(2024-03-23) TimberWest flubs the first step in a critical timber supply review

The first public engagement step in a timber supply review is the licensee's submission of an "Information Package" for public consideration and comment. The Discovery Islands Forest Conservation Project raised questions about the licensee's position on climate change, past promises, lack of protection of old forest, inaccurate mapping, a dubious account of the timber harvesting land base—and a glaring conflict of interest.

To: Whom it may concern at TimberWest Forest Corp: communications@mosaicforests.com

Cc: Lesley Fettes RPF, Campbell River District Manager

Cc: Chief Ronnie Chickite, We Wai Kai First Nation

Cc: Michelle Babchuk, MLA, Michele.Babchuk.MLA@leg.bc.ca

Our comments below are in response to an invitation to respond to the information package for TimberWest’s Management Plan #5. As this package does not meet the requirements of a draft management plan, we look forward to being able to comment on that plan at a later date.

Our understanding is that the legal holder of the licence for TFL 47 is TimberWest Forest Corp. If the licence has been transferred to Mosaic Forest Management please let us know.

As you know, the main purpose of establishing a new management plan is to provide a timber supply analysis in preparation for a new determination by the Chief Forester’s Office of an allowable annual cut for the Quadra Island and Bonanza Lake blocks of TFL 47. An integral part of that analysis is a land base netdown summary that estimates the size of the timber harvesting land base in the two blocks. We critique that summary later in the comments below.

First, though, the Discovery Islands Forest Conservation Project offers the following general comments about the contents of the information package and TimberWest’s current practices:

Climate change

The information package contains this comment on climate change: “TimberWest is concerned about the potential long-term implications of climate change on its forestry holdings and has dedicated time and resources to understand the issue better. However, given the current scientific understanding, it is not yet possible to make reasonable quantitative predictions about the impact of climate change on timber supply. Therefore, the base case will not include specific accounting for climate change projections.”

This statement is hard to reconcile with the announcement by Mosaic Forest Management on March 16, 2022, that it can make more money from letting trees grow and selling carbon credits than from logging its privately owned land. At that time, Chief Forester Domenico Iannidinardo told the Globe and Mail, “We expect to make at least as much from the BigCoast initiative as we would earn from harvesting these forests.”

The decision to sell carbon credits instead of logging TimberWest’s own land is apparently a sound business response to the climate emergency. Why would this not also be the case for the publicly owned land of TFL 47? Why couldn’t the government of BC expect to make at least as much from letting the trees grow than from licensing TimberWest to log them? If TimberWest’s chief forester thinks this is an economically sound idea, why wouldn’t BC’s chief forester, too?

In both cases, there would be few if any manufacturing job losses since TimberWest exports—as raw logs—virtually everything it cuts in TFL 47.

Moreover, logging is a significant contributor of carbon emissions via the accelerated release to the atmosphere of biogenic carbon. The short-rotation clearcutting practices used by TimberWest will inevitably cause a profound diminishment of the carbon sequestration capacity of the forests TimberWest is logging in TFL 47.

In determining a new AAC for the Bonanza Lake and Quadra Island blocks of TFL 47, the expected impacts of climate change on the incidence of insect infestation, forest diseases, prolonged drought and the occurrence of extreme fire weather should all be considered—along with the more economically profitable alternative (apparently) of letting the trees grow to mitigate climate change. All of these factors point to a significantly lower AAC than is currently allowed.

Clearcut logging

In 1999 TimberWest announced that it would no longer practice clearcut logging. Back then, the CBC reported “Timberwest President Scott Folk says clearcutting is being phased out in response to marketplace demands.” TimberWest promised to phase out clearcut logging over a 4-year period. Nothing like that ever happened, but it is time for TimberWest to resurrect this promise.

As the climate emergency and biodiversity crisis deepen, the over-sized role logging companies play in both those disasters is becoming clearer. Public pressure to end clearcut logging is building. Marketplace demands are hardening.

The Discovery Islands are a biodiversity hotspot, a place of immense recreational and tourism potential and an area blessed with a forest type and climate in which forest fires are less likely than in most other parts of BC. Government will come under increasing pressure to conserve such areas in order to mitigate the biodiversity and climate crises and reduce forest fire hazard. Clearcut logging eliminates the existing natural advantages that are required for building and maintaining a sustainable local economy based on undisturbed nature.

This reality, apparently clear to TimberWest in 1999, now needs to be incorporated in this AAC determination.

