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David Broadland

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  1. David Broadland
    The area within which TimberWest proposes to locate 6 cutblocks and new roads Comments on proposed cutblocks 11623, 11624, 11625, 11626, 11627, 11628 and roads [1] The total area of forest cover loss from these six proposed cutblocks would be 15.82 hectares. The permanent forest loss as a consequence of the proposed 2.03 kilometres of logging road, at 4 metres wide, would be 8,120 square metres. This loss of forest cover and permanent forest loss would have significant climate impacts compared to the economic value of the logging. This development would also degrade and fragment five important forest-aquatic ecosystems in the area, as described below. [2] The small Lake to the southeast of Two-Mile Lake is known to our project as Floating Islands Lake. It’s name comes from six small, apparently floating (or partially floating) islands of vegetation and soil around the lake’s edges that have formed, perhaps the result of trees having fallen into the lake over time. This is the only lake of Quadra’s 80-plus lakes/ponds that has these special habitats. TimberWest’s proposed cutblocks 11623, 11625 and 11626 would degrade the surrounding ecosystems both physically and aesthetically. Floating Islands Lake looking northwest toward Two-Mile Lake One of six floating islands on the lake [3] Proposed cutblock 11625 would encroach on a unique bog to the east of the lake, most of which is inside Main Lake Provincial Park, and around which there is a unique old-forest ecosystem that includes an active osprey nest (on the south side of the bog) and many large, old Douglas firs. The osprey nest tree is about 250 metres from the east edge of proposed cutblock 11625. The Ministry of Environment recommends no blasting within 1000 metres of an osprey nest and a buffer of between 200 and 500 metres between the nest and logging, especially during nesting season. The osprey nest close to where TimberWest proposes to log Looking across Cedar Bog from the near the osprey nest to an area (on left side of photo) which TimberWest proposes to log [4] Proposed cutblock 11628 and the adjacent proposed roads encroach very closely on a beaver pond known to the project as Castor Pond. The pond has supported an active beaver lodge and mating beaver pair for many years. There are very few remaining beaver lodges on Quadra Island and the proposed logging would fragment and degrade the habitat required for their survival. The existing Clear Lake Main road along with the proposed new roads and cutblock 11628 would virtually encircle the pond, degrading its potential as a safe habitat for the beaver pair and the numerous resident and migratory birds that use the pond. Listed species including northern red-legged frog and Hammond’s flycatcher have been recorded in the area by our project, along with cougar, wolf and black bear. Beaver at Castor Pond, August 2019 [5] Cutblock 11627 is also located close to a wetland area/pond, the west end of Floating Islands Lake and the creek between Floating Islands Lake and Two-Mile Lake. Like the other proposed cutblocks in this area, this cutblock and road would badly fragment what is known to be well-occupied wildlife habitat that includes Douglas fir veterans. [6] The proposed complex of clearcuts around and between the lakes, the beaver pond, the bog and the wetland will dramatically fragment and diminish this important wildlife habitat area. If TimberWest will log here, they clearly will log anywhere on Quadra Island. By definition, the “timber harvesting land base” only includes forested land which is “acceptable” for logging. This area is completely unacceptable. [7] We also note that three of the proposed cutblocks are within 50 metres of Main Lake Provincial Park. A more appropriate buffer would be 200 metres in an area that was more acceptable for logging. TimberWest has a history of encroaching on the park along its western edge. In 2004-2005, cutblock 12-44A crossed into the park at the west end of Little Main Lake. [8] As mentioned in our comments about the other proposed cutblocks, these cutblocks would produce significant deleterious impacts on carbon emissions, forest carbon sequestration capacity and forest fire hazard. [9] Because this is an exceptionally ecologically-sensitive area right beside a provincial park, we request that TimberWest abandon its plans for these cutblocks.
  2. David Broadland
    Comments on cutblocks 11629, 11630, 11631, 11632 and 11633 southwest of Morte Lake This comment applies to all of the 18 new cutblocks TimberWest is proposing. In total TimberWest wants to log 37.39 hectares over the 18 cutblocks listed for 2024. This will result in the release of a carbon bomb into the atmosphere. By “carbon bomb” we mean a prolonged release of biogenic carbon to the atmosphere at a rate far greater than would naturally occur if TimberWest had not logged these forest stands and had, instead, let them grow through their natural lifecycle. How big is the carbon bomb? We use 2019 as a reference year. TimberWest removed an average of 1466 cubic metres of logs/hectare during its 2019 operations on Quadra Island. It left approximately the same volume of logging waste in clearcuts as the volume of logs it removed. Some of this waste was burned in slash piles but the remainder was left to decompose in the clearcut. That means the company was responsible for the premature decomposition of approximately 3000 cubic metres of biomass (logs plus waste) per hectare logged. That 3000 cubic metres/hectare would prematurely release the equivalent of 2400 tonnes of carbon dioxide per hectare logged. The total carbon emissions resulting from the 18 new cutblocks TimberWest is proposing on Quadra Island for 2024 (it has already logged two others this year) would be approximately 89,736 tonnes (37.39 hectares x 2400 tonnes per hectare) of CO2-equivalent emissions (see “Our methodology”, here). This is equivalent to putting 19,500 average Canadian passenger cars back on the road for a year. Slash pile burning by TimberWest near Beaver Lake in 2020 Even though TimberWest exports as raw logs virtually all of the forest it logs on Quadra Island, it could argue that some of the carbon removed from its clearcuts will be sequestered for many years in wood products manufactured in those countries. But consider what actually happens to the forest biomass after it is logged in BC. Most of the dead biomass left in a clearcut—which amounts to approximately half the volume of the original biomass that was in the stand before it was logged—is returned quickly to the atmosphere, much sooner than it would have been if the forest had been left standing. For the portion of that biomass which is burned in slash piles, the return is immediate. Just over half of the volume of the logs that are removed from the clearcut quickly become wood chips or sawdust; that’s because the utilization rate at sawmills is only about 50 percent (46.5 percent in BC). Most of the carbon in the sawdust and wood chips becomes sequestered in products such as cardboard, paper and other short-lived products and is returned to the atmosphere relatively quickly. Provincial carbon scientist Caren Dymond’s research (page 13) shows that only 11 percent of the carbon contained in logs removed from the stand is still safely stored 100 years later (graph below). So eighty-nine percent of the carbon in that volume has returned to the atmosphere. Since the volume of logs removed is only about half of the biomass that was originally in the forest stand, only a small fraction—about 6 percent—of the total carbon in the original biomass of the stand is likely to stay out of the atmosphere longer than 100 years. On the other hand, if the original forest had been left standing, Ministry of Forests growth and yield curves show the forest would most likely have continued to sequester more and more carbon over those 100 years. If the area cut is replanted and successfully grows back it would eventually recapture some of the carbon lost to the atmosphere; but in the meantime, the carbon debt created can never be repaid. Related to this sobering reality is the question of how logging companies will respond to the need to address climate change by mitigating (or not) the role they play in making it worse. TimberWest/Mosaic Forest Management announced on March 16, 2022, that it can make more money from letting trees grow and selling carbon credits than from logging its privately owned land. At that time, its Chief Forester Domenico Iannidinardo told the Globe and Mail, “We expect to make at least as much from the BigCoast initiative as we would earn from harvesting these forests.” So TimberWest is choosing not to log some of its privately owned land because it can make more money by letting the trees stand instead of logging them. They are able to do this because the threat of climate change and the need to mitigate that has created a new set of economic opportunities. We suggest that TimberWest could lead development of a similar market for sequestering carbon in publicly owned forests by significantly reducing the volume of trees it logs on publicly owned land. Whatever it can do to reduce the carbon bomb it is creating with these 18 clearcuts in 2024 will help to reduce its impact on climate change—not to mention forest fire hazard and biodiversity loss. This would create an outcome that is much more beneficial for the Quadra community than continuing to maximize logging on the island to produce logs for Chinese and Japanese mills and workers to process.
