The Forest Practices Board responded to this complaint—sent by email on April 4—on April 13 with the letter below, sent to the logging companies named in the complaint and copied to me. I will update this page as the Forest Practices Board proceeds. File: 97250-20 / 23021 April 13, 2023 VIA EMAIL Aaron Racher, General Manager Operations TimberWest Forest Corp. David Younger, Younger Brothers Holdings Woodlot 2032 Chantal Blumel, Okisollo Resources Ltd. Leslie Fettes, District Manager Campbell River Natural Resource District Re: Notification of Complaint – Logging of old forest on Quadra Island Dear Participants: On April 5, 2023, the Forest Practices Board (the Board) received a complaint from David Broadland on behalf of the Discovery Islands Forest Conservation Project (the complainant). TimberWest (Tree Farm License 47), Okisollo Resources Ltd. (Woodlot 2031), and Younger Brothers Holdings (Woodlot 2032) are named in the complaint. On Quadra Island, the complainant has identified approximately 655 hectares of old forest which it estimates to be 4 percent of the Crown forested land base. The complainant believes that the failure to complete landscape-level planning and to spatially designate old growth management areas, combined with government’s decision to establish or expand 11 woodlots in Special Management Zone 19, has put the remaining old forest at risk of being logged or degraded. The complainant believes that the three licensees named above continue to log old forest on the island. A summary of the complaint relevant to each licensee appears below. The complete complaint is attached for reference. TimberWest • TimberWest is degrading small patches of old forest in TFL 47. • TimberWest has no effective strategy to meet the old seral stage targets implied by the Vancouver Island Land Use Plan Higher Level Plan Order. • TimberWest is not abiding by the strategies recommended by the Vancouver Island Summary Land Use Plan for managing concentrations of veteran trees. • TimberWest’s strategy for sustaining forest ecosystem structure and function within cutblocks is ineffective because it doesn’t retain forest within cutblocks. Okisollo Resources Ltd. • Okisollo Resources Ltd. is logging old forest despite stating in its woodlot licence plan (WLP) that it would retain existing old forest, even “scattered small patches of old forest.” Younger Brothers Holdings • Younger Brothers Holdings is logging old forest for roads and degrading old forest by removing trees 250 years old and younger. • Younger Brothers Holdings made substantive changes to its woodlot licence plan in 2019 concerning old forest reserves without any written communication with the ministry about a major amendment to the plan. The complainant believes that urgent action is required to conserve all remaining old forest to protect biodiversity and other values. For relief, the complainant requests that the Forest Practices Board determine the most effective approach to conserving the remaining old forest on Quadra Island. The Board must deal with public complaints about a party’s compliance with Parts 2-5 and 11 of the Forest and Range Practices Act. The Board does not represent the complainant, rather it acts as an independent third party. It is possible that after initial investigation, certain aspects of this complaint fall outside the jurisdiction of the Board. More information on the Board’s complaint investigation process is available here. I would like to emphasize that the Board is interested in resolving complaints wherever possible, and I would appreciate any suggestions you might have to that end. I will be contacting you soon to begin investigating this complaint. If you have any immediate questions or concerns please contact me at (contact information removed). Yours sincerely, Tracy Andrews, RPF Manager of Audits and Investigations CC: David Broadland, Discovery Islands Forest Conservation Project Attachment

Thanks, Dave Younger, for responding to my letter in the Discovery Islander. You never offered to meet with me, although your contracted forester did. I declined a private meeting. After all, what would that accomplish? You have made your position on conservation of old forest clear enough through your secret 2019 amendment (even the Ministry of Forests has no record of it) and through your proposed new woodlot plan that reduces the area of old forest in mapped reserves to a little more than a third of what was mapped in 2011. Meeting with your forester privately would legitimize the current regime of professional reliance. Under professional reliance, “public engagement” on renewal of forest licences on publicly owned land occurs strictly between an employee or contractor of a logging company and concerned members of the public. Ministry of Forests personnel, who are bound by their oath of employment to put the interests of the public foremost, have no official standing in the talk-and-log dialogue that follows. Instead, a logging company pays a professional forester to brush off the concerns of members of the public and look after the company’s commercial interests. Accepting John Marlow’s invitation “to talk” would have been going along with the de facto privatization of public land that was intended when Gordon Campbell’s government introduced professional reliance. I don’t accept that privatization. This is not your private property. So I respectfully decline to meet with you or John in private. I am, however, more than willing to “talk” with you in the public sphere—out in the open. The Discovery Islands Forest Conservation Project has set up a forum on the topic of your woodlot license that can be