Old forest

In its most recent forest stewardship plan for the Quadra-Quinsam blocks of TFL 47, TimberWest states that since landscape level planning has not been completed, it will use the 2004 Order Establishing Provincial Non-Spatial Old Growth Objectives. For Quadra Island and the Bonanza Lake blocks this means the target for old forest is “>9 percent”. But both the Quadra and Bonanza blocks contain less old forest than the target level. For example, TimberWest has stated that old forest in the Special Management Zone 19 portion of TFL 47 on Quadra Island is 3.8 percent.

The “non-spatial” part of that order should not be interpreted by TimberWest to mean that the company does not need to identify specific areas of old forest for conservation. If the amount of old forest remaining in TFL 47 was greater than 9 percent, then TimberWest could reasonably interpret “non-spatial” as meaning it did not have to commit to conserving specific areas of old forest. But TimberWest has logged itself far past that luxury.

TimberWest needs to identify the location of remaining old forest in both blocks and commit in writing to conserving those forests. It should also nominate specific areas of older mature forest that it will commit to not log that would bring the total (recruitment+old) to at least 9 percent. The land base netdown summary needs to include at least 9 percent of the area of the Quadra Landscape Unit and at least 9 percent of the area of the Bonanza Landscape Unit as old forest reserves.

TimberWest acknowledges the issue of old growth deferral areas but only commits to conduct a “sensitivity analysis” to “examine the impact of prohibiting harvesting in these areas.” Based on the Technical Advisory Panel’s mapping of priority deferral areas, it appears that in every block of TFL 47, the extent of remaining old forest is well below the legal target (>9 percent) established by the 2004 Order Establishing Provincial Non-Spatial Old Growth Objectives.

Based on the TAP old forest priority deferral areas and the area of TFL 47 in each block, our calculations shows the following extent of old forest, block by block:

Block 2 (West Cracroft Island): 0 percent

Block 5 (Mainland): 0 percent

Block 6 (Hardwicke Island): 8.6 percent

Block 6 (Mainland portion): 1.3 percent

Block 7 (Mainland): 1.3 percent

Block 8 (West Thurlow Island): 8.4 percent

Block 9 & 10 (East Thurlow Island): 6.3 percent

Block 11 (Sonora Island): 4.3 percent

Block 12 (Quadra Island): 2.1 percent

Bonanza Lake (Block 17): 1.6 percent

For the entire area of TFL 47, TAP identified only 2.6 percent (3309 ha) as being old forest.

TimberWest’s position—that it will examine the “impact” of abiding by the law—is concerning. At the very least, there should be no question that it will abide by the 2004 Order Establishing Provincial Non-Spatial Old Growth Objectives, which would mean reserving all of TAP’s priority deferral areas if they are actually old forest.

TimberWest has evaded landscape-level planning in TFL 47 since 2000 and so has not established a single legal old growth management area (OGMA) in the entire TFL. Coupled with the need to meet the target for the Provincial Non-Spatial Old Growth Objectives, there is the added impetus that arises from the fact that old forest throughout the TFL has been logged below the level considered to be high-risk for biodiversity loss (10 percent). Obviously, all remaining old forest should be identified as reserves of some form, preferably legal OGMAs. As mentioned above, the netdown summary of areas to be excluded from the timber harvesting land base (THLB) should include an area of mature recruitment forest and all existing old forest, equivalent to at least 9 percent of each landscape unit. In the proposed management plan netdown summary there is currently only a 547-hectare removal for old forest in the Bonanza Lake block. The netdown summary should include at least 9 percent of the 48,805 hectares of Block 12 and Block 17 (4392 hectares) for a minimal old-forest target.

Lack of accurate timber harvesting land base mapping for TFL 47

A TFL management plan is required, in part, to guide the Chief Forester’s Office in revising the allowable annual cut for the TFL. An essential part of that determination involves an accurate estimate of the area of productive forested land that is acceptable and economically feasible to log, which is the definition of the “timber harvesting land base”. Although many TFLs in BC have created detailed mapping of the THLB in their licence area, TimberWest has not. The timber supply analysis performed by Ecora is, therefore, based on crude, opaque estimates of the THLB that cannot be verified and are, therefore, unreliable for the purpose of determining a sustainable AAC.

