To: Jennifer Peschke, RPF, Area Forester, TimberWest TFL 47
cc: Lesley Fettes, RPF, Campbell River District Manager of Ministry of Forests
cc: Domenico Iannidinardo, RPF, TimberWest Chief Forester
Dear Jennifer,
Regarding your response to our comments on the proposed forest stewardship plan (FSP) for the Johnstone Strait unit of TFL 47:
[1] Mapping accuracy
Thank you for adjusting the map of TimberWest’s tenure so that it shows the Thurlow Special Forest Management Area is outside of TFL 47.
[2] The ecological sensitivity of small islands
In response to to our concern about the ecological sensitivity of small islands, you note that for TimberWest’s operations in the Great Bear Rainforest Land Use Order (the Order) area, “ecosystem-based management guides forest management activities (EBM). EBM has two concurrent goals, maintaining ecosystem integrity and improving human well-being.”
With respect, this reference to EBM does not address our concern about the ecological sensitivity of small islands. Moreover, since TimberWest has raised EBM as though that is an answer to our concern, it appears necessary to review with you the full description of EBM that is included in the Order and to examine what this means.
The Order states: “The Province is committed to implementing ecosystem-based management in a manner that maintains ecosystem integrity and improves human well-being concurrently. Ecosystem integrity is being maintained when adverse effects to ecological values and processes are minimal or unlikely to occur. A high level of human well-being is being achieved when the quality of life in communities is equal to or better than the Canadian average.”
We believe TimberWest’s record of recent logging on the small islands in the Thurlow Landscape Unit are having a much greater adverse effect on ecological values and processes than “minimal” or “unlikely to occur”.
We provided you with the example of West Thurlow Island. We stated: “Over the 27-year period between 1990 and 2015, for example, 3818 hectares of 8133-hectare West Thurlow Island were logged. That is equivalent to 47 percent of the entire area of the island. Most of that (3369 hectares, or 41 percent) occurred in the 19 years between 1997 and 2015. The worst damage—by far—was caused by TimberWest.”
However, when we consider the loss of forest cover on what TimberWest considers to be productive forest on West Thurlow Island, the actual ecological damage comes into clearer focus. Based on Ecora’s 2012 estimates of the Crown forested area in the entire Thurlow Landscape Unit (page 6 of that report), we estimate that the area of productive forest on West Thurlow Island is approximately 5980 hectares. Between 1990 and 2015, then, approximately 64 percent of the productive forest cover was removed.
It should be self-evident that removing 64 percent of that island’s productive forest over a 27-year period (or 56 percent over a 19-year period) could not reasonably be judged to have had “minimal” adverse effects on ecological values and processes. Clearcut logging an area of forest causes an immediate cessation of most of the ecological processes that occurred previous to logging. For example, photosynthesis no longer takes place in that area; the cycling of carbon and nutrients associated with the trees no longer takes place; carbon sequestration no longer takes place; the forest’s hydrological function is lost.
The meaning of “minimal”, according to the Oxford English Dictionary, is “extremely small; very slight; negligible”. We suggest that TimberWest’s understanding of the word “minimal” needs some work.
In the years 2012, 2013 and 2014 (three years) TimberWest cut 943 hectares of the 5978-hectare productive forest area of West Thurlow Island, or about 16 percent. That works out to an average of 4 percent per year. In the worst year (2012), TimberWest cut 6 percent of the island’s entire productive forest area. That is far above any reasonable interpretation of the meaning of the word “minimal”.
What would be a reasonable interpretation of the word “minimal” on an island by island basis?
The Thurlow Landscsape Unit lies mainly within the CWHxm2 biogeoclimatic zone variant. According to the most recent science, which is included in the 2020 Standards for Assessing the Condition of Forest Biodiversity under British Columbia’s Cumulative Effects Framework, the estimated minimum natural disturbance return interval for West Thurlow Island is about 700 years. That is, the average period of time between stand-replacing natural disturbances for any given area of forest would be a minimum of 700 years. In other words, scientists now understand that the shortest period of time in which the entire forested area would naturally replace itself would be about 700 years. For logging to mimic that natural rate of replacement, only 1/700 of the productive forested area could be logged each year, or 8.54 hectares.
For the entire Thurlow Landscape Unit, the allowable annual cut on the 31,540 hectares of productive Crown forested area should be no more than 45 hectares, and this should be spread commensurately between the islands.
In our view, this is the only scientifically defensible interpretation of the word “minimal” in the Great Bear Rainforest Order’s definition of “ecosystem-based management”.
We note, too, that under section 9 of the Forest Planning and Practices Regulation, the objective set by government for wildlife and biodiversity at the landscape level is: “to the extent practicable, to design areas on which timber harvesting is to be carried out that resemble, both spatially and temporally, the patterns of natural disturbance that occur within the landscape”.
