(2023-08-16) Comments regarding the draft woodlot plans for WL 1969 and WL 1970

August 16, 2023

To: Chief Ronnie Chickite, We Wai Kai First Nation

cc Gary Gallinger, RPF; Ministry of Forests’ Campbell River District Manager Lesley Fettes

Dear Chief Chickite,

I trust this finds you well. I am writing on behalf of the Discovery Islands Forest Conservation Project in response to Cape Mudge Forestry’s invitation to the public to submit comments on the draft woodlot plan for Woodlots 1969 and 1970.

Our project is conducted by residents of the Discovery Islands. Our goal is to provide other settlers with accurate information about the physical state of the forests on the Discovery Islands and their value in supporting fish and wildlife, storing carbon, and for providing economic and spiritual support for the human communities that live here. We are also developing information about what forest conditions are needed for minimizing the rate of spread of fire.

Those of us on Quadra Island who are working on this project acknowledge that we are living and working on the unceded traditional territory of the We Wai Kai First Nation. We fully support the return of your land to your control as quickly as possible. We are disappointed by the provincial government’s slow progress in this direction.

We fully support your right to use your land as you decide. Yet land ownership comes with the responsibility for land stewardship. Your land provides essential life support: clean air, clean water and naturally balanced communities of plants and animals that allow essential ecological functions to continue. So the condition of the land and its ability to continue to meet the needs of the plants, animals and humans who live on it is a matter of deep concern for all of us. It is from that perspective that we respectfully offer the following comments regarding Cape Mudge Forestry’s draft proposed woodlot plans.

In both draft woodlot plans, Cape Mudge Forestry makes the following commitment: “While Section 13 (3) of the Forest and Range Practices Act (FRPA) states that a WLP need not be consistent with objectives set by government to the extent that those objectives pertain to retention of old forest, seral stage distribution, landscape connectivity, or temporal and spatial distribution of cutblocks, the licensee has committed in the Management Plan (MP) to adhere to and implement the Special Management Zone (SMZ) 19 objectives and strategies.”

The Discovery Islands Forest Conservation Project applauds Cape Mudge Forestry’s choice to adhere to and implement SMZ 19’s objectives and strategies, including those government objectives that FRPA makes discretionary for woodlots. We would also point out that under Section 21 (1) of FRPA, “The holder of 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.”

In our view, the draft woodlot plans don’t adhere to Objective A. 1. (b) of the Vancouver Island Land Use Plan Higher Level Plan Order. Note that section 13 (3) of FRPA does not exempt woodlots from meeting this particular objective. As well, even though the draft woodlot plans commit to adhere to the objectives and strategies for SMZ 19 that are made discretionary by section 13 (3) of FRPA, certain sections of the draft woodlot plans do not align clearly with those objectives. We address these two issues below.

A legal requirement for SMZ 19 has not been adhered to by the licensee (or any forest licensees on Quadra Island)

Objective A. 1. (b) states: “Sustain forest ecosystem structure and function in SMZs, by... retaining within cutblocks, structural forest attributes and elements with important biodiversity functions…”

To meet this objective would entail leaving—within all cutblocks—wildlife tree retention areas that would sustain forest ecosystem structure and function. A full discussion of what is necessary to sustain forest ecosystem structure and function can be found here: https://www.for.gov.bc.ca/ftp/hfp/external/!publish/FPC%20archive/old%20web%20site%20contents/fpc/fpcguide/biodiv/chap4.htm

We note that TimberWest’s stated strategy for meeting Objective A. 1. (b) in SMZ 19 is: “Retaining wildlife trees as specified in Section 66 of the Forest Planning and Practices Regulation”.

Section 66 of the Forest Planning and Practices Regulation states, in part: “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.”

A review of logging since 2007 in Woodlots 1969 and 1970 shows that objective A. 1. (b) of the HLPO has not been adhered to. The licensee should have left—within cutblocks—a minimum of 7% of the area of the cutblocks it logged as wildlife tree retention areas in order to meet the legal requirements of Objective A. 1. (b) of the VILUP Higher Level Plan Order.

Although I have stated it above already, for emphasis I will restate that section 13 (3) of FRPA does not exempt woodlots from meeting this particular SMZ 19 objective.

So let’s return now to the second point I raised above, that the draft woodlot plans do not align clearly with those SMZ 19 objectives that are discretionary for woodlots, but which Cape Mudge Forestry has committed to adhere to in both its management plans and woodlot plans.

The draft woodlot plans do not align with the licensee’s written commitment to adhere to SMZ 19 objectives and strategies

Objective A. 1. (a) of the VILUP Higher Level Plan Order states “Sustain forest ecosytem structure and function in SMZs, by creating or maintaining stand structures and forest attributes associated with mature and old forests, subject to the following: the target for mature seral forest should range between one quarter to one third of the forested area of each SMZ (mature seral targets will be established through landscape unit planning…).”

We can only understand the outcome intended by this objective by considering other details of land use planning current at the time the VILUP Higher Level Plan Order was implemented.

