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    David Broadland
    The “unduly clauses” are gone. The public must now be notified about proposed logging before a cutting permit is issued and the public gets to voice their concern about every proposed cutblock. Now it is mandatory for a district manager to refuse to issue a cutting permit if doing so would “compromise” a government objective. Now is the time for citizens to act.
    RECENT CHANGES made by the NDP government to the Forest Act, the Forest and Range Practices Act and the Forest Planning and Practices Regulation may be good news for BC forests. But that “may” is conditional on the public getting its act together. Let’s start with the changes.
    At the heart of the changes is the new Part 3.1—Cutting Permits—in the Forest Act. Section 52.05 of Part 3.1 states that the minister “must refuse to issue a cutting permit” if the “issuance of the cutting permit would compromise a prescribed government objective.” The minister’s designate in individual forest districts is the district manager. Similarly, issuance of a cutting permit must be refused if the applicant has not made “publicly available a forest operations map before applying for the cutting permit”.
    By removing the “unduly clauses” from the objectives set by government in the Forest Planning and Practices Regulation (FPPR), the government has made it clear that potential impacts on timber supply can no longer be used by a district manager to decide to what extent an objective set by government must be met. Now, if a cutting permit would “compromise” an objective, a cutting permit must be refused.
    This, in effect, returns reponsibility for stewardship of BC forests back to the Minsitry of Forests. It has been in the logging industry’s hands since 2004.
    The reason these amendments could result in a sea change in the management of BC’s publicly-owned forests is that they could reduce the current rate of logging from one based entirely on a faux “allowable annual cut” that is technically flawed and politically determined, to one that is based, primarily, on ecological objectives. These new laws fit with the government’s declared intention to move logging in BC to ecosystem-based management.
    Before reading the recent changes to BC’s forest legislation (implemented on April 1), I was dubious about the depth of this government’s commitment to moving toward ecosystem-based management. Now, I think forest conservationists need to dig deep into the possibilities for change the new legislation opens up.
    Consider, for example, the objective set by government for wildlife and biodiversity at the landscape level in section 9 of the FPPR. The regulation now states: “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.”
    In the FPPR, a logging company is exempted from the requirement to describe a strategy for how it will meet an objective set by government if it promises in its forest stewardship plan to abide by prescribed sections of the regulation. For the objective for wildlife and biodiversity at the landscape level, a logging company’s forest stewardship plan usually states that it will abide by sections 64 and 65 of the FPPR. The logging company doesn’t actually have to demonstrate that application of those regulations has had, or will have, the result—on the ground—of making their logging “resemble, both spatially and temporally, the patterns of natural disturbance that occur within the landscape.”
    Instead, all that was required was for a logging company to have a forest stewardship plan that promised to abide by sections 64 and 65. It it did, a district manager had to issue a cutting permit when one was requested.
    In the 20 years since the Forest Planning and Practices Regulation was implemented, a lot of information about whether sections 64 and 65 have been effective has accumulated in the Ministry of Forest’s RESULTS Openings database.

    The ruined landscape just north of Fairy Creek, west of Victoria. Logging at this rate is far above that required by the Forest and Planning and Practices Regulation’s section 9 objective for biodiversity and wildlife at the landscape level.
    This database records, for example, the area of each biogeoclimatic zone variant that has been logged in a given landscape unit in BC. We can compare the loss of forest cover in each zone’s variants in a landscape unit with the loss that would be expected due to natural disturbance (the expected rate of natural disturbance varies greatly between biogeoclimatic zones and variants).
    If the area logged in a given period of time exceeds that which we would expect through natural disturbance, then the logging does not “resemble, both spatially and temporally, the patterns of natural disturbance that occur within the landscape.” In that case, the objective has been compromised. In such a case, according to the new section 52.05 of the Forest Act, the minister “must refuse” to issue further cutting permits.
    Over the past month I have been examining the RESULTS Openings data that covers the last 20 years for landscape units across BC. I have yet to find a case in which the record of area logged “resemble[s], both spatially and temporally, the patterns of natural disturbance that occur within the landscape.” In some cases, the difference between the objective and reality is dramatic.
    The science around natural disturbance has evolved significantly over the past 20 years. The current understanding of the spatial and temporal dimensions of natural disturbance in coastal BC are summarized by the 2020 Standards for Assessing the Condition of Forest Biodiversity under British Columbia’s Cumulative Effects Framework (see the table in Appendix 3 on page 52).
    In coastal BC, the average time between natural disturbances—known as the stand-replacing natural disturbance interval—ranges between 10,000 years and 500 years, depending on the biogeoclimatic zone variant.
    In the zone in which I live on Quadra Island—predominantly CWHxm (1 and 2)—the interval settled on by the Cumulative Effects Framework is 700 years. That means that for any given area of forest in my zone, it is likely to be naturally replaced, on average, about every 700 years. Not all at once, but stand by stand. If logging at the landscape level in my area is to resemble natural disturbance, then, the rate of logging in the landscape unit I live in can be no greater than 1/700 of the timber harvesting land base in the landscape unit area per year. (I ran this by forest scientist Dr Karen Price, an expert in natural disturbance. She agreed.)
    If the rate of logging in a landscape unit is greater than the rate of natural disturbance, then the logging is compromising the objective set by government for wildlife and biodiversity at the landscape level.
    Let me give you a real-life example of comparing the rate of logging in a landscape unit with what is allowed under section 9 of the FPPR.
    Most of the Quadra Landscape Unit is either in TFL 47 or is occupied by woodlot licence tenures. The latter are not required to meet the objective set by government for wildlife and biodiversity at the landscape level. TimberWest’s operations in TFL 47 are.
    TFL 47 occupies about 11,000 hectares on Quadra Island and its timber harvesting land base is about 7000 hectares.
    Based on that information we determined that the annual area of logging on the timber harvesting land base of TFL 47 in the Quadra Landscape Unit that would resemble natural disturbance at a natural disturbance return interval of 700 years is about 10 hectares (1/700 x 7000).
    But in the TFL 47 portion of the Quadra Landscape Unit in the 20 years between 2004 and 2023, 1694.5 hectares were cut, according to RESULTS Openings. That averages out to 84.73 hectares per year (1694.5/20).
    The average yearly cut (84.73 hectares per year) then is 8.5 times higher than the natural disturbance rate if the natural disturbance return interval used is 700 years.
    A rate of logging that’s 8.5 times faster than that called for by an objective set by government definitely compromises that objective, in our view. We expect to find that is not unusual throughout BC. No wonder Premier Eby has described BC’s forests as “exhausted”.
    Application of sections 64 and 65 of the FPPR by TimberWest in its forest stewardship plan have clearly not resulted in the outcome for conservation of wildlife and biodiversity at the landscape level sought by the regulation. We have used the last 20-year period because the area of TimberWest’s TFL 47 in the Quadra Landscape Unit has not changed during that time, and the Forest Planning and Practices Regulation has been in effect throughout.
    In the parlance of the newly-amended Forest Act, TimberWest has “compromised” the objective set by government for wildlife and biodiversity at the landcape level.
    And now we know, thanks to the recently developed Forest Operations Map portal, that TimberWest is planning to do more of the same. This is a powerful new tool that allows the public to know the location and the area of each cutblock and road segment that a company wants to log before a cutting permit or a road permit is issued, and allows direct public comment on those plans. The system is not perfect, but it is a tool we have never had before.
    What can we do with all of this?
    As a result of our analysis of over-cutting in the Quadra Landscape Unit, we wrote a letter to Campbell River District Manager Lesley Fettes requesting that she not issue cutting and road permits to TimberWest that would result in logging at a rate that is greater than would be the case if the objective set by government for wildlife and biodiversity at the landscape level was being met. Under the newly amended Forest Act, the district manager must not issue such cutting permits.
    We have prepared a complaint to the Forest Practices Board based on the above. We await Ms Fettes response to guide us on whether we file the complaint with the board.
    For any district manager in BC to refuse to issue cutting and road permits, they will need to be prompted by members of the public armed with accurate information about how one or more of the objectives set by government are being compromised in their forest district.
    This puts the onus on citizens concerned about conservation of forests to stand up and speak out. If we don’t stand up and speak out, we will get more of what we have been getting. As Plato wisely advised, “Silence gives consent.” 
    If you do not feel confident that you can do the analysis required for your area of concern, you can still help. You can add your name to a letter that will be sent to your district manager regarding logging companies operating in your area that are going to exceed the natural rate of forest disturbance and compromise a government objective. Just email us your name, where you live, the logging company you are concerned about and we will do the analysis and send it to the appropriate district manager, copied to you.
    Parting thought
    There are 9 other objectives set by government for which unduly clauses have been removed and which the Forest Act now declares cannot be compromised. Each of those needs to be analyzed in terms of the actual results produced by the “strategies” logging companies have been using to get forest stewardship plans approved. The Evergreen Alliance is working at putting together a group of experts who can analyze those objectives and develop techniques for measuring the results of the past 20 years so that we can create an even deeper critique to communicate to district managers. If you can help, please contact us.

    Rochelle Baker
    Quadra Island’s Copper Bluffs community worries about the fate of prized wetlands (above) in the Missing Links watershed after Mosaic recently logged around a nearby lake.
    A Quadra Island community is increasingly frustrated by its inability to protect vital watersheds from being clear-cut despite the increasing risks of climate change.
    Many residents in the Copper Bluffs community and elsewhere on the island have been urging Mosaic Forest Management to reconsider logging remnants of mature forests, particularly in stream sheds and wetlands.
    Despite long-standing opposition from residents, Mosaic has harvested six parcels totalling five hectares from tree farm licence 47 (TFL 47), which spans most of the island north of Gowlland Harbour and Hyacinthe Bay.
    The logging removed much of the remaining mature forest circling a small lake in a watershed already degraded by logging, said longtime resident Jim Leishman. Known as Swan Lake, the pond is often frequented by trumpeter swans when they come south for the winter.
    After last week’s logging took place, Leishman surveyed the largest parcel and found a number of small streams feeding the lake damaged and buried under debris. He also noted the tree buffer between the clear-cut and the pond’s edge was scanty with mostly poor-quality trees remaining.
    “They’ve removed the mature growth, which acted as one of the last [forest] sponges left on the lake,” Leishman said, noting the surrounding watershed’s ability to absorb rainwater has already been compromised by extensive logging.
    Mosaic did not respond to Canada’s National Observer’s requests for an interview.
    However, in an emailed statement, Mosaic said it remains committed to ongoing collaboration with Quadra Island communities and residents.
    Mosaic originally planned to log the parcels adjacent to Swan Lake in fall 2023 but delayed operations to allow for further community engagement, the email said.
    The company also contracted an independent report to see if logging on the cutblocks would endanger drinking water quality for residents.
     “Our professional foresters, biologists, and area planners carefully considered safety, recreation, water quality, fish, visual quality, wildlife, and other values when planning the area,” the email said.
    However, island resident Kailea Rendle is cynical about the company’s good faith when it comes to community engagement. The company logged the Swan Lake area against residents’ wishes with no significant alterations to its plans, particularly for the largest block above the lake.
    The logging company has ignored residents’ concerns about the significant climate impacts of logging the sensitive areas in the watershed and aggravating the danger of drought and wildfires, Rendle said.
    The Swan Lake parcels may be small, but the resulting environmental impacts will be compounded by numerous other recent clear-cuts near the pond and throughout the watershed, Leishman stressed.
    Mature forests are critical to slowing winter rains, allowing water to filter into aquifers that feed residents’ wells. They also help dampen increasingly dry conditions that threaten fish and wildlife and set the stage for severe wildfires during summer.
    Severe drought on Quadra Island is no longer an isolated event. The island is part of the eastern Vancouver Island water basin, which has suffered Level 5 droughts (the most extreme rating) for the past three summers.
    An exceedingly low snowpack and record-high temperatures this winter are setting the stage for another province-wide drought and savage wildfire season. Like many communities across B.C., Quadra Island fought to contain a wildfire last year.
    Residents have even greater concerns about Mosaic’s future logging plans for a cutblock bordering critical beaver wetlands and three popular hiking trails in the Missing Links watershed that traverses the Copper Bluffs community, said resident Rolf Erdmann.
    Residents say they have been pushing Mosaic to respond to their concerns since 2020.
    Aside from preserving the views from the bluffs at the top of the trails, maintaining the ecological integrity of the Missing Links watershed is vital to buffer the risks of fire, particularly for Copper Bluffs residents, who are outside the Quadra Island Fire Department’s response zone, Erdmann said.
    Mosaic has not responded in a transparent manner or to community concerns, Erdmann said, adding they still don’t know what the forestry company’s plans are for the parcel.
    The community’s trust in Mosaic has eroded further after getting an email from the company suggesting it has no interest in logging the Missing Links watershed, he said, yet the forestry giant has still secured a cutting permit for the area.
    In its email statement to Canada’s National Observer, Mosaic acknowledged plans to log in the Missing Links watershed have been in the works for several years.
    “We are listening to the community’s feedback on the harvest plan and have deferred this block until at least 2025 to allow for further engagement.”
    The province’s long-standing promise to transform the logging industry to prioritize ecological, community and cultural values over timber extraction when managing forests isn’t playing out on the ground, Rendle said.
    By the time any shift actually occurs, the opportunity to preserve the island’s most valuable mature forests so they can transition into much-needed old-growth areas to boost communities’ resilience to climate change will likely be long gone.
    “It really feels hopeless,” Rendle said, noting families choose to live in the small remote island community because they appreciate and want to protect its natural beauty and environmental values.
    “We gathered in every way we knew how to voice our concerns and protect our community and it made no difference.
    “It’s so clear to me that they couldn’t care less about our well-being.”
    Rochelle Baker / Local Journalism Initiative / Canada’s National Observer 

    David Broadland
    In 2003, an employee of the ministry of forests offered confidentiality agreements to TFL holders ensuring that mapping of the timber harvesting land base in those TFLs would not be released to the public. Whether or not it was the original purpose of the confidentiality agreements, they seem to have had the effect of thwarting designation of legal, spatially-designated old-growth management areas in the majority of the TFLs that were offered confidentiality.

    Western Forest Products’ surveyors work in an area of old-growth forest in TFL 19 near Tahsis on Vancouver Island. TFL 19 contains zero legal old-growth management areas. Across BC, there are over 3 million hectares of land spread across 22 TFLs where logging companies have evaded establishing spatially-designated old-growth management areas. (Photo: TJ Watt)
    THE FIRST PART OF AN INQUIRY conducted by the Office of the Information and Privacy Commissioner of BC (OIPC) recently received written submissions from the Ministry of Forests, three of the affected logging companies and the Discovery Islands Forest Conservation Project. The inquiry was held to consider a simple question: Is the right of the public to access maps of the “timber harvesting land base” (THLB) on publicly owned land in tree farm licences outweighed by the private interests of logging companies currently holding those tree farm licences?
    The logging companies provided written submissions strenuously objecting to release of the maps on the basis that making them public could fuel civil disobedience, cause disruption of their operations, bring financial loss, damage their “negotiating position” and unduly benefit their competitors.
    A lawyer for Interfor wrote: “For example, the information could be used to create a narrative regarding timber harvesting plans and modelling based on the THLB information released, with the goal rallying a cause, fuelling civil disobedience, and creating operational disruptions.”
    Teal Cedar Products stated: “Significant financial harm would result if the data were released to the [Applicant] whereby the [Applicant] uses the data in a manner that would disrupt Teal’s operations by protests, road blocks, or other social media campaigns…In this case, if the data were released, it would result in financial loss to Teal as operations could not proceed as planned due to road blockades and protests…”
    Western Forest Products’ lawyers felt so strongly that release of the maps would cause harm to the company that they didn’t even want their arguments to be publicly known—so they redacted them from their submission. Only the inquiry’s adjudicator will ever know what Western claimed would happen if “the data were released”.
    What is it about the mapping of the timber harvesting land base on publicly owned land in a tree farm licence (TFL) that is so hot that Western Forest Products doesn’t even want the public to know its arguments for why the mapping should be kept secret?
    As a tool for igniting blockades of logging roads, using maps of the timber harvesting land base would be something like trying to start a fire with a water hose. Most British Columbians don’t even know what the “timber harvesting land base” is or the critical role it plays in determining how much logging occurs in BC. Land defenders, largely motivated to protect big, old trees, use more direct tools—like day-old satellite imagery showing where logging roads are being built—in their efforts to slow down destruction of old-growth forests.
    But the Office of the Information and Privacy Commissioner will likely take seriously the overblown speculations of the logging companies and rule in favour of not releasing the maps of the timber harvesting land base on the basis that doing so would be harmful to the business interests of the logging companies. Our project submitted an argument based on Section 25 1(b) of the Freedom of Information and Protection of Privacy Act, namely that it would be “clearly in the public interest” to release the maps. However, in the 30 years since this legislation was enacted, there has never been an OIPC adjudication that ordered a public body to release a record on the grounds that it would be “clearly in the public interest” to do so.
    The OIPC inquiry did, however, unearth a document that sheds light on how the Ministry of Forests has managed to hide these maps from the public. The ministry submitted to the inquiry a letter that had been written in August 2003 in which an employee of the Ministry of Forests’ tenure and revenue branch asked each of the 22 TFL holders affected by the Forestry Revitalization Act (2003) for maps of its timber harvesting land base.
    In exchange for these maps, the employee offered confidentiality agreements in which the ministry promised not to disclose the maps to any third party. According to the ministry’s submission to the inquiry, all of the TFL holders provided the requested maps to the ministry. Only two of the TFL holders—TimberWest and Canadian Forest Products—actually requested confidentiality agreements, but the ministry claimed at the inquiry that the letter itself was an implicit promise of confidentiality to all of the TFL holders.
    The letter stated: “The information provided will be considered single purpose data and will be held in confidence.” This appears to mean that the mapping would be used for the purpose of taking back volume from the TFLs as set out under the Forestry Revitalization Act, but it couldn’t be used for any other purpose—like, for example, establishing old growth management areas. More on this later.
    Those confidentiality agreements, both explicit and implied, have had the effect of keeping the mapping of the timber harvesting land base in TFLs hidden from public view for over 20 years.
    Yet that mapping is information that section 9 of the Forest Act requires TFL holders to “prepare and supply”—at the TFL holders expense—and which they must provide “at the time and in the form and manner required by the chief forester”. Indeed, if it isn’t prepared and supplied when requested, the chief forester can reduce the TFL’s allowable annual cut by 25 percent until it is supplied. That’s because the mapping is essential for an allowable annual cut determination.
    In its submission to the inquiry, the Ministry of Forests admitted that the “TFLs create this data as a condition of their TFL to enable the Province’s Chief Forester to determine an allowable annual cut”. But the ministry made no reference to the Forest Act’s stipulation that the TFL holder must “prepare and supply” the data to the chief forester.
    Moreover, the 2003 Forestry Revitalization Act itself, the pending implementation of which precipitated the promises of confidentiality in the first place, contained a similar command to TFL holders to provide any information that was required to implement the Act’s provisions.
    All of this goes to show that confidentiality agreements were not required to obtain maps of each affected TFL’s timber harvesting land base. Preparing and supplying the maps was a condition of their licences.
    The Ministry of Forests’ submission to the inquiry shows that 10 years later, in 2013, the ministry repeated the whole exercise of requesting the timber harvesting land base from TFL holders and promising not to share that mapping with the public. In this case, too, the ministry ignored the provisions of the Forest Act that empower the chief forester to demand that maps of the timber harvesting land base be prepared and supplied at the TFL holder’s expense.
    The Ministry of Forests provided no explanation at the inquiry for why it had ignored the provisions of the Forest Act and the Forestry Revitalization Act when it came to obtaining information from TFL holders. But two motivations for the ministry’s chosen course of action to keep these maps out of the public’s hands are apparent.
    First, from what I have seen of mapping of the timber harvesting land base, it is very crude and that crudeness would introduce significant uncertainty into the main product that is derived from mapping the timber harvesting land base: allowable annual cut determinations. By hiding this problem behind confidentiality agreements, the ministry has kept that uncertainty out of public sight.
    Secondly, by hiding this critically important mapping behind serial confidentiality agreements, the ministry was pursuing a strategy it had quietly developed in 2003: To undertake measures that would minimize the actual impact on timber supply from highly-publicized conservation initiatives such as the establishment of legal old-growth management areas. The ministry wanted to look good without actually being good.
    Below, I’ll examine in detail some of the real-world impacts of the crude mapping and the ministry’s desire to look good to the public.
    A crudely mapped timber harvesting land base would likely lead to over-cutting
    Let’s consider, first, the impact of a crudely mapped timber harvesting land base and why the ministry would want to hide that behind confidentiality agreements.
    As I mentioned above, even those British Columbians who are concerned about what’s happening to their forests likely don’t have a clear idea of what the “timber harvesting land base” is and why its areal extent is so critical to the rate at which BC’s forests are being logged. The term is defined by the ministry as “Crown forest land within the timber supply area where timber harvesting is considered both acceptable and economically feasible, given objectives for all relevant forest values, existing timber quality, market values, and applicable technology.”
    Why is the timber harvesting land base critically important? There is a direct connection between the timber harvesting land base and the allowable annual cut. The allowable annual cut of a TFL is determined, in effect, by multiplying the areal extent of the timber harvesting land base by the average rate of annual forest growth on that area. That areal extent can only be ascertained from an accurate map of the timber harvesting land base. An accurate map would show areas that are too steep or unstable to log or build roads, areas of unproductive or non-commercial forest, areas of rock, swamps, creeks, lakes, roads, and so on.
    From the mapping that has been released to us so far (some TFL holders voluntarily released their maps in response to the inquiry), it’s clear that in many TFLs the “timber harvesting land base” hasn’t even been differentiated from the legal boundaries of a TFL. As a result, many timber supply analyses are based on numbers that have no direct connection to forest conditions on the ground. They are merely informed guesses, and these guesses, therefore, introduce significant uncertainty into allowable annual cut determinations. Why would the ministry want to keep that off the public’s radar?
    The image of the logging industry that government and industry have created over the years—both in BC and internationally—has been one of  a “sustainable” industry, one which is highly regulated, with those regulations based on peerless science. Neither government or industry want the public to know that they collectively don’t have a good idea of the exact condition of BC’s forests on the ground. Their grand project of liquidating most natural forests in BC and replacing them with managed plantations is rife with uncertainty, including the whereabouts of commercially available forests.
    When that uncertainty is compounded by other uncertainties associated with timber supply reviews—like the uncertainty inherent in the tree growth and stand yield computer models being used by the ministry to predict future timber supply, as well as uncertainty about the impacts of climate change and cumulative effects—the potential for the ministry to have overestimated timber supply becomes clear. (On top of all that uncertainty, the allowable annual cut is often fiddled upward by the chief forester to meet the political expectations of the forests minister of the day.)
    If the timber harvesting land base has been overestimated, then the allowable annual cut will be too high. Indeed, comparison of the timber supply that was predicted 20 years ago with what appears to be available today suggests a dramatic decline in supply. The graph below is taken from the 2004 State of British Columbia’s Forests report—authored by the Ministry of Forests and signed by the chief forester of the day. We have added what the actual harvest has been for the period 2019-2023 (see the plunging black line). The years 2021-2022 included record high lumber prices, yet BC’s timber supply could not rise to the occasion. This is what we would expect to see if the allowable annual cut had been set too high because the areal extent of the timber harvesting land base had been overestimated, and/or the ministry’s growth and yield modelling was flawed and/or it hadn’t accounted for cumulative effects or climate change.

