The following letter was received by the DIFCP from TimberWest in response to our comments regarding a proposed forest stewardship plan that would cover TFL 47 on Sonora Island, East Thurlow Island, West Thurlow Island and Hardwicke Island:
April 3, 2024
Thank you for providing your comments on behalf of the Discovery Island Forest Conservation Project (dated March 14, 2024) on the proposed amendment to the Johnstone Strait Forest Stewardship Plan (FSP). This FSP is being amended to reflect the recent amendment to the Great Bear Rainforest Land Use Objectives Order (GBRLUO 2023).
Please see the information below provided in response to your comments. Note that our response is limited to comments directly related to the proposed FSP amendment. However, when submitting the FSP amendment to the Ministry of Forests, a copy of all written comments received will be included.
[1] Mapping accuracy
The Thurlow Special Forest Management Area (SFMA) was established in 2016, which “resulted in the deletion of Crown land from the tree farm licence area” (Great Bear Rainforest (Special Forest Management Area) Regulation, effective December 31, 2016). The FSP map associated with the proposed amendment has been updated to include the SFMA. See attached map.
Mosaic is in discussions with Ben Morton (Director, Strategic Initiatives) and Montana Goddard (Manager, Ecosystem-Based Management), with the Ministry of Forests, regarding the TFL 47 boundary and the Thurlow SFMA. We are working together on next steps to formally remove the Thurlow SFMA from the TFL 47 boundary.
[2] Ecological sensitivity of small islands
Sonora, East Thurlow, West Thurlow and Hardwicke Islands are located within the GBRLUO Order Area. Under the JS FSP, TimberWest operates within the GBRLUO Order Area where ecosystem-based management guides forest management activities (EBM). EBM has two concurrent goals, maintaining ecosystem integrity and improving human well-being.
[3] Red- and blue-listed animal species
The Queen Charlotte Goshawk, Red-legged Frog and Keen’s Long-eared Myotis have Orders for Wildlife Habitat Areas. The Species at Risk Notices (FPPR Section 7) for the Campbell River District can be found at the following link: https://www.env.gov.bc.ca/wld/frpa/notices/sar.html#cr.
Please note that Keen’s Long-eared Myotis is no longer a recognized species, they are now combined with Little Brown Myotis (Myotis lucifugus).
Queen Charlotte Goshawk (Accipiter gentilis laingi) are managed through a combination of legal WHA’s developed by the provincial government and voluntary non-WHA goshawk breeding areas. Mosaic monitors all known or suspected goshawk breeding areas for occupancy and activity during the breeding season.
Management for Red-legged Frog (Rana aurora) is achieved through a combination of legal WHA’s and more locally, maintaining riparian buffers where breeding may occur.
[4] Queen Charlotte Goshawk
Contrary to your assertion, the West Thurlow WHA has in fact been active since 2014. The territory was active and successful in 2016, occupied but inactive in 2017 & 2018 and active and successful in 2023. The nests that the West Thurlow WHA is anchored around were found by David Vey, Registered Professional Biologist (RPBio), Stewardship Biologist with Mosaic.
Despite your claim that the area of Hardwicke Island is “barely large enough to support one or two breeding pairs of goshawk”, Hardwicke Island supports at least four (4) goshawk breeding areas that Mosaic monitors annually. In addition, the CDC mapped goshawk nest (HARD1) was found by field crews working for TimberWest and reported to the CDC by TimberWest. In 2004 the nest was found to have fallen from the tree and the tree was subsequently harvested in 2006 as part of block 6-82C.
Our practices around Species at Risk meet or exceed provincial standards and our monitoring results show that our practices have not impacted goshawk territory occupancy, breeding activity or nest productivity.
[5] Red- and Blue-listed plant species
The Integrated Pest Management Act (IPMA) and regulation are administered by the Ministry of Environment and Climate Change Strategy. The guiding principle in forest vegetation management is “integrated pest management”, which is the management of the forest vegetation using both preventative and direct methods of pest control.
The Forest Planning and Practices Regulation (FPPR) outlines the content requirements of an FSP - this includes the results and strategies an agreement holder must include in their FSP for the B.C. government’s eleven resource values and all measures written to protect against invasive plants and to maintain natural range barriers.
[6] Red- and blue-listed plant communities
The text that you included in your comment related to red- and blue-listed plant communities is a direct quote from the objective for red-listed plant communities and blue-listed plant communities as written in the Great Bear Rainforest Land Use Objectives Order (2023).
Schedule N (red-listed plant communities) and Schedule O (blue-listed plant communities) can be found with the GBRLUO Order at the link below:
https://www2.gov.bc.ca/gov/content/industry/crown-land-water/land-use- planning/regions/west-coast/great-bear-rainforest/great-bear-rainforest-legal- direction-agreements.
As stated in the FSP strategy, Land Management Handbook #72 will guide the identification of sufficiently established occurrences of red-listed plant communities and blue-listed plant communities.
[7] Species at risk
As per the Section 7 Notice Backgrounder, “In the four northern MAMU Conservation Regions (Alaska Border, Haida Gwaii, Northern Mainland Coast, Central Mainland Coast), spatial suitable habitat analyses indicate that amounts of suitable habitat will exceed minimum habitat thresholds without the need for additional habitat protection measures. In northern regions, the amount of suitable habitat will be monitored over time to ensure minimum habitat thresholds are achieved.” The areas you refer to in your comments (i.e. Hardwicke, West Thurlow, East Thurlow and Sonora Islands) are all within the Central Mainland Coast MAMU Conservation Region and are not within the area covered by the Marbled Murrelet Land Use Objectives Regulation Order.
[8] Old forest
Similar to [6], the text that you included in your comment is a direct quote from the objective for old forest maintenance and recovery as written in the Great Bear Rainforest Land Use Objectives Order (2023). Schedule G can be found at the link provided in [6] above.
Where there is not enough old forest available to meet the targets for each site series group in the order area (Column B Schedule G) and each site series group in a landscape unit (30%), recruitment to meet the old forest requirements no later than 2264 is done via the Landscape Reserve Design (LRD). The LRD must address the minimum old forest retention levels.
[9] Climate change and rate of cut
The Ministry of Forests provides a guide for developing stocking standards, most recently updated in September 2021 for climate change. This guide is available at the link below:
https://www2.gov.bc.ca/gov/content/industry/forestry/managing-our-forest- resources/silviculture/stocking-standards
Sincerely,
Jennifer Peschke, RPF
Area Forester, Mosaic Forest Management
See the DIFCP’s response to TimberWest
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