TimberWest’s strategy to meet that objective, as stated in its proposed FSP, is to abide by sections 64 and 65 of the Forest Planning and Practices Regulation. Section 64’s intention is to limit the size of an individual cutblock, in this case to 40 hectares. Section 65’s intention is to ensure that new cutblocks are only located near to adjacent cutblocks when the regrowth in those cutblocks has reached a height of at least 3 metres. Neither of these regulations addresses the objective of ensuring that timber harvesting resembles, “both spatially and temporally, the patterns of natural disturbance that occur within the landscape.” Those two sections alone allow a rate of logging that far surpasses the natural rate of forest disturbance, as evidenced by TimberWest’s logging on West Thurlow Island.
In our view, the plain meaning of section 9 of FPPR is that, on the scale of the Thurlow Landscape Unit, in order to protect wildlife and biodiversity, logging must resemble (look like, be similiar to, be like) natural disturbance in terms of both the expected size of natural disturbances and the expected return interval of those natural disturbances. As noted above, that would require a much slower rate of logging than TimberWest has been conducting.
In the past, a licensee was only required to implement such restraint to the extent that it would not unduly impact timber supply. As you know, with legislative changes effective April 1, 2024, that is no longer the case.
In its response to our submission, TimberWest appears to be saying that it must balance the ecological sensitivity of small islands with the requirement to improve human well-being. It seems self evident to us that the Order requires TimberWest’s practices to, first, have only minimal adverse ecological effects and, subject to that condition, TimberWest is required to use the forest that can be logged to “improve” human well-being. As noted above, the Order states, “A high level of human well-being is being achieved when the quality of life in communities is equal to or better than the Canadian average.”
TimberWest may have its own idea of what “quality of life” means, but since the Order refers to “the Canadian average”, we believe TimberWest’s understanding ought to include the “Canadian” version of what “quality of life” involves in any attempt to measure whether its forest management on these small islands is “improving” human well-being.
In Canada, the common understanding of “quality of life” has come to include a number of factors, including economic prosperity (household income, employment and job quality, skills and opportunity, acceptable housing), health, environment, ecological integrity and environmental stewardship, culture and identity, social cohesion and connections, good governance, and so on.
Logging on these islands is—by definition—an economic activity. But by TimberWest’s chief forester’s own admission, logging is not the only possible economic use of forests, and it may not even be the best economic use in the early 21st century. It is a marginal economic activity in which TimberWest’s costs of logging are sometimes greater than its revenue from logging. Apparently, unless the company is allowed to export raw logs, it is not an economically viable proposition at all. But by exporting raw logs TimberWest is also exporting milling jobs that—in a time in which timber supply is falling—could have been supported by those raws logs. Since forest-related employment in BC is falling, there’s little doubt that, as a consequence of its choice to export raw logs, TimberWest is not “improving human well-being” in Canada to the extent that is expected under the Order.
These realities suggest that TimberWest needs to look beyond logging the forests of the Thurlow Landscape Unit to improve human well-being.
As mentioned above, you have not addressed our concern about the incompatibility between the practices TimberWest employs on its own land on Vancouver Island and the use of those same practices on small islands in Johnstone Strait. The areal extent of habitat on small islands is fixed by the watery boundary around the island. Several species that require territory that would occupy a substantial portion of the islands in the Thurlow Landscape Unit occur on those islands. This includes cougar, bear, wolf and northern goshawk. Each of these need an extensive home range for foraging. None can easily move across the surrounding channels to extend their habitat. Suitable habitat across those channels may already be occupied if it hasn’t already been destroyed or degraded by logging. Logging at the scale imposed by TimberWest on these small islands can result in a loss of enough habitat that not even one pair of these animals can successfully survive. I will address the problem TimberWest has created for the Northern Goshawk further below.
[3] Red- and blue-listed animal species
You bring to our attention that Keen’s long-eared myotis “is no longer a recognized species”, yet you have named it in the proposed FSP. Surely TimberWest’s FSP should contain only the most up-to-date information about species at risk.
In your response you do not address our main concern at all, which is that no wildlife habitat areas (WHAs) have been established in the Thurlow Landscape Unit for the listed species we mentioned (other than for the Northern Goshawk). This lack of WHAs applies to Northern Red-legged Frog, Great Blue Heron and Coastal Tailed Frog.
TimberWest don’t have a strategy for protecting Northern Red-legged Frog other than to acknowledge in its proposed FSP that, by government fiat, it doesn’t need a strategy. A more suitable approach for a company claiming responsible forest stewardship on these ecologically sensitive islands would be to commit to recording and publishing occurrences of listed species and then establishing mapped buffers around areas of established occurrence. The meagre to non-existant protection of riparian areas provided by inadequate provincial regulations does not match science based understanding of the normal range of Northern Red-legged Frog, for example. In the absence of adequate protection, it falls to TimberWest to show actual leadership and minimize its impact on ecosystems. Instead, as outlined above at [2], TimberWest is ransacking these ecologically sensitive islands on the basis that this is somehow “improving human well-being”. This is having a serious adverse effects on all species and ecosystems, not just those that are listed.