accessed by anyone, including you. I am inviting you to make your case for logging old forest on your tenure at www.discoveryislandsforestconservationproject.ca/forums. The purpose of my first letter to the Discovery Islander was to bring public attention to the details of your proposed new woodlot plan, and in particular to the decrease in the extent and quality of old forest that would be fully reserved from logging. In doing that there was no implication in my letter of anyone “performing ethically questionable practices”. Rather, as I stated, “The replacement area no doubt makes economic sense to Younger Brothers, but does not meet the legal requirements for amending their Woodlot Plan.” Although there are better ways of fighting against the continued destruction of the small remaining area of old forest on the Discovery Islands, I have filed a feint-hope complaint with the Compliance and Enforcement Branch (C&E) of the Ministry of Forests and have asked it to determine whether your 2019 amendment was properly or improperly made, as defined by the Woodlot Planning and Practices Regulation. Those regulations make no mention of “ethical” standards. The regulations are laws that forest licensees need to abide by, and the question of whether your 2019 amendment met the legal requirements of a “minor amendment” can easily be determined by the ministry (although C&E has failed to obtain even a single administrative penalty, administrative sanction or court conviction under forest legislation since 2011). You could prove your case in the court of public opinion yourself. Here’s how: Find the 15 largest trees in each of the two areas in contention: the area you have removed, through your 2019 amendment, from Wildlife Tree Reserves and the new replacement area on top of Darkwater Mountain. Compare the volumes of each of those two sets of trees. Also, find the 5 largest standing snags in each of these areas, measure their circumferences and heights and compare their volumes. Do the same for course woody debris. Lastly, make a comprehensive list for each area of the plants, animals and fungii you can find in each area. Then make these volumes and lists public. If your results show that the biological productivity of the area on top of Darkwater Mountain is equal or superior to the reserve you built roads through, then your 2019 amendment should stand. But if not, according to the Woodlot Planning and Practices Regulation, your action of cutting any trees in your mapped Wildlife Tree Retention Area was contrary to the Regulation and should warrant either a fine or a period of imprisonment. That’s what the law says. I’ll quickly address two other points you raise in your letter: That you won’t cut any trees older than 250 years and that your new reserved area protects Hairy Manzanita, both of which border on the absurd. Old forest on the coast is forest that contains trees older than 250 years of age, but such forests have several other elements necessary for their ecological functioning as old forests. They have an understory of younger trees, standing snags and fallen trees and other woody debris on the forest floor. The undisturbed forest floor and the soil below it supports a rich diversity of plants, animals and fungi. Your idea of removing or disturbing all of the biomass except the trees over 250 years of age is like saying a beef stew without the carrots and potatoes is still a beef stew. In Woodlot 2032, as in TFL 47, trees older than 250 years of age are left standing while almost everything else is removed. Your concern for conserving Hairy Manzanita at the top of Darkwater Mountain is similarly noteworthy. Hairy Manzanita has no merchantable value and occurs only in areas of sparse forest on rocky soils that don’t support what you would call “merchantable timber”. Hairy Manzanita is not threatened because BC’s logging industry has no commercial interest in logging the kind of ecosystem in which it grows. That’s why Hairy Manzanita isn’t on anyone’s list of threatened or endangered species. Besides, you were never going to log the top of Darkwater Mountain, just like you were never going to log the top of North Mountain, one of your other reserves. Both places are unproductive forest that, if logged, would take a couple of centuries to recover, if ever, given climate change. To build roads to the top of those mountains would cost you more than the monetary value of the trees you might log, in both cases. No worry for you, though, since your losses would be covered by taxpayers through low stumpage fees and other subsidies to your logging company. Meanwhile, down the hill toward Logger’s Bay, you have built a road through one of your mapped old forest reserves to a grove containing tall and voluminous Western White Pine. You probably know the place I mean: the big pines are on either side of your new road. Correct me if I’m wrong, but you must have already logged—for the road—some of those big, old White Pines and you intend to take all the rest, correct? Because they aren’t over 250 years of age. But the conservation status of Western White Pine is “NT”, which stands for “near threatened”. This tree is on the red list of the International Union for Conservation of Nature. So why did you build a road through those White Pine instead of declaring them a “recreational area”? I have posted a copy of this email at www.discoveryislandsforestconservationproject.ca/forums. I hope you will follow through with your offer to talk. But let’s do it out in the open. A volunteer with the Discovery Islands Forest Conservation Project holds a cone from a Western White Pine that towers above her in Woodlot 2032.