Quinsam FDU

There is no mention of the Quinsam FDU in this proposed management plan, yet it was part of the Quadra-Quinsam Forest Stewardship Plan proposed in 2022. The management plan should include an explanation of what happened to the Quinsam FDU and the impact on both the netdown summary and the proposed AAC.

First Nations land claims

There are First Nations land claims throughout the area covered by TFL 47. The netdown summary does not include the likely loss of THLB that settlement of these claims would involve.

Land base netdown summary specific to Quadra Island

Ecora’s current netdown summary lumps both the Quadra Island and Bonanza Lake blocks together. Quadra Island has a significant human population which utilizes forested areas of TFL 47 for recreational, food gathering, ceremonial and tourism purposes. Use goes up in spring, summer and fall, and could provide the basis for business operations that rely on an abundant supply of relatively (compared to clearcuts) undisturbed nature. Much of the Quadra population is also concerned about the impact of logging on wildlife habitat, climate change and increasing wildfire hazard.

TimberWest could easily present two sets of information in the land base netdown summary: one for Quadra Island and one for the Bonanza Lake block.

Additionally, TimberWest could provide maps of where it believes logging is economically feasible.

Ecora’s 2012 timber supply analysis for TFL 47 showed (Figure 2) that approximately 7063 hectares of productive forest land in TFL 47 on Quadra Island was in the timber harvesting land base. The definition of the THLB is forested land where logging “is considered both acceptable and economically feasible”. TimberWest is the expert on “economically feasible”. But who is the judge of where logging is “acceptable”? Certainly not TimberWest. In order to reduce tensions between those interested in logging and those interested in undisturbed nature, TimberWest could provide mapping that indicates where the approximately 3140 hectares of productive forest land in TFL 47 that TimberWest does not consider to be “economically feasible” to log are located.

These two steps—providing a netdown summary specific to Quadra Island and acknowledging on a map of TFL 47 on Quadra where logging is not economically viable—would go a long way to resolving potential conflicts between TimberWest’s logging and other uses of the forest, including First Nations’ land claims.

Land Base Netdown summary for Quadra Island/Bonanza Lake (page 14)

This table has a number of obvious errors that call into question the reliability of all of the numbers included. Consider, for example, lines 3 and 4. Note the numbers in the “Area Removed” column. The number “1,455” appears on both line 3 and line 4. In both cases, the area removed (“1,455”) is greater than what appears in the “Total Area” column. According to the “Version Control and Revision History” table that appears on an unnumbered page of the report (third page from the beginning), this report was reviewed twice by TimberWest and once by the Ministry of Forests. Since an accurate land base netdown summary is foundational to a credible determination of the allowable annual cut, getting the numbers right in the netdown summary is essential. Yet Ecora, TimberWest and the Ministry of Forests didn’t catch these errors. Is any one actually reading these reports? Why should the public have any faith in any of the information included in the report?

Other errors in—and questions about—the netdown summary table include:

• The “Total Area” of Block 12 and 17 do not coincide with the areas given on the maps for TFL 47 at the MoF website. Moreover, the map for Quadra Island is incorrect since it includes District Lot 488, which was deleted from the TFL following the Forestry Revitalization Act in 2003. That lot is now part of Woodlot 2032 and Woodlot 1969. You can do the arithmetic.

• The “Non-forest” area on line 2 is intended to cover such features as lakes and areas of rock: areas where forest does not grow. In the 2012 information package for the TSR for TFL 47, “Non forest” for the entire TFL was estimated at 6,281 hectares. Of that, 6,264 hectares were removed through the netdown process. The rate of removal then was 99.7 percent. That’s what we would expect for land that is “non forest”. Yet in the proposed management plan, the “Non-Forest” (line 2) “Total Area” for just Quadra and Bonanza is given as “7,790” hectares and the “Area Removed” is “3,735” hectares. That’s equivalent to a mere 47.9 percent removal for “Non-forest”. Why is this not closer to 100 percent, as in the 2012 analysis? And since we are now considering a smaller area than in the 2012 analysis, which looked at the entire area of TFL 47, why is there a higher starting point for “Non Forest”? Again, this kind of inconsistency calls into quetion the care with which this report has been created.

• Presumably “Analysis Forested Land Base” should equal the TFL “Total Area” minus “Non-forest” minus “NP Site Series” minus “Roads”. It doesn’t.

• The area removed for “Inoperable” is 67 percent of the area judged to be “Inoperable”. In the 2012 MP it was 81 percent. Why has this fraction fallen?

