(2023-12-29) Comments on the draft woodlot plan for Woodlot 1898

December 29, 2023

To: Nigel Ross RPF, Buttle Lake Resources

cc Ministry of Forests’ Campbell River District Manager Lesley Fettes

Dear Nigel,

I trust this finds you well. I am writing on behalf of the Discovery Islands Forest Conservation Project in response to Buttle Lake Resources’ invitation to the public to submit comments on the draft woodlot plan for Woodlot 1898.

Thank you for providing access to your proposed management plan along with the other material you made available. The files provided for the reserves you have mapped for the woodlot allow us to view where your reserves are on satellite imagery and what they consist of on the ground.

As you know, the Schedule B lands of your woodlot are located entirely within Special Management Zone 19 (SMZ 19) and it is the ways in which your proposed plan—and past performance—have not or will not abide with the requirements of the Vancouver Island Land Use Plan Higher Level Plan Order for SMZ 19 that I will address below.

In my view, the draft woodlot plan does not adhere to Objective A. 1. (b) of the Vancouver Island Land Use Plan Higher Level Plan Order. Note that section 13 (3) of the Forest and Range Practices Act, which exempts woodlots from meeting a number of other government objectives, does not exempt woodlots from meeting this particular objective.

As well, there are instances where Buttle Lake Resources has logged to the road along Bold Point Road, and those cuts have contravened both the spirit of SMZ 19 and the visual quality objectives established for this important view corridor leading to Main Lake Provincial Park.

We address these two issues in more detail below, as well as a third issue— your proposal to raise the allowable annual cut for this woodlot by 35 percent.

(1) A legal requirement for SMZ 19 has not been adhered to by Buttle Lake Resources (or any forest licensees on Quadra Island)

Objective A. 1. (b) of the Vancouver Island Land Use Plan Higher Level Plan Order (HPLO) 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

Although section 13 (3) of FRPA exempts woodlots from having to meet certain government objectives, this particular objective is not exempted. Buttle Lake Resources is required to meet it.

We note that TimberWest’s stated strategy in its forest stewardship plan for TFL 47 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 2010 in Woodlot 1898 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.

I return now to the second point I raised above, that Buttle Lake Resources has not adhered to the visual quality objectives set out for Bold Point Road.

(2) Buttle Lake Resources has contravened the “Retention” visual quality objective set out for Bold Point Road

The draft woodlot plan acknowledges that Bold Point Road (formerly Village Bay Lake Road) has a “Retention” visual quality restriction attached to it. However, the Ministry of Forests’ RESULTS-Openings database (and a drive along the road) shows that this 100-metre wide corridor has been cut into in four places by Buttle Lake Resources.

Buttle Lake Resources has logged into the “Retention” visual quality objective corridor along Bold Point Road in four locations as indicated by the white dots

The Ministry of Forests’ guidance on the “Retention” level visual quality objective is “Alteration is difficult to see, small in scale, and natural in appearance.”

The four incursions into this corridor by Buttle Lake Resources do not meet this guidance. Since this is the main public gateway to Main Lake Provincial Park, these are serious degradations of the corridor and it will take many years to recover this corridor to the visual quality that was intended by the Vancouver Island Summary Land Use Plan. Woodlot 1898’s promise in its 2013 woodlot plan of “only minimal views of a clearcut forest floor from a passing car” has not been met.

Note that one of the primary objectives established for SMZ 19 were “3. Visual qualities, esp. in association with shoreline, major road corridors and high recreation use areas, as well as maintenance of coastal wildlife habitats.” (Page 80, Vancouver Island Summary Land Use Plan)

“Timber”, on the other hand, was identified as a “Secondary objective.”

This land use planning is still in force and must be respected. Given the incursions that have already occurred, we ask that Buttle Lake Resources not thin or eliminate any of the remaining forest in the corridor.

(3) The AAC for this woodlot has been set too high

While, strictly speaking, consideration of Buttle Lake Resources’ application through its new draft management plan to raise the allowable annual cut for the woodlot is not part of the draft woodlot plan, I include comments on this matter since the provisions of a woodlot management plan, especially the proposed AAC, have a fundamental bearing on whether or not the stated strategies and objectives of a woodlot plan can, in practice, be accomplished.