[4] Queen Charlotte Goshawk
Thank you for pointing out that a 178-hectare goshawk WHA was approved in 2019 for the eastern end of West Thurlow Island. This WHA does not yet appear on current BC Data catalogue mapping of WHAs and the information about the current activity of nests in this area has not been listed on the BC Conservation Data Centre’s mapping. Part of TimberWest’s stewardship role should include sharing all current information with both GeoBC and BC CDC and ensuring that the information made public regarding its tenure is accurate.
In your response to our concern for the viability of a single Northern Goshawk pair on a highly disturbed Hardwicke Island, you state, “Hardwicke Island supports at least four (4) goshawk breeding areas that Mosaic monitors annually.” It is unclear whether you are suggesting that Hardwicke Island could support 4 goshawk pairs or whether you are saying 4 nesting areas have been identified.
If it is the latter, we note that it is not uncommon for a raptor pair to have several nest sites within their territory, only one of which is used at any given time when the pair has successfully produced eggs.
If, however, you are suggesting that there may be 4 different goshawk pairs on Hardwicke Island, there is no science-based information that would support a contention that Hardwicke could successfully support more than one or two pairs.
To support our concern, we used the Forest Practices Board’s estimate of 3700 hectares being required for a pair’s home range for foraging. Hardwicke Island is 7633 hectares in extent, of which we estimate 73 percent is productive forest land, or 5572 hectares. However, Northern Goshawk require both mature and old forest for successful foraging. Since 2003, TimberWest has logged 2030 hectares of productive forest land on Hardwicke Island, leaving, at most, 3542 hectares of mature (or older) productive forest. That is less than the Forest Practices Board’s conservative estimate of 3700 hectares of mature + old forest being required for a single pair.
The Hardwicke Island example of TimberWest adversely impacting the viability of resident goshawk habitat is but one illustration of how TimberWest’s interpretation of “ecosystem-based management” needs to be reworked to meet the actual stated expectations of the Great Bear Rainforest Order. It is, in fact, disappointing to see TimberWest attempting to rationalize its adverse impact on ecosystems with inaccurate information.
[5] Red- and blue-listed plant species
In response to our concern about TimberWest’s program of spraying glyphosate on cutblocks and the subsequent irradication of native plant species, you state “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.”
By “pest” we take it that you mean “invasive plant species”. After clearcut logging, a cutblock area is susceptible to invasive plant species such as goldenrod, scotch broom and ragwort. The seed for these most likely comes from other nearby logged areas. Clearcuts also provide conditions advantageous to the native braken fern (Pteridium aquilinum). These native plants can also slow regrowth of commercially desirable conifer seedlings. TimberWest wants to remove such competitors as economically as possible and so it sprays logged-off cutblocks with glyphosate, which also kills off any native plants that may have survived the clearcut logging, as well as fire-resistant deciduous species such as red alder.
A recent (2020) science-based study found that glyphosate-based herbicide formulations have an adverse effect on the reproductive health of animals exposed to glyphosate residues. The absence of science-based evidence about the adverse effects on ecosystems of glyphosate spray used to control the competitors of plantation conifers in BC is not evidence that such effects are absent. Under ecosystem-based management, TimberWest must ensure that “adverse effects to ecological values and processes are minimal or unlikely to occur”. By practicing widespread clearcutting followed by glyphosate spraying on these small, ecologically sensitive islands, TimberWest is, instead, maximizing the risk that damage will be done.
Greatly reducing the rate of logging in the Thurlow Landscape Unit will help TimberWest to ensure that it will meets its legal requirement to create only minimal adverse effects on ecosystems. The risk of creating adverse effects could be further reduced by using manual brushing to control plants that shade seedlings in a clearcut. That measure would also increase the local employment associated with TimberWest’s logging, thus helping it to meet the “improving human well-being” requirement of the Great Bear Rainforest Order.
[6] Red- and blue-listed plant communities
When TimberWest refers in its FSP to any document that is not appended to the FSP, it needs—at the very least—to provide a link to that document. The public has no idea what “Schedule N” is or what it states. “Schedule N” should have been appended to the FSP. Otherwise, the request for public comment on the FSP, which is required by law, appears to be shallow and inauthentic. Why not also append Schedule O?
The most useful approach TimberWest could take here is to provide a list of the red- and blue-listed plant community occurrences that TimberWest has mapped in the landscape unit along with a map showing where those occurrences are. This mapping should be TimberWest’s responsibility as a part of its required forest stewardship, not the responsibility of the under-funded BC Conservation Data Centre.