  3. David Broadland
    Comments on cutblocks 11619, 11620, 11621, 11622 and new roads [1] Proposed cutblock 11621-12-145 appears to overlap with a 1.3-hectare area of old forest that we have mapped as Area Q 163 (Long Lake Grove). You will find that area on the map on this page. You can view photographs of some of the trees in this area on this page. TimberWest’s usual practice on Quadra Island is to leave patches of trees older than 250 years of age but log all younger trees around and between them, thus destroying rare ground-level old-forest habitats and associated biodiversity. The Vancouver Island Summary Land Use Plan provided guidance on how such old forest was to be handled in Special Management Zone 19: “Strategies: to the extent that old seral forest retention will be required within the contributing land base portions of the landscape unit, such retention should be concentrated within the SMZ-portion of the landscape unit; maintain existing old forest in the zone, as well as second growth with high portion of veteran trees; manage to replace old forest in the long term (>150 years) in accordance with old seral targets for intermediate BEO; focus old seral replacement in CWHxm2, concentrated along riparian areas and, where possible, adjacent to existing old seral forest;” Given that guidance, TimberWest should plan to leave an area of recruitment forest around the existing patch of old forest at this location. We also note that this matter is part of the subject of an active complaint to the Forest Practices Board. Single Delight (One-flowered wintergreen, Moneses uniflora) found at the Long Lake Grove. On Quadra Island this plant only found in old forest. [2] Proposed cutblocks 11619 and 11622 are located close to the edge of Beech’s Creek Ravine, which contains a concentration of Douglas fir and red cedar veterans. Based on the guidance contained in the Vancouver Island Land Use Plan for Special Management Zone 19, the Discovery Islands Forest Conservation Project recommends leaving a buffer of recruitment forest above the ravine on its west and east side sto help to restore an old-growth ecosystem in this ravine. This would support listed species such as the northern red-legged frog, wandering salamander, northern goshawk and peregrine falcon—all recorded by the project—that occur in the area. A Western Red Cedar growing in the Beech’s Creek ravine [3] The crude representation of the boundaries of these cutblocks in the FOM doesn’t allow for an accurate depiction of what TimberWest is planning for the area within the cutblocks. For example, we can’t tell whether the proposed cutblocks will meet Objective A. 1. (b) of the VILUP Higher Level Plan Order (HLPO), which states: “Sustain forest ecosystem structure and function in SMZs, by… retaining within cutblocks, structural forest attributes and elements with important biodiversity functions…” Our interpretation of this objective is that “structural forest attributes and elements” includes leaving some standing mature trees within the cutblock. A full discussion of what is necessary to sustain forest ecosystem structure and function can be found here. Please provide us with assurance that TimberWest will abide fully with this legal order. We also note that this matter is part of the subject of an active complaint to the Forest Practices Board. [4] The proposed 1.64 kilometres of new roads, at 4 metres wide including ditching and clearance, will result in 6600 square metres of permanent deforestation and a commensurate permanent diminishment of the provincial carbon sequestration capacity. How will TimberWest offset that loss? [5] TimberWest’s practice has been to apply for export as raw logs all of what it cuts on Quadra Island. This logging, therefore, will provide only 2-3 months of local employment for 4 or 5 people. We recommend that TimberWest build a small mill on Quadra Island to process logs that will provide additional local employment and make available affordable, locally grown lumber on the Discovery Islands. Has TimberWest explored such a possibility with We Wai Kai First Nation? [6] TimberWest’s normal practice is, after logging, to pile and burn the approximately 40-50 percent of forest biomass that cannot be commercially utilized. This archaic practice would add immense quantities of carbon to the atmosphere during a time in which the federal government has declared a “climate emergency”. What are TimberWest’s plans for eliminating the carbon emissions associated with the non-utilizable waste from these 4 cutblocks? [7] The proposed logging would leave slash piles close to roads. This would allow islanders to salvage firewood from those piles. Unfortunately, this practice increases the risk of human-caused forest fire. The cutblock itself will have a higher fire hazard (because of the slash-type fuel ) than the mature forest that will be logged. This condition, which is most dangerous during extreme fire weather, will persist for up to two decades. Since all of these proposed cutblocks are directly upwind from the built-up part of Quadra Island, this logging and the practice of firewood salvaging will place human habitation at great risk. We recommend that TimberWest confine its logging operations in TFL 47 to north of the Mount Seymour area to avoid a repetition of the 1925 fire which destroyed much of the south island’s forest and homes. TimberWest leaves giant slash piles that attract firewood gathering. Such activity causes forest fires in coastal BC. Even after slash pile burning, TimberWest leaves behind tonnes of logging slash in a clearcut and that raises forest fire hazard during extreme fire weather [8] Mosaic Forest Management announced on March 16, 2022, that it can make more money from letting trees grow and selling carbon credits than from logging its privately owned land. At that time, Chief Forester Domenico Iannidinardo told the Globe and Mail, “We expect to make at least as much from the BigCoast initiative as we would earn from harvesting these forests.” Given all of the problems TimberWest will create by logging these cutblocks, some of which we have mentioned above, why wouldn’t it also be better for the Province of BC to make at least as much by letting these trees grow and selling carbon credits rather than letting TimberWest log them?