    Similarly, satellite imagery of BC shows widely devastated forests, providing dramatic evidence of over-cutting:
    The Ministry of Forests—through its proxies in academia and industry—now blames the sad state of BC’s forests on the mountain pine beetle and fires, but its past estimates of timber supply have always, supposedly, included those impacts.
    This is, I believe, one of the motivations for the ministry to continue hiding mapping of the timber harvesting land base behind confidentiality agreements and BC’s failed information law. The ministry is fearful that if the public could actually see the mapping of the timber harvesting land base in TFLs, the public would be appalled at the dismal quality of information that the Ministry of Forests has been using over the last 20 years to determine the allowable annual cut for TFLs (and, for that matter, for timber supply areas).
    The Ministry of Forests has, over the years, made hundreds of claims about the size of the timber harvesting land base—in timber supply analyses for both TFLs and timber supply areas—without ever having to support those claims by providing the corresponding mapping to the public.
    Let’s turn now to the ministry’s second motivation back in 2003, which was to take steps that would minimize the impact of conservation initiatives on timber supply, such as legal old-growth management areas. By making the maps of the timber harvesting land base in TFLs unavailable for any other purpose than to implement the Forestry Revitalization Act, the ministry appears to have thwarted establishment of legal old growth management areas in many TFLs.
    How to look good while ensuring nobody actually knows you’re not doing good
    I have reported previously about a memo written in 2003 by a member of the Ministry of Forests’ “Forest and Range Evaluation Program” that shows the ministry had—out of the public’s view—established a strategy “to ensure that conservation of non-timber values is undertaken in balance with economic benefits associated with values.” That “balance” might sound good, but in practice this meant “conservation of non-timber values” could result in no more than a 6 percent reduction in “timber supply”.
    But just establishing legal old-growth management areas at the minimum density then recommended by forest scientists would have had more than a 9 percent impact on timber supply. So the ministry, which was—and still is—closely aligned with the values and objectives of the logging industry, chose to ensure that establishment of old-growth management areas was limited. Were the confidentiality agreements that were exposed by the OIPC inquiry used to thwart establishment of legal old-growth management areas in TFLs? That’s how it appears to me.
    Back in 2020, I was working on the Discovery Islands Forest Conservation Project. The project’s objective is to build up the capacity of communities living on those islands to communicate effectively with government about the impacts of logging. The intention is to create conditions that will lead to an increase in the amount of protected forestland. Our project supports the idea that “nature needs half”.
    Toward that end, we were trying to determine why there were no legal old-growth management areas on Quadra Island, a large part of which is in TimberWest’s TFL 47. “Legal” old-growth management areas are legally mandated, spatially defined areas intended to conserve old forest within the timber harvesting land base. Forests scientists have determined that such measures are required to conserve the biodiversity and structure associated with old forests. Legal old-growth management areas are the product of “landscape level planning”, a process started by the Ministry of Forests in the late 1990s. Quadra Island had been given “high” priority for such planning in 2000, but it never took place. So we decided to carry out that planning ourselves, as best we could.
    We had mapped and ground-truthed where old forest exists on Quadra Island and just needed to know where those areas coincided with the timber harvesting land base. We reasoned that if the Ministry of Forests didn’t have the resources to do this, we would do it for them. We intended to nominate those areas of old forest that overlapped the timber harvesting land base for conservation as legal old-growth management areas. But we needed to know where the timber harvesting land base was. Finding no publicly available mapping for the timber harvesting land base, we filed the FOI that led to the OIPC inquiry.
    It turned out that it wasn’t just Quadra Island that didn’t have legal old-growth management areas. There were none in the entire 125,635-hectare-area of TFL 47. The current tenure holder of TFL 47 is TimberWest. The inquiry revealed that TimberWest had signed a confidentiality agreement with the Ministry of Forests in 2003. As I mentioned earlier, this agreement included a promise to use the data for a “single purpose” and that purpose, apparently, did not include establishing legal old-growth management areas.
    Over the past twenty years, TimberWest has been able to log old forest throughout TFL 47 without ever having to plan for even the 9 percent minimum target for old forest set out in the 2004 Order Establishing Non-Spatial Old Growth Objectives for areas of BC that didn’t get landscape level planning. TimberWest admits that on Quadra Island the level of old forest has fallen to about 3.8 percent of the area in its TFL. The 2020 old-growth strategic review panel recommended that if the level of old forest falls below 10 percent in a landscape unit, there should be an immediate deferral of any further logging of old forest (recommendation 3.b). Yet logging of old forest in the Quadra Landscape Unit continues. We have filed a complaint with the Forest Practices Board.
    This isn’t a problem that’s confined to TFL 47. In fact, 22 of the 33 TFLs scattered around BC that existed in 2003 do not contain legal old-growth management areas. Sixteen of those 22 “no-OGMA” TFLs were covered by the 2003 confidentiality/single purpose agreement (see list below). The TFLs with no legal old-growth management areas cover a gross area of 3,097,403 hectares. Of that, according to the ministry, 1,471,825 hectares are in the timber harvesting land base. That means that approximately 132,400 hectares of productive forest that should have been designated as legal old-growth management areas haven’t been.
    Legislation that led to the establishment of old-growth management areas was enacted in recognition of the critical need to protect the biological diversity and structure associated with old forests. The legislation is proof that protecting biological diversity is a matter of public policy in BC. If the confidentiality agreements signed by the Ministry of Forests in 2003 and 2013 have thwarted the ability of public officials to carry out that public policy, then the confidentiality agreements should be, under the common law doctrine of “Public Policy”, unenforceable, and the mapping should be released to the public.
    Once the Office of the Information and Privacy Commissioner has made an order regarding the mapping, I will report on that.
    Below is a list of the TFLs in BC that have no old-growth management areas. Areas shown are gross areas. Those marked with an asterisk* were offered confidentiality agreements in 2003:
    TFL 3—Interfor—78,672 hectares*
    TFL 8—Interfor—77,870 hectares*
    TFL 14—Crestbrook Forest Industries—150,968 hectares*
    TFL 19—Western Forest Products—171,111 hectares*
    TFL 23—Pope & Talbot—313,778 hectares*
    TFL 25—Western Forest Products—196,233 hectares*
    TFL 26—District of Mission—14,828 hectares
    TFL 30—Canfor—179,809 hectares*
    TFL 33—Federated Co-operatives—8396 hectares*
    TFL 38—Interfor—177,381 hectares*
    TFL 43—Holmalco Forestry—5405 hectares
    TFL 45—Interfor—223,272 hectares*
    TFL 47—TimberWest—125,635 hectares*
    TFL 48—Canfor—625,980 hectares*
    TFL 49—Tolko—110,510 hectares*
    TFL 53—Dunkley Lumber—87,838 hectares*
    TFL 54—Ma-Mook Natural Resources—136,008 hectares*
    TFL 55—Louisiana-Pacific Canada—92,657 hectares*
    TFL 56-Revelstoke Community Forest—119,353 hectares
    TFL 59-Weyerhauser—46,894 hectares
    TFL 60—Taan Forest—134,565 hectares
    TFL 61—Pacheedaht-Andersen Timber Holdings—20,240 hectares
    Total gross area of TFLs with no OGMAs—3,097,403 hectares

    Rochelle Baker
    Crews work through the night to dampen out-of-control Quadra Island wildfire

    Forest fire near Village Bay Lake on August 17 (photo by BC Wildfire Service)
    BC WILDFIRE SERVICE’s specialized attack crews worked through the night to tame an out-of-control wildfire that broke out in a populated area of Quadra Island Thursday afternoon.
    Three first-response attack crews, a helicopter and two tree-fallers continue to fight the blaze east of Village Bay Lake near Bold Point Road and it has shrunk from four hectares to 1.5 hectares in size, BC Wildfire Service information officer Sam Bellion told Canada’s National Observer early Friday.
    The wildfire service’s latest alert at 11 a.m. said the fire is being held. It broke out in the island’s Village Bay Lake area, a popular summer destination with numerous recreational properties and homes.
    Rapid attack crews, an air tanker dropping fire retardant and two helicopters with water buckets were initially dispatched when the fire was reported about 3:30 p.m. Thursday.
    “They did great work last night,” Bellion said. “They dropped a lot of retardant on the eastern flank of the fire, and worked through the night on the western flank to get that down.”
    Friday morning, crews reported the western flank of the blaze was limited to a creeping, smoldering ground fire, she said.
    Firefighters will now focus on the southern edge of the blaze.
    “They’re not expecting any significant growth there,” Bellion said.
    “So, today, they’re just going to be working for containment and doing what they can.”
    Islanders work to quench fire
    Residents from Village Bay Lake and Bold Point were reportedly first on the scene to quench the blaze with hoses and pump equipment before being rapidly replaced by professional wildfire service crews and seven members of the Quadra Island Volunteer Fire Department who worked until nightfall.
    No structures have been officially reported as lost or damaged and no evacuations took place, Bellion said.
    The fire is deemed as human-caused, but any specifics won’t be known until a full investigation takes place after the blaze is out, she added. Reports on Quadra’s social media sites suggested at least part of the fire was caused by a tree breaking a hydro line after falling in heavy wind.
    The Quadra Island Volunteer Fire Department appealed to people to stay clear of the area.
    A fire advisory remains in place and the BC Wildfire Service and Quadra Island Volunteer Fire Department are reminding people to follow the directions of local authorities.
    The best source of updates is the BC Wildfire Service app or its website. Or people can sign up or check for alerts at alertable.
    Rochelle Baker / Local Journalism Initiative / Canada’s National Observer

    David Broadland
    The BC government is committing a 220,000-square-kilometre, biodiversity-killing, climate-destabilizing fraud on its own citizens and the international community.
    THERE’S BEEN A LOT OF WRITING over the past year about the “Big Lie” in American politics: A deliberate, gross distortion of the truth, repeated over and over, even in the face of evidence that what’s being claimed is false.
    This isn’t just a sickness affecting American politics. Month after month, around the globe, scientists uncover more of the truth about how badly humanity has overshot Earth’s ecological limits. Perversely, the scientists’ dire warnings simply cause governments, corporations and their political proxies to respond with measures that protect the status quo. Rather than addressing the issues head-on and making plans to address the overshot in a meaningful way, these entities resort to greenwashing, denial and deliberate, gross distortions of the truth.
    The British Columbia government has its own version of a Big Lie, which it uses to manufacture continued public consent for the immense transformation of 220,000 square-kilometres of BC’s publicly owned primary forests into clearcuts, permanent logging roads and managed, short-rotation monoculture plantations.
    BC’s deliberate, gross distortion of the truth has two parts: First, that this transformation is being conducted under strict, science-based regulations that ensure “sustainability.” And second, that the liquidation of natural forests is being carefully monitored using powerful information technology to ensure we don’t exceed natural limits.
    Both of these claims can readily be shown to be false, yet government and industry make them so often that almost everyone believes them.
    Real progress at turning away from the endless, destructive exploitation of nature in our province won’t be possible until the BC government acknowledges the deception behind its claims of strict regulatory control and creates an accurate inventory of what remains of nature in this province—and a plan for how to restore it where it is most damaged.
    If new Premier David Eby’s commitment to sustain BC’s biodiversity by doubling the amount of protected area by 2030 is to be successful, it’s essential that his initiative doesn’t become just another exercise in protecting more rock and ice and adding more territory to BC’s Big Lie.

    This satellite photo of logging west of Kelowna covers an area of 63 square kilometres. The 220,000 square kilometres of primary forest in BC that is being converted to clearcuts, logging roads and plantations is 3,500 times greater than the area shown here (click image to enlarge). For context, the entire state of Washington covers 184,827 square kilometres.
    Does BC have strict, science-based regulations that ensure the “environmental sustainability” of converting primary forests to managed plantations?
    The short answer to that question is “No.” Converting primary forests, most of which are old, to short-rotation industrial plantations in which trees will never be allowed to grow old, profoundly changes the nature of a forest. Just one example of that change: The species of animals that need old primary forest—like Marbled Murrelets, Northern Goshawks and Mountain Caribou—won’t survive for long in a landscape covered by clearcuts, logging roads and managed plantations. It would take hundreds of years for an old forest ecology to re-emerge, but that’s not in the government’s plan. So how could the conversion ever be considered “environmentally sustainable”?
    It follows, then, that when anyone claims logging in BC occurs according to strict regulations that ensure environmental sustainability, the only part of that claim that might be true is the “strict regulations” part. So let’s examine that.
    After the BBC recently caught the British energy corporation Drax in the act of logging primary forest southeast of Prince George and turning it into fuel pellets, one of the defences Drax CEO Will Gardiner offered was this: “Areas identified by the [BC] Government for harvest are carefully selected by them using an exhaustive list of environmental criteria that includes but is not limited to; old growth management; landscape and site level biodiversity; age class distribution (old growth); riparian management; watershed management; wildlife management; visual quality; species at risk; rare and sensitive ecosystems; cultural heritage resources; soil quality; species diversity; site productivity; as well as social and economic considerations.”
    Gardiner was repeating the first part of the lie: Logging companies in BC labour under a great weight of stringent science-based regulations imposed by the government that are designed to ensure environmental sustainability.
    A more succinct expression of this part of the lie was recently offered by then BC Forests Minister Katrine Conroy, who explained to a Business in Vancouver reporter why other countries—like Japan—prefer to buy wood products from BC: “They recognize that we have some of the most stringent regulations for environmental sustainability when it comes to how we take care of our forests, as well as how we harvest them.”
    But the claim that BC has “stringent regulations for environmental sustainability” is not actually supported by forest legislation. Instead, all of BC’s legislated, science-based “stringent regulations” aimed at protecting non-timber values can only be enforced to the extent that they do not “unduly reduce the supply of timber from British Columbia’s forests”.
    That constraint on regulation, by its use seven times in the Forest Planning and Practices Regulation, legally limits the extent to which wildlife, soils, fish, riparian areas, sensitive watersheds and biodiversity (at both the landscape and stand levels) can be protected when an area is logged.
    To what degree are conservation objectives limited by the “unduly” clauses? Pretty darn close to 100 percent.

    Logged and burned primary forest in the Klanawa Valley (Photo by TJ Watt)
    That detail is not spelled out in the Forest Planning and Practices Regulation itself. But a Ministry of Forests’ document written by staff of the Forest and Range Evaluation Program in 2003, just before the Regulation was enacted, stated that the impacts of conservation objectives on timber supply were to be capped at no more than 6 percent—province-wide (1).
    The reason for the “unduly” clauses in the Forest Planning and Practices Regulation was also made clear in the document: “The intent of this language is to ensure that conservation of non-timber values is undertaken in balance with economic benefits”.
    That lop-sided, politically determined “balance”—94 points for logging and 6 for conservation—makes it clear that imposing “stringent regulations” was never the purpose of the legislation.
    The purpose was to create laws that appear to impose stringent regulations without actually imposing stringent regulations.
    The Forest Planning and Practices Regulation and its hidden cap on timber supply impact have allowed 20 more years of nearly unfettered destruction of primary forests, while at the same time providing excuse-makers in government and industry with credible “proof” that it’s all under control.

    Can you spot the protection of conservation values in this clearcut east of Prince George? (Photo: Sean O’Rourke/Conservation North)
    The office that’s supposed to enforce those “stringent regulations” is the Natural Resources Compliance and Enforcement branch (C&E). But its record of protecting BC’s forested ecosystems suggests that it knows it’s not supposed to do anything that might impact timber supply. Over the last 11 years, C&E has failed to get even a single administrative penalty, administrative sanction or court conviction against any company or individual under the Forest and Range Practices Act, the Forest Act, the Forest Stand Management Fund Act, or the Forest Practices Code of British Columbia Act, according to its public record of such cases.
    You might think that’s because no one in the logging industry has done anything wrong in the last decade.
    But I know of one slam-dunk case in which old primary forest on Quadra Island was logged in contravention of the tenure-holder’s commitment to retain old forest—and C&E declined to investigate due to budgetary and staff constraints.
    According to the BC government directory, C&E currently employs 8 people as “investigators” of infractions of forest-related laws. To cover the entire 22-million-hectare timber harvesting land base—the area in which logging is occurring in BC—each investigator would be responsible for an area about the size of Vancouver Island.
    By putting a 6 percent cap on the impact that conservation measures can have on timber supply, the forests ministry long ago signalled to its managers, employees and the logging industry that it wasn’t watching to see if science-based objectives were being met—or any other nicety of “environmental sustainability” either.
    By the way, this idea of arbitrarily limiting the impact of conservation measures on timber supply wasn’t invented by Gordon Campbell’s Liberals. Under the 1990s NDP government that preceded the Liberals, provisions for protecting biodiversity were subject to a 4 to 4.3 percent cap on timber supply impact (2). Different government, same message, same reason: To ensure that conservation of non-timber values is undertaken in “balance” with economic benefits.
    You might be wondering: “What should the balance between logging and conservation have been?” Let me answer that question and that will lead us to the second part of BC’s Big Lie.

    Logging of primary forest near Prince George (Photo: Sean O’Rourke/Conservation North)
    If BC did have stringent, science-based regulation of logging, what should the balance between logging and conservation be?
    The basic consensus of provincial forest scientists back in the 1990s and early 2000s was that logging would not threaten biodiversity unduly if it mimicked natural disturbances. After all, nature itself eventually turns old forest into young forest: by blowing it down, burning it, infesting it with insects or infecting it with disease. If logging mirrored the rate at which old forest is naturally turned back into young forest, the scientists reasoned, then logging would present only a low risk of biodiversity loss.
    But it has turned out that the natural rate at which old forest is turned into young forest is much slower, and the areas impacted are smaller in size, than had been understood in the 1990s when land use planning for BC’s publicly-owned forests began.
    A 2003 study (3) by forest ecologist Dr. Karen Price and forester Dave Daust found that forests on Haida Gwaii and on the central mainland coast were disturbed far less frequently—and those disturbances involved much smaller areas—than forest scientists had previously understood.
    That finding meant that, in their natural state, BC forests would have contained a much higher percentage of old forest than had previously been estimated. If the rate of logging was going to mimic nature, then in order to protect biodiversity and other ecological values, a much higher percentage of old forest than government had planned to leave would need to be left for nature.
    For example, where I live on Quadra Island, the return interval for stand-replacing natural disturbances was estimated at 200 years in 2001 (Biodiversity Guidebook). The minimum old forest retention target on Quadra Island, based on that return interval, was 9 percent. But the 2020 Interim Assessment Protocol for Forest Biodiversity in British Columbia, which has built on Price’s, Daust’s and other forest scientists’ findings, now estimates the stand-replacing disturbance return interval on Quadra Island and surrounding area to be 700 years. It’s now estimated that old forest (greater than 250 years old) would have covered about 70 percent of the forested area of the island (4).
    According to other work (5) done by Price, Daust and forest ecologist Dr Rachel Holt, keeping the risk of biodiversity loss to “low” would mean maintaining at least 70 percent of that area of old forest. So at least 49 percent (70 percent of 70 percent) of the forested area of Quadra Island would need to be old forest to keep the risk of biodiversity loss to “low”—far above the 9 percent used as a guide to manage old forest there since 2001.
    On Quadra Island, the imposed “balance” of 94 to 6 in favour of economic use over conservation of old forest should have been more like 50-50. But under the current management regime, the area of old forest has been allowed to fall to just under 4 percent of the original forested area on Quadra Island (6).
    The impact of all those years of logging old forest far past the limits of ecological sustainability in BC has left us with a collapse in biodiversity and a critical need to draw lines around the remaining old forest. The most advanced forest scientists tell us we urgently need to implement our new science-based understanding of how much old forest is needed to protect biodiversity. We would do that by identifying suitable old forest, providing it with legal protection, and if that’s not enough, then recruiting the balance needed from mature second-growth forests in the timber harvesting land base.
    And that brings us to the second part of BC’s Big Lie: That the BC government has a reliable inventory of the provincial forest, and, in particular, the extent of old forest that remains, and where it is.

    Removal of primary forest in the Inland Temperate Rainforest (Photo: Mary Booth/Conservation North)

    Is the liquidation of primary forests in BC being carefully monitored?
    First, let’s consider why having a reliable inventory of old forest is essential.
    A New Future for Old Forests, the report of the Strategic Review of How British Columbia Manages for Old Forests Within its Ancient Ecosystems, appeared in September 2020. Since then the Ministry of Forests has struggled to implement temporary logging deferrals in some old-growth forests. One of the criticisms of the deferral process has been that logging has continued in old forests despite the deferrals. But there is an even more fundamental problem with the process: The Ministry of Forests doesn’t have a good understanding of how much old forest remains, or where it’s located.
    Yet an accurate assessment of each of these will be critical to the success of the current old-growth logging deferral process and Premier Eby’s promised doubling of protected areas by 2030. If an area is deferred because the ministry believes it contains old forest but it doesn’t, and another area that does contain old forest isn’t deferred, the process could end up being a pointless exercise in drawing meaningless lines on maps.
    To identify at-risk old forest, the deferral process has relied entirely on a Ministry of Forests’ inventory called the Vegetation Resource Inventory (VRI) that estimates, among other things, the age, site index and dominant tree species growing in almost every stand of BC’s publicly owned forests. The database is used in decisions about where to log and how much can be logged and it is held up by the Ministry of Forests as just one of the many powerful, science-based tools it has for managing the “sustainable” liquidation of old forest.
    But is VRI accurate? No. In terms of locating old forest, throwing a dart at a map would be just as accurate.
    Over the past four years, the Discovery Islands Forest Conservation Project has been mapping the remaining old forest on Quadra Island and other islands in the Discovery Islands area. Like the Ministry of Forests, the project uses analysis of satellite photography. But unlike VRI, the project complements satellite image analysis with local knowledge, extensive drone videography and, finally, on-the-ground confirmation that old forest is indeed present.
    There is very little similarity between the mapping of old forest being used by the Technical Advisory Panel (TAP) to identify old forest and the Discovery Islands project’s mapping of old forest. In general, VRI puts old forest where there isn’t any and misses the vast majority of actual old forest on Quadra Island. Of the 171 small fragments of old forest the project has mapped so far, only 19 of those overlap with areas in TAP’s Priority Deferral Map. Since the total area of old forest on Quadra Island is down to around 4 percent of the area of the original forest (6), old-forest-dependent biodiversity could hardly be at higher risk. All the remaining old forest needs to be deferred.
    Yet logging of old forest is still occurring on Quadra Island and the ministry’s inventory doesn’t even know it’s there.

    Priority deferral areas (solid green) on Quadra Island have little overlap with actual areas of old forest (outlined in yellow) found and mapped by the Discovery Islands Forest Conservation Project (click image to enlarge).
    One particular failure by VRI to identify old forest seems emblematic of its inaccuracy: The TAP Priority Deferral Map, using VRI, shows there are only two small remnants of “Ancient Forest” remaining on the Discovery Islands. TAP says that this is forest that has been “identified as over 400 years old”.
    The Discovery Islands Forest Conservation Project visited one of these two areas of “Ancient Forest”, a 5.7-hectare patch at Rosen Lake on Read Island. Unfortunately, this “Ancient Forest” had been logged sometime early in the 20th century and is now covered with second growth. On our visit we observed two or three large, old Douglas firs that undoubtedly were over 400 years old, rejected by the first loggers.
    Yet VRI showed the “projected age” of the forest as “833 years”. By the way, this area was in Read Island Provincial Park and is an Old Growth Management Area. So there was no need for it to be mapped as a priority deferral area.
    Perhaps even worse, though, a portion of the road into Rosen Lake was also given priority deferral. Just the road mind you, not the forest on either side of the road.

    Above: The forest at Rosen Lake, one of just two areas of “Ancient Forest” on the Discovery Islands, according to the Vegetation Resource Inventory. The inventory says it is 833 years old, but it had been logged in an era when loggers used spring boards, axes and crosscut saws. (Photo: David Broadland)
    On the other hand, the Discovery Islands Forest Conservation Project has identified several areas of “Ancient Forest” on Quadra Island that aren’t acknowledged in the VIR database.
    I have no reason to believe that VIR’s inaccuracy in predicting where old forest is on the Discovery Islands is any different from the province as a whole.
    To be fair, TAP warned that such errors were going to occur and that the Vegetation Resource Inventory would be the source of the inaccuracy. It’s not the deferral process that we need to be wary of. It’s the quality of the tools the Ministry of Forests has created to conduct its program of old forest liquidation that are the problem. They certainly don’t work for identifying old forest, but the problem is much larger than that.
    All timber supply reviews and allowable annual cut determinations in BC over the past 20 years have relied on the Vegetation Resource Inventory to predict the existing volumes of wood remaining in unmanaged forests. Yet the inventory is hopelessly inaccurate. I’ve written previously about the failure of the ministry’s growth and yield models to accurately predict growth and yield in managed plantations, its failure to incorporate uncertainty in its calculations, and its refusal to be guided by the precautionary principle. The ministry’s tools and operational choices seem ideally suited for producing self-delusion: The ministry has an unshakeable belief that it knows what it is doing and what the outcomes will be. But in 2021, a year of record market demand and high prices for BC wood products, what publicly owned forest could be found to log only amounted to 62 percent of what the ministry timber-supply experts had long predicted would be available.
    Is it a Big Lie—or just a Big Delusion?
    For BC’s “Big Lie” to meet the definition of a lie, the tellers of the lie must know that what they are saying is not true but say it anyway. There needs to be an intention to mislead.
    But did former Forests Minister Conroy know about the “unduly” clauses in BC’s forest legislation? Did the minister know about the 6 percent cap on the impact of conservation measures on timber supply? Did she know about the under-resourced Compliance and Enforcement branch and the failures of her ministry’s vaunted information technology? If she didn’t, then whenever she boasted about the “environmental sustainability” of BC’s logging industry, she wasn’t really telling a lie.
    She was merely suffering from an unshakable belief in something that’s untrue—a delusion.
    We can only hope that new Premier David Eby and new Forests Minister Bruce Ralston are neither liars nor prone to delusion. But only time will tell.
    David Broadland started working for the Discovery Islands Forest Conservation Project in 2018 and thinks other people would enjoy the experience of discovering old forest that—according to the Ministry of Forests—doesn’t exist.

    Loys Maingon
    There is no legal requirement for forestry companies and forestry stakeholders, such as First Nations, the Ministry of Forests, or the Ministry of Environment and Climate Change, to carry out biological surveys and identify species at risk that may be impacted by forestry operations. Instead, Western legal ownership rights trump environmental obligations to community stewardship of biodiversity. Industry and government say they care about biodiversity but, in practice, do little to protect it. BC urgently needs a Biodiversity Protection Act.

    A TimberWest clearcut above Granite Bay on Quadra Island. The company is not required to carry out biological surveys and identify species at risk before it logs such areas on Quadra Island. (Photo: David Broadland)
    FREDERIC E. CLEMENTS (1874-1945), who is best known as a pioneer plant ecologist and taxonomist, was one of the last disciples of Alexander von Humbolt in American botany before the re-birth of interest in Humboldtian Science in the 1990s. That makes Clements a forerunner of modern biologists and foresters who advocate for plant sentience, such as Suzanne Simard and others who tend to see forests as super-organisms. It is noteworthy that while Clements’ organismic view of nature may have been viewed as “unscientific” in some quarters during the post-1945 era, Clements was responsible for developing some of the most rigorous methods used in the study of plant ecology. It was Clements who introduced America to the methodical survey of plants and their landscapes by quadrats, transects, bisects, camera sets, and ring counts. These methods were described in the second chapter of his 1929 classic text, Plant Ecology, that he co-authored with John Weaver.
    One hundred years on, these methods remain fundamental to our knowledge of site biodiversity. Even if the sampling methods are refined by technological advances to aerial, soil, or aquatic environmental DNA analysis, they remain essentially the same. They are systematic subsamples of hard data to be analysed statistically. Biologists can only assess the species composition of a site and its biodiversity by carrying out systematic site surveys. It is a simple fact: no data, no science, only hearsay.
    That has an important implication if we bear in mind current growing concerns about climate change. As recent IPCC reports have been at pains to stress, climate change cannot be addressed if we do not also address the biodiversity crisis. The planet is not a machine. It is a living system. The complex interactions of living organisms control and regulate climate. Federal and provincial institutions that claim to protect or be concerned with biodiversity, and by extension, climate change, without supporting a programme of systematic biological surveys to assess biodiversity, are simply misleading the public. The state of our forests’ biodiversity is essential to the future of climate change. The state of our forests’ biodiversity can only be ascertained by carrying out rigorous species composition surveys.
    In a remarkable entry regarding the application of belt-transects, Clements makes the following observation about the use of ecological survey methods in forestry:
    “The belt-transect method has been used very successfully for recording the composition of tropical rainforest and especially for commercially important trees. The belts are of sufficient width (66 ft) and frequency (1.25 miles apart) to include 1 per cent of the area. In fact, the method has long been used by American foresters, although they make an optical estimate of the width of the area cruised and record the number and size of merchantable trees instead of mapping them.”
    This archaic forestry norm has largely remained unchanged and unquestioned for the past century. As John Neilson and I discovered in the course of an effort to save a population of Pseudocyphellaria rainierensis (Oldgrowth Specklebelly), a rare lichen nominally protected by a provincial and federal agreement, and listed in standard forestry documents, that norm still applies in BC. While some forestry companies may elect to carry out biological species surveys before clear-cutting an area, in British Columbia there is no legal requirement for forestry companies and forestry stakeholders, such as First Nations, the Ministry of Forests, or the Ministry of Environment and Climate Change, to carry out biological surveys and identify species at risk that may be impacted by forestry operations. Western legal ownership rights trump environmental obligations to community stewardship of biodiversity. In forestry operations, barring explicit cultural interests, the value of “merchantable trees” remains the primary, if not the only, determinant of where forestry operations will take place. Species composition and biodiversity assessments are disregarded.

