-tree selection—is allowed in pockets of old forest reserved as Wildlife Tree Reserves.
    (25) The proposed plan would expose even more of the old forest that was clearly reserved in the original Woodlot Plan to this scheme of “modification”. This includes the 45 hectares of old forest to the southwest of Darkwater Lake on the slope down to Discovery Passage. It also includes the 14 hectares of old forest on the western side of Darkwater Mountain.
    (26) A 16.5-hectare area of primary old forest with big trees—a very rare ecosystem on Quadra Island—just southwest of Darkwater Lake, has no designation whatsoever. This area, along with the old forest north of Darkwater Lake, should be given the highest priority for preservation. Instead, a portion of it has been flagged for logging.
     

    The areas of old forest that would be open to logging southwest of Darkwater Lake contain many of Quadra Island’s largest and most ancient Douglas firs. The entire area escaped the 1925 fire.
     
    C. The remaining area of old forest on Quadra Island is well below the level required by the provisions of SMZ 19, and TimberWest has committed in its own forest stewardship plan to consult with woodlot tenure holders in SMZ 19 in order to meets its SMZ 19 obligations.
    (27) Woodlot 2032 is in the area of Quadra Island designated as Special Management Zone 19 by the Vancouver Island Land Use Plan.
    (28) The target for old forest over the entire area of SMZ 19 is “greater than 9 percent”.
    (29) The Discovery Islands Forest Conservation Project has established that there are approximately 590 hectares of old forest remaining in the approximately 15,800-hectare area of SMZ 19. That works out to 3.7 percent, far below the target of 9 percent, which itself is an outdated target based on 1990s-era forest management. More current science indicates this would need to be at least 49 percent for a “low risk” of biodiversity loss.
    (30) Although the 11 woodlots on Quadra don’t necessarily need to meet government objectives for seral stage distribution, TimberWest does. It is legally responsible for ensuring the full 9 percent target for old forest in SMZ 19 is met. To meets its legal responsibility, TimberWest has made a commitment in its forest stewardship plan that it will consult with the woodlot tenure holders to ensure that the seral stage distribution target for SMZ 19 is met.
    (31) If TimberWest has consulted with Younger Brothers Holdings in an effort to conserve all remaining old forest, for example, there is no evidence of this in Younger Brothers’ proposed Woodlot Plan.
    (32) The Ministry of Forests is responsible for ensuring that the commitments TimberWest has undertaken in its forest stewardship plan are carried out. Rather than approve the provisions of this Woodlot Plan that would result in logging of old forest, the ministry needs to ensure that TimberWest compensates Younger Brothers for conserving all remaining old forest on Woodlot 2032. This is the only way that TimberWest can meet its own obligation to conserve an area equivalent to at least 9 percent of the total area of SMZ 19 as old forest.
     
    D. Renewal of Woodlot 2032 under any plan will result in several unwanted consequences, the cumulative impact of which is much greater than any economic benefits derived from logging in the woodlot. These impacts include:
    (33) Premature release of carbon emissions, adding to climate instability. For each cubic metre of scaled log volume taken from Woodlot 2032, approximately 1.64 tonnes of CO2-equivalent emissions will be prematurely released to the atmosphere. Since 2011, the accumulated carbon emissions attributable to logging on Woodlot 2032 amount to about 59,000 tonnes. This is equivalent to the emissions created by 12,900 average Canadian passenger vehicles in one year.
    (34) Loss of carbon sequestration capacity, adding to climate instability. Compared to allowing a forest stand to grow for 300 years, logging the same area on short rotations of about 60 years results in a loss of about 75 percent of the area’s carbon sequestration capacity. Loss of 75 percent of BC’s carbon sequestration capacity will worsen growing climate instability.
    (35) Increase in forest fire hazard. Logging old or mature forest creates clearcuts and plantations, both of which have a higher forest fire hazard associated with them than does the forest before logging.
    (36) All logging in BC is subsidized by the public, and the hidden costs of that subsidization are far greater than the short-term economic benefits derived from logging employment and public revenue.
    (37) A large fraction of the logging that takes place on Quadra Island is used to feed TimberWest’s raw log export business. Log exports have the long-term result of the loss of future local wood product manufacturing jobs.
    (38) Clearcut logging of areas of Quadra Island that have high recreational value, such as the area of Woodlot 2032, provides the lowest long-term economic value to the local community. Visitors do not intentionally come to Quadra Island to view clearcut logging. They come here to experience the island’s scenic beauty, its many lakes and developed tourism amenities.
     