  4. David Broadland
    Comments on cutblocks 11616, 11617 and 11618 and roads [1] Proposed cutblock 11616 is in an area between Two-Mile Lake and a pristine bog that nearby residents Jolie and Greg Shea have informed TimberWest contains old forest, is a wildlife corridor and is in the small watershed that feeds their source of drinking water. TimberWest’s usual practice on Quadra Island is to leave individual trees older than 250 years of age but log all younger trees around and between them, thus destroying the rare ground-level old-forest habitats and associated biodiversity. The Shea family told TimberWest: “We have put wild life cameras system in this area and have seen wolf, cougar, fishers, deer, raccoons and seen northern pygmy owls, peregrine falcons and many migratory birds that use these lakes and bogs to rest.” TimberWest is proposing to log the forest on the right side of the bog in the photo above. That stand contains patches of old forest with Douglas fir and western red cedar. The bog is part of the watershed that supplies water to residences along Granite Bay Road, to the left. Regarding such patches of old forest, as mentioned above, the Vancouver Island Summary Land Use Plan provided guidance on how they were to be handled in Special Management Zone 19: “Strategies: to the extent that old seral forest retention will be required within the contributing land base portions of the landscape unit, such retention should be concentrated within the SMZ-portion of the landscape unit; maintain existing old forest in the zone, as well as second growth with high portion of veteran trees; manage to replace old forest in the long term (>150 years) in accordance with old seral targets for intermediate BEO; focus old seral replacement in CWHxm2, concentrated along riparian areas and, where possible, adjacent to existing old seral forest;” Given that guidance, TimberWest should abandon this cutblock and plan to leave an extended area of recruitment forest around the existing patches of old forest at this location. [2] Proposed cutblocks 11617 and 11618 are near to 11616 and may also contain concentrations of Douglas fir and red cedar veterans. In any case, based on the guidance contained in the Vancouver Island Land Use Plan for Special Management Zone 19, the area of these proposed cutblocks should be used for recruitment of mature forest to bolster the long-term ecological viability of the old forest/concentration of old trees that exists in proposed cutblock 11616. [3] The crude representation of the boundaries of these cutblocks in the FOM doesn’t allow for an accurate depiction of what TimberWest is planning for the area within the cutblocks. We can’t tell whether the proposed cutblocks will meet Objective A. 1. (b) of the VILUP Higher Level Plan Order (HLPO), which states: “Sustain forest ecosystem structure and function in SMZs, by… retaining within cutblocks, structural forest attributes and elements with important biodiversity functions…” As mentioned above, our interpretation of this objective is that “structural forest attributes and elements” includes leaving some standing mature trees within the cutblock. Please provide us with assurance that TimberWest will abide fully with this legal order. [4] The proposed .484 kilometres of new road, at 4 metres wide including ditching and clearance, would result in 1936 square metres of permanent deforestation and a commensurate permanent diminishment of the provincial carbon sequestration capacity. How will TimberWest offset that loss? [5] TimberWest’s past practice has been to apply for export of all of the logs it cuts on Quadra Island. This logging, therefore, will add minimally to local employment, providing only 1-2 months work for 3 or 4 people. We recommend that TimberWest build a small mill on Quadra Island to process logs that will provide additional local employment and make available affordable, locally grown lumber on the Discovery Islands. Again, has TimberWest explored such a possibility with We Wai Kai First Nation? [6] TimberWest’s usual practice is, after logging, to pile and burn the approximately 50 percent of forest stand’s biomass that cannot be commercially utilized. This archaic practice would add immense quantities of carbon to the atmosphere during a time that the federal government has declared a “climate emergency”. What are TimberWest’s plans for eliminating the carbon emissions associated with the non-utilizable waste from these 3 cutblocks and all the others it creates in TFL 47? [7] The proposed logging would leave slash piles close to roads. These would allow islanders to salvage firewood from those piles. This salvaging is often done during the summer, often without permits. Unfortunately, this practice increases the risk of human-caused forest fires. The cutblocks will have a higher fire hazard (because of the slash-type fuel) during extreme fire weather than the mature forest that would be logged. This higher-hazard condition will persist for up to two decades. These proposed cutblocks are in close proximity to the Shea’s and other homes. This logging slash—made riskier by the practice of salvaging firewood from clearcuts—will place these homes at greater risk. We recommend that TimberWest confine its logging operations in TFL 47 to areas that are at least 2 kilometres distant from the nearest buildings. TimberWest was aware of the existence of private property on Quadra Island at the time it acquired TFL 47. It should accept that it cannot safely and responsibly log near to built-up areas, especially with climate change expected to bring longer periods of extreme fire weather to its licence area.
  5. David Broadland
    This is an area old forest that Sonora Islanders have fought against TimberWest to protect since 2010. The area of old forest garnered media attention and was latter nominated to become a “BTMA” (biodiversity, mining, tourism area). The area containing most of the big, old trees was then deleted from TFL 47 in 2016 and is currently known as the Thurlow Special Forest Management Area (see map below). It has apparently been reserved as a future ecological reserve. In spite of deletion of the area from TFL 47 in 2016, TimberWest mistakenly included the area as within the TFL in maps accompanying its draft 2024 forest stewardship plan for the Great Bear Rainforest portion of its licence. The odd shape of the special forest management area would allow logging in a part of the reserve that contains big old trees, so Sonora Islanders work on the old forest reserve may not yet be complete. The photographs below are all in what is currently known as the Thurlow Special Forest Management Area, or in the areas not yet included in the reserve. Photos are by Tavish Campbell and others.
  6. David Broadland
    The first public engagement step in a timber supply review is the licensee's submission of an "Information Package" for public consideration and comment. The Discovery Islands Forest Conservation Project raised questions about the licensee's position on climate change, past promises, lack of protection of old forest, inaccurate mapping, a dubious account of the timber harvesting land base—and a glaring conflict of interest. To: Whom it may concern at TimberWest Forest Corp: communications@mosaicforests.com Cc: Lesley Fettes RPF, Campbell River District Manager Cc: Chief Ronnie Chickite, We Wai Kai First Nation Cc: Michelle Babchuk, MLA, Michele.Babchuk.MLA@leg.bc.ca Our comments below are in response to an invitation to respond to the information package for TimberWest’s Management Plan #5. As this package does not meet the requirements of a draft management plan, we look forward to being able to comment on that plan at a later date. Our understanding is that the legal holder of the licence for TFL 47 is TimberWest Forest Corp. If the licence has been transferred to Mosaic Forest Management please let us know. As you know, the main purpose of establishing a new management plan is to provide a timber supply analysis in preparation for a new determination by the Chief Forester’s Office of an allowable annual cut for the Quadra Island and Bonanza Lake blocks of TFL 47. An integral part of that analysis is a land base netdown summary that estimates the size of the timber harvesting land base in the two blocks. We critique that summary later in the comments below. First, though, the Discovery Islands Forest Conservation Project offers the following general comments about the contents of the information package