Your response here does not address the main issue we raised with regards to listed plant communities. We noted that TimberWest’s logging on West Thurlow Island, for example, has overlapped all four areas that have been mapped by the CDC as containing red-listed plant communities. TimberWest’s FSP states that, in certain circumstances, it reserves the right to “disturb” up to 5% of each occurrence of a red-listed plant community. It appears that in each of these four cases, more than 5% of the mapped areas of red-listed communities have been logged. This gives the appearance that TimberWest will say one thing in its FSP but will, in fact, consistently do the wrong thing out in the forest.
Please provide an explanation for each of the 4 cases on West Thurlow Island for why TimberWest logged into areas mapped by the BC CDC as occurences of red-listed plant communities.
[7] Species at risk
On this issue we observed in our submission that TimberWest has logged into areas that have been identified as potential suitable nesting habitat for the endangered Marbled Murrelet. TimberWest’s response is that a provincial backgrounder on Marbled Murrelet habitat states that “spatial suitable habitat analyses indicate that amounts of suitable habitat will exceed minimum habitat thresholds without the need for additional habitat protection measures.”
The backgrounder notes that its content is not part of the legal notice and “Its purpose is to provide additional information for review and consideration by delegated decision makers and by those persons required to prepare results and strategies consistent with section 7(1) of the Forest Planning and Practices Regulation…”
TimberWest has apparently reviewed and considered the backgrounder and decided that it does not need to ensure that previously identified suitable Marbled Murrelet habitat in the Thurlow Landscape Unit is conserved.
If so, this is another unfortunate indicator that TimberWest does not understand the over-arching requirement for it to practice ecosystem-based management, which states: “Ecosystem integrity is being maintained when adverse effects to ecological values and processes are minimal or unlikely to occur.”
We are concerned that TimberWest apparently has no concern for ensuring that Marbled Murrelets continue to inhabit the Thurlow Landscape Unit. All that is required for continued habitation is for TimberWest to identify suitable nesting habitat on each of the four islands in the landscape unit and to leave a suitable buffer around these habitats.
If TimberWest logs identified Marbled Murrelet habitat, it is not having a “minimal” effect on this already-endangered species. If it keeps logging this bird’s habitat until there is none left, for example, it will cause local extirpation of this species. That is not a “minimal” effect. It is a maximal effect.
The only realistic forest management choice for TimberWest under the Great Bear Rainforest Order’s requirement to practice ecosystem-based management is to not log into previously mapped Marbled Murrelet habitat. If it has ascertained that mapped areas of critical habitat do not, in fact, contain suitable nesting habitat, then it should make that clear in its FSP.
[8] Old forest
As mentioned above: When TimberWest refers in its FSP to any document that is not appended to the FSP, it needs to provide a link to that document. The public has no idea what “Schedule G” is or what it states. “Schedule G” should have been appended to the FSP. Otherwise, the request for public comment on the FSP, which is required by law, appears to be shallow and inauthentic.
We recommend that TimberWest provides in its FSP a table containing the biogeoclimatic zones, variants and site series that are applicable in the Thurlow Landscape Unit, along with the minimum old forest retention level for each site series.
In its response to our submission, TimberWest has failed to address the main issue we raised regarding old forest, which is the low level of remaining old forest in the Thurlow Landscape Unit. We asked that TimberWest’s FSP acknowledge that, because the level of old forest has dropped below 10 percent, it will not log any further old forest or cut individual old trees. Our own analysis for the Thurlow Landscape Unit—Sonora, East Thurlow, West Thurlow and Hardwicke Islands—shows that the remaining old forest covers approximately 7.6 percent of the Crown forested land base. This is much lower than the required minimum old forest retention levels for most of the site series for CWHxm2.
Since the Great Bear Rainforest Order was first implemented in 2016, the provincial government has come to recognize through the Old Growth Strategic Review the urgency of protecting more old forest, especially in biogeoclimatic zones where the level of remaining old forest is below 10 percent. We believe TimberWest’s new FSP for the Thurlow Landscape Unit should unequivocally reflect this new government direction and include a commitment to not log any remaining old forest, concentrations of veteran trees or individual old trees.
As requested in our initial submission, please share with us TimberWest’s most current mapping of age class distribution so that we can compare that with and update our own analyses, which are ongoing.
[9] Climate change and rate of cut
TimberWest’s lack of a response to this issue is concerning. On the one hand it is willing to profit from the scientific consensus about carbon emissions and public concern about climate change, as demonstrated by its adoption of the BigCoast initiative for some of its own private property. Yet it takes the least responsible approach possible—business as usual under the current legislation—on the basis of “uncertainty” about how climate change will affect the public forests it manages. Why not, instead, show some leadership here?
Respectfully submitted,
David Broadland for the Discovery Islands Forest Conservation Project
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