SMZ 19 was assigned a biodiversity emphasis option of “Intermediate” by the Vancouver Island Summary Land Use Plan. According to the provincial Biodiversity Guidebook current at the time VILUP was implemented, 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. This is the correct way to interpret the meaning of the “between one quarter to one third of the forested area” range in the “mature seral target” of Objective A. 1. (a). Note, in particular, the implied target for old forest of >9 percent.

The recommended strategy for protecting old forest in SMZ 19, as stated in the Vancouver Island Summary Land Use Plan is:

“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.”

In other words, to meet the objectives and strategies set out for SMZ 19, at least 9 percent of the forested area of Woodlots 1969 and 1970 should be left as old forest, if that exists. As well, the stated strategy includes conservation of areas of “second growth with high portion of veteran trees”. We hope Cape Mudge Forestry will agree that the best practice for adhering to the objectives and strategies for SMZ 19 would be that such areas are identified on the woodlot plan maps for both woodlots and marked as areas where harvesting will be avoided.

The Discovery Islands Forest Conservation Project has mapped and estimated the area of old forest in each of the woodlots as follows:

WL 1969: 59.2 hectares (7.4 percent of woodlot area)

WL 1970: 53.2 hectares (6.6 percent of woodlot area)

In other words, in both woodlots the remaining areas of old forest cover less than the minimum area of old forest (9 percent) targeted by Objective A. 1. (a). As well, only 1.1 hectare of existing old forest is within the proposed Wildlife Tree Retention Areas in WL 1969 and only 6.52 hectares in WL 1970.

(There is an additional 2.2-hectare overlap of old forest within the Bachus Creek riparian reserve zone in Woodlot 1969.)

Since each woodlot’s plan would need to explicitly conserve all remaining old forest to meet Objective A. 1. (a), neither draft woodlot plan adheres to the objectives for SMZ 19 even though Cape Mudge Forestry has committed to do so in its draft woodlot plans.

In this mapping of WL 1969, there is minimal overlap between areas of existing old forest (outlined in yellow) and the wildlife tree retention areas (light green areas) and riparian reserve zones (light purple) proposed by Cape Mudge Forestry.

Similarly, in WL 1970, where there is very little old forest remaining, the wildlife tree retention areas proposed by Cape Mudge Forestry would have little overlap with the old forest.

In addition, the licensee states in its draft woodlot plans, under the section “Areas where timber harvesting will be AVOIDED:” that “There are no areas where timber harvesting will be avoided.” We believe that Cape Mudge Forestry ought to identify areas of old forest on the woodlot, and these then need to be identified on woodlot plan maps as “Areas where timber harvesting will be avoided.” (We are happy to share our own mapping as a starting point. See the map near the bottom of this page. )

The 2007 woodlot plan for WL 1969 identified several areas of old forest that it had designated as “Wildlife Tree Patches”. This included 16.5 hectares of rare old forest near Darkwater Lake that is important to protect for the purpose of biodiversity conservation. Cape Mudge Forestry’s 2007 woodlot plan had identified this as the “Darkwater Mountain Reserve”. In the 2023 draft woodlot plan, that reserve has disappeared. Overall, the licensee’s draft plan proposes to lower the area of wildlife tree retention areas from 78.9 hectares in the 2007 plan to 63.9 hectares in the draft plan. This direction will not allow the licensee to meet its commitment to adhere to the objectives and strategies it committed to in both its management plans and its woodlot plans, including the draft proposed woodlot plans.

Old forest on Darkwater Mountain inside Woodlot 1969

Old forest on Darkwater Mountain inside Woodlot 1969

As well, the proposed plan for WL 1969 would lower the area of riparian reserve zones from 26 hectares in the 2007 plan to 19.5 hectares. For example, Larsen Creek has been downgraded from an S2 fish stream to an S6 stream. We request an explanation for the decrease in the area of riparian reserve zones.

I end by noting that the target for minimum levels of old forest that have been designated for SMZ 19 are based on a pre-2000 forest management belief that the natural time interval between stand-replacing disturbances—like fire—for forests on Quadra Island was about 200 years. More recent scientific research indicates that the natural disturbance interval here is much longer—about 700 years. As you know, this means that in order for logging on the land to mimic natural disturbances like fire—and so not pose an unnaturally large threat to wildlife—a much greater coverage of the islands by old forest than the 9 percent target for SMZ 19 is needed. To keep the risk of biodiversity loss to a low level, approximately 49 percent of Quadra Island’s forested area would need to be covered by old forest.

Yet, driven by the forest exploitation of settler culture, the extent of old forests on Quadra Island have fallen significantly below even the minimal 9 percent level called for by VILUP. Our project estimates that old forest now constitutes only about 4 percent of the forest cover on Quadra Island, an estimate similar to TimberWest’s own analyses. This has put at risk the continued presence of salmon, wolf, cougar, goshawk and many other animals and plants which depend for their existence on the natural, long-term level of old forest that had covered these islands since time immemorial.

Thank you for taking the time to read this submission. I look forward to reading your response.

David Broadland

for the Discovery Islands Forest Conservation Project