and TimberWest’s current practices: Climate change The information package contains this comment on climate change: “TimberWest is concerned about the potential long-term implications of climate change on its forestry holdings and has dedicated time and resources to understand the issue better. However, given the current scientific understanding, it is not yet possible to make reasonable quantitative predictions about the impact of climate change on timber supply. Therefore, the base case will not include specific accounting for climate change projections.” This statement is hard to reconcile with the announcement by Mosaic Forest Management on March 16, 2022, that it can make more money from letting trees grow and selling carbon credits than from logging its privately owned land. At that time, Chief Forester Domenico Iannidinardo told the Globe and Mail, “We expect to make at least as much from the BigCoast initiative as we would earn from harvesting these forests.” The decision to sell carbon credits instead of logging TimberWest’s own land is apparently a sound business response to the climate emergency. Why would this not also be the case for the publicly owned land of TFL 47? Why couldn’t the government of BC expect to make at least as much from letting the trees grow than from licensing TimberWest to log them? If TimberWest’s chief forester thinks this is an economically sound idea, why wouldn’t BC’s chief forester, too? In both cases, there would be few if any manufacturing job losses since TimberWest exports—as raw logs—virtually everything it cuts in TFL 47. Moreover, logging is a significant contributor of carbon emissions via the accelerated release to the atmosphere of biogenic carbon. The short-rotation clearcutting practices used by TimberWest will inevitably cause a profound diminishment of the carbon sequestration capacity of the forests TimberWest is logging in TFL 47. In determining a new AAC for the Bonanza Lake and Quadra Island blocks of TFL 47, the expected impacts of climate change on the incidence of insect infestation, forest diseases, prolonged drought and the occurrence of extreme fire weather should all be considered—along with the more economically profitable alternative (apparently) of letting the trees grow to mitigate climate change. All of these factors point to a significantly lower AAC than is currently allowed. Clearcut logging In 1999 TimberWest announced that it would no longer practice clearcut logging. Back then, the CBC reported “Timberwest President Scott Folk says clearcutting is being phased out in response to marketplace demands.” TimberWest promised to phase out clearcut logging over a 4-year period. Nothing like that ever happened, but it is time for TimberWest to resurrect this promise. As the climate emergency and biodiversity crisis deepen, the over-sized role logging companies play in both those disasters is becoming clearer. Public pressure to end clearcut logging is building. Marketplace demands are hardening. The Discovery Islands are a biodiversity hotspot, a place of immense recreational and tourism potential and an area blessed with a forest type and climate in which forest fires are less likely than in most other parts of BC. Government will come under increasing pressure to conserve such areas in order to mitigate the biodiversity and climate crises and reduce forest fire hazard. Clearcut logging eliminates the existing natural advantages that are required for building and maintaining a sustainable local economy based on undisturbed nature. This reality, apparently clear to TimberWest in 1999, now needs to be incorporated in this AAC determination. Old forest In its most recent forest stewardship plan for the Quadra-Quinsam blocks of TFL 47, TimberWest states that since landscape level planning has not been completed, it will use the 2004 Order Establishing Provincial Non-Spatial Old Growth Objectives. For Quadra Island and the Bonanza Lake blocks this means the target for old forest is “>9 percent”. But both the Quadra and Bonanza blocks contain less old forest than the target level. For example, TimberWest has stated that old forest in the Special Management Zone 19 portion of TFL 47 on Quadra Island is 3.8 percent. The “non-spatial” part of that order should not be interpreted by TimberWest to mean that the company does not need to identify specific areas of old forest for conservation. If the amount of old forest remaining in TFL 47 was greater than 9 percent, then TimberWest could reasonably interpret “non-spatial” as meaning it did not have to commit to conserving specific areas of old forest. But TimberWest has logged itself far past that luxury. TimberWest needs to identify the location of remaining old forest in both blocks and commit in writing to conserving those forests. It should also nominate specific areas of older mature forest that it will commit to not log that would bring the total (recruitment+old) to at least 9 percent. The land base netdown summary needs to include at least 9 percent of the area of the Quadra Landscape Unit and at least 9 percent of the area of the Bonanza Landscape Unit as old forest reserves. TimberWest acknowledges the issue of old growth deferral areas but only commits to conduct a “sensitivity analysis” to “examine the impact of prohibiting harvesting in these areas.” Based on the Technical Advisory Panel’s mapping of priority deferral areas, it appears that in every block of TFL 47, the extent of remaining old forest is well below the legal target (>9 percent) established by the 2004 Order Establishing Provincial Non-Spatial Old Growth Objectives. Based on the TAP old forest priority deferral areas and the area of TFL 47 in each block, our calculations shows the following extent of old forest, block by block: Block 2 (West Cracroft Island): 0 percent Block 5 (Mainland): 0 percent Block 6 (Hardwicke Island): 8.6 percent Block 6 (Mainland portion): 1.3 percent Block 7 (Mainland): 1.3 percent Block 8 (West Thurlow Island): 8.4 percent Block 9 & 10 (East Thurlow Island): 6.3 percent Block 11 (Sonora Island): 4.3 percent Block 12 (Quadra Island): 2.1 percent Bonanza Lake (Block 17): 1.6 percent For the entire area of TFL 47, TAP identified only 2.6 percent (3309 ha) as being old forest. TimberWest’s position—that it will examine the “impact” of abiding by the law—is concerning. At the very least, there should be no question that it will abide by the 2004 Order Establishing Provincial Non-Spatial Old Growth Objectives, which would mean reserving all of TAP’s priority deferral areas if they are actually old forest. TimberWest has evaded landscape-level planning in TFL 47 since 2000 and so has not established a single legal old growth management area (OGMA) in the entire TFL. Coupled with the need to meet the target for the Provincial Non-Spatial Old Growth Objectives, there is the added impetus that arises from the fact that old forest throughout the TFL has been logged below the level considered to be high-risk for biodiversity loss (10 percent). Obviously, all remaining old forest should be identified as reserves of some form, preferably legal OGMAs. As mentioned above, the netdown summary of areas to be excluded from the timber harvesting land base (THLB) should include an area of mature recruitment forest and all existing old forest, equivalent to at least 9 percent of each landscape unit. In the proposed management plan netdown summary there is currently only a 547-hectare removal for old forest in the Bonanza Lake block. The netdown summary should include at least 9 percent of the 48,805 hectares of Block 12 and Block 17 (4392 hectares) for a minimal old-forest target. Lack of accurate timber harvesting land base mapping for TFL 47 A TFL management plan is required, in part, to guide the Chief Forester’s Office in revising the allowable annual cut for the TFL. An essential part of that determination involves an accurate estimate of the area of productive forested land that is acceptable and economically feasible to log, which is the definition of the “timber harvesting land base”. Although many TFLs in BC have created detailed mapping of the THLB in their licence area, TimberWest has not. The timber supply analysis performed by Ecora is, therefore, based on crude, opaque estimates of the THLB that cannot be verified and are, therefore, unreliable for the purpose of determining a sustainable AAC. Quinsam FDU There is no mention of the Quinsam FDU in this proposed management plan, yet it was part of