    E. In light of Premier David Eby’s commitment to protect 30 percent of BC by 2030, the Ministry of Forests must plan to take back the Crown land on Quadra Island currently tenured to Woodlot 2032.
    (39) Premier David Eby recently directed Minister of Land Stewardship Nathan Cullen to prepare for protecting 30 percent of BC’s land and water by 2030.
    (40) Woodlot 2032 is within the Coastal Western Hemlock biogeoclimatic zone, which contains both the greatest species richness of any BC biogeoclimatic zone and the most endangered species. In bringing BC to an overall 30 percent protected, the Coastal Western Hemlock biogeoclimatic zone should be at least 30 percent protected.
    (41) Since only 18 percent of Quadra Island is currently protected (4913 ha), an additional 3300 hectares—at least— will need to be moved from the timber harvesting land base to protected status by 2030.
    (42) There are approximately 314 hectares of Crown Land on Quadra Island (Sensitive Areas at Heriot Ridge, Hyacinthe Point and Saltwater Lagoon) that are not in a woodlot or in TFL 47.
    (43) That leaves a minimum of 3000 hectares that will need to come from Crown land that is either in a Woodlot Licence tenure or from TFL 47.
    (44) Early consultation with First Nations is required to determine what parts of the timber harvesting land base should be shifted to protected status, or perhaps Tribal Park status.
    In that context, as well as for all of the reasons noted above, approving an additional 10-year term for Woodlot 2032 at this time would be imprudent.
     