    Natasha Lavdovsky examines Oldgrowth Specklebelly growing side by side with Lobaria linita (the greener lichen), on a tree marked with falling boundary tape, indicating the edge of a future clearcut beside a creek/riparian reserve (photo by Natasha Lavdovsky)
    This common practice means that we have very little idea of what faunal and floral species have been lost and extirpated over the past 150 years of colonial occupation, which is synonymous with “forestry operations.” Indeed, the case of the discovery of hitherto undocumented populations of listed species at Fairy Creek and the demise of Pseudocyphellaria rainierensis at Fairy Creek should serve as a cautionary tale of Canada’s lack of actual concern for biodiversity, outside of the arcane world of the biological scientific circles not in the pay of industry and government. Although this area is less than 80 kilometres from the Ministry of Environment and Climate Change’s and the Ministry of Forest Lands and Natural Resources Operations’ offices, these ministries could not provide Neilson and I with data concerning faunal or floral species that might be adversely affected by ongoing and proposed forestry activity. Astoundingly, the presence of at least 16 well-recognized and easily identifiable species-at-risk was hitherto unknown and unrecorded by ministry staff, whose ministries are nominally responsible for documenting BC’s flora and fauna, and biodiversity data collection.
    As we enter what the United Nations has proclaimed to be “The International Decade of Biodiversity”, there is an obvious disconnect between stated concerns for biodiversity and actual policy direction. In keeping with the Convention on Biodiversity, the joint report of the IPCC and the IPBES, and a growing string cannot be addressed independently of the biodiversity crisis. The world is neither a machine nor a supermarket. As Humboldt and contemporary science increasingly tell us, only life makes life possible on a living planet, and even processes driving phenomena like temperature and climate that we once considered to be “abiotic” are, in fact, biologically driven by floral and faunal composition and organization. Provincial and federal governments, if they care at all for climate change, do not seem to understand the link between biodiversity and climate change. The World Meteorological Organization’s recent report State of the World’s Climate 2021 makes the transient front pages of mainstream press to tell the public that we have indeed crossed critical thresholds. However, as the WMO notes, thanks to government inaction, generations to come can expect continued ocean warming and acidity as well as increased heat waves, cyclones, and hurricanes. Political action on climate change over the past three decades appears to have been mainly cosmetic and out of touch. Within this context, when it comes to actually protecting biodiversity, at all levels government response belongs with an alternate reality reminiscent of Monty Python’s Dead Parrot Sketch.
    The recent excellent work of Melissa Aroncyk and Maria I. Espinoza, A Strategic Nature, which traces the role of corporate public relations in shaping public understanding of nature and the environment, is worth reading. It traces the evolution of public relations strategies, often illegal but highly effective, in shaping public policy by manipulating the public and political understanding of science and the response to environmental problems. Their thesis is that through public messaging, corporate interests capture and create the illusion of environmental awareness and responsibility. That illusion pervades government and mainstream environmental organizations, on whose boards corporate representatives sit, and on whom these organizations depend for funding. Indeed, in BC, the boards of many land conservancies, land trusts, and mainstream environmental organizations are peopled by corporate executives who help finance these organizations. Serious environmental concerns such as biodiversity become subordinated to corporate messaging and greenwashed. It, therefore, is not surprising to find that Calvin Sandborn and Bronwyn Roe of the University of Victoria’s Environmental Law Centre have reported that corporate greenwashing is up 40 percent.
    That is just the marketing aspect of corporate greenwash. It does not include the cultural and institutional greenwashing that pervades all aspects of our lives, as Aroncyk and Espinosa argue. For corporations and the governments that effectively serve them, climate change and biodiversity policies are just a public relations exercise, which is why they have failed for the past 40 years and are designed to continue to fail. Climate change policy and biodiversity policies in Canada fail because they are designed not to encroach or conflict with corporate forestry, mining, and oil and gas interests.
    It would be misleading to think that the problem might be limited only to British Columbia. The recent unprecedented decision of the federal government to use its powers under the Species a Risk Act to intervene by decree to protect dwindling caribou populations in Quebec raises basic questions. By setting aside 35,000 square kilometres of critical habitat amounting to 2.3 percent of Quebec’s territory, Ottawa is not simply infringing on Quebec’s jurisdiction, it is protecting First Nations’ interests. One of the principal drivers of Ottawa’s intervention is the request of the Assembly of First Nations Quebec-Labrador that Ottawa protect the cultural rights and interests of First Nations that were excluded from Quebec’s public consultative process. The commission set up by Quebec to determine the fate of the caribou was driven by forestry interests and stakeholders that did not include First Nations.
    In Quebec, as in BC, this is a debate that is focused on the fate of the last remaining “old-growth” forests, which are critical to the survival of the species, and which are also of cultural interest to local First Nations. Thirty-seven leading biologists from 11 of Quebec’s universities weighed in to protect this habitat in the interests of the species and climate change. The scientific intervention had little impact. In this instance, the Species at Risk Act is not being used to protect the species per se, but rather First Nations’ rights to the species and the forests that are their critical habitat. It is crucial to note that throughout this saga that while Quebec biologists and naturalists have been extremely vocal about the need to protect biodiversity and species at risk, the official and publicly stated position of the Legault government and the “Ministere des Forets, de la Faune et des Parcs” (“Ministry of Forests, Fauna and Parks”) has been that the economic priorities of the forestry industry trumped biodiversity. It is also worth noting that, as in BC, in Quebec the ministry responsible for biodiversity is a ministry of forests closely aligned with the interests of the forest corporations and unions. These are really ministries dedicated to the well being of the forest corporations, not to forests and biodiversity.
    So, the provincial and federal interest has only been tangentially in biodiversity and in the species themselves, though the public is misdirected to think otherwise. It has been mainly interested in either the mainstream forestry economy or in the First Nations’ cultural rights and interests in that economy and the management of the forest and its “resources.” While First Nations’ management of the forest may indeed have a better track record than mainstream industrial forestry, as has been demonstrated, it is still focused on the forest as a source of economic prosperity and employment. The fate of species and biodiversity is still subsumed to economic interests.
    It is critically important to note that although Quebec, unlike BC, has species at risk legislation, Quebec’s provincial government has an appalling track record when it comes to protecting biodiversity. The act is set aside or generously interpreted whenever the interests of development or forestry are threatened. With complete disregard for scientific advice to the contrary, the Quebec government recently opposed the protection of the copper redhorse (Moxostoma hubbsi) and authorized the extirpation of the last habitats of the Boreal chorus frog (Pseudacris maculata). These species, whose future is now largely uncertain, were only possibly saved after much public outcry, at the very last minute by federal interventions.
    The Quebec examples demonstrate that the federal Species at Risk Act has very little real power to effectively protect species biodiversity throughout Canada’s increasingly endangered ecosystems. Provincial species-at-risk legislation can be disregarded in favour of the economy at the discretion of ministers. We, therefore, have every right to ask: “Is species at risk legislation in Canada just another bureaucratic shibboleth to pay lip service to?”
    Recent variations of the same provincial and federal half-truths or prevarications can be found in BC.
    In British Columbia, the current government was elected in 2017 on an electoral platform that captured “environmental” votes with promises to implement species-at-risk legislation. Upon election, the Ministry of Environment and Climate Change (MECC) began work on species at risk by de-listing about 30 percent of listed species. After three years of delays and promises, by 2020, the MECC ceased work on this file. Responsibility for the protection of species at risk was magically transferred to the Ministry of Forests, Lands and Natural Resources Operations (FLNRO). This move corresponded to the government’s much heralded review of the Forest and Range Practices Act, to align the problem of “species at risk” with the 2019 Declaration on the Rights of Indigenous Peoples Act. The unstated aim of these changes was to put decision making back in the hands of forestry-dependent communities, which was now to include and give greater prominence to First Nations dependent on forestry revenues. This was explicitly summed up by Minister Conroy: “We’ll put government back in the driver’s seat of land-management decisions in partnership with First Nations, including where forest roads are built.” Like Quebec, the forest industry’s priorities are to be supported by communities that are economically dependent on the forest industry. Unlike Quebec, the BC government also understood that by including First Nations in the economic benefits and decision-making associated with the forestry industry, status quo could effectively be maintained without making real changes to the Forest and Range Practices Act.
    This strategic public relations move was clearly intended to download responsibility for species at risk, which has always stood in the way of the forest industry’s interests, onto First Nations. As a result of this strategic downloading, any public or scientific attempt to protect endangered species stands to be interpreted as an attack on the corporate interpretation of “ownership” under The United Nations Declaration on the Rights of Indigenous Peoples Act. Under this scenario, science no longer matters when a First Nations government beholden to the forest corporations upholds its logging interests.
    In spite of all the sweet-sounding motherhood and pie promised under the much-heralded revisions to the Forest and Range Practices Act, at no point is protection of species at risk ever really considered. There is no real interest in the Act and its revisions in the protection of biodiversity. The essential point that a biological survey needs to be carried out to determine the ecological impact of logging activities before a logging permit is issued is never even remotely considered in this legislation. The Act, together with its much-heralded “progressive” revisions, remains beholden to the forestry practices and interests described by Clements in 1929. A species at risk act, based on basic scientific principles inherent in biological surveys, such as was promised and envisioned before 2017, would seriously compromise the viability of this economic and political edifice.
    This government has not stalled work on species at risk legislation, it has duplicitously shifted the conversation to make species at risk and biodiversity legislation disappear by promoting First Nations’ interests in mainstream forestry economics. Biodiversity is inconvenient to political interests. It is neither a federal nor a provincial priority, any more than climate change has ever really been for the past 30 years, as the track record shows.
    The general assumption made by the public and the environmental community is that First Nations stewardship for the land should provide better protection for species at risk, as indeed it usually does. The assumption is largely based on the cultural value that keystone or umbrella species, such as large mammals or salmon, have within the First Nations world-view. As with the general keystone and umbrella top-down approach in ecology, this approach has all the pitfalls of coarse-grained approaches. The survival of bottom-up primary producers of lesser cultural immediacy, which is only evident in fine-grained analysis, stands to be jeopardized. In a society in which the public itself is largely unaware of species other than signal macro-species, First Nations’ cultural nature-literacy does provide definite leadership. However, as in any society, the requisite fine-grained knowledge necessary for environmental management is the domain of only a select number of trained scientists and knowledge-keepers. The problem for settler society seems to be that in rejecting a species at risk legislation, it also rejects its knowledge-keepers, its biologists, and in so doing, encourages First Nations to turn their back on their own knowledge-keepers.
    The assumption that First Nations’ leadership and engagement will substitute species at risk legislation is misleading because it depends on the ambiguity and fluidity of the concept of “ownership.” In Delgamuukw, hereditary chiefs set the bar for subsequent aboriginal rights and claims by stressing that aboriginal ownership is an obligation to the care for the territory because it is identical with the people. Aboriginal ownership is, therefore, diametrically opposed to western legal concepts of “ownership.” Anglo-American law defines “ownership” as “the power to enjoy and dispose absolutely.” Ownership as it is related to industrial practices and corporate interests, by definition invites “the power to enjoy and dispose absolutely.” The meaning of a word is always performative. There are no essences that magically define a word outside of the role it has in a context. The meaning of “ownership” shifts with the economic framework and context. In a corporate economy, ownership is the power “to dispose absolutely,” regardless of the culture. As Joel Bakan has repeatedly demonstrated, a corporation is a psychopathic entity, no matter what cultural dressing it takes.
    Through the revisions to the Forest and Range Practices Act, as well as the recent doubling of First Nations’ share of forest revenues, the provincial government has effectively modified the “ownership” of First Nations as major stakeholders in the forest industry. By increasing the dependency of First Nations communities on revenues from the forest industry as a matter of social justice, it would be naïve to argue that the meaning of ownership within those communities is not affected. Indeed, while hereditary Pacheedaht chief Bill Jones, in keeping with Delgamukw, argued against logging of old growth and for his obligations to his traditional territory, elected chief Jeff Jones has publicly argued forcefully for his right to dispose of the forest as he sees fit for the economic well-being of his community. These are two starkly different versions of “ownership.” The Jeff Jones version, which was opposed by the position taken by the BC Union of Chiefs, is the version of ownership upheld and promoted by the Minister of FLNRO and her many colonial predecessors. This version is diametrically opposed to the spirit informing Delgamuukw and UNDRIP, which the same government and its First Nations supporters claim to promote in support of corporate interests. That is corporate greenwash at its finest. Can one really have one’s cake and eat it? Apparently so....
    In 2021, this cultural contradiction had tragic consequences for the largest population of Pseudocyphellaria rainierensis ever found in Canada. This unique population of a rare lichen protected by a federal and provincial agreement received no protection whatsoever and has now been extirpated. Every level of government, starting with the elected Pacheedaht Council, MECC, and FLNRO as well as the forestry company concerned and federal Minister Steven Guibeault were formally appealed to in order to save this species at risk. What stood in the way were the financial interests of Teal Cedar and Pacheedaht council led by Chief Jeff Jones. There is no difference between Premier Francois Legault’s claim to Quebec’s territorial right to extirpate three populations of endangered mountain caribou because endangered species cannot be allowed to stand in the way of jobs, and Chief Jeff Jones territorial claim to protect aboriginal employment on Pacheedaht lands by enabling the extirpation a population of endangered lichens. The non-aboriginal logic of legal ownership gives license to those private interests that steal from the inheritance of future generations.
    The extirpation of this population is a confirmation that, while intentions may be good, and while some First Nations feel more obligations to endangered species than others, the ultimate protection of species at risk cannot be left to the discretion of First Nations, as the BC government contends, anymore than it can to municipal, provincial, or federal governments.
    Should there be any illusions about the moral high ground that the federal government may claim thanks to its obligations under the Species at Risk Act, two recent actions of Canada’s ex-Greenpeace firebrand minister of the environment may leave one somewhat nonplussed. Back in 2021, marbled murrelets (Brachyramphus marmoratus) were one of the species at risk found to be nesting in the Fairy Creek area. Leading experts urged the minister to issue a ministerial order to protect this blue-listed species whose numbers are steadily declining and which is now known to be functionally extinct. It was then thought that by November 2021, Steven Guibeault would issue a ministerial order to protect critical marbled murrelet habitat, which is known and mapped. Instead, minister Guibeault has upheld the standard provincial development and forestry guidance norm, which is an extension of the Migratory Bird Convention Act (1994), that no tree could be fallen if it was found to have an active nest. Of course that depends on making a determination that a) there is a nest, and b) that it is occupied, without actually having to carry out a minimal biological survey.

    Marbled murrelets nest on wide branches, high above the forest floor, and lay only one egg. (Photo: Peter Halasz)
    For anyone familiar with marbled murrelet habitat, this protection can only strike one as 100 percent montypythonesque. First, murrelet nests are minimal and notoriously difficult to locate, as they consist of a mossy depression enclosed between two densely vegetated branches about 30 to 60 metres (100 to 200 feet) up an old-growth tree in a dense forest. The only way to find a nest is to be on location before sunrise and observe a tiny bird come out of the ocean clouds and enter its “nest” at high speed, from which its partner will depart shortly after. Second, after August, the nests are vacated and the tree can be fallen, thereby removing critical habitat together with the need to protect this species at risk. Indeed that is what occurred in the fall to critical marbled murrelet habitat in the Fairy Creek area. That is the high level of federal protection that has not too surprisingly resulted in the extirpation of yet more marble murrelet habitat throughout BC, and the further decline of the species protected under SARA. That is what greenwashing government institutions sell to the Canadian public as a gold standard in Canadian conservation and biodiversity protection.
    It is no surprise that the Minister of Environment and Climate Change now faces a lawsuit for failing to uphold his responsibilities as outlined in the federal Species at Risk Act. For this external observer, the lawsuit itself is somewhat surreal. While one needs to keep a straight face listening to the serious intent of environmentalists and lawyers, most court and media discussions tend to be simplistically devoid of a sense of the biological reality based on facts. It is all arcane points of law between learned friends paid to argue in court. The government and the corporations don’t collect biological data. The environmental organizations rarely collect data. If they do, it is at the last minute. How can anything be based on facts without, established baselines and robust data? Yet we are told that everybody cares for “the environment,” “resilience,” and “sustainability.”
    Conservation is not difficult if you start with the facts. The facts are the data of a biological survey. But nobody, no lawyer, no environmental activist, no forestry executive or FLNRO official, or First Nations’ representative, wants to talk about the most basic and urgent fact: there has been no real data collection, because the data are inconvenient to the political and financial interests at play.
    The basic facts are either absent because a survey was not carried out, or because if the facts do exist they are disregarded in favour of forestry or natural resources industry interests, which in this case have been compounded by BC’s downloading of its responsibilities for species at risk to First Nations under UNDRIP. If we want to understand why Steven Guibeault, a bona fide environmentalist, could avoid taking action and produce an irrelevant statement, we have to understand his predicament. Should Guibeault uphold actual protection of critical marbled murrelet habitat, he would infringe on the financial interests of the forestry industry, forestry unions, and First Nations forestry revenue dependency. Under the new provisions of BC’s Forest and Ranges Practices Act, that would constitute an infringement on the United Nations Declaration on the Rights of Indigenous Peoples Act, which is a hot potato nobody wants to touch or discuss seriously. It would be interpreted as an act of colonialism infringing on the right of the Pacheedaht and Ditidaht to enjoy and dispose absolutely of their property and maintain forestry revenues, notwithstanding that this interpretation vitiates the original understanding of aboriginal ownership under Delgamuukw. So marbled murrelet protection is limited to a public relations exercise.
    This is also consistent with the federal government’s protection of Southern resident killer whales and Chinook Salmon habitat in the Salish Sea. While the fate of prime nursing habitat at Roberts Bank continues to be threatened, after adverse scientific reports were submitted to the minister three years ago, the minister has yet to sign an order to put an end to the ecological threat posed by the Vancouver Port Authority’s Roberts Bank Terminal 2 project. The problem here is not that the reality of this threat is not soundly established by scientific evidence. The problem remains that this project is considered economically essential to Vancouver’s growth. It may yet appeal to the public if the economy slumps. “Roberts Bank Terminal 2” has gone eerily silent, though mention surfaces from time to time awaiting for the right circumstances. Meanwhile, as like every good magician, Steven Guibeault has used misdirection to draw the public’s attention to a renewal of fisheries closures and the re-introduction of “sanctuary zones” for Chinook Salmon off Pender and Saturna islands. Roberts Bank used to be nature’s “sanctuary zone” for salmon. The newly selected zones may soon be used to mitigate planned losses needed to support endless growth. After all, if Legault can’t trade jobs for endangered caribou, or Chief Jeff Jones can’t trade old-growth jobs for rare Pseudocyphellaria rainierensis populations, maybe Steven Guilbeault, who could not trade oil and gas jobs on the Bay du Nord project for beluga habitat, will likely find it necessary to save jobs rather than salmon habitat and biofilm at Roberts Bank? The writing is on the wall—forget species at risk legislation, it leaves too much discretion to ministers, and only deals with isolated species within complex ecosystems.
    There is a sad consistency in this logic. Corporate interests and the jobs that come with them consistently trump endangered species legislation and biodiversity. Yes, this is psychopathic. Canada and BC claim to be able to meet climate change targets they have never met—and never will, as they develop more oil and gas! BC claims to save endangered species without even having inventoried them as it cuts old growth! We are told First Nations log sustainably without really carrying out a biological survey anymore than the corporations they work with, because this is not a permit requirement! And yet we are told that we really care about biodiversity... as we see it dwindle before our eyes and daily witness more destruction.
    Fifty years after Richard Nixon signed into law the US Endangered Species Act, the NDP government of British Columbia has shelved plans to introduce species at risk legislation. It has cleverly downloaded that responsibility to First Nations engaged in forestry and increased their dependency on forestry revenues. Maybe it is time to realize that species at risk acts were cutting edge in 1973, but are no longer up to the task? What we now need is a Biodiversity-Protection Act.
    A Biodiversity-Protection Act would really not be very difficult to write or implement. Its fulcrum is this simple point: sites must be professionally surveyed before any resource extraction takes place. It begins with the simple recognition that the protection of biodiversity is essential to humanity’s survival on this planet. Corporate interests cannot be given precedence. The protection of biodiversity is a universal human obligation based on science, which is our objective common ground. The protection of biodiversity is not a cultural privilege, and it should not be treated as a cultural football. Management protocols must be adhered to for listed species identified. Critical habitat must be mapped and protected. If we are serious about addressing climate change and biodiversity for future generations, science must take precedence over economics, politics, and cultural privilege, for the good of all humanity.
    Loys Maingon is BC director of the Canadian Society of Environmental Biologists.

    David Broadland
    A flawed Forest Practices Board investigation of logging of “old trees” at Hummingbird Lake on Quadra Island highlights the failure of 20-year-old land use planning that was supposed to resolve ongoing conflict between logging and conservation.  
    IN JUNE 2022, the Forest Practices Board released an investigation report into a complaint about old trees being logged on a Quadra Island Woodlot Licence Program tenure. 
    The investigation found that the tenure holder, Okisollo Resources, had complied with the legal requirements of its approved logging plan. The Board praised the logging company for “setting aside all of the existing old-growth stands by designating them as wildlife tree retention areas.”
    However, the investigation report contains serious factual errors, partly the result of the Board’s failure to ground-truth the descriptions of the forest and logging that were at issue. No investigators visited Quadra Island. Not the least among the errors was the Board’s assessment that Okisollo Resources had set aside “all of the existing old growth stands…”
    The report’s failings unintentionally highlight how thoroughly the landmark 2001 Vancouver Island Land Use Plan—which took nearly a decade to complete—has been circumvented by the Ministry of Forests.
    I contacted the Board and Okisollo Resources after the investigation report had been released. Because of the factual errors included in the report it’s difficult to make sense of the Board’s justification of its findings. So let’s begin with some facts I gathered even before a complaint was filed. Then we will compare that with what the Board says are the reasons for its findings.
    It just so happened that I had visited Hummingbird Lake with a drone in July 2018, one year before the logging took place. I returned again in July 2019 while the logging was taking place and a third time in June of 2020, after logging had been completed.

    Hummingbird Lake and surrounding forest in July 2018, as seen from a drone.
    On each visit, I photographed the area, both on the ground and using a drone for aerial views of the forest and lake. Over the past five years, as part of the Discovery Islands Forest Conservation Project, I have been surveying forests at dozens of locations on Quadra Island where it seems possible or likely that old-growth forest could be logged before it has been properly identified.

    Old forest at the peninsula on Hummingbird Lake. Okisollo Resources have reserved the right to log the old forest on the peninsula, yet claim to have reserved all existing old forest.
    On my 2018 visit, I could find no stumps or other evidence that would indicate the forest on the north side of Hummingbird Lake had ever been logged. The BC government’s record of road building in the province shows the north side of Hummingbird Lake had never been roaded before Okisollo Resources began logging in 2014. A forest fire in 1925 had lightly burned through the area, leaving the old trees intact. About 5 years after that fire, hemlock and fir began to grow back—naturally—between the big trees.
    All the evidence suggested that the north side of Hummingbird Lake was rare primary forest with big, old trees growing at a density that was at least equal to any other old forest I have surveyed on Quadra Island.
    The centre of the cutblock on the north side of Hummingbird Lake lies within half a kilometre of the boundaries of both Small Inlet Provincial Park and Octopus Islands Provincial Park. In other areas of the woodlot, Okisollo Resources has clear cut right to the edge of the parks.
    When I visited the logging operation in July 2019, roads had been built. There was a completed cutblock near the southwest corner of the lake where four old-growth Douglas firs still stood. Ten full-length tree trunks were lying beside the road into the second cutblock—all old-growth Douglas firs that had been removed to make way for the road.

    The new logging road built along the north side of Hummingbird Lake in July 2019.
    In a second cutblock on the north side of the lake, smaller-diameter hemlock and fir were in the process of being machine-felled (photo below). There were numerous large, old-growth Douglas firs and a few old cedars standing amongst the younger trees. It was unclear whether the dozens of old firs would be left standing or be felled. Every other tenure on Quadra Island leaves these big trees standing. I had never seen so many big trees in the middle of a Quadra Island logging operation.

    Okisollo Resources’ logging of old forest on the north side of Hummingbird Lake in July 2019.

    This photo, taken in 2020, shows the same area as in the photo above.
    I revisited the area in June 2020. Logging had been completed in the cutblock on the north side of Hummingbird Lake. Most of the old trees had been felled in both cutblocks. Along an edge of the northern cutblock, about 15 old vets still stood, testimony to the density of the grove that had just been cut.

    A line of old-growth Douglas fir vets was left along the edge of Okisollo Resource’s clearcut on the north side of Hummingbird Lake.
    I photographed the northern block where several large-diameter logs had been left beside the road. The growth rings of a recently live tree showed it had been 370 years old when it was cut. Several dead snags had also been cut and were stacked or scattered across the cutblock.

    This Douglas fir had 370 annual growth rings.

    To determine how many old firs had been logged in the northern cutblock, I searched for satellite images taken in mid-August 2019. The image below shows logging in progress in the second cutblock on August 15, 2019. At least 50 old-growth trees remained standing on this day. The smaller-diameter hemlock had all been cut, stacked and were being removed.

    The satellite image below was taken a few weeks later. Of the 50 old-growth trees that had been standing in the cutblock (see photo above), only 15 remained.

    In the cutblock at the southwest end of the lake, at least four old-growth firs that had been standing in the otherwise bare clearcut in July 2019 had been felled by mid-August.
    My photographs and notes, when combined with the satellite images, show that of approximately 64 old trees in the two cutblocks and the road, at least 50 were cut. The 3-hectare cutblock north of the lake had contained at least 55 live, old-growth trees and an unknown number of standing snags.
    The Ministry of Forests’ Harvest Billing System, which records the volume logged and the stumpage paid for trees cut on public land, shows that Okisollo Resources paid at most $3800 in stumpage for the 50-plus old-growth Douglas fir trees it felled in July and August of 2019. That’s roughly $76 per tree.
    That’s what actually happened at Hummingbird Lake in July and August of 2019. Now let’s return to the Forest Practices Board’s investigation report.
    The report gives the following chronological account of who did what and when they did it. The “complainant” was long-time Quadra Island resident Rod Burns:
    “In the spring of 2020, a Quadra Island resident (the complainant) noticed that old trees had been harvested in woodlot licence W2031. The complainant believed that the woodlot licensee was not permitted to harvest old trees, therefore filed a complaint with the Compliance and Enforcement Branch (CEB) of the Ministry of Forests in the spring of 2021. CEB looked into the matter and found that the licensee had harvested the old trees legally. When the complainant learned this, he filed a complaint with the Forest Practices Board on February 14, 2022, asserting that government enforcement was inappropriate.”
    Neither the Compliance and Enforcement Branch or the Forest Practices Board sent investigators to Quadra Island. Nevertheless, the Board released its investigation report in June 2022.

    From a drone, the areas of old forest on Hummingbird Mountain are easily visible. Since this photo was taken in 2020, additional logging has occurred.