Dave Younger, the operator of Woodlot 2032, replied to David Broadland's letter with the following letter to the editor in the February 3, 2023 edition of the Discovery Islander: I WOULD LIKE TO RESPOND to David Broadland’s letter regarding his accusation that my company, Younger Bros. Holdings Inc., is performing ethically questionable practices. We have tried to talk to Mr. Broadland about this issue and have invited him to come out to the Woodlot Licence, but he has chosen not to do that. I have found that the best way to deal with a problem is to discuss it with the people who have the objections. Unfortunately, that has not happened so I will state my case here. I have a degree in Forestry and have been working in the forest industry for the last 45 years, so I have some experience in this area. Mr. Broadland states that I “built logging roads through two areas of old forest the company had mapped in its 2011 Woodlot Plan”. In my 2011 Woodlot Licence Plan (WLP) it clearly states that “trees in wildlife retention areas may be removed if there is a need to remove the trees to provide access to adjacent stands”. To be very clear, all old growth trees are protected at Woodlot Licence W2032, and no Old Growth trees were removed during this road development. This road was constructed because access to this woodlot is very difficult, and this was the only route. I spent a long time looking at this route and it has allowed me to get down to Logger’s Bay with the least adverse grades. Mr. Broadland states that we have changed the designation of reserves of old forest such that those areas are now included in the operable landbase of the Woodlot Licence. This is in the area of Manzanita Mountain (or Darkwater Mountain). There is a legal requirement for all Woodlot Licences that a minimum of 8% of the Licence area is designated as long-term reserve (Wildlife Tree Patches). For the initial WLP, we identified 122 ha or 16% of the Woodlot Licence potential reserve areas with a clear commitment to review those areas within the first 10 years and to update the retention strategy on the updated WLP. The understanding was that “over the initial 10-year term of Woodlot License 2032, additional commitments will arise in response to government and public feedback as well as on-the- ground experience in the Woodlot Licence area and longterm objectives” which will require changes. What we found in this 10-year period was that the lower areas have had skid trails and various forms of logging in what was called “old growth forest” and that is why we removed them. Another reason was a comment found on his website in the Sierra Club’s critique of my Management Plan 2010 where they stated that “Woodlot 1969 established wildlife tree retention reserves located along the boundary with this woodlot (WL 2032) should be mapped. Future reserves within WL2032 should be considered adjacent to these reserves to add to their size” To reiterate, we have not changed our commitment not to log old growth forest and all old growth trees are reserved from harvest at Woodlot Licence W2032. Mr. Broadland goes on to state that the Manzanita Mountain old forest replacement has been logged and is younger and sparser than the previous one. This is simply untrue. The replacement forest has less disturbance and more old growth than the stand that it replaced. His statement that part of an old logging road was named “Manzanita Trail” is only partially correct. The trail follows the old road and then goes up through the old growth retention area to the top of Manzanita Mountain, to a patch of Manzanita (arctostaphylos columbiana) which is probably close to its northern-most limit of distribution. This is a very unique ecosystem and appropriately is now included in the retention strategy for Woodlot Licence W2032. I consider the self-named ‘Manzanita Mountain Recreation Area’ a jewel of this Woodlot Licence and I have diligently worked on providing access to this unique area over the last 10 years. This includes road access, parking, and trail location. Although difficult to get to and steep, this area provides for a beautiful day hike to an area of unique ecology. I hope that this area can be enjoyed by locals and tourists alike. If anyone would like to discuss any of these issues or to have a tour of Woodlot Licence W2032, please contact me at any at 250-202-1553. Dave Younger