the Quadra-Quinsam Forest Stewardship Plan proposed in 2022. The management plan should include an explanation of what happened to the Quinsam FDU and the impact on both the netdown summary and the proposed AAC. First Nations land claims There are First Nations land claims throughout the area covered by TFL 47. The netdown summary does not include the likely loss of THLB that settlement of these claims would involve. Land base netdown summary specific to Quadra Island Ecora’s current netdown summary lumps both the Quadra Island and Bonanza Lake blocks together. Quadra Island has a significant human population which utilizes forested areas of TFL 47 for recreational, food gathering, ceremonial and tourism purposes. Use goes up in spring, summer and fall, and could provide the basis for business operations that rely on an abundant supply of relatively (compared to clearcuts) undisturbed nature. Much of the Quadra population is also concerned about the impact of logging on wildlife habitat, climate change and increasing wildfire hazard. TimberWest could easily present two sets of information in the land base netdown summary: one for Quadra Island and one for the Bonanza Lake block. Additionally, TimberWest could provide maps of where it believes logging is economically feasible. Ecora’s 2012 timber supply analysis for TFL 47 showed (Figure 2) that approximately 7063 hectares of productive forest land in TFL 47 on Quadra Island was in the timber harvesting land base. The definition of the THLB is forested land where logging “is considered both acceptable and economically feasible”. TimberWest is the expert on “economically feasible”. But who is the judge of where logging is “acceptable”? Certainly not TimberWest. In order to reduce tensions between those interested in logging and those interested in undisturbed nature, TimberWest could provide mapping that indicates where the approximately 3140 hectares of productive forest land in TFL 47 that TimberWest does not consider to be “economically feasible” to log are located. These two steps—providing a netdown summary specific to Quadra Island and acknowledging on a map of TFL 47 on Quadra where logging is not economically viable—would go a long way to resolving potential conflicts between TimberWest’s logging and other uses of the forest, including First Nations’ land claims. Land Base Netdown summary for Quadra Island/Bonanza Lake (page 14) This table has a number of obvious errors that call into question the reliability of all of the numbers included. Consider, for example, lines 3 and 4. Note the numbers in the “Area Removed” column. The number “1,455” appears on both line 3 and line 4. In both cases, the area removed (“1,455”) is greater than what appears in the “Total Area” column. According to the “Version Control and Revision History” table that appears on an unnumbered page of the report (third page from the beginning), this report was reviewed twice by TimberWest and once by the Ministry of Forests. Since an accurate land base netdown summary is foundational to a credible determination of the allowable annual cut, getting the numbers right in the netdown summary is essential. Yet Ecora, TimberWest and the Ministry of Forests didn’t catch these errors. Is any one actually reading these reports? Why should the public have any faith in any of the information included in the report? Other errors in—and questions about—the netdown summary table include: • The “Total Area” of Block 12 and 17 do not coincide with the areas given on the maps for TFL 47 at the MoF website. Moreover, the map for Quadra Island is incorrect since it includes District Lot 488, which was deleted from the TFL following the Forestry Revitalization Act in 2003. That lot is now part of Woodlot 2032 and Woodlot 1969. You can do the arithmetic. • The “Non-forest” area on line 2 is intended to cover such features as lakes and areas of rock: areas where forest does not grow. In the 2012 information package for the TSR for TFL 47, “Non forest” for the entire TFL was estimated at 6,281 hectares. Of that, 6,264 hectares were removed through the netdown process. The rate of removal then was 99.7 percent. That’s what we would expect for land that is “non forest”. Yet in the proposed management plan, the “Non-Forest” (line 2) “Total Area” for just Quadra and Bonanza is given as “7,790” hectares and the “Area Removed” is “3,735” hectares. That’s equivalent to a mere 47.9 percent removal for “Non-forest”. Why is this not closer to 100 percent, as in the 2012 analysis? And since we are now considering a smaller area than in the 2012 analysis, which looked at the entire area of TFL 47, why is there a higher starting point for “Non Forest”? Again, this kind of inconsistency calls into quetion the care with which this report has been created. • Presumably “Analysis Forested Land Base” should equal the TFL “Total Area” minus “Non-forest” minus “NP Site Series” minus “Roads”. It doesn’t. • The area removed for “Inoperable” is 67 percent of the area judged to be “Inoperable”. In the 2012 MP it was 81 percent. Why has this fraction fallen? • For the category Wildlife Tree Retention/ Riparian in the netdown summaries, there is a much reduced area removed for the Bonanza-Quadra blocks compared with what is shown for the entire TFL, given the relative size of each. What accounts for this difference? • For the entire TFL, the total forested land base removed for recreation (trail + reserve + site + recreation inventory) is 355 hectares. In the 2012 management plan netdown summary, 1,100 hectares were removed for recreation. Why is there such a large decline in the area removed for recreation? Since most of the human population within TFL 47 is on Quadra Island, this is the area where the highest need for forest-based recreation exists, both for residents and visitors. It is likely that Quadra Island alone should have a recreational reserve of at least 3000 hectares to cover current and future recreational needs in these areas: Heriot Ridge, Missing Links-Nighthawk Lake, Morte Lake, Chinese Mountain-Beech’s Mountain, Nugedzi Lake-Mount Seymour, Mount Lolo-Saltwater Lagoon, plus as-yet undeveloped recreational areas towards the north end of Area A of Block 12. All of these areas have very low timber values as a result of the prevalence of rock, lakes and steep slopes. • Why has no area been removed for “high-value fish habitat” in the Quadra Island/Bonanza netdown summary? Quadra Island has three important salmon spawning streams (Hyacinthe Creek, Open Bay Creek and Village Bay Creek) which locals most definitely consider “high-value fish habitat”. Much of the watersheds of all three are within TFL 47. • There are 1012 hectares of “no harvest” ungulate winter range (UWR) and 507.5 hectares of “conditional harvest” UWR in the Bonanza Lake block, none on Quadra Island. There are only 70.6 hectares of overlap of these areas with wildlife habitat areas. Why has UWR been netted down to 810 hectares? • The wildife life habitat areas in the Bonanza/Quadra netdown summary are all in the Bonanza block. What are the specific overlaps with other exclusions that result in them being netted down from 359 hectares to 194 hectares? Please provide specific information. • Why have no wildlife habitat areas been established in the TFL 47 portion of Quadra Island? • In its current forest stewardship plan, TimberWest states that it will comply with Objective A. 1. (b) of the VILUP HLPO by: “(1) Retaining wildlife trees as specified in Section 66 of the Forest Planning and Practices Regulation (FPPR)”. Section 66 of FPPR states, in part: “(1) If an agreement holder completes harvesting in one or more cutblocks during any 12 month period beginning on April 1 of any calendar year, the holder must ensure that, at the end of that 12 month period, the total area covered by wildlife tree retention areas that relate to the cutblocks is a minimum of 7% of the total area of the cutblocks.” On the SMZ 19 portion of Quadra Island, under Objective A. 1. (b) of the VILUP HLPO this 7 percent should be within the associated cutblocks. In the rest of Quadra and in the Bonanza Lake block, Section 66 also applies, albeit without the requirement of retention areas being within cutblocks. In all cases, TimberWest cannot log these Section 66 wildlife tree retention areas until the surrounding regrowth has reached maturity. Why doesn’t the netdown summary include a 7 percent reduction in the “Forested Land Base” to account for the requirements of Section 