    Hidden in plain sight: old-growth forest
    The Forest Practices Board found that 10 old trees had been cut and “the old trees were not set aside from logging. The licensee removed the trees to build a road and for safety reasons.”
    This was at odds with what I had seen.
    I asked Chris Oman, the Board’s director of investigations, how investigators had determined that old trees had only been cut “to build a road and for safety reasons.” After all, by the Board’s own admission, no investigator from either the Compliance and Enforcement Branch or the Forest Practices Board had even set foot on Quadra Island. As far as the Board knew, only 10 trees had been cut. How did the Board conclude that those 10 trees were cut “to build a road and for safety reasons”?
    Oman did not answer that question. But it would appear that investigators simply accepted Okisollo Resources’ assurance that this was the case.
    In response to questions I put to Chantal Blumel, a registered professional forester and a principal of Okisollo Resources, Ms Blumel stated: “We removed some of the old trees during the harvest of the second growth stands, for safety and access purposes.”
    There is no dispute that some old trees were removed for building the roads. Above, I estimated that at least 10 had been removed because they were in the way of the road. But was safety really an issue? The Occupational Health and Safety Regulation of BC’s Workers Compensation Act states: “If work in a forestry operation will expose a worker to a dangerous tree, the tree must be removed.”
    At the Hummingbird Lake cutblock, all of the smaller-diameter trees had already been removed several days before approximately 35 larger old-growth Douglas firs were felled. That can be seen in the satellite images. Those old trees did not have to be logged for either “safety” or “access” purposes.
    This apparent willingness of Forest Practices Board investigators to parrot the logging company’s position when it had no evidence to do so raises questions about the independent nature of the Board’s other findings.
    For example, consider the question of whether the 50 old trees that Okisollo Resources logged at Hummingbird Lake were under any existing protection from logging as a result of the Vancouver Island Land Use Plan, as Burns had believed. This is a difficult and complex question, one that the Forest Practices Board addressed superficially, but, at the same time, with remarkable creativity.
    The Board’s report dismissed the role the Vancouver Island Land Use Plan has played in guiding protection of old-growth trees and forest on Quadra Island by referencing a speech a forests minister had once made about woodlots. Instead of providing factual information, the Board invented a “Quadra landscape unit” to explain how old growth is managed. I asked the Board to send me any written documentation it had that explained what the “Quadra landscape unit” is. The Board did not acknowledge the request. There is no such thing as the “Quadra landscape unit.” It has long been promised, but has never materialized.
    A more useful consideration of whether the old trees at Hummingbird Lake had any protection would have required a detailed investigation into what Okisollo Resources had committed to in its official, approved Woodlot Plan, and why.
    What had it committed to do? The Forest Practices Board’s reading of Okisollo’s plan led investigators to conclude: “In their [Woodlot Plan], they committed to setting aside all of the existing old-growth stands by designating them as wildlife tree retention areas.”
    Why would Okisollo have done that? A little history is needed.
    A Woodlot Licence Program tenure was awarded to Okisollo Resources in 2011. But 10 years before that, all of the old forest at Hummingbird Lake had been protected under the provisions of Special Management Zone 19, which had been created by the Vancouver Island Land Use Plan. Over 12,000 hectares of public land on Quadra Island had been given that special status. Why had that protection been granted?
    In 2001, it was well known that the area of old-growth forest in the “Coastal Western Hemlock very dry maritime” biogeoclimatic zone (which includes most of the area of the Discovery Islands) had fallen to about 9 percent of the zone’s total area. Forest biologists and ecologists had determined that if the area of old forest fell below 10 percent of the total area of the zone, the risk of biodiversity loss in that biogeoclimatic zone would be high.
    To conserve the remaining biodiversity associated with the Coastal Western Hemlock zone, and to map a course toward restoration of old forest to a higher percentage, the Vancouver Island Land Use Plan recommended a specific strategy for Quadra Island. (Quadra was one of only two of the 19 forest-based special management zones where a strategy for biodiversity conservation was detailed.)
    In practice, that meant protecting all of the remaining “old” forest (defined as greater than 250 years old) since that had fallen below 10 percent, and managing future logging so that there would always be at least 25 percent of the forested area covered with “mature” forest (defined as greater than 80 years old).
    The most critical recommendation in that strategy is captured in a single sentence: “maintain existing old forest in the zone, as well as second growth with [a] high portion of veteran trees...”
    The old trees and old forest that were logged at Hummingbird Lake met both of those descriptions. So as of 2001, the old trees and old forest at Hummingbird Lake had been protected.
    Beginning in 2005, however, the Campbell River district office of the Ministry of Forests began to locate Woodlot Licence Program tenures in Special Management Zone 19. Under forest legislation passed in 2002, woodlots did not need to meet certain objectives established by government. That exemption included objectives like conservation of Quadra’s old forest and second-growth forest that had a high portion of old trees. So establishing woodlots in SMZ 19 would have made it legal to go backward in the effort to conserve old forest and old trees at places like Hummingbird Lake.
    By the way, the 11 Woodlot Licence tenures that were created or expanded in Special Management Zone 19 on Quadra Island, from 2005 onward, were the only woodlots created in any of Vancouver Island’s 19 forest-based special management zones.
    Almost all of the new Quadra Island woodlots choose to honour most of the previous obligations to protect old forest and old trees that had existed before woodlots were dropped on SMZ 19. For example, the official plan for Woodlot 2032, established at the same time as Okisollo Resources’ Woodlot 2031 at Hummingbird Lake, stated that it would avoid logging all old-growth trees and old forest.
    Did Okisollo Resources make that commitment?
    In its Woodlot Licence Plan, its strategy for conserving biodiversity included these words: “Retaining the existing old growth forests is key to maintaining the biodiversity values of forests in the CWHxm biogeoclimatic subzone.”
    That sounds like a commitment to retain existing old growth forests. Indeed, the Forest Practices Board noted—four times—in its investigation report, that “In their WLP, they committed to setting aside all of the existing old-growth stands by designating them as wildlife tree retention areas.”
    The words that a would-be woodlot tenure holder uses in their Woodlot Licence Plan have legal consequences. Section 21(1) of the Forest and Ranges Practices Act states: “The holder of a forest stewardship plan or a woodlot licence plan must ensure that the intended results specified in the plan are achieved and the strategies described in the plan are carried out.”
    But here’s the problem: Okisollo Resources said it would retain all existing old forest, but its map of where old forest exists doesn’t match where old forest actually exists. Like at Hummingbird Lake.

    Okisollo Resources logging in old-growth forest at Hummingbird Lake in 2019.
    A map in Okisollo Resources’ approved Woodlot Plan referenced three small areas that a forester had identified as containing old forest in 2007 using the Ministry of Forests’ notoriously inaccurate Vegetation Resource Inventory. It is notorious because it fails miserably at identifying old-growth forest, and that has been an ongoing problem in BC.
    Okisollo’s map shows only three tiny areas of old forest. The total area of that old forest is a mere 15.1 hectares—only 2 percent of the woodlot’s 715 hectares. If that was an accurate assessment, the amount of old forest left would be at an even lower level than the high-risk 9 percent estimated by forest ecologists for this biogeoclimatic zone in 2001.
    If Okisollo’s map was accurate, the need to “maintain existing old forest in the zone, as well as second growth with [a] high portion of veteran trees...” would be even more urgent.
    In any case, there appears to be nothing in the legislation governing woodlots that would allow a map that fails to indicate accurately where old forest is located to overide a strategy that states existing old forest will be retained. Yet the Board’s findings depended entirely on the faulty map.
    I requested a copy of the inventory used to identify areas of old forest in the woodlot, which Okisollo Resources says had been created for the Ministry of Forests in 2007. Okisollo declined to make the inventory available. 
    Ms Blumel stated that the primary forest her company logged at Hummingbird Lake is not old forest but “scattered old trees” in “second-growth stands.”
    “Second-growth stands” implies an area that has been previously logged. In an old, primary forest on Quadra Island, regrowth of younger trees below the old-growth canopy after a fire is a natural process, no matter how dense or commercially attractive that regrowth appears to be. The regrowth’s presence does not cancel out the biological values of the old forest it’s growing in.
    Blumel did not respond to questions about whether or not, during road building and logging at Hummingbird Lake, the company had encountered any sign—like old stumps and roads—of previous logging.
    So, what is the true nature of the forest that was logged at Hummingbird Lake? Was it old forest?
    Helpfully, the Board’s investigation report included the definition it uses. The report stated: “When we refer to old-growth forests in this report, we mean stands in BC’s coastal forests that are older than 250 years, structurally complex with large old living trees, and that have large dead snags, fallen dead trees and multi-layered canopies.”
    The image below shows what the forest on the north side of Hummingbird Lake looked like in 2018 from above the lake, before logging took place. The forest that is about to be cut is on the right side of the photograph. You can see many living Douglas firs with dead tops, a good indication of great age, a fact confirmed on the ground by growth ring counts of trees cut by Okisollo Resources. There are also standing dead snags visible and a multi-layered canopy with younger hemlock and fir far below the tops of the old-growth. You can’t see them, but on the forest floor are numerous fallen dead trees. On each of my visits I found plants and animals associated with old forest, including Northern Red-legged Frog, Wandering Salamander, Osprey, and One-flowered Wintergreen. This is as “structurally complex” a stand of old-growth forest as I have seen on Quadra Island.

     The west end of Hummingbird Lake in 2018.
    There’s much more of this old forest in Woodlot 2031, none of it identified in Okisollo Resources’ official map. Below is a photograph of Hummingbird Lake looking toward the east end of the lake from just above where Okisollo Resource’s 2019 cutblock ends. Most of the forest visible around the lake is primary forest, including old-growth Douglas fir. None of it has been mapped as old forest.

    The view of Hummingbird Lake and surrounding old forest looking east from approximately where Okisollo Resources’ logging reached in 2019.

    It is also revealing to compare the biological productivity of the extensive existing old forest around Hummingbird Lake with the three small areas Okisollo Resources has mapped as “biodiversity reserves.” 
    The photograph below shows one of those three reserves, this one at the top and on the steep slopes of Wolf Mountain. The forest at the top can’t be logged because it is in a protected viewscape. When the Forest Practices Board praised Okisollo for reserving this forest “even though it didn’t have to,” the Board was wrong. Okisollo had to. But as a biodiversity reserve, how does it compare with the old forest removed by the cutblock at Hummingbird Lake?
    The 5.5-hectare reserve on top of Wolf Mountain is shown in the 2007 inventory as having a site index of 11. That means that because of conditions on the top of that hill, trees would be expected to grow to a height of 11 metres over a 50-year period. On Quadra Island, this is a low productivity site. Such forests support a lower level of biodiversity than more productive forests.

    Wolf Mountain. A portion of the top of the hill and the cliff has been reserved from logging by Okisollo Resources.
    On the other hand, the 2007 inventory estimated that the site index at the Hummingbird Lake cutblock is 24. Site index doesn’t get a lot higher than that on Quadra Island. Such sites are capable of growing big, old trees and they support a higher level of biodiversity. Moreover, big old trees beside a lake support an even higher level of biodiversity, much higher than the small old trees at the top of Wolf Mountain.
    The Forest Practices Board investigation failed to even show up on Quadra Island, let alone carefully consider all the evidence and follow it wherever it might lead. But the deeper failure in this case traces back to the Ministry of Forests’ decision in 2005 to introduce Woodlot Licence tenures into a special management zone. That didn’t happen in any other special management zone created by the Vancouver Island Land Use Plan. It was only by the voluntary compliance of woodlot tenure holders that progress could be made toward meeting the plan’s old forest objectives. Now, at least one of those tenure holders—Okisollo Resources—has decided not to comply. If it is successful at going backward, other tenure holders could follow.
    In a recent Forest Practices Board investigation of a complaint about logging in Special Management Zone 13 in the Nahmint Valley, the Board criticized BC Timber Sales for failing to meet the obligations imposed by the Vancouver Island Land Use Plan. In that case, the Board stated: “The public needs to be confident that objectives established in land use plans will actually be carried through and implemented in forestry operations.”
    At least the Board got that right.

    Related information:
    Forest Practices Board investigation report
    Information about Woodlot 2031
    Vancouver Island Land Use Plan documents

    David Broadland
    A high level ministry of forests official implied that logging will be allowed in recently announced old-growth deferral areas.
    JUST BEFORE FORESTS MINISTER KATRINE CONROY announced 2-year deferrals on logging of old growth in 2.6 million hectares of BC forest, a virtual “technical” press briefing was held. The presenters were high-level officials of the ministry of forests. The ministry didn’t want reporters to actually report on what was said at that event, and the regular contingent of pundits and reporters who attended appear to have obediently complied with the “not for attribution” proviso. With respect, I decline to be obedient—or fooled again.
    One of the questions asked by a reporter—and the response from Assistant Deputy Minister David Muter—was so informative that I feel compelled to report what I heard (and recorded). Below is the reporter’s question followed by Muter’s response.
    Reporter: “In the past, old-growth deferral areas still allowed for logging of second growth, cutting new forestry roads, that type of thing. People saw some major activity in and around some major trees. Is that still allowed here? Is it still allowed to have activity in deferral areas, logging in and around the rare and ancient trees?”
    Assistant Deputy Minister David Muter: “I think you are asking about the deferral areas done in September 2020, and those deferral orders prevented the harvest of old growth within the identified areas. That was just under approximately 200,000 hectares of old growth identified and the order prevented the harvest of old growth in those stands. There were some specific exemptions in the minister’s order for cultural harvest to support Indigenous nations and I think there was some specific aspects that allowed the removal of hazardous trees. But these orders prevented the harvest of old growth within identified areas.”
    Muter then paused, long enough for the facilitator to think he had finished. Perhaps realizing that he hadn’t actually answered the reporter’s question, Muter went on: “The recommendations from the panel are to prevent the harvest of old growth in these identified areas of 2.6 million hectares and that’s going to be the focus of our discussions with Indigenous nations based on that recommendation.”
    In the end, Muter didn’t answer the reporter’s question directly, which was: Is logging of “second growth” trees and development of logging roads in the deferral areas going to be allowed? Muter’s response was that “harvest” of old-growth in those areas would be deferred.
    I emailed Muter asking that he clarify whether logging would be allowed in the deferral areas. He didn’t respond by my deadline. Instead, a public affairs officer sent a 136-word email that avoided addressing the question.
    My read of Muter’s response to the reporter’s very specific question is that logging will be allowed in these deferral areas. Within a deferral area, unless a tree is “old growth,” it would appear it can be logged. Muter made it clear that this is the case for the “200,000 hectares” where logging of old growth was deferred last year.
    Following Conroy’s public announcement about the deferral areas, I contacted forest scientist Rachel Holt, who was one of five people on the old-growth review panel that had recommended the 2-year logging deferrals on 2.6 million hectares. Holt had not been in attendance at the press briefing.
    I read her the reporter’s question and Muter’s response. Did the issue of whether logging would be allowed in the deferral areas even come up in the months-long discussion with the ministry? It had not, she said, but she didn’t believe that it was the intention of the ministry to allow logging of younger trees around the old-growth trees. Yet that had clearly been the intention of the ministry in its 2020 deferral areas, and it didn’t make that clear at the time, either.
    Holt, along with forest scientist Karen Price and forester Dave Dauss, authored the seminal BC’s Old Growth Forests: A Last Stand for Biodiversity. That report, published in mid-2020, warned of the high risk of biodiversity loss BC faces as a result of over exploitation of old-growth forests. I asked Holt if leaving old trees standing but logging everything between them would provide protection for biodiversity. “No,” she said.
    To give you a picture of what loggable deferrals might look like on the ground, consider the image below. I photographed this group of 250- to 400-year-old Douglas firs in TFL 47 on Quadra Island. The largest tree in this small grove measured 22.5 feet in circumference at breast height. Every single small tree between them, save one, had been removed.

    This is how old growth forest is managed for biodiversity on Quadra Island, which is a Special Management Zone under the Vancouver Island Land Use Plan (Photo by David Broadland)
    Old-growth forests are almost always a mix of different tree species of different ages. The younger trees are not plantation regrowth, or “second growth.” They are an essential component of an old-growth forest, which is a dynamic process that can go on for thousands of years. On Quadra Island, like elsewhere, the plants and animals that live in these forests are not found in plantations created by humans following clearcutting: The Northern Goshawk, the Marbelled Murrelet, the Northern Red-legged Frog, the Northern Pygmy Owl, the Wandering Salamander, and so on. They all need a complete old-growth forest to survive, not just the big, old trees.
    In the—let’s call it the old-growth deferral area—on Quadra Island, the ground was littered with logging slash and several unburned piles remained. The land between the trees had been heavily disturbed and machinery had been driven through a small creek; the creek passed through a culvert under a branch of the main road. The road was heavily ballasted with rock which had been obtained by blasting bedrock in the deferral area. Roads like this are unlikely to ever support trees, let alone biodiversity.
    I photographed this area on June 22, just as the “heat dome” was building over the Pacific Northwest. The temperature in the deferral area was almost unbearable, yet intact forest nearby remained cool.

    Managing for old-forest retention and biodiversity in a Special Management Zone means clearcutting around old trees and leaving slash piles, permanent roads and damaged hydrological function (Photo by David Broadland)
    Why were these old trees left by the logging company, TimberWest? This area of Quadra Island was given rare “Special Management Zone” status under the 2004 Vancouver Island Land Use Plan. The main objective of SMZ 19 was to “sustain forest ecosystem structure and forest attributes associated with mature and old forests.” Driving that was recognition of the need to preserve “structural forest attributes and elements with important biodiversity functions.” The trees were left to protect against loss of biodiversity, in particular the species listed above.
    Most of the requirements established for SMZ 19 have been ignored by the company and ministry, and the community has lost track of what was supposed to happen.
    Given Muter’s response to the reporter’s question, this appears to be what the ministry of forests has in mind for the 2.6 million hectares of forest that has been mapped as “deferral areas.”
    I asked forester Herb Hammond what effect logging between old trees would have on those forests. Hammond is a well-known advocate for creating a new, ecologically-based relationship between humans and forests.
    Hammond replied, “Logging in old-growth forests destroys old-growth attributes, like multi-layered canopies, irregular canopy gaps, lichen populations throughout the canopy and on the ground, decayed fallen trees. All of these components of an old-growth forest play vital roles, from interception, storage, and filtration of water to provision of unique habitats for specialized species that only live in old-growth forests, like carnivorous beetles necessary to keep herbivorous beetles in check in the surrounding landscape. Simply put, logging in an old-growth deferral area eliminates old-growth protection in that area and just moves us closer to the travesty of losing the benefits of old-growth forests that are vital to maintaining forest integrity, both in the old forests and in the young forests beyond. Logging and old-growth forests is an oxymoron and the height of human-centred thinking.”
    Rachel Holt says: “I feel really positive with where we’re at.” But she also says, “the proof is in the pudding.”
    It is going to take a large, dedicated community of forest watchers to monitor the making of the pudding. The ministry itself is under immense pressure from the logging industry to permit removal of as much of the remaining old-growth forests in the timber harvesting land base as is physically possible. It’s up to the rest of us to guard the larger public interest—protection of our life support systems.
    David Broadland and others are working on a tool that will soon allow the community of vigilant mindustry watchers to up their game and monitor the making of the pudding more closely.

    David Broadland
    Over the past 20 years, BC forests were so heavily logged that net carbon emissions caused by the industry are now twice as large as Alberta’s oil sands.
    AT THE HEIGHT OF LAST SUMMER'S ECONOMIC MELTDOWN in the BC interior’s forest industry, Marty Gibbons, president of United Steelworkers Local 1-417, based in Kamloops, told the Canadian Press: “Something needs to change immediately or these small communities that don’t have other employers are going to wither and die.” Gibbons concluded that “the largest driving factor is the Province’s complex stumpage system that results in high fees.”
    The average stumpage rate in BC—the price the Province charges forestry companies for harvesting a cubic metre of tree on Crown land—was around $23 for both the interior and the coast in 2019 (1). But the average stumpage paid for timber harvested from Crown land by major raw log exporters like TimberWest and Western Forest Products in the Campbell River Natural Resource District was much lower, ranging between $8 and $11 per cubic metre. Smaller companies paid even less—as little as $5 per cubic metre. Yet raw logs for export were selling at an average price of $128 per cubic metre through 2019 (2).
    Raw logs worth $4.146 billion were exported from BC to other countries for processing over the past five years (3). This huge overcut—unnecessary to meet domestic and international demand for BC’s finished wood products—has averaged 6.5 million cubic metres per year over those five years, equal to 41 percent of the total cut on Crown and private land on the coast (4). So claims that high stumpage rates in BC are the problem that needs to be solved seem out of touch with reality.
    But Gibbons is still right: something “needs to change immediately.” The required change, however, might be more than what he’s thinking. The interior’s forest industry has been destabilized by two climate-change-related phenomena—devastating wildfire and explosive mountain pine beetle infestation—that have been amplified by the immense extent of BC’s clearcut logging. Gibbons wants to knock a few bucks off the forest companies’ costs so they can run more shifts at the mills. What’s really needed, though, is a much deeper kind of change, one that would quickly transform BC’s forest industry. To start, we need to end the export of raw logs and shift that same volume to a new class of forest: protected forest-carbon reserves.
    There’s an urgent need to remove carbon from the atmosphere and reduce emissions at the same time. The only way to remove carbon on a large scale and then store it safely for a long time is to not harvest healthy, mature forests of long-lived species.
    The next 10 years need to be full of bold ideas as we look for and find solutions to the climate crisis. Initiatives like the Carbon Tax in Canada are necessary to disincentivize the use of fossil fuels, but planet Earth isn’t going to give us time to tax our emissions into submission. We need some quick shifts that will cut 10 megatonnes with a few strokes of the Premier’s pen. In BC, protecting the forest instead of destroying it is our only realistic option. If we don’t do this, we’ll run the risk that the rest of the world will start counting the emissions we are releasing from our forests and begin to think of us—and our manufactured wood products industry—as the Brazil of the North.
    Perhaps what’s required most at this critical moment is recognition by the BC government that an international market for sequestered forest-carbon is coming soon, and that forest companies need to start switching from destroying publicly-owned forests to protecting them. Not just old-growth forests, but mature second-growth stands of long-lived species, too.

    Forest loss (yellow) on Vancouver Island and the south coast mainland between 2000 and 2018 Source: Hansen/UMD/Google/USGS/NASA
    Our government leaders don’t seem to be thinking straight yet. Instead, deforestation on the BC coast is accelerating. Over the past six years, the area of coastal Crown land that was clearcut increased 16 percent over the previous six-year period. Our provincial forest’s capacity to serve as a carbon sink has vanished. Its catastrophic collapse is recorded in a 20-year segment of the Province’s annual inventory of provincial greenhouse gas emissions. In 1997, BC forests could sequester the equivalent of 103 megatonnes of CO2 annually. By 2017 that had fallen to 19.6 megatonnes (5). From 2020 on, our forests will be a net source of emissions—even without including those from wildfires. The image above shows—in yellow—the physical area of Vancouver Island, and the adjacent mainland coast, that was clearcut between 2000 and 2018. Vancouver Island has become an ecological war zone. But a different economic role for the forest is emerging, one that doesn’t destroy it.
    That new purpose is highlighted by a gaping hole in Canada’s plan to meet its emissions reduction commitment under the 2015 Paris Agreement. Canada’s 2018 progress report to the UN admits there’s a nearly 100-megatonne gap in the plan to 2030 (and this assumes the rest of the plan will actually work). How will Canada live up to its promise over the next 10 years? The progress report puts it this way: “Potential increases in stored carbon (carbon sequestration) in forests, soils and wetlands will also contribute to reductions which, for a country such as Canada, could also play an important role in achieving the 2030 target.”
    The report offers no other possibility for filling that gap.
    Canada, then, will likely depend on using the carbon sequestration capacity of its forests to meet its Paris Agreement commitments.
    Article 5 of the Paris Agreement encourages all countries to “…promote and cooperate in the conservation and enhancement, as appropriate, of sinks and reservoirs of all greenhouse gases not controlled by the Montreal Protocol, including biomass, forests and oceans as well as other terrestrial, coastal and marine ecosystems.”
    Depending on how Article 6 of the Paris Agreement is eventually detailed (its development was stymied at the Madrid COP), it’s possible that an international market mechanism for forest carbon is coming, and it can’t come soon enough.
    The over-exploitation of BC’s forests has added to an explosion in net carbon emissions, delivered to the atmosphere each year by the forest industry’s endless road building and progressive clearcuts. Below, I’ll show why this now amounts to over 190 megatonnes every year (and possibly much more), a far more powerful carbon bomb than is being dropped by Canada’s oil sands industry (6). It’s long past time for us to understand the inner workings of the bomb and to defuse it.
    There are two separate parts to BC’s bomb, and I will take you through each of these in some detail below.
    First, when a mature or old forest stand is logged, assuming it’s healthy, the living biomass that’s killed and cut up into small pieces begins a premature process of decay, often hundreds of years before that decay would occur naturally.
    Secondly, when that mature or old, healthy stand is clearcut, its potential to sequester carbon in the future is lost and it could then take anywhere from 60 years to several hundred years before a new replacement forest could sequester as much carbon as was being stored in the previous stand.
    Let me take you through the inner workings of each of these parts of BC’s carbon bomb. First, let’s consider the magnitude of the carbon emissions released when wood prematurely decays.

    Biomass left behind after clearcut logging by Okisollo Resources on Crown land on Quadra Island (Photo by David Broadland)
    WHEN AN AREA OF FOREST IS CLEARCUT, three decay processes are initiated that result in emissions of carbon to the atmosphere.
    First, the removal of the trees allows the sun to warm the forest soil to a higher temperature than was possible when it was shaded by trees. That additional warmth speeds up decay processes and the release of greenhouse gases, a process somewhat akin to the melting of permafrost in the Arctic. Soil scientists tell us that forest soil contains even more carbon than all the trees and other biomass that grow in it. Recent studies have reported that as much as 20 percent of the carbon in the layer of soil at the forest floor is released to the atmosphere after an area of forest has been clearcut. This release is a wild card in our emerging understanding of the impact of clearcut logging on carbon emissions. For now it remains unquantified, but it’s definitely not zero.
    The second decay process begins after an area of forest is clearcut and the unused parts of trees left on the forest floor begin to decay. In his 2019 report Forestry and Carbon in BC (document at end of story), BC forest ecologist Jim Pojar estimated that 40 to 60 percent of the biomass of a forest is left in a clearcut. That includes the branches, stumps, roots, pieces of the stems that shattered when felled, the unutilizable tops of the trees, and unmerchantable trees that are killed in the mayhem of clearcut logging.
    For our purpose, we will use the mid-point of Pojar’s 40 to 60 percent estimate: half of the biomass is removed, and half remains on the forest floor. The Ministry of Forests’ log scaling system tells us what volume of wood is removed from the forest as merchantable logs. We then assume that an equal volume of wood is left in the clearcut.
    In 2018, the total volume of wood removed from BC’s forests, as reported in the ministry’s Harvest Billing System, was 54.1 million cubic metres. As per above, we are using the same number for the volume of wood that was left in clearcuts all over the province. So the total volume of wood in play is 108.2 million cubic metres. Both pools of wood—the wood left behind and the wood trucked away—begin to decay after a relatively short period of time following harvest. Each cubic metre of wood will eventually produce about 0.82 tonnes of CO2-equivalent emissions (7). So the wood left behind will produce 44 megatonnes and the wood trucked away will also produce 44 megatonnes of CO2-equivalent emissions—eventually.
    The average 6.5-million-cubic-metre cut for raw log exports accounts for 11 megatonnes of that 88-megatonne carbon bomb.
    You might have heard that the carbon in the logs that are harvested and turned into finished wood products will be safely stored in those products indefinitely. But the Ministry of Forests’ own research shows that after 28 years, half of the carbon in the wood products is no longer being safely stored; at 100 years, less than 25 percent of the carbon is still in safe storage (graph below). The rest will have returned to the atmosphere or is headed in that direction.

    This BC Ministry of Forests graph shows how the carbon stored in wood products declines over time. After 28 years, half of the carbon stored has been lost to the atmosphere. At 100 years, 33 percent remains.
    BC’s Greenhouse Gas Inventory quantifies the magnitude of the currently acknowledged deterioration of wood products. For 2017 it noted that “Emissions from Decomposition of Harvested Wood Products” contributed 42 megatonnes annually to the provincial greenhouse gas inventory, which is close to our estimate of 44 megatonnes for 2018 (8).
    For ethical reasons, we ought to attribute all of those future emissions to the year in which the wood was harvested.
    Note that the period of safe storage of carbon in wood products is much shorter than the expected life of most of the tree species that grow in coastal BC. A Sitka spruce is capable of attaining 700 years of age. Douglas fir commonly reach 600 to 800 years of age, and have been known to survive to 1000 years. Red cedar can reach even greater longevity. The Cheewat Lake Cedar near Clo-oose has been estimated to be as old as 2,500 years.
    The coastal forest’s longevity—compared with BC’s interior forests—arises, in part, because the coast’s wetter climate lowers the incidence of drought and wildfires that could kill the forest. As well, there are no mountain pine beetles in coastal BC.
    By eliminating the export of raw logs and instead protecting an equivalent volume of long-lived coastal stands each year, 11 megatonnes of CO2-equivalent emissions could be avoided. That would be a much more substantial reduction in provincial emissions than, for example, the BC Carbon Tax has produced after 10 years.

