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.
Forest Practices Board investigation report
Information about Woodlot 2031
Vancouver Island Land Use Plan documents
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