The Discovery Islands Forest Conservation Project has analyzed the Crown land (Quadra Island) portion of this woodlot and the comments below apply only to that area. Based on your maps of voluntary reserves included in the proposed woodlot plan,

The mandatory and voluntary reserves and visual quality objectives that apply to the proposed woodlot plan for Woodlot 1898. The boundaries of the woodlot are marked by dotted red lines. Riparian management zones are solid red and voluntary reserves are marked in transparent yellow. Note the 100-metre-wide “Retention” visual quality reserve along Bold Point Road, approximately one-third the width of which applies to WL 1898. Other areas subject to visual quality objectives are shown as solid yellow or light green. The blue areas are old-growth deferral areas. Areas coloured in darker green indicate riparian management zones where as much as 100 percent of trees may be cut.

your estimate of the eventual area of roads and landings, existing visual quality objectives and our own analyses of satellite imagery for rock and inoperable areas, we make the following estimate of the areas of voluntary reserves and necessary exclusions from the overall area of the woodlot and arrive at an estimate of the net timber harvesting land base:

Total area of woodlot 1898 on Quadra Island: 400 ha

Exclusions from the timber harvesting land base

Voluntary reserves as per proposed woodlot plan: 85 ha

Meadows/wetlands: 37.5 ha

Eventual permanent access structures (as per the licensee’s estimate of 7 percent of total woodlot area): 28 ha

Net impact of “Retention” VQO along Village Bay Lakes Road: 6 ha

Net impact of other VQOs and RMZs: 5 ha

Rock: 2 ha

Unstable slopes/inoperable areas: 2 ha

Total exclusions: 165.5 ha

Net area available for logging: 234.5 ha

Estimated AAC at an average mean annual increment (MAI) of 7.3 cubic metres per hectare: 1710 cubic metres per year. (This is the average MAI used by TimberWest in its last timber supply analysis for all of TFL 47.)

As we understand it, the current AAC is set at 2393 cubic metres per year.

Buttle Lake Resources is proposing a new AAC of 3232 cubic metres per year, 35 percent higher than the current level.

On only 20 years of experience, Buttle Lake Resources is convinced that third-growth trees are growing faster than did the second growth trees it is logging. This reflects a long tradition of the BC logging industry over-estimating its future prospects.

In 2004, then BC Chief Forester Jim Snetsinger predicted in The State of British Columbia’s Forests (page 34) that BC’s annual timber supply from Crown land would be about 75 million cubic metres in 2023. The actual cut in 2023 will be closer to 36 million cubic metres, approximately half of Snetsinger’s prediction. The optimism bias at work in the logging industry is legendary and Buttle Lake Resources’ prediction of future growth continues that tradition. Both the ministry and industry have failed for many years to realistically include in their timber supply analyses the expected impacts of global heating on the size and frequency of droughts, forest fires and insect infestations.

Note that increasing the AAC for this woodlot would be contrary to the stated recent policy direction change of the Ministry of Forests, as outlined to Forests Minister Bruce Ralston by Premier David Eby in his December 2022 letter of expectations. At that time Eby directed Ralston to “Accelerate the transition of our forestry sector from high-volume to high value production, with fewer log exports, more innovative wood products manufactured locally, and support to mills to transition to second and third growth trees.”

Increasing the AAC of this woodlot would result in younger, less valuable trees being logged instead of allowing them to grow older, contain a lower percentage of sapwood, be more free of knots and be tighter grained—wood that is more able to contribute to the transition to higher value that Premier Eby has directed the ministry to accelerate.

Moreover, BC has committed to protect 30 percent of land and water by 2030. In 2023, only 18 percent of the land area of Quadra Island has any form of conservation status. The best use of the area occupied by this woodlot, adjacent as it is to a beloved provincial park and Village Bay, is not as a site for more intense industrial development but as a more protected area, possibly as an Indigenous protected and conserved area.

For all these reasons the Discovery Islands Forest Conservation Project strenuously objects to an increase in the AAC for Woodlot 1898.

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

Sincerely,

David Broadland

for the Discovery Islands Forest Conservation Project