66? • Red-listed plant communities have been identified by the BC Conservation Data Centre on Quadra Island. Why is there no area removed for these occurrences? • Only 100 hectares of karst has been removed. Presumably, this is on Quadra Island, where there is a significant karst area below TFL 47. Please provide a map showing the location of the 100 hectares of karst that have been reserved. • The netdown summary shows that 1369 hectares of CWHvm1 old growth in the Bonanza block have been netted down to 547 hectares. What specific overlaps with other categories of removals have reulted in this reduction? • Why is there no area reserved for blue-listed plant communities? • Why is only 21 percent of the most unstable terrain (Class V) removed from the forested land base in the netdown summary? • Why has no area been removed to meet visual quality objectives for both Quadra Island and the Bonanza block? Conflict of interest TimberWest is owned by the British Columbia Investment Management Corporation (BCI). BCI’s investments fund pensions for retired BC government employees, including those of the Ministry of Forests. The health of those pension funds is naturally an important part of the considerations about the future personal economic security of any BC government employee, including those who work for the Ministry of Forests. Therefore, when an employee of the Ministry of Forests—or any provincial government ministry or agency—makes a decision that could affect the economic position of TimberWest, they likely know they are making a decision that could influence their own long-term financial security. In that circumstance, a conflict of interest—or, at the very least, the perception of a conflict of interest—exists between the general public interest and the individual interests of BC government employees making decisions about TFL 47. An AAC determination for TFL 47 should, therefore, be conducted by an independent body or person with no possible personal interest in the outcome of the determination. That would exclude the BC chief forester or their designate, which creates a legally untenable situation: Only the chief forester is empowered by the Forest Act to undertake an AAC determination for a TFL. Thank you for reading. We look forward to your full response. Sincerely, The Discovery Islands Forest Conservation Project
  7. David Broadland
    To: Jennifer Peschke RPF, TimberWest Forest Corp, jennifer.peschke@mosaicforests.com cc Lesley Fettes RPF, Campbell River District Manager, Lesley.Fettes@gov.bc.ca cc Chief Ronnie Chickite, We Wai Kai First Nation, ronnie.Chickite@WeWaiKai.com Dear Jennifer, In the comments below, we refer to “TimberWest” rather than “Mosaic Forest Management”. TimberWest Forest Corp appears to be the legal licence holder of TFL 47, as shown by the most recent publicly available licence (2010), management plan (2012), timber supply review (2014) and TFL boundary change (2016). Please let me know if legal ownership of TFL 47 has changed. The Discovery Islands Forest Conservation Project offers the following comments: [1] Inaccurate mapping The map for Sonora Island provided in the proposed forest stewardship plan (FSP) does not acknowledge the existence of the Thurlow Special Forest Management Area. This 324-hectare area was deleted from TFL 47 in 2016. It has since been reserved for a future ecological reserve. This boundary change came after several years of lobbying by Sonora Islanders. While TimberWest’s information package includes a map of TFL 47’s boundaries on Sonora Island, that map shows the future ecological reserve as still being part of TFL 47. This error raises questions about the accuracy and completeness of all the other information TimberWest has provided. [2] The ecological sensitivity of small islands A significant area of the forest in the Johnstone Strait portion of TFL 47 is spread over 4 relatively small islands: Sonora, East Thurlow, West Thurlow and Hardwicke. Small islands are ecologically fragile. It has taken thousands of years for their ecosystems to develop—including discovery of and habitation by plant, animal, lichen and fungi species—and for the populations of these species to come into equilibrium. Because they are surrounded by waters rich with food, they are naturally biologically rich. At the same time, those watery boundaries make it difficult for certain species to survive events that cause rapid and large losses of habitat, such as fire and logging. Rapid logging of these small, ecologically fragile islands degrades and fragments habitat and many species are now in danger of local extirpation. Over the 27-year period between 1990 and 2015, for example, 3818 hectares of 8133-hectare West Thurlow Island were logged. That is equivalent to 47 percent of the entire area of the island. Most of that (3369 hectares) occurred in the 19 years between 1997 and 2015. The worst damage—by far—was caused by TimberWest. We invite you to watch time-lapse satellite photography of logging on Hardwicke, West Thurlow, East Thurlow and Sonora which took place 1984-2020. Keep your eye on West Thurlow Island in particular (near the centre of the screen), especially the two waves of logging that started first in 1997 and then again in 2011. It is not possible to remove 47 percent of the forested area of a small island over a 27-year period without causing local extirpation of certain species. TimberWest’s approach to logging on islands needs to be rethought to take into consideration a rate of logging that will not cause local extirpations. If TimberWest can’t evenly spread out its logging on these ecologically sensitive islands over a much longer period of time—a rotation period of 120 years would be more appropriate—then it shouldn’t be logging on these islands at all. [3] Red- and blue-listed animal species In its proposed FSP, TimberWest acknowledges the Great Bear Rainforest Order requirements for certain wildlife (grizzly and black bear) and red- and blue-listed plant communities and states that it will abide by those GBR objectives. TimberWest also acknowledges the Forest and Range Practices Act requirements for red- and blue-listed animal species. In the case of the Queen Charlotte Goshawk, Northern Red-Legged Frog, and Keen’s Long-Eared Myotis, however, the proposed FSP simply states that since an order has been issued establishing wildlife habitat areas (WHAs) for each of these species, “a result and strategy is not required”. But no WHAs have been established for the Northern Red-Legged Frog, Keen’s Long-Eared Myotis or any other red- or blue-listed animal (aside from the goshawk). It is a 100 percent certainty that these species have occurred in this portion of TFL 47, yet TimberWest is taking no action to protect their habitat. [4] Queen Charlotte Goshawk On Sonora Island, East and West Thurlow Islands and Hardwicke Island, four WHAs have been mapped, totalling 760 hectares. These WHAs have been established to protect nesting sites of the red-listed Northern Goshawk liangii subspecies. Unfortunately, a high percentage of these islands’ old and mature forest—required by goshawks for year-round foraging—has been degraded or fragmented by logging companies—mainly by TimberWest. For example, 3819 hectares of 8133-hectare West Thurlow Island were logged between 1989 and 2015. As mentioned above, that’s 47 percent of the entire area of the island. The Forest Practices Board has estimated that, on the coast, a pair of Northern Goshawks require up to 3700 hectares of home range for foraging. Not surprisingly, 3 goshawk nests on West Thurlow were recorded by the BC Conservation Data Centre (CDC) to be inactive in 2014. The CDC mapped a goshawk nest on Hardwicke Island in 2004. The area of the island is 7633 hectares, barely large enough to support one or two breeding pairs of goshawk. TimberWest began logging on Hardwicke Island in 2003. By 2005 the CDC reported the nest and nest tree had disappeared. In 2006 the area in which the nest tree stood was logged by TimberWest. In the 20 years since 2004, TimberWest has logged 2029 hectares of the island—27 percent of the entire area of the island. TimberWest’s proposed FSP may meet the legal requirements of a forest stewardship plan, but its actual logging practices do not meet government promises and public expectations that species at risk will be protected. [5] Red- and blue-listed plant species TimberWest sprays glyphosate on logged cutblocks in the Johnstone Strait portion of TFL 47. This practice ensures