(2023-05-12) Comments regarding the proposed draft Woodlot Plan for Woodlot 2031

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