    Records released by Ministry of Forests: FOR-2022-22703 Record of communications between Ministry of Forests and Woodlot 2032.pdf 
    For more information about Woodlot 2032, including the proposed Woodlot Plan, see this page.
    For more information about Darkwater Forest, see this page.
    For more information about Darkwater Mountain Forest, see this page and this page.
    Herb Hammond
    Dear President Mierau and Council Members, Association of BC Forest Professionals (ABCFP):
    By way of this letter, I resign my membership in the ABCFP.
    I no longer wish to be part of an organization that alleges to “care for BC’s forest and forest lands,” while remaining silent about the degradation and frequent destruction of natural forest integrity and resilience perpetrated by the vast majority of forestry activities. I will provide examples of these endemic problems below.
    The ABCFP spends more time worrying about what title people involved in forest management do or do not use than providing standards and oversight of activities to protect forest integrity and resilience. The constant reminder, under threat of fines and potential incarceration, to retired forest professionals that they are not permitted to practice forestry, even to provide advice, is a specific example of this problem. In many aspects of societies retired people are viewed as sources of wisdom to be consulted and listened to as a way of reaching sound conclusions that protect the public interest and the ecosystems that sustain them.
    In the absence of definition and oversight of forest management in BC by the ABCFP, the organization has contributed significantly to the many endemic problems that plague the profession. Here are a few examples:
    (1) A plethora of scientific articles urge the protection of primary forests and remaining intact forests to mitigate climate change and reduce loss of biodiversity. Incorporation of this knowledge into new ways of forest protection and use that maintain forests as carbon sinks, and sources of high levels of biodiversity are professional obligations to protect the public interest. Instead, the ABCFP promotes, often by their silence, “business as usual” forest management that exacerbates climate change and biodiversity loss, and shifts forests from carbon sinks to carbon sources.
    (2) The determination of the allowable annual cut (AAC), along with where and how the AAC is extracted have major impacts on the integrity of forests and the well-being of forest-based human communities. However, the AAC is based on questionable (or no) science. Together with a strong lobby from the timber industry to keep the cut as high as possible for as long as possible, the structure used to calculate timber available results in non-sustainable AACs. This problem has become increasingly obvious as industrial forest tenure holders are unable to find trees to cut to meet their AACs and/or resort to logging of younger and younger trees to reach their AAC.
    The ABCFP has an obligation to provide scientifically sound and precautionary models, inventory standards, and forestry methods that protect the broad public interest. This obligation has been shirked to the point that the ABCFP may be viewed as more of an industry lobby group than a professional association that stands up for the well being of the public. The actions and inaction of the ABCFP may be interpreted as being in support of keeping the level of cut as high as possible for as long as possible.
    (3) Pure water is a vital ecological benefit produced by forests at no cost, as long as the natural integrity of forests are maintained. However, with the exception of some small non-industrial forestry operations, industrial forestry degrades water quality, quantity, and timing of flow. The degradation of water starts as soon as roads and the first logging occur in a watershed. As more roads and logging occur in a watershed the degradation of water grows.
    The type of logging and its location within a watershed influence how large and long lasting the negative impacts of forestry on water are. The work of Younes Alila, UBC forest hydrologist, and his graduate students has been seminal in urging big changes to forest management to protect water. The public has also been very vocal (and right) about the many negative impacts of forestry to water. Science supports that old growth forests provide the best water with the most reliable flows. Climate scientists reminds us that with the loss of intact, natural forest cover, water problems will increase as climate change progresses, leading to more floods, droughts, and water shortages. However, the ABCFP has been silent about the wide ranging impacts of forestry on water, including floods and drought. This silence certainly looks like the ABCFP is captured by the timber industry and not acting in the public interest.
    (4) Professional reliance, which was put in place by a provincial government that desired to privatize public forests has been entrenched in forestry practices as the modus operandi. This approach permits no disclosure of information to the public by timber companies about the standards and specific forest data on which timber management operations are based. Thus, we have private entities preparing plans and carrying out timber extraction on public lands with no effective accountability to the public. The ABCFP support for professional reliance is a direct conflict with their stated intention to protect the public interest. If that intention was real, the ABCFP would support the abolition of professional reliance and support the development and enforcement of clear, precautionary standards for forest management. The public interest is not protected by turning forests over to the discretion of the timber industry. The public interest is protected by ensuring that all forest activities maintain the natural ecological integrity and biodiversity that provide the ecological benefits that the public depends upon.
    (5) Clearcutting has been thoroughly discredited for its wide ranging negative impacts on carbon sequestration and storage; biodiversity; water quality, quantity, and timing of flow; and non-timber forest uses. Climate scientists have been vocal in their opposition to clearcutting, because it exacerbates climate change and fuels biodiversity loss. Yet, despite a mountain of evidence to the contrary, clearcutting remains the system of choice for most timber management in BC. This is another place where the ABCFP silence is in direct opposition to the public interest. Even if short-term employment is the only aspect of the public interest considered, clearcuts still fail to deliver as much employment as ecologically responsible partial cuts.
    (6) In the world’s rush to commit to less carbon intensive forms of energy, BC forests have now become a target for the wood pellet industry that supplies wood pellets to burn for the production of electricity in the United Kingdom, Japan, and elsewhere. Burning wood pellets to produce electricity emits significantly more greenhouse gas emissions per unit of electricity produced than burning coal. At best, burning wood pellets is a misguided attempt to lower greenhouse gas emissions. At worst, it is blatant greenwashing.
    As another place to market timber, the timber industry in BC has eagerly joined the chorus promoting the development of the wood pellet industry in BC. Allegedly, the wood for these pellets comes from waste from logging and sawmilling operations. This situation has been rationalized by the declaration by forest professionals that portions of trees that are not merchantable logs are “waste” that is burned after logging is finished. In reality, no tree parts are waste. The “waste” that is now burned needs to be left on the ground, because it is an important part of forest composition that functions to replenish soil nutrients, conserve water, and provide habitat for a variety of organisms essential to forest functioning.
    To add to the problems created by wood pellets, there is abundant, credible evidence that intact BC forests, including old-growth forests, are being logged to produce and export wood pellets. Protection of these intact forests, particularly old-growth and other primary forests, is extremely important to mitigate climate change and slow biodiversity loss
    The ABCFP is silent about the problems created by the wood pellet industry, despite the fact that creation of wood pellets is not in the best interest of the public, particularly since it increases greenhouse gas production. Apparently, the ABCFP maintains that what is good for the timber industry is good for the public interest.
    Another aspect of this issue is that the former chief forester of BC, Diane Nicholls, is now the Drax vice president of sustainability. Drax, located in the UK, is the world’s largest user of wood pellets to generate electricity. The switch from senior government official to senior industry manager was made after Nicholls facilitated the development of the wood pellet industry in BC.
    Nicholls is a prominent member of the ABCFP. Despite her unethical actions around facilitation of the expansion of the wood pellet industry and then leaving government to join Drax, the ABCFP has not initiated a review of Nicholls behaviour vis a vis the Code of Ethics. The likely reason to be cited by the ABCFP is that disciplinary proceedings need to be initiated by an individual, either a member of the ABCFP or the general public. This raises another example of the ABCFP practicing a culture of silence on prominent issues they need to speak out about in order to protect the public interest and the overall credibility of forest professionals.
    (7) In her role as Chief Forester, Diane Nicholls established the “Chief Foresters Leadership Team,” to provide her with advice about how to manage the forests of BC. The Leadership Team consists of the chief foresters of all the major timber companies throughout BC. Such a “team” skews the advice to recommendations that support timber extraction and away from advice that supports protection of forest integrity and the broad public interest. This is yet another example of the silence of the ABCFP in issues critical to the conservation and sustainable management of the public forests of BC. The ABCFP has the opportunity to support development of a Chief Forester’s Leadership Team that is inclusive of experts on the diverse issues affected by forest management, from climate change and biodiversity loss to non-timber enterprises and Indigenous reconciliation. Such a leadership team would also include representatives of the general public, who are familiar with the current practices of forest management. The failure of the ABCFP to suggest a more appropriate leadership team than that appointed by the chief forester appears to be another example of the systemic timber bias of the organization.
     