    The author measures the circumference (27 feet) of an apparently healthy 700-800-year-old Douglas fir on Quadra Island. Douglas fir are known to live for as long as 1000 years.
    THE SECOND PART OF THE BOMB—the loss of sequestration capacity—is a measure of the net growth, per year, of the carbon stored by our forests. Provincial data shows that sequestration capacity held steady at about 103 megatonnes of CO2-equivalent emissions per year between 1990 and 1999, and then began to decline through to 2017, the last year for which data is available. But the rate of decline suggests that our forests are now a net source of emissions, even without including the emissions released as a result of natural disturbances such as wildfires.
    The impact on climate stability of BC’s forests losing the ability to absorb 103 megatonnes of CO2-equivalent emissions per year is no different than the impact of releasing 103 megatonnes of CO2-equivalent emissions every year. Let me give you just a glimpse of how unbridled logging has reduced sequestration capacity. Consider the impact of logging roads.
    Logging in BC has required the construction of a vast and very expensive network of industrial-duty roads that have gouged out an equally vast area of previously productive forest and covered it over with blasted rock and gravel. The public has paid for these roads through reduced stumpage payments. They’re poor, if not impossible places for trees to grow.
    In BC, logging roads and landings are allowed to occupy up to seven percent of the area of a cutblock. As well, to avoid slash burning, the unmarketable wood left in a clearcut is increasingly consolidated in semi-permanent piles that, like the roads and landings, reduce the space available for a new forest to grow.
    A recent report at The Narwhal by Sarah Cox described a study in Ontario that examined the extent of such forest loss in that province. Cox reported that researchers there found “logging scars created by roads and landings…occupied an average of 14.2 percent of the area logged.” So our province’s seven percent restriction could well be an underestimation of the forest base that’s being lost. But let’s use seven percent and calculate how much forest has been lost.
    Sierra BC’s recent report, Clearcut Carbon (document at end of story), put the total area logged in BC between 2005 and 2017 at 3,597,291 hectares, which included private land on Vancouver Island.
    If seven percent of that area was covered with roads and landings, the area of forest lost over that 13-year period would be 251,810 hectares. That’s larger than Vancouver Island’s largest protected area, Strathcona Park.

    In this randomly selected, typical aerial view of Crown forest on Quadra Island, the permanent, ballasted logging roads occupy 8.2 percent of the area of the recent clearcuts.
    Sierra BC chose a 13-year period for its report because it takes at least 13 years after a clearcut has been replanted for the area to shift from being a source of carbon emissions to a carbon sink. The report grimly observed: “For at least 13 years, these areas are ‘sequestration dead zones’: clearcut lands that emit more carbon than they absorb.”
    In the case of roads, though, the forest land they now occupy has become a permanent just-plain-dead zone, and another one the size of Strathcona Park is being created every 13 years.
    While the blame for BC’s forests becoming a net source of carbon emissions has been directed at non-human causes like the mountain pine beetle and wildfires, the forest industry’s production of 251, 810 hectares of just-plain-dead zones and 3.6 million hectares of sequestration dead zones every 13 years is pushing ecological stability to the brink.
    Once upon a time, management of BC’s forests was based on the concept of “sustained yield.” It was a commonly held belief of residents of this province that this meant the annual allowable cut was restricted to no more than the amount of new forest growth each year. Many of us, including myself, have mistakenly believed that approach to managing the public forests was how the Forest Service still operated. This is clearly not the case.
    The Forest Service has turned the resource into an annual carbon bomb that has become one of the largest carbon emitters/carbon-sink killers in Canada. At more than 190 megatonnes a year (88 from premature decay emissions and 103 from loss of the forest-carbon sink), it’s well over twice the size of emissions from Canadian oil sands operations and three times the rest of BC’s emissions. Yet we cut far more than we need for our own use. That’s just plain nuts.
    The most obvious starting point for repairing BC’s broken forest-carbon sink would be to ban the export of raw logs. That would make it possible to put the 6.5 million cubic metres of trees that weren’t harvested into a protected carbon reserve each year until the provincial forest-carbon sink has been rebuilt to at least 1997’s level: 103 megatonnes per year.
    YOU MIGHT THINK THAT THE GREATEST CHALLENGE to eliminating raw log exports and putting that uncut volume into protected carbon reserves would be the huge loss in employment that would result. You’d be wrong.
    There were 17,800 people employed in “forestry and logging with support activities” in all of BC in 2018, according to BC Stats (9). This figure doesn’t include BC’s wood products manufacturing jobs, but eliminating log exports wouldn’t affect those jobs since raw log exports create zero manufacturing jobs in BC.
    2018 was a very good year for employment in the forest industry. The total volume cut in BC forests, including on both public and private land, was 54.1 million cubic metres. Of that, 30 percent was cut on the coast and 70 percent in the interior. Based on that split, about 30 percent of the employment in “forestry and logging with support activities” was on the coast, or about 5340 jobs. In 2018, raw log exports were at a five-year low of 5.03 million cubic metres, equivalent to 31 percent of the coastal cut. So eliminating log exports that year would have eliminated about 31 percent of those 5340 coastal logging jobs, or 1650 jobs. It would have also eliminated, or at least greatly delayed, 8.3 megatonnes of emissions.
    To put those 1650 jobs in perspective, they represented less than one-tenth of one percent of BC’s total workforce in 2018. They are amongst the most carbon-emission-intensive jobs on Earth. In the approaching low-carbon economy, employment will need to shift from carbon-emission-intensive to carbon-absorption-intensive. Any job that is part of a low-cost process for removing carbon from the atmosphere is going to be in demand. Allowing trees to grow is currently the lowest-cost process for absorbing carbon from the atmosphere. This is unlikely to change.
    When BC starts to put thousands of hectares of forest land into carbon sequestration reserves each year, optimizing the amount of carbon stored will require scientists, surveyors, mappers, planners, foresters, tree planters, thinners, pruners, salvagers and fire suppressors. It’s likely to include some selection logging. If anything, optimizing the forests’ capacity for sequestration is likely to require more workers than are provided by road building and the mechanized form of clearcutting widely practiced on the coast. Where would the money for all this employment come from?
    The Carbon Tax is slated to rise to $50 per tonne in 2021. If the 5-year-average export cut was ended and the trees left standing, a net reduction in emissions of 11 megatonnes would have an annual value of $550 million. That’s a lot more than necessary to keep 1650-2000 jobs in a transformative BC Forest-Carbon Service. Do the arithmetic yourself.
    David Broadland is exploring the potential for conserving selected BC forests for carbon sequestration, biodiversity conservation and short-distance tourism potential. He welcomes your feedback.
    Forestry and Carbon In BC by Dr. Jim Pojar: Forestry and Carbon in BC Dr. Jim Pojar.pdf3.51 MB · 49 downloads 
    Clearcut Carbon by Sierra BC: 2019-Clearcut-Carbon-report.pdf2.14 MB · 35 downloads 
    Edited January 7 by admin

    David Broadland
    If history repeats itself, local plans to reduce GHG emissions will come up far short of targets. Shouldn’t there be a Plan B?
    IS THE APPROACH TAKEN BY Victoria and Saanich to reduce GHG emissions within their jurisdictions flawed in some fundamental way that guarantees little or no reduction?
    This is a vital question to consider. Almost all local governments in the CRD have recently declared a “Climate Emergency,” yet the best local example of a well-considered climate action plan—put in place ten years ago by Saanich—has produced only a small reduction in emissions. If the action plans local governments are creating are just more of the same approach Saanich has already tried—and they are—why would the result be any different?
    In 2008, during a previous peak in public interest and concern about global climate change, the BC government introduced North America’s first broad-based carbon tax. At the same time, the municipality of Saanich began drafting a plan to reduce territorial sector-based GHG emissions. By 2010, Saanich had launched its forward-thinking “Climate Action Plan.” One of the plan’s primary goals was an “at least 33 percent” reduction in territorial emissions from 2007 levels by 2020. Ten years later, how did that go?
    Back in 2010, Saanich’s Climate Action Plan put the municipality’s 2007 sector-based territorial GHG emissions at 521,000 tonnes per year. What are they now? In 2019, after declaring a Climate Emergency, the municipality quickly developed the outline (see document 1 at end of this story) of a new climate action plan that plotted a pathway to reduce sector-based territorial emissions by 50 percent by 2030 and reach carbon neutrality by 2050. Saanich’s new starting point, according to that outline, would be 512,900 tonnes. So nearly 10 years after launching its 2010 action plan, Saanich’s sector-based territorial emissions are only 8,100 tonnes below 2007 levels. That works out to a 1.6 percent reduction, well within the uncertainty associated with the accuracy of the 2007 estimate of emissions. Why does Saanich now expect a different result on its second try using the same approach? Victoria is using the same methodology in its Climate Leadership Plan (see document 2).

    “Pathways to 2050 GHG Reduction Targets” from the City of Victoria's Climate Leadership Plan. Plotting points on a graph has been tried before.
    According to the climate action plans for both communities, all that residents need to do is summed up in three initiatives: First, property owners need to get rid of their oil and natural gas heating and hot water systems and buy electric heat pumps. Second, car drivers need to switch to a bicycle, an electric bus, or an electric car. Third, Victoria and Saanich foresee the availability of “renewable natural gas,” although it’s uncertain where that will come from and how much such facilities would cost, both in dollars and embodied emissions. But residents should get ready to pay for it.
    All of these provisions require new consumption: of electric cars and bicycles, new heating systems, new infrastructure to create biogas, and probably new offices to house a growing contingent of Climate Emergency managers. We just need to buy our way to lower emissions.
    While the experience of Saanich’s 10-year-long unsuccessful attempt at lowering emissions should provide local governments with ample warning that it’s far easier to plot reductions on paper than to achieve them in the real world, there are other reasons to doubt substantial reductions will ever materialize.
    One example: neither community has any intention of constraining population growth or the gentrification of existing neighbourhoods. Thus, we will continue to see, as long as the Canadian economy is growing, new buildings and infrastructure created to service a growing population, and neighbourhoods becoming increasingly affluent and filled with bigger, more luxurious homes. Such growth comes with immense embodied emissions, and some of what’s being created right now is surprisingly energy-inefficient.
    In the City of Victoria, much of the growth is in the form of concrete and glass condominium highrises in the Downtown core. While emissions reduction planners might think that such modern buildings will be energy efficient, BC Hydro doesn’t. In High-Powered Highrise, a report released earlier this year, Hydro noted: “Despite the suites in newer high-rise buildings often being marketed as energy-efficient and including things like LED lighting and Energy Star® appliances, the combined electricity usage of the overall building is approximately two times more than high-rises built in the 1980s, and almost four times more than low-rise buildings built that same decade.”
    Why? According to BC Hydro, “This increase can largely be attributed to these newer, high-rise condo buildings (those with five stories or more) being equipped with high consuming luxury amenities, including pools, hot tubs, party rooms and fitness centres.”
    The strong desire for a luxurious home is also evident in many new low-rise multi-unit buildings in Victoria and Saanich. The market for luxury, it turns out, is a far more powerful determinant of what gets built than concerns about energy efficiency or carbon emissions, even in the midst of a Climate Emergency.
    The relentless demolition of perfectly useable smaller, older homes, which are then replaced with high-end single-family homes two or three times the size, doesn’t support the Climate Emergency managers’ expectation, which underpins their emission-reduction targets, that consumers of housing are seriously concerned about either energy or material conservation.
    The absence of any measures in their climate action plans to constrain population increase and physical growth in Victoria and Saanich isn’t the only reason to doubt real reductions in carbon emissions will be achieved.
    The most serious problem with both action plans is that they only address a small fraction of the emissions that Victoria and Saanich create, or cause to be released somewhere else.
    Civic governments count their emissions using what is known as “sector-based territorial emissions accounting.” In developing their climate action plans, both Saanich and Victoria have identified emissions created by the burning of fossil fuels, or the release of methane, within their boundaries using four sector-based GHG inventories: transportation (automobiles and buses), stationary energy (which includes, for example, all energy related to buildings), industrial products and processes (for example the City’s asphalt plant) and waste (solid waste, sewage, composting). Both Saanich and Victoria are acting in accordance with what is known as the Global Protocol for Community-Scale Greenhouse Gas Emission Inventories (GPC) and their methodology aligns with the guidelines of the Intergovernmental Panel on Climate Change (IPCC). Using this protocol, Victoria identified 387,694 tonnes of territorial carbon emissions; as mentioned above, Saanich estimated 512,900 tonnes. The two communities’ analyses of territorial emissions yield similar per capita levels: 4.52 tonnes per person in Victoria and 4.8 tonnes per person in Saanich.
    Both these numbers, though, are far lower than the known per capita emissions of Canadians, which were 19.6 tonnes per person in 2017.
    Saanich and Victoria, then, have set their sights on addressing less than 25 percent of our known per capita emissions. Where do the other 75 percent of Canada’s per capita emissions come from?
    About 26 percent of emissions come from the oil and gas industries, releases that occur before their end-products reach consumers. Another 10 percent comes from heavy industry (fertilizers, iron and steel, cement, aluminum, and pulp and paper). The vast majority of the remaining 64 percent of emissions are created by the production and use of housing, transportation, and goods and services consumed by Canadians in their daily lives. Because 85 percent of Canadians live in cities, most of this consumption occurs in urban centres like Victoria. So cities, and how their governments approach emissions reduction, will have a large impact on whether Canada’s response to the Climate Emergency is effective or not.
    It’s only been in the last couple of years that comprehensive attempts have been made to quantify all the carbon emissions that human activity in cities creates directly or causes to be released elsewhere. Research done by the international organization C40 Cities provides some valuable insight. C40 Cities describes itself as “a network of the world’s megacities committed to addressing climate change.” Its board includes such climate luminaries as former New York City Mayor Michael Bloomberg and current Paris Mayor Anne Hidalgo. Vancouver is participating in the initiative.
    C40 Cities has developed an alternative emissions accounting approach that focuses on the consumption of goods and services by residents of a city. In this approach, GHG emissions are reported by consumption category rather than GHG emission source category.
    The 12 categories of consumption C40 Cities uses (and the percentage each category adds to emissions in a North American city) are: capital (15.3 percent); utilities and housing (26 percent); food, beverage and tobacco (7 percent); public transport (10.2 percent); private transport (7.3 percent); government (9.5 percent); clothing, furnishing and household equipment (8.8 percent); restaurants, hotels, recreation and culture (7.2 percent); communications (2.7 percent); education and health (3 percent); miscellaneous goods and services (1 percent); and “other” (2 percent).
    A C40 Cities study (see document 3), released in March 2018, noted that “consumption-based GHG emissions of C40 cities are significant, and significantly larger than sector-based GHG emissions established using the GPC.”
    How much larger? The C40 study found that “16 cities, mostly in Europe and North America, have consumption-based GHG emissions at least three times the size of their sector-based GHG emissions.”
    Although Victoria and Saanich weren’t part of this study, it’s not unreasonable to surmise that consumption-based emissions here are also “at least three times the size” of the sector-based emissions used by Victoria and Saanich in their climate action plans. It should be noted that Saanich commissioned a study of its 2015 consumption-based emissions. That report was released in 2018. It concluded that consumption-based emissions were two times higher than emissions based on sector-based accounting. The study did not include several of the categories C40 Cities uses, including “government services.”
    Let me give you just a few examples of emissions not counted by Victoria or Saanich in their sector-based territorial accounting that would be counted in consumption-based accounting.
    Emissions associated with the cement used in concrete for constructing buildings, foundations, sidewalks, retaining walls, overpasses, etc, are not counted because the cement is manufactured elsewhere. So, too, is the steel rebar used to reinforce this concrete. Saanich has an aggregate mine that provides the sand and gravel used in concrete, but Victoria doesn’t. Thus no emissions related to producing and transporting the ingredients of the concrete in Victoria’s downtown highrise boom are included in its territorial accounting of emissions.
    Another example is “government services.” While both Victoria and Saanich do count GHG emissions caused directly by the burning of fuels resulting from their own operations, they don’t include the carbon emissions embodied in the more than $500 million in funding the two governments collect each year from residential, institutional and business taxpayers.
    There are no lumber or plywood mills in Victoria or Saanich, so none of the emissions or loss of forest carbon sinks associated with the forest industry and its products are included in municipal accounts of emissions, even though these products are essential for the physical growth and maintenance of our homes, hospitals, schools, and places of business.
    Nor do Saanich or Victoria count the emissions created when their residents fly, for business or pleasure, to Vancouver, Paris—or wherever.
    Although a small amount of the food we consume is grown here, most is grown elsewhere and transported to the island. Virtually none of the emissions embodied in our food is counted by Victoria or Saanich. Missing from their tallies, too, are the emissions embodied in the cellphones, computers, flat-screen TVs and other electronic devices manufactured elsewhere but consumed widely by Victoria businesses, institutions and households.
    I won’t go on. You get the idea. In Saanich and Victoria, Climate Emergency managers are counting only a small fraction of the GHG emissions that households, businesses, institutions and governments here are actually causing, directly or indirectly, to be released into the atmosphere. Using C40 Cities’ “at least three times” multiplier, a more realistic estimate of the City of Victoria’s emissions would be 1.2 megatonnes per year. Let’s put Saanich down for 1.5 megatonnes.
    Obviously, local climate action plans will have no success at reducing emissions that they’re not even acknowledging or targetting.

    Focus editor Leslie Campbell admires a carbon sequestration facility on Quadra Island (Photo by David Broadland
    IS THERE A DIFFERENT COURSE OF ACTION that municipal governments could take to mitigate their emissions? Yes, there is. In a written response (document 1) to Saanich council’s declaration of a Climate Emergency, Manager of Sustainability Ting Pan noted there were two ways to achieve carbon neutrality. The first was to eliminate carbon emissions completely. The second was to “balance carbon emissions with carbon removal.”
    By “carbon removal,” Pan meant the sequestration of carbon by trees. The simplest form of this approach to mitigate emissions, known as “offsets,” is available to a person making a trip by airplane. Payment of an additional small fee—which, the offsetting company promises, will go towards planting a seedling somewhere on the planet—helps to expunge feelings of guilt and shame that some people experience when boarding an airplane. But this form of offsetting has been widely criticized, and rightly so. Forest scientists tell us (document 4), for example, that it takes about 17 years after a coastal BC clearcut has been replanted (which is often delayed several years after harvesting) to switch from being a source of carbon emissions to being a carbon sink. So offsetters that promise to plant a tree to mitigate emissions from, say, your flight to Stuttgart or Calgary, have no immediate effect on reducing atmospheric carbon. Moreover, if trees planted for offsets are cut down in 30 or 40 years, and that low-quality juvenile wood is then used for some short-lived product like shipping pallets or pulp for paper or biofuel, most of the carbon that tree stored is quickly released to the atmosphere. But there’s another possibility for using carbon removal, and this would be similar to that developed for the Great Bear Rainforest, which protects mainly old-growth forest.
    If second-growth trees on the south coast of British Columbia that are slated to be logged (and all Crown land currently under forestry tenures is slated to be logged, eventually) were left to grow, they would sequester more and more carbon each year for a few hundred years. If they were left until they get very old—a Douglas-fir tree, for example, can reach 1000 years of age or more—they would sequester large amounts of carbon over long periods of time.
    Saanich’s Ting Pan put the current cost of offsets at $25 per tonne. At that rate, to offset Saanich’s estimated 1.5 megatonnes of consumption-based emissions for a year would cost about $38 million, and Victoria’s 1.2 megatonnes would cost $30 million a year.
    Ting Pan noted that, while “carbon removal” was “theoretically possible,” there is “no known precedence of any Canadian municipalities taking this approach to become a carbon neutral community.” She added that such offsets “will have to be generated outside of Saanich’s municipal boundary…and would likely contribute to global emissions reduction. However, purchasing offsets have limited direct benefits to local residents, businesses or the local environments.”
    That last statement is ironic, and I’ll explain the irony later. But the only alternative to a “carbon removal” approach is to repeat the actions Saanich took starting in 2010—an approach that hasn’t proven effective and addresses only a third or less of the actual emissions it should. It seems doomed to fail. In a Climate Emergency, shouldn’t our governments be trying out different options to see what works best?
    THE RISK THAT CIVIC CLIMATE ACTION PLANS WILL FAIL to deliver significant reductions in community-based emissions demands a Plan B for insurance.
    Certain species of trees, like Douglas fir, Western red cedar and Sitka spruce, can store atmospheric carbon for several hundred, even thousands of years. Forest scientists tell us that coastal old-growth forests store from 750 to 1130 tonnes of carbon per hectare, all absorbed from the atmosphere over the centuries. Our coastal rainforests can contain twice as much carbon per hectare as tropical rainforests like those in the Amazon jungle.
    While old-growth forests around the Salish Sea are becoming increasingly rare, second-growth forests that have a high percentage of Douglas fir, with trees up to 80 years old, are, by comparison, widespread. Select areas of the coast that measure high for biodiversity, tourism and recreation potential, and have the capacity for growing large Douglas fir, cedar or Sitka spruce, could be set aside and managed for optimal carbon sequestration. This wouldn’t mean an end to forestry jobs in these selected areas, but clear-cut logging would end. This approach is already being employed with old growth in the Great Bear Rainforest by the First-Nations-operated Great Bear Carbon Credit Corporation.

    Second-growth forests on Crown land like those on Sonora Island (left) and Maurelle Island (right) are slated for clear-cutting. Municipal governments could conserve these areas’ biodiversity, tourism potential, and carbon sequestration capacity by paying fees to offset their own communities’ GHG emissions. (Photograph by David Broadland) 
    The Crown-owned second-growth forests around the Salish Sea could absorb many millions of tonnes of carbon from the atmosphere and store that carbon for several hundred years. But they are being clear-cut at an unsustainably high rate, and their potential for storing carbon is rapidly being lost. Tragically, these second-growth forests are being harvested at an age when they are just beginning to absorb carbon at the highest rate per year, a pace that would continue for another 100 to 200 years if left to grow. Through a combination of government shortsightedness and mechanized-forestry corporate greed, BC is losing one of the most effective tools available on the planet for removing carbon from the atmosphere. Some of the loss is justifiable to the extent that lumber is necessary for building housing in BC. A substantial portion of that loss, however, is being exported as raw logs, which provides minimal economic benefit for coastal residents.
    Ironically, most of the rapid liquidation of both old-growth and second-growth forests on Vancouver Island and the northern Gulf Islands is being carried out by TimberWest and Island Timberlands, both of which are owned, to a large extent, by public service pension funds that provide many former government (federal, provincial and municipal) employees with good pensions. Many of these former civil servants have retired to the Victoria area. The community benefits greatly by their presence here, but some of that economic benefit has come at the cost of widespread environmental damage caused by logging of both old-growth and second-growth forests. The south coast is not just losing the potential for carbon sequestration; logging-road construction and clearcutting are blasting, filling and shredding wildlife habitat, diminishing biodiversity and the land’s ability to store water.
    Can municipal governments step forward and preserve carbon sinks as an insurance policy against the potential failure of their climate action plans to perform as needed?
    Saanich’s Ting Pan, as noted above, wrote that, “purchasing offsets have limited direct benefits to local residents, businesses or the local environments.” The irony in that assessment is that local residents and businesses have already benefitted—through money that has flowed into this community from those public service pension plans and increased government revenues—from the destruction of forest-based carbon sinks that is occurring all around the Salish Sea.
    HOW MIGHT THE COST of protecting the remaining old growth and selected areas of second growth be charged against consumption-based emissions in communities like Victoria and Saanich? Households would pay a fee, based on household income, to municipal governments. Municipalities would transfer that money to the Province. The Province would then allocate funds to those affected resource communities selected for carbon sequestration projects to transition them away from timber extraction on Crown land and towards carbon sequestration, biodiversity conservation, and development of tourism/recreation/research infrastructure.
    Why should Saanich and Victoria collect carbon sequestration fees based on household income? A new scientific study (see document 5) on consumption-based household GHG emissions provides evidence for what most people already know: The greater the household income, the higher its consumption-based emissions. This peer-reviewed research quantifies the substantial difference in emissions between low-income and high-income households in the US. Canadians and Americans have very similar per capita GHG emissions, so the data from this new study is useful in Canada. The numbers suggest that Canadian households with incomes of $150,000 have consumption-based annual emissions of about 56 tonnes; a household income of $100,000 produces 50 tonnes; $60,000 in household income produces 33 tonnes; and $30,000 in income produces 22 tonnes. At Tang’s estimate of $25 per tonne to offset emissions, a household with $60,000 in income would pay an annual emissions offset fee of $825. A household with $150,000 in income would pay $1400.
    If Victoria’s or Saanich’s Climate Emergency managers could prove that their action plans had reduced community emissions by, say, five percent, then their residents’ fees could be reduced by five percent, or whatever reduction had been achieved. If emissions go up, the fees go up, and more forest land is converted to carbon reserve.
    As Saanich’s Ting Pan noted, “there is no known precedence of any Canadian municipalities taking this approach to become a carbon neutral community.” There’s also no known example in Canada of a municipal climate action plan producing significant emission reductions. Such plans are often branded to include the word “leadership.” Victoria has called its plan the “Climate Leadership Plan.” But can following a path that’s known to badly underestimate actual emissions, and which uses an approach that has already proven itself to be ineffective, be regarded as “leadership”?
    David Broadland is the publisher of Focus. He is working with a group of scientists, journalists and citizens to explore the potential for conserving selected BC forests for carbon sequestration, biodiversity conservation and short-distance tourism potential.

    Briony Penn
    Management of public forests by the forest industry isn’t in the public interest.

    BC’s forests have become a vast patchwork of roads, clearcuts and mainly young trees. Of the latter, critics say, there has been no reliable inventory. As well, the Province has relied less on its own scientists and more on forest industry professionals to conduct management of public forests, blurring the distinction between public and private interest.
    FORMER GOVERNMENT FOREST SCIENTIST Andy MacKinnon’s battle cry, as he knocks on doors as a Green Party candidate in the upcomming provincial election, is: “Wake up British Columbians!” He’s one of an increasing number of scientists who are getting into politics to raise the alarm about what happens when proper government oversight is put at risk through budget cuts and political interference.
    MacKinnon believes the threat to BC’s greatest public asset—tens of millions of hectares of forests—should be one of the election’s foremost issues. “We have rapidly disposed of it for too few jobs and too little money,” MacKinnon says, “and this is all happening within our provincial model of ‘professional reliance,’ as the BC government sheds scientists of all sorts—professional foresters, biologists, engineers—and hands responsibility to professionals employed by the forest companies. Some have called this ‘the fox guarding the henhouse’ model.”
    This apparent loss of ability to properly manage BC’s forests isn’t just Green Party rhetoric. “We were hearing this from scientist after scientist,” says Katie Gibbs, one of the co-authors of an April 2017 report, Oversight at Risk: The State of Government Science in British Columbia. The report, commissioned by Evidence for Democracy, an Ottawa-based watchdog for promoting the transparent use of evidence in government decision-making, interviewed scientists across BC ministries. The aim was to assess their independence and capacity to produce and communicate reliable data. Highlighted in this review was the scientists’ response to the BC Liberals’ Orwellian term “professional reliance,” which is described in the report as “outsourcing both research oversight and decision-making activities that were formerly done by government.”
    Evidence for Democracy chose the BC situation for its first provincial review, says Gibbs, “because there had been lots of rumours that BC’s public sector was particularly dysfunctional in Canada and badly in need of an independent review.” When she and her co-author started interviewing, she says, “I couldn’t believe what I was hearing from these scientists: That monitoring was outsourced to the professionals who were contracted by the very companies that they were monitoring? Was this for real?”
    It appears to be. The 64-question survey was circulated to 1159 government scientists this past November, with most of the responses coming from the Ministry of Forests, Lands and Natural Resource Operations (FLNRO). The report provides the historical context for the survey, which includes the dramatic reduction of provincial staff-scientists starting in 2001. BC now has the smallest public sector per capita of all Canadian provinces, despite its wealth of natural resources.
    Of those government scientists still working for the Province who were allowed to participate in the survey (and not all were), around half “believe that political interference is compromising their ministry’s ability to develop laws, policies and programs based on scientific evidence.” One FLNRO scientist wrote, “The reduction in staff and financial resources has caused us to not be able to conduct the scientific work that would best support changes in policy. Instead, policy is most often developed as a result of political pressure from select interest groups, in particular forest industry stakeholders.”
    The survey didn’t include scientists who are members of the BC Government Employees Union which, according to Gibbs, denied a request to distribute the survey to their members because “it was not in line with their priorities at the time.”
    IN A BRISTLING REPORT delivered to the Coastal Silviculture Committee this spring, authors Anthony Britneff and Martin Watts, non-partisan forest professionals, dug deep into the structural details of how “professional reliance” without independent third-party oversight has set off a domino effect of poor policy decisions affecting everything from stumpage rates, tree planting and water quality to the health of moose and grizzly populations. Britneff describes the resulting and ongoing grab of timber as “the rape of the land.” A 40-year career forester with the provincial government, Britneff says that during his last ten years in government, “[I experienced] radical budget cuts and changes in policy that I saw as being detrimental to the forests and to the life within them.”

