(2024-04-26) Discovery Islands Forest Conservation Project response to TimberWest's Forest Operations Map of 18 proposed cutblocks and road segments on Quadra Island

cc’d by email

We Wai Kai First Nation Chief Ronnie Chickite: ronnie.Chickite@WeWaiKai.com

TimberWest: ForestOperationsMap@MosaicForests.com

Campbell River District Manager Lesley Fettes: Lesley.Fettes@gov.bc.ca

Comments on cutblocks 11619, 11620, 11621, 11622 and new roads

[1] Proposed cutblock 11621-12-145 appears to overlap with a 1.3-hectare area of old forest that we have mapped as Area Q 163 (Long Lake Grove). You will find that area on the map on this page. You can view photographs of some of the trees in this area on this page. TimberWest’s usual practice on Quadra Island is to leave patches of trees older than 250 years of age but log all younger trees around and between them, thus destroying rare ground-level old-forest habitats and associated biodiversity. The Vancouver Island Summary Land Use Plan provided guidance on how such old forest was to be handled in Special Management Zone 19:

“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;”

Given that guidance, TimberWest should plan to leave an area of recruitment forest around the existing patch of old forest at this location.

We also note that this matter is part of the subject of an active complaint to the Forest Practices Board.

[2] Proposed cutblocks 11619 and 11622 are located close to the edge of Beech’s Creek Ravine, which contains a concentration of Douglas fir and red cedar veterans. Based on the guidance contained in the Vancouver Island Land Use Plan for Special Management Zone 19, the Discovery Islands Forest Conservation Project recommends leaving a buffer of recruitment forest above the ravine on its west and east side sto help to restore an old-growth ecosystem in this ravine. This would support listed species such as the northern red-legged frog, wandering salamander, northern goshawk and peregrine falcon—all recorded by the project—that occur in the area.

[3] The crude representation of the boundaries of these cutblocks in the FOM doesn’t allow for an accurate depiction of what TimberWest is planning for the area within the cutblocks. For example, we can’t tell whether the proposed cutblocks will meet Objective A. 1. (b) of the VILUP Higher Level Plan Order (HLPO), which states: “Sustain forest ecosystem structure and function in SMZs, by… retaining within cutblocks, structural forest attributes and elements with important biodiversity functions…” Our interpretation of this objective is that “structural forest attributes and elements” includes leaving some standing mature trees within the cutblock. A full discussion of what is necessary to sustain forest ecosystem structure and function can be found here. Please provide us with assurance that TimberWest will abide fully with this legal order. We also note that this matter is part of the subject of an active complaint to the Forest Practices Board.

[4] The proposed 1.64 kilometres of new roads, at 4 metres wide including ditching and clearance, will result in 6600 square metres of permanent deforestation and a commensurate permanent diminishment of the provincial carbon sequestration capacity. How will TimberWest offset that loss?

[5] TimberWest’s practice has been to apply for export as raw logs all of what it cuts on Quadra Island. This logging, therefore, will provide only 2-3 months of local employment for 4 or 5 people. We recommend that TimberWest build a small mill on Quadra Island to process logs that will provide additional local employment and make available affordable, locally grown lumber on the Discovery Islands. Has TimberWest explored such a possibility with We Wai Kai First Nation?

[6] TimberWest’s normal practice is, after logging, to pile and burn the approximately 40-50 percent of forest biomass that cannot be commercially utilized. This archaic practice would add immense quantities of carbon to the atmosphere during a time in which the federal government has declared a “climate emergency”. What are TimberWest’s plans for eliminating the carbon emissions associated with the non-utilizable waste from these 4 cutblocks?

[7] The proposed logging would leave slash piles close to roads. This would allow islanders to salvage firewood from those piles. Unfortunately, this practice increases the risk of human-caused forest fire. The cutblock itself will have a higher fire hazard (because of the slash-type fuel ) than the mature forest that will be logged. This condition, which is most dangerous during extreme fire weather, will persist for up to two decades. Since all of these proposed cutblocks are directly upwind from the built-up part of Quadra Island, this logging and the practice of firewood salvaging will place human habitation at great risk. We recommend that TimberWest confine its logging operations in TFL 47 to north of the Mount Seymour area to avoid a repetition of the 1925 fire which destroyed much of the south island’s forest and homes.