    FROM THE STANDPOINT OF THE FOREST and all life that depends on healthy, intact forests, the success (or failure) of a forest professional is measured by their footprints in the forest. Good forest management leaves few footprints and fully functioning forests. Unfortunately, most of the forestry done in BC leaves many large footprints and degraded forests. The ABCFP’s role in the large footprints of forestry is a measure of their hypocrisy when one compares their code of ethics and other public documents with what actually happens in the forest.
    All one needs to do is fly across the province to see the dire state of forest management. From there it requires little analysis to understand the large negative impacts that forestry has on all aspects of ecological integrity and biological diversity. The ecological benefits from pure water to carbon storage have been seriously degraded by industrial forestry. This has resulted in forestry being the largest source of greenhouse gas emissions in BC. Industrial forestry exacerbates climate change and biodiversity loss, thereby contributing globally to the climate and biodiversity crises. Industrial forestry is part of the problem, not part of the solution.
    The forests are in trouble. Earth’s climate is collapsing. The ABCFP and many of its members are complicit in this trouble.
    Transformational change in how we define and practice forestry is needed. However, the ABCFP seems to have chosen to ignore increasingly loud and dire warnings from climate and ecological scientists that intact natural forests need protection to mitigate climate disruption and reduce biodiversity loss. Instead of supporting needed change to forestry/forest management, the ABCFP and most of its members have chosen to support continued logging of intact natural forests across BC. That approach leads to a dead end that will not only harm forests, but also human society.
    I no longer wish to be part of an organization that is unable to see the forest for the timber.
    Yours truly,
    Herb Hammond
    David Shipway
    “Mature” hemlock and Douglas fir typical of second-growth being harvested on the Discovery Islands
     