the eventual eradication of all red- and blue-listed plant species in those sprayed areas. Because of the extensive nature of logging in TFL 47, there has likely been a high level of local extirpation of red- and blue-listed plant species following TimberWest’s logging and subsequent glyphosate spraying. Yet there is no mention in the FSP about TimberWest’s use of glyphosate spraying. The ecological impacts of glyphosate spraying on red- and blue-listed plant species and its impact on eradicating fire-resistant deciduous trees such as red alder need to be addressed in a revised FSP. [6] Red- and blue-listed plant communities TimberWest states in its proposed FSP that it will “Protect each occurrence of a red-listed plant community during a primary forest activity in accordance with Schedule N”. Unfortunately, the proposed FSP contains no “Schedule N”, so we have no idea what TimberWest is actually proposing to do regarding listed plant communities. Notably, TimberWest’s logging on West Thurlow Island has overlapped all four areas that have been mapped by the CDC as containing red-listed plant communities. TimberWest’s actual logging record in areas containing listed plant communities suggests there is no “Schedule N” used to guide its operations. [7] Species at Risk The proposed FSP acknowledges federally-listed species at risk but provides no mapping of the critical habitat of those species, which includes the Marbled Murrelet. What mapping of critical habitat that does exist shows that TimberWest has logged into designated critical habitat on Hardwicke Island, East and West Thurlow Islands, Sonora Island and the mainland portion of TFL 47. [8] Old forest TimberWest’s proposed FSP, under “Objectives for old forest maintenance and recovery” contains this sentence: “(1) Maintain landscape level biodiversity as follows: (a) for each site series group in the order area, maintain a distribution of forest stand ages that will achieve the old forest representation targets listed in Column A in Schedule G by no later than 2264;” What’s wrong with this? First off, there is no “Schedule G” provided in the FSP. So the public has no idea of what the “targets listed in Column A” are. The only thing we know for sure, is that TimberWest has 240 years to meet that target. Talk about kicking the can down the road. That 240-year planning horizon is the equivalent of the colonial government of Canada establishing in the year 1784 targets for the distribution—by 2024—of British Loyalists flooding into Cape Breton as a result of the American Revolution. That would have been a strange exercise in futility then, and the inclusion of a 240-year planning horizon for old forest in this FSP in the midst of the current biodiversity and climate crises is equally strange. TimberWest and other logging companies have already logged old forest on the islands in Johnstone Strait to below the “high risk” level of 10 percent, a critical level set out in the Gorley-Merkel report A New Future For Old Forests. According to the current mapping of old forest priority deferral areas, the entire area of Hardwicke Island is down to 8 percent old forest, East Thurlow and West Thurlow Islands have both been reduced to 6 percent, and Sonora is down to 4 percent. Gorley and Merkel’s recommendation #6 (page 56) implied an immediate deferral on logging of old forest in the CWHxm2 biogeoclimatic zone variant in the Thurlow Landscape Unit, which covers most of the land in the Johnstone Strait portion of TFL 47. The final FSP should acknowledge the current old forest deferral areas and indicate whether or not they have been approved. TimberWest should state in its forest stewardship plan—just as it has done for the SMZ 19 portion of Quadra Island—that it will not log or degrade any remaining old forest or cut individual old trees on any of the islands in the Johnstone Strait portion of TFL 47. It is known that TimberWest logged old forest (age class 8 near Knox Bay on West Thurlow Island in 2014. It has also done so in other parts of the Johnstone Strait portion of TFL 47, including on Sonora Island. As a first step toward ending logging of old forest in the TFL, TimberWest should release to the public any mapping it had done of old forest in the Johnstone Strait portion of TFL 47, just as it has done for Quadra Island. [9] Climate change and rate of cut The proposed FSP states: “The potential effects of climate change have been considered in the development of this FSP and in particular, the development of the stocking standards.” No other details are provided. There is no other mention of climate change in the document. Climate change is caused mainly by the increasing level of carbon dioxide in Earth’s atmosphere. The logging of old forest and conversion of areas of natural forest into permanent roads and short-rotation plantations results in a dramatic drop in the carbon sequestration capacity of once naturally-forested land in BC. At the same time, the logging industry speeds up the rate at which biogenic carbon is returned to the atmosphere. Climate change is inextricably linked to biodiversity loss, and biodiversity loss is accelerated by the reduction in area and fragmentation of forested habitats. Climate change is resulting in extended periods of drought, longer periods of extreme fire weather and, as a consequence, creates conditions favourable to the formation of larger forest fires. Logging creates fuel conditions (clearcuts, slash piles and young plantations) that make ignition of fires easier and make fires more difficult to initially control. Logging roads provide easy access to firewood in slash piles and therefore create a greater likelihood of human-caused fires. Climate change is also expected to increase the frequency and impact of insect infestations and forest-related diseases, which will negatively impact timber supply and increase the potential for forest fires. This was confirmed by Ministry of Forests scientists in 2009 and there is no credible rationale for continuing to ignore the facts 15 years later. Notably, the proposed forest management plan information package that includes the Johnstone Strait portion of TFL 47 states: “…given the current scientific understanding, it is not yet possible to make reasonable quantitative predictions about the impact of climate change on timber supply. Therefore, the base case will not include specific accounting for climate change projections.” TimberWest’s position is unrealistic and incautious. In 2004, then-Chief Forester Jim Snetsinger predicted (page 34) that timber supply in BC in 2024 would be approximately 73 million cubic metres per year. But the current provincial AAC has actually been lowered to 57 million cubic metres per year. In 2023, even while logging companies complained about a “shortage of fibre”, the total provincial cut was only 36 million cubic metres. This dramatic decline in timber supply and industry viability has lately been attributed by the Ministry of Forests to insect infestations and forest fires—both of which have been made worse by climate change. TimberWest’s unwillingness to reduce the rate of cut in TFL 47 as a precautionary response to the known impacts of climate change is foolish and irresponsible. This is especially true since TimberWest continues to export as raw logs most of what it cuts in TFL 47. TimberWest cannot argue that the need to adjust the cut downward in response to climate change must be balanced against avoiding potential “job loss”. If the company was actually concerned about getting the greatest number of jobs in BC from what is cut in TFL 47, TimberWest would end its heavy reliance on exporting raw logs. [10] Etcetera The problems with TimberWest’s proposed FSP don’t end at [9]. We could go on, but won’t other than to say this: The basic problem with a “forest stewardship plan”, in general, is that it is produced for public review only because that is legally required by the Forest and Range Practices Act. It is easy for a well-funded company like TimberWest to create a plan on paper that appears to cover all the bases and that meets the legal requirements for a forest stewardship plan (after all, the rules were written by the logging industry.), but actually provides little indication of the actual state of the forest in a TFL. That’s because a “forest stewardship plan” is actually a logging plan. There is no legal requirement whatsoever for the licensee to include details about how, over the past 5 years, its practices have degraded ecosystems, exacerbated species loss, contributed to climate change, made the landscape more susceptible to forest fires and reduced forest-related job opportunities. A real forest stewardship plan would require such an acknowledgment of the damage done, and then would inform the public in detail about the measures a logging company would take over the next 5 years to steer away from those unwanted outcomes. Sincerely, David Broadland for the Discovery Islands Forest Stewardship Project Draft forest stewardship plan for the Johnstone Strait portion of TFL 47 TFL 47 Johnstone Strait Forest Stewardship Plan (proposed).pdf