Comments on proposed cutblocks 11623, 11624, 11625, 11626, 11627, 11628 and new roads

[1] The total area of forest cover loss from these six proposed cutblocks would be 15.82 hectares. The permanent forest loss as a consequence of the proposed 2.03 kilometres of logging road, at 4 metres wide, would be 8,120 square metres. This loss of forest cover and permanent forest loss would have significant climate impacts compared to the economic value of the logging. This development would also degrade and fragment five important forest-aquatic ecosystems in the area, as described below.

[2] The small Lake to the southeast of Two-Mile Lake is known to our project as Floating Islands Lake. It’s name comes from six small, apparently floating (or partially floating) islands of vegetation and soil around the lake’s edges that have formed, perhaps the result of trees having fallen into the lake over time. This is the only lake of Quadra’s 80-plus lakes/ponds that has these special habitats. TimberWest’s proposed cutblocks 11623, 11625 and 11626 would degrade the surrounding ecosystems both physically and aesthetically.

[3] Proposed cutblock 11625 would encroach on a unique bog to the east of the lake, most of which is inside Main Lake Provincial Park, and around which there is an equally unique old-forest ecosystem that includes an active osprey nest (on the south side of the bog) and many large, old Douglas firs. The osprey nest tree is about 250 metres from the east edge of proposed cutblock 11625. The Ministry of Environment recommends no blasting within 1000 metres of an osprey nest and a buffer of between 200 and 500 metres between the nest and logging, especially during nesting season.

[4] Proposed cutblock 11628 and the adjacent proposed roads encroach very closely on a beaver pond known to the project as Castor Pond. The pond has supported an active beaver lodge and mating beaver pair for many years. There are very few remaining beaver lodges on Quadra Island and the proposed logging would fragment and degrade the habitat required for their survival. The existing Clear Lake Main road along with the proposed new roads and cutblock 11628 would virtually encircle the pond, degrading its potential as a safe habitat for the beaver pair and the numerous resident and migratory birds that use the pond. Listed species including northern red-legged frog and Hammond’s flycatcher have been recorded in the area by our project, along with cougar, wolf and black bear.

[5] Cutblock 11627 is also located close to a wetland area/pond, the west end of Floating Islands Lake and the creek between Floating Islands Lake and Two-Mile Lake. Like the other proposed cutblocks in this area, this cutblock and road would badly fragment what is known to be well-occupied wildlife habitat that includes Douglas fir veterans.

[6] The proposed complex of clearcuts around and between the lakes, the beaver pond, the bog and the wetland will dramatically fragment and diminish this important wildlife habitat area. If TimberWest will log here, they clearly will log anywhere on Quadra Island. By definition, the “timber harvesting land base” only includes forested land which is “acceptable” for logging. This area is completely unacceptable.

[7] We also note that three of the proposed cutblocks are within 50 metres of Main Lake Provincial Park. A more appropriate buffer would be 200 metres in an area that was more acceptable for logging. TimberWest has a history of encroaching on the park along its western edge. In 2004-2005, cutblock 12-44A crossed into the park at the west end of Little Main Lake.

[8] As mentioned in our comments about the other proposed cutblocks, these cutblocks would produce significant deleterious impacts on carbon emissions, forest carbon sequestration capacity and forest fire hazard.

[9] Because this is an exceptionally ecologically-sensitive area right beside a provincial park, we request that TimberWest abandon its plans for these cutblocks.

Comments on cutblocks 11629, 11630, 11631, 11632 and 11633 southwest of Morte Lake

This comment applies to all of the 18 new cutblocks TimberWest is proposing.

In total TimberWest wants to log 37.39 hectares over the 18 cutblocks listed for 2024. This will result in the release of a carbon bomb into the atmosphere. By “carbon bomb” we mean a prolonged release of biogenic carbon to the atmosphere at a rate far greater than would naturally occur if TimberWest had not logged these forest stands and had, instead, let them grow through their natural lifecycle.