• For the category Wildlife Tree Retention/ Riparian in the netdown summaries, there is a much reduced area removed for the Bonanza-Quadra blocks compared with what is shown for the entire TFL, given the relative size of each. What accounts for this difference?

• For the entire TFL, the total forested land base removed for recreation (trail + reserve + site + recreation inventory) is 355 hectares. In the 2012 management plan netdown summary, 1,100 hectares were removed for recreation. Why is there such a large decline in the area removed for recreation? Since most of the human population within TFL 47 is on Quadra Island, this is the area where the highest need for forest-based recreation exists, both for residents and visitors. It is likely that Quadra Island alone should have a recreational reserve of at least 3000 hectares to cover current and future recreational needs in these areas: Heriot Ridge, Missing Links-Nighthawk Lake, Morte Lake, Chinese Mountain-Beech’s Mountain, Nugedzi Lake-Mount Seymour, Mount Lolo-Saltwater Lagoon, plus as-yet undeveloped recreational areas towards the north end of Area A of Block 12. All of these areas have very low timber values as a result of the prevalence of rock, lakes and steep slopes.

• Why has no area been removed for “high-value fish habitat” in the Quadra Island/Bonanza netdown summary? Quadra Island has three important salmon spawning streams (Hyacinthe Creek, Open Bay Creek and Village Bay Creek) which locals most definitely consider “high-value fish habitat”. Much of the watersheds of all three are within TFL 47.

• There are 1012 hectares of “no harvest” ungulate winter range (UWR) and 507.5 hectares of “conditional harvest” UWR in the Bonanza Lake block, none on Quadra Island. There are only 70.6 hectares of overlap of these areas with wildlife habitat areas. Why has UWR been netted down to 810 hectares?

• The wildife life habitat areas in the Bonanza/Quadra netdown summary are all in the Bonanza block. What are the specific overlaps with other exclusions that result in them being netted down from 359 hectares to 194 hectares? Please provide specific information.

• Why have no wildlife habitat areas been established in the TFL 47 portion of Quadra Island?

• 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)”. 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.” On the SMZ 19 portion of Quadra Island, under Objective A. 1. (b) of the VILUP HLPO this 7 percent should be within the associated cutblocks. In the rest of Quadra and in the Bonanza Lake block, Section 66 also applies, albeit without the requirement of retention areas being within cutblocks. In all cases, TimberWest cannot log these Section 66 wildlife tree retention areas until the surrounding regrowth has reached maturity. Why doesn’t the netdown summary include a 7 percent reduction in the “Forested Land Base” to account for the requirements of Section 66?

• Red-listed plant communities have been identified by the BC Conservation Data Centre on Quadra Island. Why is there no area removed for these occurrences?

• Only 100 hectares of karst has been removed. Presumably, this is on Quadra Island, where there is a significant karst area below TFL 47. Please provide a map showing the location of the 100 hectares of karst that have been reserved.

• The netdown summary shows that 1369 hectares of CWHvm1 old growth in the Bonanza block have been netted down to 547 hectares. What specific overlaps with other categories of removals have reulted in this reduction?

• Why is there no area reserved for blue-listed plant communities?

• Why is only 21 percent of the most unstable terrain (Class V) removed from the forested land base in the netdown summary?

• Why has no area been removed to meet visual quality objectives for both Quadra Island and the Bonanza block?

Conflict of interest

TimberWest is owned by the British Columbia Investment Management Corporation (BCI). BCI’s investments fund pensions for retired BC government employees, including those of the Ministry of Forests. The health of those pension funds is naturally an important part of the considerations about the future personal economic security of any BC government employee, including those who work for the Ministry of Forests.

Therefore, when an employee of the Ministry of Forests—or any provincial government ministry or agency—makes a decision that could affect the economic position of TimberWest, they likely know they are making a decision that could influence their own long-term financial security. In that circumstance, a conflict of interest—or, at the very least, the perception of a conflict of interest—exists between the general public interest and the individual interests of BC government employees making decisions about TFL 47. An AAC determination for TFL 47 should, therefore, be conducted by an independent body or person with no possible personal interest in the outcome of the determination. That would exclude the BC chief forester or their designate, which creates a legally untenable situation: Only the chief forester is empowered by the Forest Act to undertake an AAC determination for a TFL.

Thank you for reading. We look forward to your full response.

Sincerely,

The Discovery Islands Forest Conservation Project