January 17, 2024
To: Nigel Ross RPF
Buttle Lake Resources
cc Lesley Fettes RPF, Campbell River District Manager, Ministry of Forests
I hope this finds you well. Thank you for your response to the Discovery Islands Forest Conservation Project’s submission regarding your draft woodlot plan. I appreciate the time and thought you put into your response.
I would like to address some of the points you have made.
First, regarding Objective A. 1. (b) of the Vancouver Island Land Use Plan Higher Level Plan Order for Special Management Zone 19.
Thanks for the list of the efforts you have made “to preserve and enhance biodiversity” on your woodlot. However, I believe your interpretation of the full meaning of this objective falls short of what was intended. In my submission I provided you with a link to the material from the Biodiversity Guidebook that describes the full ramifications of “Sustain forest ecosystem structure and function in SMZs, by... retaining within cutblocks, structural forest attributes and elements with important biodiversity functions…”
I do not believe that the order applies simply to “snags, wildlife trees and downed logs”.
Given the full explanation of “structural forest attributes and elements” in the Guidebook, it is clear to me that the intention of the order was to ensure that, within cutblocks, all of the recommendations would be adhered to, not just retention of course woody debris and the occasional dead snag or live veteran. This would have included leaving undisturbed wildlife tree patches within the area of each cutblock, including “the provision for recruitment of suitable replacement wildlife trees over the rotation period”. Please read the full set of “Recommendations” at the link provided. That section includes “Area and distribution of patches or individual trees”, “Patch and live tree retention characteristics” and “Management principles for wildlife trees”.
I noted that TimberWest has addressed Objective A. 1. (b) by stating in its forest stewardship plan that its strategy for meeting this objective was to meet the requirements of Section 66 of the Forest Planning and Practices Regulation. Including this point in my submission was intended only to provide you with a sense of TimberWest’s interpretation of what Objective A. 1. (b) requires of them. Although woodlots are not subject to the Forest Planning and Practices Regulation, woodlots on Quadra Island are subject to the requirements of Objective A. 1. (b). It appears to me that you—and the other woodlots operators on Quadra Island—are incorrectly interpreting what is required of you to meet that objective.
I didn’t mention it in my submission, but this issue is part of the subject of an active complaint to the Forest Practices Board. That part of the complaint is directed at TimberWest, but it is applicable to all of the woodlots operating in SMZ 19 as well. Your cutblocks should end up looking more like the one near Lake Assu in Woodlot 1969, pictured below:
Regarding your explanation of the degradation of the visual corridor along Bold Point Road, I have included a before-and-after image (below) of logging you did in 2019 alongside the road. The RESULTS-Openings ID of the cutblock at issue in this case is #1737238. The satellite image taken before you logged that area shows a minor amount of alder near the road. But the vast majority of the trees you harvested in that section of the retention corridor were second-growth hemlock and fir. The Harvest Billing System report for your logging shows that alder only accounted for 2.6 percent of the 8204 cubic metres you logged in WL 1898 in 2019.
Before and after logging in cutblock #1737238 along the south side of Bold Point Road. The trees in the “Retention” visual quality corridor were predominantly hemlock and fir.
The fact that there are some deciduous trees growing in the retention corridor does not give you licence to ignore the “Retention” visual quality objective. You must abide by the visual quality constraints. If BC Hydro judges that some trees need to be limbed to mitigate risk to power supply lines, that is their business, not yours. We will follow up any subsequent logging in this corridor with a complaint to the Forest Practices Board.
If you disagree with our account of the exclusions from the timber harvesting land base on the Quadra Island portion of your woodlot, please provide details. For your reference, I will copy our summary immediately below.
Total area of woodlot 1898 on Quadra Island: 400 ha
Exclusions from the timber harvesting land base
Voluntary reserves as per proposed woodlot plan: 85 ha
Meadows/wetlands: 37.5 ha
Eventual permanent access structures (as per the licensee’s estimate of 7 percent of total woodlot area): 28 ha
Net impact of “Retention” VQO along Village Bay Lakes Road: 6 ha
Net impact of other VQOs and RMZs: 5 ha
Rock: 2 ha
Unstable slopes/inoperable areas: 2 ha
Total exclusions: 165.5 ha
Net area available for logging: 234.5 ha
My original submission did not include your private land. Like many other woodlot licensees have done, you could withdraw your private land from the woodlot at any time. Our interest, therefore, is constrained to the 400 hectares of publicly-owned land in Woodlot 1898. Again, please let me know if you have specific disagreements with our account of your THLB.
By the way, our summary of the net area available for logging on the Quadra Island portion of your woodlot matches very closely that provided in your AAC report by Econ Consulting. By our numbers, the forested area of your woodlot that is under a conservation constraint (including the net effect of visual quality objectives) is 96 hectares. That is 27 percent of the forested area (359 hectares) of the woodlot. Our project supports the notion—which is supported by scientific analysis—that we should leave at least half of the area of Quadra Island’s forests in a natural state in order that logging creates only a low risk of biodiversity loss. If you truly want to be ahead of your time, you only need to find another 83 hectares of forested land to set aside for conservation and then abide fully with the legal constraints applicable to your woodlot.
Thanks again for your response.
David Broadland for the Discovery Islands Forest Conservation Project