How big is the carbon bomb?

We use 2019 as a reference year. TimberWest removed an average of 1466 cubic metres of logs/hectare during its 2019 operations on Quadra Island. It left approximately the same volume of logging waste in clearcuts as the volume of logs it removed. Some of this waste was burned in slash piles but the remainder was left to decompose in the clearcut. That means the company was responsible for the premature decomposition of approximately 3000 cubic metres of biomass (logs plus waste) per hectare logged. That 3000 cubic metres/hectare would prematurely release the equivalent of 2400 tonnes of carbon dioxide per hectare logged.

The total carbon emissions resulting from the 18 new cutblocks TimberWest is proposing on Quadra Island for 2024 (it has already logged two others this year) would be approximately 89,736 tonnes (37.39 hectares x 2400 tonnes per hectare) of CO2-equivalent emissions (see “Our methodology”, here). This is equivalent to putting 19,500 average Canadian passenger cars back on the road for a year.

Even though TimberWest exports as raw logs virtually all of the forest it logs on Quadra Island, it could argue that some of the carbon removed from its clearcuts will be sequestered for many years in wood products manufactured in those countries. But consider what actually happens to the forest biomass after it is logged in BC. Most of the dead biomass left in a clearcut—which amounts to approximately half the volume of the original biomass that was in the stand before it was logged—is returned quickly to the atmosphere, much sooner than it would have been if the forest had been left standing. For the portion of that biomass which is burned in slash piles, the return is immediate.

Just over half of the volume of the logs that are removed from the clearcut quickly become wood chips or sawdust; that’s because the utilization rate at sawmills is only about 50 percent (46.5 percent in BC). Most of the carbon in the sawdust and wood chips becomes sequestered in products such as cardboard, paper and other short-lived products and is returned to the atmosphere relatively quickly. Provincial carbon scientist Caren Dymond’s research (page 13) shows that only 11 percent of the carbon contained in logs removed from the stand is still safely stored 100 years later. So eighty-nine percent of the carbon in that volume has returned to the atmosphere.

Since the volume of logs removed is only about half of the biomass that was originally in the forest stand, only a small fraction—about 6 percent—of the total carbon in the original biomass of the stand is likely to stay out of the atmosphere longer than 100 years. On the other hand, if the original forest had been left standing, Ministry of Forests growth and yield curves show the forest would most likely have continued to sequester more and more carbon over those 100 years.

If the area cut is replanted and successfully grows back it would eventually recapture some of the carbon lost to the atmosphere; but in the meantime, the carbon debt created can never be repaid.

Related to this sobering reality is the question of how logging companies will respond to the need to address climate change by mitigating (or not) the role they play in making it worse. TimberWest/Mosaic Forest Management announced 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, its 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.”

So TimberWest is choosing not to log some of its privately owned land because it can make more money by letting the trees stand instead of logging them. They are able to do this because the threat of climate change and the need to mitigate that has created a new set of economic opportunities. We suggest that TimberWest could lead development of a similar market for sequestering carbon in publicly owned forests by significantly reducing the volume of trees it logs on publicly owned land. Whatever it can do to reduce the carbon bomb it is creating with these 18 clearcuts in 2024 will help to reduce its impact on climate change—not to mention forest fire hazard and biodiversity loss.

This would create an outcome that is much more beneficial for the Quadra community than continuing to maximize logging on the island to produce logs for Chinese and Japanese mills and workers to process.

Comments on cutblocks 11616, 11617 and 11618 and new roads

[1] Proposed cutblock 11616 is in an area between Two-Mile Lake and a pristine bog that nearby residents Jolie and Greg Shea have informed TimberWest contains old forest, is a wildlife corridor and is in the small watershed that feeds their source of drinking water. TimberWest’s usual practice on Quadra Island is to leave individual trees older than 250 years of age but log all younger trees around and between them, thus destroying the rare ground-level old-forest habitats and associated biodiversity. The Shea family told TimberWest: “We have put wild life cameras system in this area and have seen wolf, cougar, fishers, deer, raccoons and seen northern pygmy owls, peregrine falcons and many migratory birds that use these lakes and bogs to rest.”