    Attn: Colin Koszman/ Land Use Forester, Molly Hudson/ Director of Sustainability
     
    I STARTED OUT IN MY WORKING LIFE in the late ’60s, surveying cutblocks and new roads with MacMillan Bloedel on many of the lands now being managed by Mosaic—up in the headwaters of the Oyster, the Quinsam, the Campbell, the Eve and the Salmon. I witnessed the last of the valley bottom old growth being logged, magnificent cedar groves that would now be considered a national treasure, and saw the montaine plateaus of Mountain Hemlock, Yellow Cedar and Western Yew before anyone had touched them. 

    Since then, I’ve watched pretty much everything on the private managed forest land of Vancouver Island get mowed down, even where regeneration is poor, and especially in the second growth stands that were nowhere near reaching maturity. And now in an act of insanity even the third growth “pecker poles”. It’s no secret to anyone paying attention that our overcut forests are in ecological decline. It’s an easy concession now for your industry to set aside some token old growth remnants, since these areas are just the hard to reach “guts and feathers” of the great forests that once existed all over this part of the coast. But the greater crime of liquidation is now happening in immature forests. We have gone from that heroic age of the Tall Timber Jamboree to an age of weasely politicians promoting chopstick factories, in less than one human lifetime. 

    I’ve spent the last 40 years woodworking and homebuilding here on Cortes, and have watched the quality of native wood species plummet as its price keeps climbing. I’ve watched the sapwood in anything made just rot away, since it’s sugar content quickly attracts fungi and insects. I’ve noticed powder worms find their way into the widely spaced grain of second growth fir and cedar heartwood, whereas the tighter grain of resinous old growth was impervious.

    What shocks me most about the simultaneous decline of professional forestry on the coast is this complete ignorance about wood quality. Foresters seem to be operating on the obsolete myth that an 80 year old Douglas Fir or Red Cedar is a “mature” tree, when it is really just an adolescent. At the “culmination age” of mean annual increment, these trees may be growing volume at their fastest rate, but that also means that the sapwood layer is also at it’s maximum volume in the tree.  In other words, trees harvested at this age may be up to 50 percent sapwood that has no endurance, no longevity in wood products. Even the heartwood is unstable and full of knots. What an incredible waste of potential. What a sad lack of patience!
     

    Just under half of the volume of this 95-year-old tree was low-value, non-durable sapwood (lighter coloured wood on left) around the time it was harvested

    In an age of accelerating climate change, the best terrestrial carbon sinks that we must take care of are our native forests. Here on the coast, where the risk of fire is less than in the Interior, the capacity to store a huge amount of carbon at landscape levels is more achievable, and must be seen as the highest priority and professional responsibility among coastal foresters.

    I’m not saying we need to stop harvesting trees, but that we must let them grow a lot older before doing so. We need to adopt a holistic forest management regime that aims for three crucial goals at once—high carbon capture in a biodiverse ecosystem with many old growth attributes, high carbon storage in mature durable wood products and high quality artifacts, and the economic perpetuation of good honest forestry and our inherited multitude of traditional woodworking crafts.

    What professional foresters must not continue to do is steal the young forests and future forest livelihoods from all our grandchildren, just to keep adults in luxury, while simultaneously spouting the deceptive language of sustainability. The current rapid liquidation of the immature second and third growth forests on the BC coast is just that, a trans-generational crime of grand theft that I hope will not go unpunished.