    From left: Katie Gibbs, Anthony Britneff, Diane Nicholls, Andy MacKinnon
    The biggest problem, according to Britneff, is the corrupt data and unreliable models for determining the inventory of the forests—known as the “Timber Supply Review”—that’s used by the Chief Forester to determine how much forest can be cut each year, the “Annual Allowable Cut” (AAC).
    “If this information is wrong, which it is,” Britneff says, “then we put whole communities at risk. Job losses, mill closures, community hardships, very little stumpage [royalties] flowing back to the community, have all resulted because there is no reliable inventory or analysis to determine [appropriate] rates of cut.”
    One of the clearest indicators that there is a problem is the discrepancy between the allocation of timber in the AAC and what is actually cut. As Britneff puts it, “Industry can’t even find the wood allocated to them for the cut because the Timber Supply Review is an economic fiction, supported and informed by unvalidated computer models. Companies are pushing further and further into previously protected areas like the wildlife habitat areas and right up to the edge of provincial parks. They are making no provisions for climate change, and have used beetle kill to escalate the cut. To add insult to injury they are giving it away at 25 cents for a telephone pole.”
    In response to Britneff’s allegations, Chief Forester Diane Nicholls told Focus: “The people of BC can have complete confidence in Allowable Annual Cut (AAC) determinations as they are based on robust complex analysis of many factors that pertain to timber supply and other forest values. The process that supports my AAC determinations is open to public and First Nations for review and comment. All documents generated, including a detailed description of how I arrived at my decision, are available online.”
    Nicholls also noted, “The uncertainties in the analysis and data are managed through sensitivity analyses that allow me to assess the impact of these uncertainties on my decision. We continuously improve and update our data and analysis based on field audits and assessments and new or additional information.”
    But Britneff takes issue with Nicholls’ defence. He notes that “uncertainty” is a technical term used in the international accounting world when measurements “are based on estimates, judgments, and models rather than on exact depictions.” The absence of independent auditors to verify the data means there is no sound basis upon which to trust Nicholls’ numbers. Britneff and Watts also believe that the sensitivity analyses to which Nicholls refers are incorrectly applied.
    Remarkably, there is no legal requirement for Nicholls to conduct an actual inventory of provincial forests. That used to be a statutory responsibility of the chief forester, but changes to the Forest Act in 2002 transferred the inventory function to what was then called the Ministry of Sustainable Resource Management. When that ministry was disbanded, inventory staff returned to the Ministry of Forests and Range but the legal requirement to conduct inventories didn’t. It simply disappeared.
    Both Oversight at Risk and Britneff point to problems beyond the uncertain timber supply, including insufficient capacity and budget within the Ministry to do an inventory. There is also no legal requirement for foresters working outside of government to maintain their data and records.
    There is also evidence that a political agenda at least partially determines the Annual Allowable Cut. This is perhaps best illustrated by an historic directive issued in 2006 by then Minister of Forests Rich Coleman to “maintain and enhance” the timber supply. This directive is still in force and, in effect, means that the AAC would never go down. This approach has left towns like Merritt with no timber and a long wait until the trees grow back.
    As Britneff notes: “It isn’t AAC that’s ‘maintained and enhanced,’ it is forests!” Foresters on the ground are the only ones who can determine whether what grows—or doesn’t grow—lines up with what the models predict. As Britneff argues, “When one has a centralized high priesthood of timber supply analysts, inventory gatekeepers and ivory-tower computer modellers, most of whom are out of touch with what the forestry staff on the ground are observing, then, by convenient omission, timber supply estimates and AAC determinations become economic fiction and AACs are maintained fraudulently high to align with Coleman’s directive—to keep raising the cut.”
    While Gibbs and her co-authors don’t use the word “fraud” to describe what they found, they do note, “The results from our survey show that around half (49 percent) of government scientists surveyed across ministries believe that political interference is compromising their ministry’s ability to develop laws, policies and programs based on scientific evidence.”
    As Gibbs states, “This ‘professional reliance’ system is a huge public interest issue but it hasn’t received the attention it should because it is a difficult thing to communicate precisely. It sounds all fine, and people think that qualified professionals are looking after their interests.”
    But the growing record of scrutiny of professional reliance—by bodies including the Centre for Public Policy Alternatives, the Environmental Law Centre, and the Auditor General in his scathing 2016 report—suggests otherwise. Professionals aren’t able to look after the public’s interests when they have no legal requirement to do so; they are employed by the companies they are expected to monitor; and their professional organizations are not at arm’s length from the forest companies that employ them. Last year, only one disciplinary case was brought to the Association of BC Forest Professionals—and it was thrown out. The year before, five cases were brought forward; three were thrown out and two are still in play.
    The findings of Oversight at Risk suggest that the professional reliance experiment has not only failed but should be scrutinized for fraud. Industry and government remain complicit and unaccountable to the public. Fifty-seven percent of BC government scientists are concerned that government’s reliance on external professionals compromises the ability of their Ministry to use the best evidence or information in decision-making. One forester wrote: “Decisions and objectives are fettered to the industry interests due to government/industry working groups. The industry-sympathetic administration does not always permit us to assess evidence, and even when we have evidence it does not easily accommodate providing direction to industry or changes in policy that may negatively impact (even in a small way) existing mainstream industry and their interests.” Another scientist working in FLNRO reported, “government rarely or perhaps never suppresses scientific findings. They do, however, by way of lack of funding, suppress research and data collection which are necessary for proper science based management.”
    Cases like the Mount Polley disaster, the green-lighting of the Site C project through exemptions of the Wildlife Act, and Elk River selenium risks are cited in the report as the most egregious examples of the failure of professional reliance, so the problem extends well beyond forest management.
    On the issue of being free to communicate their concerns to media, only 3 percent of scientists stated they could do so without approval from their bosses; 32 percent said that they were not able to communicate at all with media; 42 percent had to seek approval; the rest didn’t know. During my own 16 years of writing on the subject, no permissions have ever been granted to speak to a government scientist without public relations approval, even for data as seemingly apolitical as the population of black bears.

    COURT CHALLENGES—at both federal and provincial levels—are tackling the issue of scientific muzzling. A recent court case initiated by Martin Watts against the Province of BC is over “blacklisting” professional foresters for raising concerns with the Ministry of Forests, Lands and Natural Resource Operations over the quality of inventory data, and being excluded from contract opportunities and given only limited access to information. On May 11, a judge in the Supreme Court of BC will decide if the civil claim will proceed. As Britneff states: “Couple this apparent negligence with the fact that the chief forester is operating without a statutory mandate to maintain an inventory of the lands of the province, and one has a pernicious boondoggle of proportions sufficient in seriousness to cut rural jobs, close mills and harm forest-dependent communities, which is exactly what has been happening over the last 15 years.”
    Another insider scientist, who spoke to Focus on condition of anonymity due to fear of being fired or blacklisted, makes even stronger allegations: “Industry and government are inextricably bound, providing the conditions and potential for monkey business at every level. This failure has gone unseen for 16 years by bullying the civil servants who found problems with this model. Untouchable teams moved, fired and ignored people who did not support this model. Some districts simply suspended all staff meetings for years to hide this fact. One need only look as far as the way that volumes used for cutting permits are calculated. The Province uses outdated tables, ‘Loss Factors,’ which date back to the sixties. The more precise ‘Call Grade Net Factor’ volumes are also collected, but not used to assess stumpage volumes because business prefers lower taxes. This speaks to the influence that business has over government policy.”

    WITH LITTLE ABILITY TO GET EVIDENCE, no jurisdictional oversight to even enforce against fraudulent activity, and little confidence that the current government wants to change the status quo, some scientists like Andy MacKinnon are turning to the political sphere.
    Yet, strangely, the management of public lands (94 percent of this province) is not a big election issue. Raw log exports have grabbed more attention, but their revenue impacts are small compared to the scale of the economic problems created by the diminishment of proper government oversight.
    NDP leader John Horgan, who comes from a forestry background on the island, released his party’s forestry platform in April. Aimed more at top-of-mind issues like curbing log exports and job creation, it doesn’t mention reforming the professional reliance system, raising stumpage, or bringing back the scientific research branch—not surprising because it is hard policy to explain.
    MacKinnon admits the communications challenge of this issue. “What I have found works, though, is that if you tell someone that our vast provincial forests and wildlife are being looked after by just a handful of foresters who work for the companies that cut them down, they get that there is a problem.”
    Katie Gibbs, a scientist herself, feels a better job needs to be done in connecting the dots for people. “Public science affects all of us—from clean drinking water to making sure bridges and roads are safe—it’s in all of our best interest to ensure that government science is independent, robust and openly communicated.”
     Briony Penn’s most recent book, The Real Thing: The Natural History of Ian McTaggart Cowan, won the Roderick Haig-Brown Regional Prize and the inaugural Mack Laing Literary Prize.

    Briony Penn
    Tourism operators on the coast have been forced to watchdog forestry operations since government introduced self-monitoring.
    JOHNSTONE STRAIT, around Robson Bight, is one of the most scenic and busy sections of the Inside Passage for Vancouver Island tourism in general, and for whale watching in particular. Across the water from the Bight, in Boat Bay on West Cracroft Island, is Spirit of the West Adventures’ base camp. There owner Breanne Quesnel is juggling her busiest time of year for kayak guiding, looking after her two under-two-year-olds, and fielding my questions on an issue she has been watchdogging for the last five years.
    Quesnel has been monitoring harvesting operations by TimberWest, the company that holds the Tree Farm Licence in the area. It all started in June of 2011 when she found cutblock boundary marker ribbons near her licenced camp. Since then she has been researching, meeting with government and TimberWest, and offering recommendations on how best to conserve local viewscapes. 

    Breanne Quesnel
    Managing viewscapes is a legal requirement of BC’s forest practices that has been around for a long time. WAC Bennett popularized the concept because he knew that visitors to Beautiful BC actually came to see trees—not stumps. Since those days, it has become a more exacting science than just keeping a strip of trees between the highway and the clearcut—and an increasingly contentious issue. Quesnel and others involved in tourism in the area know that clients choose other destinations when they start seeing too many big, ugly clear-cuts. 
    Focus spoke with Quesnel back in 2013 when she went public about concerns not being addressed by TimberWest or the district manager of the North Island Central Coast Forest District—concerns also voiced by the Sea Kayak Guide Alliance of BC, the Wilderness Tourism Association, the North Island Marine Mammal Association and others. 
    Three long years later, triggered by TimberWest’s submission of a cutting permit application, Quesnel filed a complaint with the Forest Practices Board (FPB). She argued the concessions to visual quality were inadequate, the process flawed, and government wasn’t acting in a timely manner. The FPB is an independent board that investigates complaints with forest practices and makes recommendations to the regulator, the Ministry of Forest, Lands and Natural Resource Operations, and companies holding licences to log Crown land.
    Quesnel’s chief frustration lay in the lack of opportunity for the public to review and comment, specifically on cutblock layouts. The mechanism by which a company can legally get away with no input from the public is by requesting an “extension” or renewal of an existing Forest Stewardship Plan (in this case a plan developed more than a decade ago). There is no legal requirement for public input on an extension. 
    A Forest Stewardship Plan is a regional plan that describes how the area will be managed for a variety of values. It is the only legally-binding planning document under the Forest and Range Practices Act (FRPA). Quesnel describes it as “so vague, it allows forestry companies the ability to push through cuts just about anywhere once it is approved or extended.” The public has no recourse except a cumbersome legal appeal process in which they need to prove that stopping the logging plans would not unduly impact the supply of timber on the coast or the economics of the logging company, and that the public benefits outweigh any constraints or impacts on the licencee. As Quesnel asks, “How does a member of the public prove these tests?” 
    The answer is they aren’t supposed to. The onus is on the professionals to weigh up the varying priorities of serving the interests of the company, the government and the public.
    THIS IS CALLED “professional reliance” and it finds its way into much of our legislation these days. The Province recently rescinded it for the real estate industry, but it’s alive and kicking in the Forest Range and Practices Act. In theory, it allows government to cut costs and “get out of the way” of business. 
    In his previous employment with UVic Environmental Law Centre, lawyer Mark Haddock, now a lawyer for the Forest Practices Board, wrote in a 2015 paper: “Just over a decade ago, the British Columbia government embarked on a significant regulatory experiment. It adopted an ambitious goal of cutting or deregulating one-third of the regulations, coupled with an equivalent reduction in the size of the public service. Natural resource management and environmental protection laws and agencies were a prime focus for this initiative as government believed resource companies were significantly over-regulated.”
    To assure the public that standards wouldn’t diminish, the responsibility of managing our forests for aspects such as wildlife, tourism and water—as well as timber—was to be put in the hands of the professionals instead of government. Professional reliance is preferred by business for its flexibility and lack of regulatory controls, but it has been characterized by many as the fox guarding the chicken coop. Government’s role was converted to reviewing the “results.” Results are what you see once the harvesting is done; they provide evidence of whether the professionals did their job—or not. 
    Under this deregulated system, the responses of the FPB to Quesnel’s concerns were predictable: 1) that there was little more that the district manager could do other than encourage her to continue to discuss concerns with TimberWest and, 2) that TimberWest did voluntarily reduce some of the visual impact of the cutblocks to accommodate non-forestry business interests. 
    Is Quesnel assured that the experiment is working? As she points out, “Well you can’t stand the trees back up!” 
    The Ministry’s own study on the effectiveness of managing visual quality objectives (VQOs) found they were only achieved, across the province, an average of 61 percent of the time. The most stringent category of visual quality (which represents 13 percent of scenic areas) was effective less than half the time. 
    After five long years of gathering a large body of evidence in a field she’s worked hard to learn, Quesnel now wonders: “Why do members of the public have to do all of this? And where are all the foresters on this issue? I can’t even dig a pit toilet here without getting an archaeological impact assessment and they are blasting a road behind us?” 
    Mike Larock of the Association of BC Forest Professionals supports the professional reliance system, pointing to 90 percent compliance in terms of government monitoring. He sees the Association’s key priority as educational, working closely with government advisory and appeal boards, watchdogs and members of the public. He notes that every allegation raised by any of these groups is investigated. Around 10 complaints are reviewed annually. He says there have been some suspensions of licences (unconfirmed at time of press). In the online case digests, it is evident that in the majority of cases offending firms didn’t end up with fines. And the number of citations in 2014, listed in the Association’s annual report, was zero. 
    A minimalist approach to penalties also appears to be the policy of the Ministry. With a results-based system, if a district manager is alerted that legislated standards might not have been met, he or she informs the Compliance and Enforcement (C & E) branch who monitor “the results.” 
    West Coast Environmental Law did an analysis of the Ministry’s C & E branch, called Few Inspections—Low Consequences. Since 1999/2000 the number of inspections has dropped from 34,046 to 7,976. Despite so few inspections, inspectors are finding the same number of non-compliance actions. However, the amount of fines collected has plummeted from $561,511 to $72,585. 
    TIM RYAN, CHAIR OF THE FOREST PRACTICES BOARD, has concerns similar to those of Quesnel’s. “I have heard many of these issues myself and have seen the efforts [members of the public] make to gather the information, and I agree, they shouldn’t be in that position.” The FPB has reviewed numerous complaints about impacted viewscapes. In a 2014 complaint brought forward by the Council of Haida Nations, for instance, the FPB found that the results on the ground for visual quality were not in compliance and, more importantly, that the Ministry’s C & E branch itself “did not provide an adequate rationale or a reasoned decision for stopping the investigation, nor was the pace of the investigation satisfactory. Government’s enforcement of Forest Range and Practices Act was not appropriate.”
    To that end, the FPB has made various recommendations over the years to the Ministry to improve the process. Chief amongst them was stopping the practice of approving “extensions” of Forest Stewardship Plans that preclude any public review, and increasing the discretionary powers of district managers so that if they see the runaway train coming they can do something about it. As the FPB wrote in a December 2015 report, “In recent years, the Forest Practices Board has seen situations arise where forestry development was putting local environmental and community values at risk, yet district managers could do little to affect the development and protect the public interest.” The FPB has also prepared reports on contentious issues like visual quality, endangered ecosystems and professional reliance. It cites the Haida Gwaii visual quality complaint report, and the Mount Polley mine disaster report as examples that “point to the need for a review of all parties’ roles and responsibilities in supporting professional reliance, including effectiveness and monitoring.”
    Key to effectiveness is a genuine penalty for the non-compliers. In one of the first cases of its kind for visual quality, the Ministry’s C & E branch successfully brought a non-compliance case against Interfor. It concerns the visual quality objectives of Stuart Island, one of the Discovery Islands, another high- profile tourism area south of Johnstone Strait that Focus reported on in 2013, alerted by another tireless tourism operator, Ralph Keller of Coast Mountain Expeditions. Keller’s experience was similar to Quesnel’s with no real opportunity for input and huge investments of his limited time. After investigation of the complaint by the FPB, the case was heard and it was found that “Interfor had erred on the side of risk instead of on the side of caution” and that the company “had failed to take all reasonable care to avoid a contravention.” A penalty of $20,000 was levied. 
    When Interfor appealed to the Forest Appeals Commission, the FPB provided its evidence and Keller and others were invited as witnesses. Interfor’s appeal was turned down this summer. (Legal costs assuredly exceed the $20,000 penalty.)
    One of the findings in the Interfor case was that a forester involved failed to do a “proper peer review because of his earlier involvement with Interfor in the design of the cutblock” and was found not to be independent.
    INDEPENDENCE LIES AT THE HEART of concern over professional reliance. How can foresters whose work is controlled by so few companies be independent of them? Haddock put it this way in his report: “In some cases the same individual can be the evaluator, planner, approving professional and the supplier of goods and services. In many cases that professional may be an employee or contractor of the proponent, with duties of loyalty that may conflict with optimal environmental outcomes.”
    And then there’s the matter of discipline and penalties. The Association of BC Forest Professionals’ Mike Larock could not comment on any disciplinary action for the foresters named. He said they would be looking at the case and that they take objectivity very seriously under their professional legislation, the Foresters Act. 
    The FPB’s Tim Ryan feels the economics make it challenging to ensure consistent standards and practices across a big landscape where there are lots of complicated technical problems. The Association of BC Forest Professionals operates on a budget of $2.3 million to cover the education, monitoring and disciplining of 5000 members over the entire province. Larock admits, “We are stretched pretty thin.” Ryan’s own agency has not had any increase in funding for 10 years and operates on $3.8 million. Is this enough to provide independent education, monitoring, investigation and enforcement for a profession overseeing an industry generating $15.7 billion dollars in sales? 
    Keller feels the Interfor/Stuart Island case may make a positive difference. Interfor had already had a case brought against them earlier for another infraction in Pryce Channel and so a second strike against them could be more damaging. In 2015, the Forest Practices Board made a recommendation that the cases of non-compliance should be made more public on an easily accessible website to act as a deterrent. Keller couldn’t agree more. “The professional reliance around how well the companies do is hollow since monitoring and enforcement is underfunded, understaffed and underpublicized. Most members of public are so cynical they don’t even bother writing complaints any more,” he said.
    The Association of BC Forest Professionals’ Mike Larock says the decision on Interfor’s performance on Stuart Island was welcome and “will shape the management of visual quality objectives.”

    Interfor logging on Stuart Island
    When Focus asked Interfor about its next steps in light of the case, its Director of Economic Partnerships & Sustainability Karen Brandt responded: “Before the Tribunal’s decision, Interfor and tourism groups had already begun to work together to improve communications and collaboration. Interfor is now a member of the Discovery Island Tourism-Forestry Group, shared its 10-year harvesting plans with tourism operators, hosted open houses and developed new operating procedures and training for staff to guide visual management. The recent Tribunal decision provides further learnings to improve independent peer reviews.” 
    Quesnel does feel things might be improving, citing the forester from Interfor for finally bringing maps to the table for their Tourism-Forestry Group. Still, she cautions, “While all of this is going on, logging is actively taking place. None of the companies have agreed to halt plans until agreements can be reached with the tourism sector.”
    And what of the Ministry of Forest, Lands and Natural Resource Operations? Is it listening to the Forest Practices Board? In a letter addressed to its chair, Deputy Minister Tim Sheldan wrote, “Now that FRPA has been in effect for over a decade it is appropriate to acknowledge and address areas of learning and longstanding concerns. And begin integrating them into our administration and implementation of the Act and framework.” The Forest Practices Board chair Ryan believes the government is beginning to take a more “aggressive” stand on the over 270 Forest Stewardship Plans up for renewal. “We will see some improvements,” he predicts. Sheldan stated that “province-wide expectations are also being set for the submission of new plans that will be subject to full review and comment by the public and stakeholders. Achieving a new standard will take time and collaboration.”
    Quesnel, Keller and many others frustrated with the system will be watching with sharp eyes as to whether genuine change is afoot or simply more delaying tactics. Meanwhile the two tourist operators are confident that the business case for logging is losing out to tourism values in their regions. Quesnel calculates “our one business generated more income in less than four years than [forestry generated] from the entire cut—which can only be done every 60 years or so.” 
    Briony Penn is the author of the new book, The Real Thing: The Natural History of Ian McTaggart Cowan. She recommends Daniel Pierce’s Heartwood videos on forestry issues on the Island.

    Briony Penn
    Owned by government pension plans, TimberWest appears set to ignore a Forest Practices Board finding about its logging on the island.
    IT HAS TAKEN SIX YEARS, but just about everything with the Great Bear Rainforest (GBR) Agreement has been innovative. That includes new models for financing forest conservation; new ways of managing forests where the well-being of ecosystems and First Nations are the twin goals; new ways of resolving conflict where once-battling industry and environmental groups sit down committed to solutions; and finally, new ways to draft regulations through real BC-government-to-First-Nation-governments decision-making. 
    With public reviews now all in, the final ratification of the GBR Land Use Order will unfold in the next couple of months. It will result in the provincial government amending laws to enable a plan painstakingly crafted by multiple stakeholders to “establish a Natural Forest of 3,108,876 hectares and to maintain old forest representation of each ecosystem at 70 percent.” The proposals include eight new areas fully protected from logging, covering about 290,000 hectares (an area larger than Clayoquot Sound).
    In addition, the new laws would increase the forest area set aside from logging outside of protected areas by approximately 600,000 hectares. Half a million hectares is planned as “Managed Forest” with an annual cut of 2.5 million cubic metres until 2025. Central to the plan is the intent “to protect and conserve First Nations forest and cultural values…and provide enhanced access to opportunities for carbon benefits and commercial forestry” under a new type of management called Ecosystem-Based Management. (EBM recognizes the importance of preserving habitats that wildlife need to maintain viable populations.)
    The only problem, not to put too fine a point on it, is western Canada’s largest private forestry company, TimberWest, and its behaviour in the Sonora/Thurlow region at the very southern tip of this huge area. These are the islands where the conservation and timber values are the highest, and the plan and relationships the weakest. As Dallas Smith, representative of the Nanwakolas Council (consisting of seven local First Nations), says of the Sonora/Thurlow region, “It is one of those litmus tests for engaging with the current process. Ninety percent of us have all agreed to play by the ground rules for some years and now TimberWest is finally being held accountable as well.”
    Perhaps ironically, the bad boy on the block is owned by British Columbia Investment Management Corporation and the Public Sector Pension Investment Board which manage government pension funds—raising questions around the government itself being in a conflict of interest. Almost all of the calls for tighter legislative controls during the review process have been prompted by TimberWest’s dismal show in the southern region of the GBR.
    Smith is hopeful the process will bring the company into line, but others, like Jens Wieting of Sierra Club BC, one of the three environmental groups involved in the process under their banner of Rainforest Solutions Project, are more skeptical. They will be watching closely to see if government will close the loopholes to make everyone truly accountable.
    TimberWest has amassed a significant record of finding loopholes over the years. In the Great Bear Rainforest, TimberWest has steadfastly refused to join other industry participants, like Interfor and Western Forest Products, who are playing by the rules. They have been “cutting as if there is no tomorrow” according to Sierra Club and allies who found TimberWest had overcut by a million cubic metres. While not technically illegal, their overcutting contradicts the spirit of the efforts being made by everyone else. It has meant that potential conservation areas were logged before stricter legally-binding agreements could be put into place.
    Ross Campbell, an independent ecotourism operator from Sonora Island, points to government as a big part of the problem: “Sonora is emblematic of the lack of oversight from government.” With legislative proscriptions stripped from BC’s old Forest Act to form the new Forest and Range Practices Act, reliance on self-policing by forestry professionals is all there is protecting the public interest.
    So in 2014 Sonora citizens stepped up. Campbell’s family and the Sonora Island community hired their own forester to prepare an independent report as part of their complaint to the Forest Practices Board (see Focus, Sept 2014). They catalogued recent stumps of old-growth trees and prepared maps of where TimberWest had clearcut old-growth forests. Those forests had contained communities of red and blue listed species—plants and animals that are extirpated, endangered, threatened, or of special concern.
    Their complaint led the Forest Practices Board to conduct an audit of TimberWest’s Tree Farm Licence in the area. It recently finished its investigation and found TimberWest “did not meet the spirit and intent of Ecosystem-Based Management for old forest representation and management of red and blue listed plant communities.” TimberWest’s forester defined old growth forest as one where 50 percent of all the trees were over 250 years old. Labelled a “bizarre” definition by Valerie Langer of Forest Ethics, the Board stated more diplomatically: “This initial interpretation of the definition of old forest and red and blue listed communities as well as lack of caution in its old forest recruitment strategy, did not demonstrate the careful management associated with EBM to meet the goal of maintaining ecological integrity.” They also noted that the government district staff knew this yet didn’t raise any concerns, and that TimberWest was making some effort to change with a decision to hold off on a very small number of cut blocks starting in 2013.
    In its response to Focus’ questions, TimberWest’s Domenico Iannidinardo directed me to the website which states: “TimberWest continues to operate above legal requirements…As the Forest Practices Board acknowledges, assessing spirit and intent is a subjective exercise. Ecosystem-Based Management is a complex undertaking of balancing human well-being and ecological integrity. At TimberWest, we strive to continuously improve.”
    But many feel the company will have to be dragged kicking and screaming to improve and that it will take more than good will to finally bring them into the agreement.
    According to Wieting of the Sierra Club, the industry (excluding TimberWest) and ENGO groups, focused on such improvements as how to protect red and blue listed ecosystems, provide more clarity for riparian protection, and set aside a forest buffer around black bear and grizzly bear dens. Wieting also notes the critical importance of getting the reserve designs in the south done right, where about 90,000 hectares of rainforest will be set aside in new “restoration reserves”—a special challenge in this part of the GBR with little old growth remaining and every old-growth Douglas-fir tree worth 15 times an old-growth hemlock in the north.
    Campbell, working in the heart of this endangered ecosystem, is more critical of the plan and process in the south: “The draft shows government hasn’t really taken any lead on anything, and is passing TimberWest’s proposals straight through, verbatim. No one has ever stopped to see if there is any scientific analysis of their landscape design.”
    When TimberWest was asked if they would continue logging in the contentious cutblocks, it responded that their “harvest planning is being informed by the current iteration” which technically allows that. This is despite the Forest Practices Board’s recommendation that “surrendering declared cutblocks with outstanding conservation values and low levels of investment by the licensee could demonstrate a commitment to the spirit and intent of EBM.”
    Rory Annett, executive director of Coastal Projects, Ministry of Forests, Lands, and Natural Resource Operations, says it’s too early to speculate about government closing the loopholes: “All comments received will be screened and we will make final recommendations about what is next. It is very difficult to say what we will change. What I can tell you is that there has been a long discussion between environmental groups, First Nations and the companies and that is what led to the draft Land Use Order.” When asked what kind of technical experts would be working on the reviews, Annett commented that, “we cobbled together a team of government scientists and members of the consulting community, but it is not the Coast Information Team.” The CIT was an international scientific team that developed guidelines on Ecosystem-Based Management for land use planning processes on the coast. Disbanded well over a decade ago, there are few scientists left in government.
    To complicate matters, TimberWest has contracted Homalco Forestry Limited Partnership, owned by the Homalco First Nation, to log the contentious southern cut blocks. Smith, from the larger First Nation alliance, however, is confident that the agreement forged by 90 percent of the stakeholders will carry the day. “Council are confident in the process. We are very happy that TimberWest will finally be accountable.” To close the loopholes, the Forest Practices Board made a key recommendation “that government clarify the definitions and guidance for old forest and at-risk plant communities.” Now it is in the government’s court to follow their advice and make everyone fully accountable—even the company that invests their pensions.
    Briony Penn PhD has been reporting on the environment since 1975. She recently wrote The Real Thing: The Natural History of Ian McTaggart Cowan. The book is scheduled for release in September.