TimberWest is proposing to log the forest on the northeast side of the bog. That stand contains patches of old forest with Douglas fir and western red cedar. The bog is part of the watershed that supplies water to residences along Granite Bay Road, to the left.

Regarding such patches of old forest, as mentioned above, the Vancouver Island Summary Land Use Plan provided guidance on how they were to be handled in Special Management Zone 19:

“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;”

Given that guidance, TimberWest should abandon this cutblock and plan to leave an extended area of recruitment forest around the existing patches of old forest at this location.

[2] Proposed cutblocks 11617 and 11618 are near to 11616 and may also contain concentrations of Douglas fir and red cedar veterans. In any case, based on the guidance contained in the Vancouver Island Land Use Plan for Special Management Zone 19, the area of these proposed cutblocks should be used for recruitment of mature forest to bolster the long-term ecological viability of the old forest/concentration of old trees that exists in proposed cutblock 11616.

[3] The crude representation of the boundaries of these cutblocks in the FOM doesn’t allow for an accurate depiction of what TimberWest is planning for the area within the cutblocks. We can’t tell whether the proposed cutblocks will meet Objective A. 1. (b) of the VILUP Higher Level Plan Order (HLPO), which states: “Sustain forest ecosystem structure and function in SMZs, by… retaining within cutblocks, structural forest attributes and elements with important biodiversity functions…”

As mentioned above, our interpretation of this objective is that “structural forest attributes and elements” includes leaving some standing mature trees within the cutblock. Please provide us with assurance that TimberWest will abide fully with this legal order.

[4] The proposed .484 kilometres of new road, at 4 metres wide including ditching and clearance, would result in 1936 square metres of permanent deforestation and a commensurate permanent diminishment of the provincial carbon sequestration capacity. How will TimberWest offset that loss?

[5] TimberWest’s past practice has been to apply for export of all of the logs it cuts on Quadra Island. This logging, therefore, will add minimally to local employment, providing only 1-2 months work for 3 or 4 people. We recommend that TimberWest build a small mill on Quadra Island to process logs that will provide additional local employment and make available affordable, locally grown lumber on the Discovery Islands. Again, has TimberWest explored such a possibility with We Wai Kai First Nation?

[6] TimberWest’s usual practice is, after logging, to pile and burn the approximately 50 percent of forest stand’s biomass that cannot be commercially utilized. This archaic practice would add immense quantities of carbon to the atmosphere during a time that the federal government has declared a “climate emergency”. What are TimberWest’s plans for eliminating the carbon emissions associated with the non-utilizable waste from these 3 cutblocks and all the others it creates in TFL 47?

[7] The proposed logging would leave slash piles close to roads. These would allow islanders to salvage firewood from those piles. This salvaging is often done during the summer, often without permits. Unfortunately, this practice increases the risk of human-caused forest fires. The cutblocks will have a higher fire hazard (because of the slash-type fuel) during extreme fire weather than the mature forest that would be logged. This higher-hazard condition will persist for up to two decades. These proposed cutblocks are in close proximity to the Shea’s and other homes. This logging slash—made riskier by the practice of salvaging firewood from clearcuts—will place these homes at greater risk. We recommend that TimberWest confine its logging operations in TFL 47 to areas that are at least 2 kilometres distant from the nearest buildings. TimberWest was aware of the existence of private property on Quadra Island at the time it acquired TFL 47. It should accept that it cannot safely and responsibly log near to built-up areas, especially with climate change expected to bring longer periods of extreme fire weather to its licence area.

Sincerely,

David Broadland for the Discovery Islands Forest Conservation Project

PS This comment has been made public (in 4 parts with supportive photographs and other documents) here: https://www.discoveryislandsforestconservationproject.ca/comments-on-proposed-cutblocks-and-roads/