    Sincerely,
    David Shipway
    Sabina Leader
    Mosaic Forest Management
    Colin Koszman/ Land Use Forester
    Molly Hudson/ Director of Sustainability
     
    Good Morning Molly and Colin,
    Spring Greetings from Cortes Island.
    Thank you for your invitation to comment on Mosaic Forest Management’s 3-year draft plan for Island Timberland’s (IT) private managed forest land (PMFL) holdings on Cortes Island. 
    My husband and I moved to Cortes Island in 1992 and have been permanent residents since; we are professionals in physiology and ecology respectively, self-employed under our own consulting firm.
    As an ecologist, I was impressed when the Cortes Island Forest Committee (CIFC) commissioned Herb Hammond/ Silva Forest Foundation (SFF) in 1996, to undertake “a detailed ecological study and computer based mapping” of Cortes Island, to inform forest management on island. Central to the SFF philosophy was/is the concept of ecosystem based conservation planning (EBCP); the focus of which is to first identify what to protect and second, what to use.
    EBCP is not based on the need to fill timber quotas or meet company profits, rather, it is based on the knowledge that preservation of the environment and ecosystems in which we live, is first priority.
    EBCP protects and maintains ecological integrity and biological diversity at all spatial scales; most importantly, CIFC adopted the landscape level for their initial planning process.
    SFF produced a series of maps for the CIFC that described the ecological landscape of Cortes Island: protected landscape network, ecological sensitivity to disturbance, landscape connections etc. These maps provide a valuable baseline for forest management on Cortes Island.
    My first introduction to IT PMFL holdings on Cortes Island came in 2008, when IT publicly announced timber harvesting plans for these lands. IT advised the Cortes community that, in their opinion, timber extraction was the “highest and best use" of these lands. 
    In order to respond to IT in an informed and responsible manner, the Cortes community undertook to inform themselves; we initiated a citizen-science mapping project of IT lands. Trained teams of citizens ground-truthed the sensitive ecosystems that were mapped for Cortes Island during the Sunshine Coast Sensitive Ecosystem Inventory (SEI) 1999. The SEI was undertaken to address the increasing rate of loss of ecologically significant lands and important wildlife habitat in the Strait of Georgia. All five provincially designated sensitive ecosystems were represented on IT PMFL, including mature forest, “the other important ecosystem class” that provides the significant function of buffering the sensitive ecosystems within the landscape. From our fieldwork, we generated an inventory of species and ecological communities at risk (SEAR) referencing the BC Conservation Data Centre’s (CDC) data base in Victoria. 
    Taking our field data and looking at it through the lens of EBCP and alongside the SFF mapping, we were able to identify leave areas on the IT land base, that were integral to healthy ecological function at the landscape level.
    The Delight Lake Watershed was identified as a leave area, notable as a primary water recharge area at the heart of the island with intact hydrology and water quality. This watershed also boasted a diversity of sensitive ecosystems: Wetland (WN), Riparian (RI), Terrestrial Herbaceous ((HB), Woodland ((WD) and Old Forest (OF). Our field work confirmed that this high habitat diversity equated with high species diversity; significantly, several SEAR were observed. 
    SFF mapping had identified this watershed as a strong biological node along an important riparian landscape connector north to south.
    Our fieldwork also resulted in the Basil Creek Old-Growth Reserve proposal, which identified both old-growth forest and old-growth recruitment forest, as leave areas, in the Basil Creek Watershed.
    We are now ten plus years down the road and the Cortes community’s local ecological knowledge has grown substantially and continues to be informed by research initiatives spanning a full spectrum of studies: ecological function, conservation biology, human-wildlife coexistence, connectivity science and climate resiliency.
    Once again, our community is being asked to comment on draft logging plans for the IT PMFL on Cortes Island.
    The ever present “elephant in the room” these past ten years has been and ever more ominously continues to be… climate change. The latest report of the Intergovernmental Panel on Climate Change (IPCC) is a sobering read and prompts each of us to take a precautionary approach to proposals such as that drafted by Mosaic Forest Management, for timber extraction on Cortes Island.
    In my opinion, the “highest and best use” of the majority of the IT PMFL on Cortes Island, today, is clearly conservation and I would, therefore, be pleased to proactively participate in a process whereby Mosaic Forest Management return these lands to community hands.
    Sincerely,
    Sabina Leader Mense
    Riki Vogt
    From Nov 26, 2021 Discovery Islander
    Dear Mr. Iannidinardo,
    I am writing to ask you to abandon your planned logging in this little watershed for the sake of saving the creek and its salmon runs. I believe you are planning to do more logging there this fall/winter.
    This little creek was bone dry this past summer and I and other islanders are concerned that further disturbance from logging in the watershed will kill off this small but important ecosystem. As you know, the local Salmon Enhancement Society has worked tirelessly over many years to maintain the runs. The creek will need every drop of moisture from its tributaries in a warming climate which is now upon us. For this reason I believe that the forest cover around these tiny tributaries should not be logged as planned. In fact, none of the watershed should be logged again. Exposed ground causes faster run-off and silting and faster evaporation from little wetland patches and puddles etc. Wild salmon are struggling mightily to survive and more habitat destruction could be the final straw for these runs.
    Why do I refer to Hyacinthe Creek watershed as little? Because that’s truly what it is, a mere 1550 hectares or so. That’s about 1 percent of the size of your TFL 47, which is 165,000 hectares. So whether you turn a profit here or not seems immaterial. Further, we are not dealing with old growth trees here as everything has already been logged at least once.
    So you see, this is your chance to do something good, something right. You could help these salmon and this ecosystem to survive and perhaps thrive again by not further degrading a watershed that is already heavily impacted. (Walcan road, logging roads, past logging). This is in your power.
    Biodiversity IS life and there is no life without biodiversity, as David Attenborough puts it. Please consider seriously my suggestion to put off your logging in this small watershed. I would appreciate getting a serious reply from you.
    Sincerely,
    Riki Vogt, Grandmother
    Jim Leishman
    Attention:
    Mosaic Forest Management Mosaic Forest Management
    Vice President of Forest & Logistics  President & CEO Jeffery Zweig
    Chief Forester Domenico Iannidinardo