    Katherine Palmer-Gordon
    The extraordinary potential of Vancouver Island forests to sequester carbon from the atmosphere is being lost due to government inaction.
    VICKY HUSBAND, one of BC’s best-known environmentalists and a member of the Order of Canada and the Order of BC, states the situation in her typical forthright fashion: “Our forests are being completely plundered. It’s a cut-and-run approach that isn’t providing local jobs, isn’t going into value-added products, and certainly isn’t seeing money coming back into the pockets of the people of BC. Forest management in BC, as it is practised today, is none of those things.”
    It also isn’t helping preserve the capacity of BC’s unique coastal forests, world-famous for their huge and ancient spruce, fir and cedar, to absorb greenhouse gases from the atmosphere and sequester that carbon in those giant trees. 
    In the mid-1950s, as Husband points out, old-growth forests (more than 140 years old) once painted Vancouver Island and the south coast of BC a rich dark green. By 2014, as shown on the map below by David Leversee, green has been almost completely replaced by the purple of second-growth trees, some still in their infancy. Even second-growth forests are now at risk, as logging companies turn their eyes towards trees as young as 40 years old in the quest to meet their bottom lines.

    Since 1952 there has been a dramatic decline in the average age of trees on Vancouver Island and the amount of carbon they store. 
    Why does it matter? The Sierra Club calculates that remaining high-quality old-growth forests on Vancouver Island and the South Coast are still currently storing at least 225 million tonnes of carbon, equivalent to more than 13 times BC’s annual greenhouse gas emissions. But that clearly can’t be taken for granted. With a business-as-usual rate of logging, those remaining old trees—along with their remarkable ability to capture and store massive amounts of carbon—could vanish in our lifetimes. With the way things are going in Canada’s efforts to reach greenhouse gas emissions reduction targets, it’s a loss we can ill afford. 
    BY NO LATER THAN the end of March, Canada is required to submit a preliminary long-term greenhouse gas emissions reduction plan to the United Nations in anticipation of the annual UN Climate Change Conference taking place in Paris in December 2015. 
    Given the federal government’s track record to date (Canada perennially wins the Climate Action Network’s Fossil of the Year Award), it’s difficult to imagine the plan will commit to any significant transition away from fossil fuel exploitation. That’s despite the fact that by 2020, Canada’s oil and gas sector is expected to have increased its annual emissions from 2005 levels by 45 megatonnes.
    It’s also despite the fact that 2020 is the year by which Canada is supposed to reduce its annual emissions by 17 percent from 2005 levels of 731 megatonnes of carbon dioxide, equivalent to a target of 611 megatonnes. We already know that we’re not going to get even close. Environment Canada estimates that Canada’s annual emissions will still be as high as 727 megatonnes by 2020. 
    In BC, emissions reduction targets are considerably more ambitious—and equally tenuous. The Province has committed to reduce its emissions to 33 percent below 2007 levels (64.3 megatonnes) by 2020, and 80 percent by 2050. In its 2014 Progress Report on Climate Action, the provincial Ministry of Environment (MoE) reported that it had achieved an interim target of 6 percent by 2012. The next interim target is a significantly higher 18 percent reduction in emissions by next year.
    Yet the provincial government continues to frantically promote massive high-emissions LNG development. It has also done little to stand in the way of oil infrastructure proposals (i.e. pipelines). BC’s carbon tax, though lauded by some, is viewed by many economists as too low to effectively discourage fossil fuel use. Falling oil prices aren’t helping. MoE openly admits: “More action will be needed to move from each target to the next. With current policies remaining as they are, BC greenhouse gas emissions may begin to increase.” 
    Meanwhile, the temperature keeps going up. Climate scientists recently announced that 2014 was the hottest year on record. They said the same thing about 2013. According to the US National Ocean and Atmospheric Administration, 11 of the 12 warmest years on record have occurred since 2000. The Intergovernmental Panel on Climate Change (IPCC) has warned against the drastic consequences of a global average temperature increase of two degrees Celsius. At current rates of emissions, that may well occur before the end of this century, with consequences typically described in biblical terms: extreme storms, lengthy droughts, flooding, famine, and pestilence.
    The IPCC also states: “Forestry can make a very significant contribution…to mitigation. In the long term, a sustainable forest management strategy aimed at maintaining or increasing forest carbon stocks…will generate the largest sustained [contribution].” 
    GIVEN CANADA'S FAILURE TO REDUCE fossil fuel exploitation in the last decade, could forest carbon sequestration offer the solution to achieving our emissions reduction targets? Victoria-based Natural Resources Canada senior research scientist Dr Werner Kurz is unequivocal in his response: “Forests can definitely make a meaningful and significant contribution.” 
    Global forests currently remove up to one-third of the world’s carbon emissions from the atmosphere and sequester or store them in their wood, leaves and roots and in the surrounding soil. 
    They also emit carbon in a variety of ways, including through decay and wildfire. 
    Forests are carbon sinks if they absorb more carbon than they emit, or carbon sources if they emit more than they absorb.
    How forest resources are used also affects whether forests are carbon sinks or sources. When cut timber is stored in long-lived wood products, like construction lumber and high-end value-added products, it continues to store carbon for a long time. Emissions are also reduced if those products are used in construction to replace emissions-intensive products like steel and concrete. 
    Converting wastewood to biofuel may also reduce emissions if the biofuel replaces fossil fuel energy. Conversely, burning wood or using it for shorter-lived products like pulp and paper will result in the tree’s carbon being released to the atmosphere in the short term, thus adding to emissions totals. 
    With 310 million hectares of forests, 55 million of them in BC, Canada has the potential to contribute significantly to global carbon sequestration. Since 2002, however, Canada’s forests—including BC’s—have been a carbon source, not a sink. The reasons include wildfires and unprecedented insect outbreaks (both of which can result from warming temperatures). However, it's the rate at which our trees are being cut down that is the biggest contributor.
    Environment Canada openly acknowledges in Canada’s Emissions Trends 2014: “The human activity that has the most impact on Canada’s forest emissions/removals is harvesting.” In BC’s 2010 State of the Forests report, the provincial Ministry of Forests, Lands and Natural Resource Operations includes a graph that clearly shows that the emissions from continued harvesting in BC far exceed those from fire and slashburning, and outweigh emissions sequestered in growing trees by a factor of two to one. In its 2013 publication Growing Carbon Sinks, Ministry of Forests also admits that increased harvest rates are a problem. 
    Despite both admissions, neither Canada nor BC has moved to limit harvesting towards reducing overall carbon emissions. 
    WERNER KURZ BEGAN WORKING WITH the University of Victoria’s Pacific Institute for Climate Solutions in mid-2014 to research the ways in which BC’s forests can contribute to climate change mitigation. Kurz says that BC’s coastal forests are key in the carbon sequestration equation: “On Vancouver Island and the coast, trees can grow for hundreds of years. They may be taking up carbon at fairly high rates for two or three centuries. The risk of loss due to natural forces is also probably lower than elsewhere in Canada, so [this is where] we likely have the greatest opportunity to grow long-lived forests storing a lot of carbon for a long time.”
    The provincial government appears to agree: “Some of [BC’s] forests,” boasts its Ministry of Forests, “contain the most carbon storage per hectare of any forest type in the world.” Ministry of Forests states that a 100-year-old coastal Sitka spruce will store about 1.84 tonnes of carbon (compared to an interior spruce the same age, at 0.47 tonnes). Coastal red cedar and Douglas fir aren’t far behind their spruce cousins, storing 1.47 and 1.32 tonnes of carbon respectively by the time they hit a century (an interior Douglas fir, by comparison, stores about one-third that amount). 
    An assumption oft-quoted by the forest industry is that the rate at which mature trees sequester carbon slows down and becomes negligible after about 100 years. It’s used as a justification to cut down relatively young trees: If they’ve become “decadent” and they’re not continuing to absorb carbon from the atmosphere, why leave them standing? 
    But in 2008, a scientific study in the US established that forests as old as eight centuries in fact do continue to accumulate carbon, and at a significant rate. In 2014 another group of US scientists built on that finding, concluding not only that old trees continue to accumulate carbon but that the larger a tree gets, the more carbon it accumulates each year. In just one West Coast forest plot that the scientists studied, trees larger than one metre in diameter comprised just 6 percent of the trees, but accounted for 33 percent of the growth. Lead scientist Stephen Sillett concluded: “The idea that older forests are decadent—it’s really just a myth.”
    Kurz believes there’s no time to waste in implenting forestry-related mitigation measures aimed at meaningful long-term reductions in provincial emissions. 
    “Ecosystems are slow-moving,” he explains. “At the rate trees grow in Canada, it could take several decades to see the full benefit of changes to forest management. We have to start making those changes now so they are having an impact by 2050, when we need our forests to be making the biggest contribution to emissions reductions.” 
    Unfortunately, there’s little sign of anything actually happening on the ground. When Kurz was asked about the timeline for implementation of his research results, he responded candidly: “I honestly don’t know.” 
    In the meantime, as usual, the economy continues to drive the federal government’s agenda. Canada’s Action on Climate Change “Reducing Greenhouse Gases” webpage contains no reference to forest management. Moreover, Natural Resources Canada suggests that reducing harvesting would have a negligible impact on emissions. That’s despite their own admission that “[It is clear] that where deforestation is reduced, the immediate outcome is reduced GHG emissions.” NRC also admits that the rate at which net deforestation is occurring is only expected to drop by a fraction from 2005 levels by 2020, “due to the expansion of the oil and gas industry.”
    NRC says that it would simply cost too much to engage in afforestation, or the creation of new forests where none exist now: “One problem identified is that many of the costs of afforestation must be paid for upfront, but the carbon sink benefits develop slowly over time. This means that afforestation is not always economically attractive to the private sector.” Heaven forbid companies profiting from resource extraction should have to pay for mitigation of the impacts of their activities.
    BC at least promotes forest carbon management as “an immediate imperative.” But as usual, talk is one thing, action another. In 2013’s Growing Carbon Sinks, the Ministry of Forests admits “no official strategy exists currently.” The Ministry has committed to developing a climate action plan by March 31 of this year. A request for an update on the status and likely contents of the plan received no response, however.
    In 2010, the provincial government did enact a net-zero-deforestation policy for BC. As Kurz points out, however, while that may mean there have been no further reductions in forest land area in BC, that doesn’t mean a net-zero impact on carbon emissions: “You’re typically cutting down mature trees but replacing them with small ones, so you likely still have a net reduction in carbon stocks.” 
    To the Province, age doesn’t seem to matter, despite the science pointing to the carbon storage efficiency of older trees. The Ministry of Forests states: “[The] minimum harvestable age is an estimate of the earliest age at which a stand has reached a harvestable condition—i.e., has met minimum merchantable criteria.” In other words, if there’s a market for it, you can chop it down. For Douglas fir, admits the Ministry of Forests, that can be as young as 40 years.
    Then there’s the issue of private forest land, comprising 20 percent of Vancouver Island’s forest cover. The provincial government doesn’t regulate harvesting on private land. The Ministry of Forests confirms that: “The determination of minimum harvest age on private-managed forest land is at the discretion of the landowner.” Commons BC geographic information system mapper Dave Leversee estimates that from 2012 to 2014, of the more than 40 million cubic metres of timber logged on Vancouver Island, one-third of it came from private lands. That’s a lot of unregulated wood.
    Here are some more depressing statistics. Unprocessed logs, more than 40 percent of which come from private forest land, comprise more than 30 percent of coastal forest exports. Forty-six percent of the Coast-Douglas Fir Zone—southeastern Vancouver Island and the Gulf Islands—had been lost to non-forest use by 2010. Seventy-five mills have closed permanently in BC since 2000, 17 of them on Vancouver Island and another 33 on the rest of the coast. In the two decades to 2011, forest sector jobs had declined by 52 percent to just over 46,000. 
    In other words, strategies to support the forest economy on the BC coast—let alone promote carbon sequestration or the local wood product industry—seem to be thin on the ground. There is an upside to all this, according to the Ministry of Forests: mill closures and a reduction in industrial activity in recent years “have contributed to a decrease in emissions.” 
    THE SIERRA CLUB ADVOCATES that from a carbon storage perspective, logging of old-growth forests needs to stop today. Their 2013 report Carbon at Risk: BC’s Unprotected Old-growth Rainforest, concluded, “Avoided logging of old-growth rainforest is one of the most immediately effective actions to reduce emissions.” It argued that from a carbon perspective, “converting old-growth rainforest to second growth is like giving away a safe, hefty bank account with a decent interest rate in exchange for a start-up bank account with almost zero money and the promise of spectacular growth based on unreliable forecasts.”
    Vicky Husband believes that given how little old-growth remains, it is now just as necessary to provide similar protection to mature second-growth forests: “It’s absolutely critical,” she declares emphatically, “to preserve all these big trees.”
    Given how important a role BC’s coastal forest could play in terms of carbon emissions reductions, preserving mature trees—on both Crown and private land—would seem logical as a simple matter of precaution. 
    Katherine Palmer Gordon has written six books of non-fiction, including several BC Bestsellers and a Haig-Brown prize-winner. Her most recent book is We Are Born with the Songs Inside Us: Lives and Stories of First Nations People in British Columbia.

    Briony Penn
    Evidence of destruction of old-growth forest on Sonora Island appears set to shake up BC’s South Central Coast forest policy.
    OVER MY YEARS OF REPORTING on TimberWest, there has been virtually nothing that could bring the company’s inexorable liquidation of their forestlands to heel. Being named in a case before the Inter-America Commission for Human Rights, for example, hasn’t slowed the company down; nor has being the focus of a wide-spread media campaign by Greenpeace in 2011. Nor has being challenged by shareholders. Nothing seemed able to slow TimberWest’s relentless pace. 
    That is until two pairs of siblings, all born and raised in the shadow of the last of the old growth on the Discovery Islands, took to the woods of TFL 47 to investigate if TimberWest’s logging had transgressed rules protecting endangered old-growth ecosystems.
    The Sonora Island foursome—Farlyn Campbell, her partner Jody Eriksson, Farlyn’s twin Tavish, and Jody’s brother Cam—have helped convince TimberWest to put a moratorium on the logging of old growth in one of the most threatened regions of the Great Bear Rainforest (parts of the Thurlow, Gray and Fulmore Landscape Units) while the company rethinks its approach. 
    It all started in February of 2013 when TimberWest flagged a cutblock in seven hectares on Sonora Island. This cutblock contained 160 old-growth trees, some with six-foot diameters and heights of 200 feet. The Sonorans obtained the cutblock plans from TimberWest and laid them down over Google Earth, discovering that numerous other planned cutblocks on Sonora’s Crown lands coincided with the last of the old growth on the island. Under existing rules, the company should have avoided any of the last remaining (four percent) old-growth Douglas-fir. 
    When they initially took their complaints to TimberWest, the Sonorans were given a variety of excuses. The most egregious justification for the locals was TimberWest’s claim that these were “second-growth” forests and they had a right to log them. It appears that TimberWest’s definition of old growth was “forest with more than 50 percent of the stand volume over 250 years old.” As Valerie Langer of Forest Ethics stated in her blog “How did they pull that off? By using a bizarre, technically-unheard-of definition they made up.” 
    So the Sonorans commissioned their own professional forester to come up with an opinion on that definition. Registered Professional Forester Doug Hopwood was “unable to find any documented scientific basis” for TimberWest’s definition of old growth. The Sonorans took the definitions to the Forest Practices Board (FPB), asking them to intervene, but the Board can only respond to a complaint once a violation has occurred. 
    The FPB told them, “Go talk to TimberWest and come back to us if they chop them down.” Throughout the rest of 2013, the company and the Sonorans did just that. Sonorans talked and TimberWest cut. TimberWest’s Chief Forester and VP for Sustainability Domenico Iannidinardo assured the Sonorans that TimberWest would be “precautionary” while the Forest Practices Board, the government, and First Nations developed their final ecosystem-based management agreement and definitions. 
    TimberWest’s definition of “precautionary,” however, seemed to be as shaky as their definition of old growth, and trees of great stature continued to fall. So in January of this year the Sonorans decided to collect evidence of violations of the “South Central Coast Order” for a formal complaint to the FPB. They mapped out where the company’s cutblocks were in the Thurlow Landscape Unit on Sonora and where endangered (red and blue listed) ecosystems overlapped. Then they packed some tents, a couple of bicycles and $500 worth of spray paint into their boat and set off to assess the situation on the ground. They had little difficulty finding huge stumps from recent logging; these they identified and marked with bright red paint. 
    Anyone can now see the painted stumps as they fly over Sonora Island at the southern edge of the Great Bear Rainforest. Each tree has been catalogued by the team, with its age and geographic location. Catalogues of seven cutblocks, which the foursome calls “Stump Reports,” document the cutting of close to 500 old-growth trees with an average age of 300 to 400 years old, with some as old as 800 years. 
    The team then made a formal complaint to the Forest Practices Board, which is now exploring whether TimberWest fulfilled the objectives of the South Central Coast Order. This legal order, passed to (temporarily) satisfy the Great Bear Rainforest Agreement in 2009, has obligations to maintain biodiversity, protect 30 percent of the old growth of each forest type and protect red- and blue-listed plant communities. The FPB has stated that it will be investigating whether the company “physically adhered to the spirit and intent of the Agreement,” which required them to use “ecosystem-based management.”
    Ecosystem-based management recognizes the importance of preserving  habitats wildlife need to maintain viable populations. For example, the red-listed (in BC “red listed” means extirpated, endangered, or threatened) marbeled murrelet can nest only in old-growth trees. Their population continues to decline in BC.
    With the Sonora Island old-growth trees having a monetary value of up to $10,000 each, depending on their size and condition, the temptation for TimberWest to overlook its obligation to practise ecosystem-based management was perhaps too great.
    Formerly in BC government foresters told companies where they could log on Crown land, and government foresters monitored the cutblocks. But the Liberal government argued company foresters could monitor themselves through their professional organization by a process known as “professional reliance.” It’s now evident this system is not working. 
    Lately, when professional foresters fail to protect endangered ecosystem or species, the responsibility has fallen on citizens to file complaints, but that requires discovery of the offense and the collection of evidence—a challenging proposition, especially when cutblocks are as remote as that documented on Sonora Island. That’s one weakness of “professional reliance.”
    A second is that such self-policing requires a robust disciplinary process. In 2009, the Association of BC Forest Professionals committed to “improve the transparency of the discipline process” and started to publish case digests. We now know that from 2010 to 2013 there were only seven complaints of failure to protect endangered ecosystems/species or riparian areas. Only one of those was investigated and no citations were issued. Although transparency is improving, there’s still no real deterrent for bad practices. 
    All that remains to keep companies honest is the Forest Practices Board, which has been gutted by the provincial government. The Board now does only one random annual audit of a TFL each year. At that rate, the odds are good a TFL won’t get audited more than twice in a century. 
    So it’s encouraging that, as announced this past month, the Board is conducting an audit of all of TFL 47. That audit, as well as a report on the Campbell-Eriksson complaint, is expected at the end of the year. 
    Meanwhile, with the threat of a judgement looming, everyone appears to be leaping into action. The Province, in conjunction with First Nations and licence holders, is finally redoing the 2009 Orders for the Great Bear Rainforest with the stated intent of “achieving low ecological risk” and a higher percentage of protected old growth. TimberWest has voluntarily made significant changes to their 2014 logging plans and, in fact, is going one step further than is required by the rules, creating restoration planning areas because of the extent of the damage in this region.
    But would any of these moves towards accountability have occurred without the hundreds of hours devoted to documenting TimberWest’s misdeeds by four young Sonora Islanders?
    Briony Penn PhD has been reporting on the environment since her first article in The Islander in 1975 on Garry oak meadows. She lives on Salt Spring Island.

    Briony Penn
    International courts and BC teachers try to make up for government and corporate abuse of human and environmental rights.
    THE EXTRAORDINARILY RICH FORESTS of Vancouver Island have been fought over since James Douglas had 14 Vancouver Island chiefs sign a blank piece of paper. The frustration in losing virtually every battle by four generations of First Nations and concerned citizens has bred some sophisticated new approaches to the old task of protecting Indigenous rights and nature. These reach out internationally and to corporate shareholders. As a result, 2014 is off to a difficult start for Island Timberlands, the corporation most in the news these days for questionable logging practices.
    First, a resolution on an ethical investment issue was passed unanimously on January 31 by the BC Teachers Federation. The resolution urged BC Investment Management Corporation (bcIMC), which invests the teachers’ pensions and is a majority shareholder in Island Timberlands, to send the company back to the planning table over its liquidation of old growth forests on Vancouver Island, specifically around Port Alberni (near Cathedral Grove and McLaughlin Ridge). This resolution built on a 2012 recommendation that “the BCTF seeks legislative or regulatory changes that would clarify the definition of fiduciary duty to include consideration of long-term financial sustainability through environmental, social, and governance responsible investing principles.” Since pensions are fuelling the logging rates, this hits at the heart of the problem. 
    In support of their resolution, members of the BCTF used the argument presented in the 2008 Supreme Court of Canada judgment that the directors must resolve to balance stakeholder interests “in accordance with their fiduciary duty to act in the best interests of the corporation, viewed as a good corporate citizen.” 
    This leaves it wide open for the courts and citizens to define “a good corporate citizen.” 
    Another case brought by Robert Morales, chief negotiator for six southeast Vancouver Island First Nations of the Hul’qumi’num Treaty Group (HTG), might do just that at the international level. The Inter-American Commission for Human Rights (Focus, November 2011) will assess the culpability of Canada and three corporations (including Island Timberlands) who are the “successors in interest” in breaching human rights. Morales explains that after the original application to the international tribunal was filed in 2011, the government of Canada objected on the grounds that the native groups had not exhausted all domestic remedies. 
    Morales states, “We argued that no Canadian court has ever recognized Indigenous people’s rights to private property. The Inter-American Commission agreed with us, and were satisfied that there were no domestic remedies. Canadians don’t realize the gravity of this statement. Here is an international body of human rights experts stating that in Canada a situation exists where a group of people’s human rights cannot be effectively dealt with under the existing legal and political structures here.” The case is now awaiting the final hearing—and we can anticipate that this court’s judgment might point to a lack of good corporate citizenship.
    Island Timberlands’ third worry is a cluster of community groups up and down the island, who, under the slogan “No community stands alone,” have been seeking an improvement in forest practices of the company. On February 4, Jane Morden, spokesperson for Watershed Forest Alliance out of Port Alberni, released in a letter to bcIMC and IT “the evidence for our concern regarding Island Timberlands’ logging practices on private lands in the Alberni Valley area.” 
    In the documents submitted to bcIMC and IT, the Alliance detailed the history of the IT lands in question. In 2004 the provincial government removed 74,000 hectares of Island Timberlands private land from Tree Farm License 44 with a letter of intent that grandfathered the protection of 2400 hectares of critical wildlife habitat (old growth) for wintering ungulates (deer and elk) and the nesting Northern Goshawk—a red-listed species at risk. After long negotiations between 2005 and 2008, and upon acquiring these lands, IT agreed to the boundaries of the 2400 hectares of ungulate winter range (UWR) and wildlife habitat area (WHA) for goshawk as the minimum area required for protection. Shortly after, however, IT began clearcutting these lands. 
    In a document obtained by FOI, government scientists Darryn McConkey and Erica McClaren stated “negotiations ceased because we could not agree on the management regime within these boundaries. Island Timberlands wanted to extract timber resources from within UWRs and WHA 1-002 and Ministry of Forests could not scientifically rationalize how the quality of these areas could be maintained.” Ministry scientists go on to say that IT’s proposed management “did not incorporate any input from the Ministry of Environment” and “is not supported by the best available science.” 
    Island Timberland’s spokesperson Morgan Kennah, in answer to this claim of unscientific forest practices, stated IT stands by its forest certification process, Sustainable Forestry Initiatives (SFI). SFI has received strong criticism for being an industry-financed certification system. ForestEthics, for example, has stated, “The SFI certification program actually assures its timber company customers that it does not prohibit logging in old growth forests, wild areas that do not currently have roads, or other places in which ecological values are especially rich.” 
    When asked about these critiques and industry ties to SFI, IT’s Kennah responded, “Many people would say that it [SFI] is independent. The board is made up of economic and environmental interests. We feel strongly, as [do] others, that it is not controlled by industry.” On the SFI board various non-profits are represented, including Bird Studies Canada whose website states that SFI is a Gold Donor with donations of over $50,000 for projects like their Bird Atlas, which ironically would include the goshawk nesting site that the Alliance seeks to protect. Bird Studies Canada President George Finney, defended his role: “From Bird Studies Canada point of view, we are just giving them bird information and how they can be less detrimental to various bird populations.” He said, “Complaints could be registered and they will be investigated.”
    The Kwakiutl First Nation also added their voice to the chorus of disenchanted Vancouver Islanders with an ongoing peaceful protest when Island Timberlands started to log cultural sites, traplines and cedar trees in their territory. The Douglas Treaty (signed 163 years ago to the day of their February 9 press release) stipulated “that lands and waters were to be set-aside for the exclusive use by Kwakiutl to maintain livelihood ‘as formerly’ and for ‘generations to follow.’” Chief Coreen Child of Kwakiutl First Nation stated: “The people of Kwakiutl have been left with no choice but to protest and stop Canada and BC from allowing Companies to cut and remove cedar trees from our land.” IT’s response to this was: “We have done due diligence by sending in an archaeologist to do an Archaeological Impact Assessment with members of the band attending.” Focus asked to view the report or the terms of reference, but was refused. Chief Child argues that these studies don’t address cultural land-use issues granted in the Douglas Treaty. 
    Morales and the Hul’qumi’num Treaty Group are also pointing to these cultural land-use issues as the nub of the case: “The Inter-American Commission is not judging whether the action of transferring the land to private corporate hands was legal or not, but whether the ability of the people to practice their culture has been significantly affected by this action today.” He argued that the privatization resulted in a situation in which First Nations cannot practice their culture due to the losses that they have sustained. “How can you teach your children how to build a canoe when there are no longer any cedar trees? That is the loss that the Inter-American Commission is considering.” 
    Finally, Cortes Islanders, who have successfully fended off Island Timberland’s clearcutting plans for the old growth on their island to date (Focus, January 2013), celebrated—after 20-plus years of negotiation—realization of a community forest agreement (CFA). The agreement covers Crown lands adjacent to IT’s land and includes equal partnership with the KIahoose First Nation. The partnership is in the process of developing a Community Forest Operating Plan that reflects community values and will guide forest management within the CFA. Cortes Islanders had asked IT to bring their own forestlands under a similar value-added ecosystem management and certification system, Forest Stewardship Council, but IT has consistently rejected that idea, citing increased costs. Today, with shareholders demanding this type of ethical management, IT’s excuse of fiduciary responsibility is sounding less and less convincing. 
    Documenting all these examples of citizens fighting back is Dan Pierce who, with producer Cari Green (of the award-winning documentary The Corporation), is developing a feature documentary (through crowd sourcing) on these initiatives. That gives hope to the idea that community involvement could finally supplant the old corporate model—from how we invest our pensions and how we run our timber companies to how we fund our films. See www.heartwoodfilm.com.
    Briony Penn has been writing about controversial issues surrounding bcIMC and Island Timberlands since 2006.

