(2023-01-21) Regarding the renewal of Woodlot Licence 2032 and its proposed new Woodlot Plan

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.