    As Mosaic Forest Management’ has expressed an interest in BC’s wild West Coast in the form of a photo contest I draw your attention to such a scene, a recent photo representing a Quadra Island wild place TFL47 that is regarded by Quadra Islanders and visitors as particularly “special”.
     

    Missing Link Watershed enjoying beaver dam wetland
     
    This image was taken as visitors followed the layout of a cutting boundary only a couple of meters from the photographer. The proposed boundary is blatantly in contravention of regulations and does not bode well in terms of excellent practices nor excellence in attention to environmental certification guidelines.
    A forest company demonstrating leadership and commitment to environmentally-responsible stewardship might recognize that the mosaic pattern of recent TFL 47 cut blocks are now intersecting the pattern of urban development on Quadra Island This intersection is presently an issue to be addressed.
    Referring to most any guide to tourism or recreation for Quadra Island would indicate that the current and proposed timber harvesting of Public Crown Land TFL 47 encompasses portions of three of the seven listed accessible hiking areas in the southerly mapped portion of the urban/residential Quadra Island Recreation Society. These areas are the Missing Link, Eagle Ridge and Blind-man's Bluff. These areas, are located within the Missing Link Watershed and contain particularly significant viewscapes for our community and our guests.
     

    Recreation Areas 6 and 7
     

    Signage at Missing Link
     

    A section of the Quadra Island Trails Guide
     
    This trails guide brochure states in part:
    “The Eagle Ridge Trail follows an old road to a wetland, (Missing Link Watershed) then after crossing a stream (cut block flagged) climbs steadily onto open bluffs with splendid views over Quadra and especially the wetlands below.” (Missing Link Watershed)
    These areas of the Missing Link Watershed are notably significant to the community.
    Note the Quadra Island Recreation Guide financial supporters (below). It might be suggested these supporters have both a personal, recreational as well as a livelihood/financial interest in the maintaining the of the area’s integrity.
     