I sent the following letter to the editor of the Discovery Islander. It was published in the January 20 edition under the title: Re Younger Brothers Holdings Woodlot Licence Renewal I have some good news and some bad news. The bad news is that the Discovery Islands Forest Conservation Project’s first estimate of remaining old-growth forest on Quadra Island is 650 hectares spread over 174 fragments. That’s less than 4 percent of Quadra Island’s original extent of old forest before European colonists arrived. According to leading forest ecologists, that means Quadra Island is at “high risk” of extirpation of species that need old forest to survive: The northern goshawk, marbled murrelet, wandering salamander, northern red-legged frog, pygmy owl...well, it’s a long and illustrious list of long-time residents. They are all needed to keep this place working properly, ecologically speaking. Why would we knowingly kill them off? The good news is that you can do something about this if you do it before February 7. That’s the last day that you can submit a response to the application for renewal of Younger Brothers Holdings’ woodlot licence. The woodlot is located near Darkwater Lake, one of Quadra Island’s most delightful places. Younger Brothers’s revised woodlot plan shows that required reserves of old forest that it had promised in 2011 wouldn’t be cut, have been reclassified as areas of the woodlot that will be cut. Younger Brothers is only permitted to do this, by law, if the area it is taking out of its required wildlife tree reserve is replaced with an area “that will not decrease the nature or quality of wildlife trees or wildlife tree retention areas.” In this case, Younger Brothers is removing from the reserves areas that contain large, very old Douglas-fir and is replacing them with an area of much smaller trees on the top of Darkwater Mountain—an area that appears to have been previously logged. The replacement area no doubt makes economic sense to Younger Brothers, but does not meet the legal requirements for amending their Woodlot Plan. Younger Brothers says it will not log any single tree over 250 years of age (to “protect biodiversity”), but will log everything else between those trees. TimberWest does this with old forest, too, on TFL 47. Forest ecologist Rachel Holt and forester Herb Hammond have stressed this logging technique will not protect biodiversity. Younger Brothers has already flagged an area of rare old primary forest just west of Darkwater Lake. If that cut is allowed to proceed, the area of old forest remaining on Quadra will drop even further. Prior to 2011, when the area of Younger Brothers’ woodlot was part of TFL 47, TimberWest had mapped as “old forest” the areas that Younger Brothers is now trying to remove from its required wildlife tree reserve. TimberWest needs to get involved in preventing any further loss of old forest on Quadra. In TimberWest’s own application for renewal of its TFL 47 tenure on Quadra last year, it promised to consult with woodlot tenure holders—like Younger Brothers—to ensure that the area of old forest in Special Management Zone 19 on Quadra Island would not fall below the required minimum of 9 percent. It is well below that now, yet where is the consultation between TimberWest and Younger Brothers? TimberWest should step up and put its money where its mouth is and agree to compensate all woodlot tenure-holders for conserving areas of old forest, including all of the old forest on Younger Brothers’ woodlot. If these issues concern you, please check out the article posted on the Discovery Islands Forest Conservation Project website (look under “New” on the home page) which has more details about this renewal application and how you can engage with the issue.

Regarding renewal of woodlot 2032.

Since 2010, Min. of Forest designate 67 year olds as Prime harvestable trees. With and average age of trees in BC at about 400 years, that's about 20% of its potential life. By comparison to humans and values, If the modern day average age of Canadians is 75 years, any human over 16 years of age (20%) are past their value to society. Any Canadian over 20 years of age should be re-cycled (movie Carousel or Solient Green)

In the map below the gray-coloured private land areas are NOT protected since government has no policy or authority to regulate how private land is managed. During public review of the Draft VQO there were requests for this “misrepresentation” to be corrected; however, the Ministry’s final maps (still) show private waterfront coloured with “protection”—which makes government’s “protected-area” appear much larger than in reality. Private land protections are only what the landowner chooses to implement. The new VQO does offer additional visual protection for a number of areas, which is a welcome improvement. It’s noteworthy that both sides of Hole-In-The-Wall are now better protected, and Bute Inlet up to Orford River has been elevated from Modification to Partial Retention. However, there is one serious omission: The west side of Maurelle Island has had its protection downgraded! This Okisollo shoreline has been a matter of community concern and discussion for many years, and there have been deliberate community requests for the Maurelle shoreline to be upgraded to “Retention” due to its high tourism values and proximity to the Octopus Islands Marine Park. Except for the big trees that BCTS wants to log, there is no rationale for degrading this viewshed that has in recent years been elsewise prioritized through public and government investments of time and energy and millions of tax dollars. Please note: there is discussion underway about how to respond—and information will be circulated when there is a plan for how to make our community response(s) most effective.