    Briony Penn
    Government’s reluctance to limit logging in wilderness areas makes no sense when you do the math.
    SOMEWHERE AROUND July of 2005, the tourism sector in British Columbia, for the first time in history, outstripped the forestry sector in GDP—in fact it outstripped all sectors including oil and gas—and hasn’t relinquished that position. 
    During the 10 years between 2001 and 2011, the GDP of forestry only increased 6 percent while tourism increased 23 percent. Vancouver Island and Vancouver Coast and Mountains regions attracted most (79 percent) of that tourism activity for BC, so the hot spot is right here on the coastal islands. In 2011, tourism on Vancouver Island increased 4 percent in just 12 months alone, beating all other industries hands down. 
    These statistics come from a recent government report called The Value of Tourism. One would think that smart government analysts would naturally prioritize budgets and land use decisions around the growth sectors. 
    Yet British Columbia’s government is not doing that, which is surprising given it is led by a party that ran on a platform of jobs, jobs, jobs. So why not? 
    Ralph Keller, owner of Coast Mountain Expeditions in the Discovery Islands for 27 years, asked that question five years ago when timber companies began in earnest to liquidate the wilderness that people were coming to his lodge to see. Many Victorians will be familiar with the Discovery Islands, which lie between Campbell River and Desolation Sound and include Quadra and Cortes along with many other lesser-known islands. Only a few hours drive from Victoria, they attract many of the eight million residents of the Salish Sea, along with international visitors. People go there to kayak, fish, sail, eat fresh seafood, watch grizzlies, beachcomb, wander under the old growth and gaze at the views. One of Keller’s guests, Francois, makes a typical comment: ”Coming from far away France, I couldn’t think of a better introduction to Canada than these islands, some of the last gems of our crowded and drifting planet.” 
    Such tourists don’t travel from France to see clearcuts, hear chainsaws and avoid log booms in their kayaks. As Keller says, “In today’s sophisticated tourism market with tools like Google maps and TripAdvisor, people are checking out for themselves where they can find first-class wilderness and if they don’t see it, they don’t come.”  
    So Keller talked to the other operators around the Discovery Islands and they started to do the math. There are over 120 tourism companies from lodges to marinas, which are completely dependent on tourism in the area. In just this collection of islands, the 120 businesses generate directly $22.3 million in revenue each year and employ 625 people full-time or seasonally full-time. Since the vast majority of these businesses are family operations like the Kellers, half the employment activity isn’t even captured in these statistics. If you add up self-employed business owners and contractors then the stats for jobs double. If you add in Campbell River businesses which rely on the Discovery Islands for their tourist clientele, those figures double again. 
    The Discovery Islands came in as the second most lucrative marine wilderness destination in BC after Tofino/Pacific Rim for provincial tax revenues. So it’s no surprise that Victoria, as the entry port for island tourism depends on the Discovery Island/Tofino destinations for a large portion of its tourism dollars. The argument for good management of wilderness, therefore, lies very close to home.
    Let’s compare tourism revenues with what logging brings in—a sector that government statistics say only represents 11 percent of the overall GDP activity for the region. Tourism operator Breanne Quesnel who has been operating the Spirit of the West Adventures Company for 17 years with her husband and business partner, demonstrates a typical comparison, using her own business base at Cracroft Island, which is directly opposite Robson Bight, the world-famous orca marine reserve. This area brings in millions annually in whale watching and ecotourism revenues. Quesnel has calculated that their one operation employs 656 person days of employment annually. 
    According to TimberWest, which has the lease to log the west slopes all around her operation, a one-off three-month contract for five logging contract workers is pretty much all the logging promises. There is little value-added since half of the wood from southern Vancouver Island gets exported as raw logs offshore. There is little stability because those contractors turn up for a few months then leave and never come back. Says Quesnel, “If it is a numbers game, we win hands down in jobs, revenue and taxes—every year, not just once every 100 years!”
    Once they had built their business case, Keller, Quesnel and the other 120 businesses organized themselves into the Discovery Islands Marine Tourism Group, and met with district forest managers and companies to present their economic arguments about why logging impacts in the view corridors needed to be reduced. 
    After two years of such meetings, they were told that there was nothing the leaseholders or district managers could do and that it was a ministerial matter. So in November of 2011, they sent a letter to Steve Thomson, then (and now) minister responsible for forests and Pat Bell, then minister responsible for tourism. They had three moderate requests: that at least one of them come to the Discovery Islands and meet with them to see and hear their concerns first-hand; that a hold be put on the proposed viewshed logging in the three remaining unimpacted marine corridors until after the meeting; and that government strike a land-use committee of stakeholders to negotiate the demands of the different major economic interests.
    More than a year later, prior to the election, Pat Bell, finally told the Discovery Island operators that it wasn’t his job and to go back to the companies. Meanwhile Steve Thomson approved the BC Timber Sales’ tendering of the road building and logging in one of the three last intact corridors, the Lower Okisollo Channel, which connects Octopus Islands Provincial Park, Surge Narrows Marine Park and the tidal rapids at Cooper Point—pristine wilderness areas visited by tens of thousands of visitors annually. There was no shift in the existing logging intensity in the region. 
    Over on Cracroft, TimberWest wouldn’t budge on clearcutting plans for the slopes around Breanne Quesnel’s operation despite various offers from the couple, including buying the net value of the trees to allow them to stand. 
    Frustrated with the lack of responsiveness to their concerns, the operators went to the media and things started to change. The election saw a shift in the cabinet and the file was passed on to Naomi Yamamoto, the new minister for small business and tourism.
    At the end of this July, an inter-ministerial delegation of public servants went on a day-long boat tour of the region and lodges for a fact-finding mission with tourism reps. Keller reported to Focus on the results of that day from a satellite phone on his boat (it is the height of his season and he’s touring officials as well as his guests). “It seemed productive. They were suitably impressed! The delegation wanted to meet again in a month. But meanwhile, the logging is poised to start as soon as the first rains come in September.” Yamamoto’s office responded with a promise to Focus of an interview with the minister when she returned from holidays at the end of August, stating that the fact-finding mission was consulting various stakeholders in the region and would report back in September. 
    Meanwhile, the Ministry of Forests appointed staff to review the visual quality objectives for all the tourism hot spots and make recommendations to the minister. Visual quality objectives (VQOs) are guidelines brought in to reduce the visual impact of clear cuts in high tourism corridors by locating cutblocks behind ridges in the view line. As Keller says, “This is a good step, but unfortunately there doesn’t seem to be confidence that what they say is going to happen will actually happen on the ground.” As an example, Keller cites skepticism around current ministry claims—and computer models illustrating—that the visual quality impacts of proposed cutblocks on Maurelle Island will be minimal. He points to the cutblocks on neighbouring Stuart Island, just across the channel from Maurelle: “The computer-generated VQO’s for Stuart Island didn’t look as bad as [the reality], so none of us trust the system. This view underscores the mistrust. And these cutblocks are going on everywhere.”
    The lack of trust that companies will follow rules is not just confined to the VQOs. On Sonora Island, TimberWest, for instance, was supposed to follow guidelines on old growth retention under the Great Bear Rainforest Agreement. When Fern Kornelsen and Ross Campbell of Mothership Adventures stumbled over flagging tapes in groves of endangered old growth trees, TimberWest had to “about face” and admit they had neither prepared high level plans identifying the endangered forest types nor even had a scientifically-accepted definition of old growth. Their definition was that “old growth forest becomes a second growth forest when younger trees growing up under the canopy of the ancient trees get bigger.” On both counts they have been sent back to the drawing board to try again. 
    Mothership Adventures paid for the forest consultants to verify that TimberWest wasn’t doing their job and TimberWest is now revising plans. As Kornelsen states, “Why do citizens have to be the watch dogs over companies at their own expense? It is not our job; it is the forestry ministry’s, but it’s useless.”  
    As Keller points out, the trouble is that even though the Discovery Island tourist operators’ demands are reasonable (“we aren’t even asking for parks, just a higher land use plan which recognizes the importance of the tourism sector to the economy”), the forest minister is limited in what he can do, because government gave away so many powers to regulate—including oversight. In 2003, radical changes were made to the Forest and Range Practices Act: Government threw away its responsibility to monitor and regulate. Instead, they rely on professional contractors, which is only as good as the professionals’ ability to distance themselves from the very small number of large corporate employers. Says Keller, “They’ve boxed themselves into a corner. What they need to do, especially in these hot-spot tourism areas, is identify the tourism values and get back control of these Crown lands for the public good.” 
    The real question for Keller and others is: why would a government touting itself as pro-business, pro-jobs, with sound economic management, kill the golden goose? If the minister doesn’t provide a satisfactory answer in September, what is the group going to do? “Go back to the media,” Keller states. “We had National Geographic just up here rating us as one of the top places in North America to visit. Everybody else is seeing the real values here but the government. I thought these guys were businessmen but they’re back in the last century.” 
    Briony Penn has worked part time in the marine ecotourism industry on the coast for over 20 years. Such work provides an important part of her income as other sectors that she works in—environmental education, journalism and art—decline.


    Briony Penn
    Pension-owned companies may be liquidating our forests, but some communities are fighting back.
    JOHN WOOLLEY, a retired public school teacher, recently blockaded a logging road with family and fellow islanders on Cortes Island to protect the 2,700-acre forest from an unlikely adversary—his own pension funds. Woolley is the latest kind of Vancouver Island activist: a pensioner appalled at the way his pension is being invested in the liquidation of private forest lands on Vancouver Island by companies in the portfolio of BC Investment Management Corporation (bcIMC). Says Woolley, “We are killing our own local economy and we are doing it to ourselves.” 
    Woolley is outraged that the company managing his pension—and those of half a million other British Columbians—has moved aggressively over the last ten years into “destruction of habitat and the devastation of our forests, which is not responsible investing.” bcIMC owns 25 percent of Island Timberlands, 50 percent of TimberWest (the other half is owned by the federal Public Sector Pension Investment Board), and is a major shareholder of a Brookfield Asset Management (BAM) company that owns another 51 percent of Island Timberlands and 49 percent of Western Forest Products. 
    Says Woolley, “This means that virtually every retired teacher, university professor and public servant at all levels of government is unknowingly invested in unsustainable and destructive industrial logging practices that weaken the economy of Vancouver Island and nearby coastal regions.” 
    In correspondence with Doug Pearce, CEO of bcIMC, which touts its “responsible investing” practices, Woolley offered a challenge to the company: “As an institutional investor with massive influence, will they apply direct engagement to shift their heavily invested logging companies (Island Timberlands, TimberWest and Western Forest Products) toward ecosystem-based forestry practices that will sustain future generations?”
    Neither bcIMC or Island Timberlands returned calls to Focus, but David Vipond, Director of Collective Agreements with the BC Government Employees Union, who contribute to one of the five pension plans managed by bcIMC, had little to allay Woolley’s concerns. “We are not opposed to logging and if there is a problem with forest practices, then that is a public policy issue. The only company we have ever divested stock from was weapons and antipersonnel mine manufacturers because it was illegal. If people want to challenge the company’s practice, they can propose their own shareholder resolution at the company’s AGM.”
    Woolley’s reaction is symptomatic of the widening and deepening range of voices in this new “war in the woods.” Zoe Miles, a young Cortes Islander who helped deliver a petition of 7000 names to BAM’s corporate offices in Toronto, says, “With the spotlight on us at the moment, we want to shine it on an issue that is affecting every rural community, not just Cortes Island—industrial forest liquidation by large corporations and the pension funds that invest in them—and the alternatives.”
    Multi-billion dollar companies might not think a small island of 1000 people has much clout, but they might well be reconsidering in light of recent events. The Christmas blockade by islanders—both on land and by sea—that saw Island Timberlands back off temporarily, is now spotlighting ideas on sustainable economies that have been decades in the formation. Bruce Ellingsen, a fourth-generation islander who owns a local sawmill and is director for the Cortes Community Forest Co-op, advocates a type of forestry that sees logs, jobs and profits stay in the community rather than shipped off to mills and offices around the globe. “Cortes has a high proportion of people with knowledge and experience who are interested in a discussion of the future direction of rural economies. We have been meeting in our community hall for 20 years about how to manage our forests sustainably.”
    The issue started in 1990 after a bitter battle between islanders and then-Macmillan Bloedel. The islanders stopped the logging and MacBlo agreed to stop clear-cutting and come up with a plan that was sustainable. It took MacBlo four years, but the amount and rate of harvesting were still too high for islanders. Ellingsen says, “This firmed up the community’s attitude about what our bottom line was.” In 1998, islanders established the Cortes Community Forest Committee with an ecosystem-based management plan.
    Iconic forester Herb Hammond helped islanders prepare the plan that gave the community what it wanted—logs for their own sawmills, jobs for their own kids, a 200-year rotation with selective logging that maintains the major functions of a forest: watershed protection, conservation and social benefits. 
    Making this type of forestry pay meant exploring diversified revenue streams through eco-certification, local log markets, developing tourism and recreation, and exploring carbon revenues, while saving money on avoiding flood controls and infrastructure. Unfortunately, MacBlo was taken over by Weyerhaeuser, which was bought by Brascan, which turned into BAM. And the rest is history. 
    With the arrival of pension investment shareholders, the three major timber players converted themselves into asset liquidation and real estate companies. Ellingsen and other Cortes islanders approached Brascan about the community forest plans. “We were told ‘No,’—they didn’t want to join in an ecosystem-based management plan because the profit margin wouldn’t be large enough to be responsible to their shareholders, and that has been the story every since.”
    Carrie Saxifrage, a Cortes landowner and journalist, targets the inequity of the current forest policy: “The province has given the forest companies big financial breaks from the very start, including extremely low property tax rates. In return, the forest corporations are exporting raw logs and converting forests to real estate to fulfil the short-term expectations of shareholders. It is the province’s duty to protect the long terms interests of BC’s citizens by regulating forests lands for these purposes, or, if corporations want to liquidate forests without regard for local value-added jobs or ecosystems, by taxing their land at the rate of other private property.” 
    As Zoe Miles points out, this two-decade-long discussion has positioned the community well to comment on current gaps in forest policy: the regulations are inadequate; the model of “professional reliance,” where government relinquishes oversight and puts it in the hands of the companies, isn’t working; and the checks and balances of what companies claim as “ethical investment policies” aren’t there.
    Anthony Britneff, an ex-provincial forester— and a pensioner—couldn’t agree more. The Private Forest Managed Land Council, which oversees the 2 million tax-exempt acres regulated under the Private Forest Managed Lands Act is “the fox guarding the coop.” The Private Forest Landowners Association is, according to Britneff, “perceived as a bullhorn for the huge corporations answerable only to holding companies and shareholders.” 
    Down the Island Highway, Bruce Fraser, also retired from public service and now regional director for Shawnigan, is watching his pension’s impacts on private land logging in his own watershed. He estimates 70-80 percent of the forest cover has been removed—which, under provincial Crown land regulations that he oversaw as past-Chair of the Forest Practices Board, would be illegal and signal a red alert for flooding, erosion, ecological and visual impacts. He points out that the biggest legislative gap is that there is no mechanism to deal with the cumulative impacts of all these companies. Fraser asks, “Each cutblock might be regulated, albeit weakly, but who is watching over the ‘collective coop’? At Shawnigan, residents look up into a fragmented and devalued landscape, logging is continuing and there is not a thing that we can do about it, nor a mechanism to comment.”
    Back on Cortes, Zoe Miles points out that Island Timberlands has proposed token concessions to its plans—like saving single trees over 250 years old, or moving a proposed road out of a riparian zone where it shouldn’t have been considered in the first place, and leaving small, contested areas for a period of one year. “Essentially, it is a bunch of smoke and mirrors and it still remains industrial forestry. They are really talking about liquidating the forest and selling it as real estate, as they are doing everywhere.” Island Timberlands says they won’t log the old growth over 250 years , but Miles claims this just diverts people from the real issue at hand: “We want a fundamental change in the way forests are managed—not just saving a token 250-year-old tree surrounded by a clearcut.”
    Woolley, in correspondence with bcIMC’s Pearce, questions bcIMC’s claims as an ethical investor. Pearce claims that at 25 percent ownership, bcIMC is only a minority investor, and therefore has no say in day-to-day operations. Woolley argues that “does not excuse blindness to corporate responsibility.” But Pearce says Island Timberlands operations meet ethical investment standards under Sustainable Forestry Initiative (SFI) certification, a certification that leading market campaigner and Cortes Islander Tzeporah Berman has plenty to say about. A recent report by ForestEthics, which she co-founded, describes SFI as a front for the paper and timber industries, from which it derives virtually all its funding. SFI does not perform rigorous audits or any chain-of-custody tracking, and there is a legal investigation regarding the legitimacy of this corporate “brand” by the US Federal Trade Commission and the IRS. Berman and Miles have launched a campaign aimed at the mills which buy SFI-certified raw logs and the retailers which sell the lumber: Home Depot, Lowe’s and ProBuild amongst others.
    Cortesians are mounting an offensive on all fronts including building a war chest to buy parcels of land—if all else fails. A recent offer by the Strathcona Regional District to purchase just 70 acres from Island Timberlands was rebuffed however, on the grounds that the timber prices were valued too low and not at international prices. Given the history of logging conflicts in BC, sooner or later intransigent companies fall victim to market campaigns. It worked in the Great Bear Forest, and they now have a legislated ecosystem-based management model with carbon revenues. It’s fair to speculate that between market boycotts, angry pensioners, impacted politicians and young women raised on sophisticated talk of sustainability, islanders might have some success in pushing the provincial discussion ahead. If the Goliaths think they can get off lightly on this one, they had better think again.
    Briony Penn PhD is a naturalist, journalist, artist and award-winning environmental educator. She is the author of The Kids Book of Geography (Kids Can Press) and a A Year on the Wild Side.

    Briony Penn
    A First Nations case before an international court could spell trouble for the government pension funds that purchased TimberWest.
    FOR THE FIRST TIME IN CANADIAN HISTORY, an international human rights tribunal, the Inter-America Commission (IAC), will hear a human rights complaint against Canada, one brought forward by six southeast Vancouver Island First Nations of the Hul’qumi’num Treaty Group (HTG). With the failure of our provincial and national treaty process, First Nations are taking their cases to such international bodies to seek justice and, judging from comparable cases in the Americas, are likely to succeed.
    All of us in the Capital region should be paying attention to this case as it could have broad and far-reaching implications—whether you are interested in human rights, urban sprawl, water quality, the future of our endangered forests…or your pension. 
    Yes, pensions. Pension fund investments for many Victoria residents are involved in the complaint and might soon be found in violation of international law.
    The Hul’qumi’num have charged Canada with the illegal and uncompensated seizure of their ancestral land—an act of “egregious piracy”—for the benefit of corporations which have engaged in clear-cutting, deforestation and environmentally-destructive development activities. Together with Amnesty International and over a dozen Canadian First Nations governments and organizations, including the Assembly of First Nations, HTG has been presenting evidence that Canada has failed to recognize and protect their rights to property, culture and religion, as recognized under the Organization of American States’ principal human rights instrument: the American Declaration of the Rights and Duties of Man, as well as the UN Declaration on the Rights of Indigenous People. This is following on an earlier ruling by the Commission that the BC treaty process has failed to find a timely and effective remedy to land claims.
    The land in question—a full 40 percent of the land base of the southeast part of Vancouver Island, extending down into the backyard of the Capital Regional District—is part of the original E & N land grant stemming from 1884. BC awarded over 300,000 hectares, primarily old-growth forest and representing two-thirds of the HTG’s ancestral territory, to Robert Dunsmuir and his company  in return for building the Esquimalt & Nanaimo Railway. Dunsmuir had launched his company, which also received substantial cash grants, with US investors who were buying the coal. 
    Robert Morales, chief negotiator for the HTG, says: “We cannot accept the position of the Canadian government to let it go just because the theft took place over 100 years ago. We are suffering the impacts of that decision now, and there has to be some kind of restitution.”
    Three corporations are now the “successors in interest” to 190,000 hectares of that original land grant: TimberWest, which this spring was purchased outright for just over a billion dollars by two pension fund managers for federal and provincial government employee pensions; Hancock Timber Resource Group, owned by Manulife; and Island Timberland, an asset of the notorious Brookfield Asset Management Corporation, a company with multiple ties to BC Liberals, pension funds, and Western Forest Products (and on whose New York property Occupy Wall Street protesters are camped).
    Morales believes the Hul’qumi’num’s case will be successful: “I believe that the international jurisprudence is going farther than domestic jurisprudence. Under international law there is a duty to consult under the principle of Free, Prior and Informed Consent.”
    The decision is expected soon and if HGT wins, Canada will be in violation of international human rights law and will have to decide how it is going to redress this violation. International law standards demand a duty to return, replace or make compensation for the violation of seized lands.
    Victorians are implicated and affected in many ways by this case. Victoria is a government and armed forces town. TimberWest’s new ownership, BC Investment Management Corporation (bcIMC) has clients with public sector pension plans, insurance funds and public trusts, while PSP Investments is a pension investment manager for the federal public service, the Canadian Forces, the Royal Canadian Mounted Police and the Reserve Force. All employees in these agencies, some of whom have shown leadership in socially responsible investment in the past, will have to ask some tough questions of their employers, their unions, their investment managers and themselves—about who was/is responsible; about the implications for redress; and about future investments and whether they will exclude those that breach the OAS human right declaration and the UN International Convention.
    Insurance holders with Manulife, of which there are a healthy number in Victoria, will also have to ask themselves these questions, as will shareholders of Brookfield Asset Management.
    From the perspective of ecological justice, the implications are huge. The HTG has compiled a compelling case of photographs, maps, reports and other evidence of environmental degradation in now-endangered ecosystems. Over 1000 photographs alone of the clearcutting and deforestation are lodged in the file. 
    In TimberWest’s own management circular outlining the sale last spring, the harvesting rates are currently at 1.9 million cubic metres per annum, which already exceeds any sustainable rate of harvest, even by Crown forest standards. In another 2011 public document, the company states, “given TimberWest’s historical practices and emerging markets, harvesting will continue and will be accelerated to meet emerging market demand and future supply shortfalls due to the Mountain Pine Beetle epidemic in the interior of BC.”
    The creation of TimberWest’s real estate arm, Couverdon, is described as “an enabler of growth on Vancouver Island…To accomplish its mission, Couverdon is actively working to entitle land for these end uses in and around communities on the southeast coast of Vancouver Island.” Over 55,000 hectares are slated for “entitlement changes”—new-speak for urban sprawl in rural areas. 
    In the April 11 press release from bcIMC and PSP Investments on the purchase of TimberWest, they state, “No fundamental changes in the operations of the business are anticipated. It will be business as usual on the ground and existing operating systems and processes will remain in place.” 
    “Business as usual” was laid out fairly clearly in a TimberWest PowerPoint presentation delivered to the McElvaine Investment Management 2010 Partner Conference on May 7, 2010. There are plans for resorts to villages and sprawl in-between, from Sooke to Port Renfrew, and the Malahat to Campbell River. For areas like Port Renfrew, it notes: “Opportunities best pursued after a five-year development timeframe due to lack of current development, a need for increased infrastructure or a change in the political environment.” [emphasis added] One wonders what change they are anticipating. And how objective will governments be in their decision-making around smart growth strategies and development of rural lands (consider the recent Juan de Fuca resort debacle) if civil servants’ pensions are relying on real estate development? (Not to mention the lobbying and political donations such large corporations often engage in.)
    The decision to find redress in the international tribunals is taking place against the recent announcements of the failed internal BC treaty process, with a half billion dollar debt incurred by First Nations to participate in the negotiations. Head of the BC Treaty Commission, Sophie Pierre, recommended both governments shut the treaty process down unless they can commit to the agreements reached by the negotiating teams. The HTG themselves have incurred a $22 million debt during the failed negotiations.
    Another very interesting element to this story is the recent announcement by TimberWest and Pacific Carbon Trust (PCT) that these same ancestral lands have been developed as a carbon offset project—the Strathcona Ecosystem Conservation Project. 
    PCT wrote the forest protocol, and is the buyer and seller of the credits to public sector bodies, which in itself differs from other international offset regulatory bodies, like the Verified Carbon Standard. The project commits TimberWest to leave what’s left of the old growth—only eight percent remains on these lands. The conservation of the old growth is expected to reduce emissions by nearly 8,749,482 tonnes over a 25-year crediting period, which will net TimberWest and its pension fund owners a healthy return over time, depending on the price of carbon (currently $5-$25). Yet, it is only because of ancestral stewardship that the carbon is even stored on the land. This carbon has taken 500 to 1000 years to be stored in the old trees and soil—it certainly wasn’t done by TimberWest.
    The case that business-as-usual would have meant liquidation of old growth is made clearly in the Project Summary prepared by the Pacific Carbon Trust. It states, “In the absence of this project, old-growth forest would be harvested and converted to second-growth forest with higher timber production values.”
    While it’s encouraging that TimberWest is now bound by a legal agreement to not cut down old growth anymore, it is worrying that we have had to pay through our own public sector organization’s carbon liabilities to get that agreement. Also on the negative, the continued lack of separation between government employee pension holders, the Pacific Carbon Trust, government, land-use decision-makers, and the company are enough to make any conflict commissioner’s head spin.
    Come the Commission’s decision, Canada will have to respond. Redirecting these carbon revenues to the rightful owners, as is already being done in Haida Gwaii and the central coast for stewarding their ancestral lands, seems to me to be the first act of redress that the federal and provincial governments are supremely poised to make.
    Naturalist and writer Briony Penn, PhD has been working on forest carbon projects for a couple of years in the non-profit sector. She is author of A Year on the Wild Side and The Kids Book of Geography.

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