     
    Quadra Island currently has the population that Campbell River had in the 1950s. An exponential increase in populations on Vancouver Islands and Quadra Island in the coming years will require our commitment to the protection and the enhancement of watershed health and recreational and tourism values.
    Comparable to the highly valued Beaver Lodge Lands adjacent to urban development in Campbell River are the Quadra Island community values associated with the Missing Link Watershed. These watersheds are unarguably a highly valued assets for both communities. Understandably Quadra Island residents do not want this resource as a legacy of desecration.
    The best interests of the Quadra Island Community require the foresight to initiate actions today to protect resources for future generations
    Our growing resident population are and will be directly impacted by resources extracted.
    Encroachment on the unique and sensitive bio-climatically zoned watershed certainly deserves our action to preserve the integrity of the area.
    Brought to the attention of recreational users of the area by the appearance and the placement of a proposed falling boundary blatantly underscores the inadequate regard for the future integrity of the Missing Link Wetland.
    The process of obtaining social licence to operate is currently running parallel to Mosaic’s failing attempt to apply technical adherence to government regulatory processes.
    Government regulatory process itself fails to fully address community concerns and interests.
    Further cutting within the Missing Link Watershed is unequivocally not in the best interests of our community as we loose or are left with a devalued resource. The very unstable state of the present world economy spotlights and underscores this natural resource as genuinely precious.
    Our Intention is to act in a manor honouring our grandest vision for the future of our local environment and our community. This initiative is a “local priority” of the Quadra Island Community
    As each stakeholder in this process is accountable to the Quadra Island Community and to all users, now and for future generations today presents an opportunity for more socially positive change involving accountability both individually and professionally.
    This initiative is brought forward with a vision to ensure and to enhance rather than degrade and devalue the Missing Link Watershed for both the immediate and the future generations.
    The focus of this initiative is to secure removal of the TimberWest portion of the Missing Link Watershed from any further timber harvesting.
    This initiative is not focused on arguing the adherence or non adherence to government regulatory process although we do have a full roster of related issues at hand. We wish instead to address the implementation of actions for the manifestation of our grandest vision for the future of our local environment and our community.
     

    “Please Protect Your Resource”
     

    Portion of Missing Link Watershed in TimberWest TFL 47 (white tinted)
     
    The total area of the Missing Links watershed is 138 hectares.
    The area within the TimberWest TFL 47 portion of the watershed is approximately 85 hectares, or 61.6% of the 138-hectare watershed.
    This initiative is to address a global vision with foresight, integrity and accountability, both personally as well as professionally.
    Globally, humanity has in the past fallen short of acting with integrity. As Community (and you are included), we have this opportunity to visualize more globally while taking action locally.
    This initiative requires decisions that define both who we are and what we believe in and have an impact on our self-respect, our integrity, and ultimately our reputation.
    As one of Mosaic’s identified values is described as “Integrity: Respectful and honest in our relationships by always doing the right thing and holding ourselves to account”
    Intention, with integrity will provide an opportunity that Mosaic, TimberWest, is recognized as demonstrating leadership with integrity with the removing of the TimberWest portion of the Missing Links watershed from any approval as an available harvesting area within TimberWest TFL 47.
    Identifying that the Program for the Endorsement of Forest Certification endorses forest certification systems “developed collaboratively by diverse stakeholders, tailored to local priorities and conditions” the Missing Link Watershed is tailored to the priorities and conditions of the Quadra Island Community. This initiative presents an opportune occasion for recognition of a Mosaic, TimberWest Sustainable Forest Initiative to provide an important contribution addressing the unique needs and values of this British Columbia forest and community. Looking to the future this contribution will be of high value in the best interests of shareholders.
    Looking forward to your responses to this initiative
    We thank you, on behalf of Concerned Citizens of Quadra Island and Beyond
    Most sincerely,
    Jim Leishman
     
    https://quadraislandtrails.ca/trail-map/
    https://www.mosaicforests.com/our-company-people
    https://www.supplypro.ca/sfi-forest-management-standard-meets-assessment-criteria/
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