  8. David Broadland
    TimberWest has invited public comment on two planning documents that will establish foundational parameters for what happens in all of Tree Farm Licence 47 over the next 10-15 years. Over 11,000 hectares of Quadra Island is in TFL 47. Part of the TFL lies within the area of BC now regulated by the Great Bear Rainforest Order and that portion of the TFL is getting a brand new forest stewardship plan (FSP). That includes all of TFL 47 except Quadra Island and the Bonanza Lake block. The deadline for public comment on the FSP for the Great Bear Rainforest Order area is March 18. The Quadra and Bonanza blocks are getting an updated management plan, which will set an allowable annual cut for those two blocks. The document, made available for comment until March 23, is an “information package”, not the final draft management plan. The draft management plan will be presented for public comment at a later, as yet undetermined date. Both documents are attached at the bottom of this page. The Discovery Islands Forest Conservation Project will comment on both documents. Since the “information package” for the draft management plan for Quadra Island and Bonanza Lake is just a preliminary step towards providing the public with the full draft management plan for comment, Discovery Islanders may want to focus their attention on the draft forest stewardship plan for that part of the TFL that includes Sonora Island, East and West Thurlow Island and Hardwicke Island. Our project’s comment on the FSP will include information about the high rate of logging that has occurred on those islands, especially since 1997 . The short 40-second video below shows time-lapse satellite imagery of the islands between 1984 and 2020. Watch carefully what happened to West Thurlow Island, which is the island near the centre of the screen. Between 1984 and 2020, almost the entire timber harvesting land base of the island was clearcut, the vast majority of it by TimberWest. The island was hit by two waves of logging by TimberWest, the first starting in 1997 and the second wave striking in 2012. The company’s claim that its logging is “sustainable” obviously does not apply to small, ecologically sensitive islands. The proposed FSP provides no indication that the AAC for this portion of the TFL would be reduced. We must assume that—under the proposed FSP—it would stay the same (388,500 cubic meteres per year). This is far too high and will only result in other islands getting the same treatment as West Thurlow Island. If you comment on the Forest Stewardship Plan, send your comment to: Jennifer Peschke, jennifer.peschke@mosaicforests.com. Please send a copy to the Campbell River District Manager, Lesley Fettes RPF, Lesley.Fettes@gov.bc.ca. If you want to comment on the management plan information package, send it to: communications@mosaicforests.com. If you have any questions about either initiative, contact us. TFL 47 Johnstone Strait Forest Stewardship Plan (proposed).pdf TFL47 information package for Management Plan 5 (proposed).pdf
  9. David Broadland
    In this letter from TimberWest forester Jennifer Peschke in 2022, she provided an age class distribution for an area of 7084 hectares of forest in Special Management Zone 19 (table at top of page 2, total of centre column). Presumably, this is the area in 2022 that TimberWest regards as the timber harvesting land base in SMZ 19. A 2012 estimate of the timber harvesting land base in TFL 47 on Quadra Island was done by Ecora Resources for a timber supply review that informed the Chief Forester’s AAC determination for TFL 47 in 2014. Ecora estimated the THLB in TFL 47 on Quadra Island—including that part of the northern peninsula not in SMZ 19—to be 7140 hectares. Of that, approximately 5500 would have been within SMZ 19. There is, therefore, significant disagreement (~1600 hectares) between Peschke’s estimate of the THLB in SMZ 19 and Ecora’s 2012 estimate. If anything, the area of TFL 47 shrank slightly between 2012 and 2022. Mosaic_Response to FSP comment 2022-03-16 signed copy.pdf
  10. David Broadland
    January 17, 2024 To: Nigel Ross RPF Buttle Lake Resources cc Lesley Fettes RPF, Campbell River District Manager, Ministry of Forests Hi Nigel, 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. Sincerely, David Broadland for the Discovery Islands Forest Conservation Project
  11. David Broadland
    December 29, 2023 To: Nigel Ross RPF, Buttle Lake Resources cc Ministry of Forests’ Campbell River District Manager Lesley Fettes Dear Nigel, I trust this finds you well. I am writing on behalf of the Discovery Islands Forest Conservation Project in response to Buttle Lake Resources’ invitation to the public to submit comments on the draft woodlot plan for Woodlot 1898. Thank you for providing access to your proposed management plan along with the other material you made available. The files provided for the reserves you have mapped for the woodlot allow us to view where your reserves are on satellite imagery and what they consist of on the ground. As you know, the Schedule B lands of your woodlot are located entirely within Special Management Zone 19 (SMZ 19) and it is the ways in which your proposed plan—and past performance—have not or will not abide with the requirements of the Vancouver Island Land Use Plan Higher Level Plan Order for SMZ 19 that I will address below. In my view, the draft woodlot plan does not adhere to Objective A. 1. (b) of the Vancouver Island Land Use Plan Higher Level Plan Order. Note that section 13 (3) of the Forest and Range Practices Act, which exempts woodlots from meeting a number of other government objectives, does not exempt woodlots from meeting this particular objective. As well, there are instances where Buttle Lake Resources has logged to the road along Bold Point Road, and those cuts have contravened both the spirit of SMZ 19 and the visual quality objectives established for this important view corridor leading to Main Lake Provincial Park. We address these two issues in more detail below, as well as a third issue— your proposal to raise the allowable annual cut for this woodlot by 35 percent. (1) A legal requirement for SMZ 19 has not been adhered to by Buttle Lake Resources (or any forest licensees on Quadra Island) Objective A. 1. (b) of the Vancouver Island Land Use Plan Higher Level Plan Order (HPLO) states: “Sustain forest ecosystem structure and function in SMZs, by... retaining within cutblocks, structural forest attributes and elements with important biodiversity functions…” To meet this objective would entail leaving—within all cutblocks—wildlife tree retention areas that would sustain forest ecosystem structure and function. A full discussion of what is necessary to sustain forest ecosystem structure and function can be found here: https://www.for.gov.bc.ca/ftp/hfp/external/!publish/FPC%20archive/old%20web%20site%20contents/fpc/fpcguide/biodiv/chap4.htm Although section 13 (3) of FRPA exempts woodlots from having to meet certain government objectives, this particular objective is not exempted. Buttle Lake Resources is required to meet it. We note that TimberWest’s stated strategy in its forest stewardship plan for TFL 47 for meeting Objective A. 1. (b) in SMZ 19 is: “Retaining wildlife trees as specified in Section 66 of the Forest Planning and Practices Regulation”. Section 66 of the Forest Planning and Practices Regulation states, in part: “If an agreement holder completes harvesting in one or more cutblocks during any 12 month period beginning on April 1 of any calendar year, the holder must ensure that, at the end of that 12 month period, the total area covered by wildlife tree retention areas that relate to the cutblocks is a minimum of 7% of the total area of the cutblocks.” A review of logging since 2010 in Woodlot 1898 shows that objective A. 1. (b) of the HLPO has not been adhered to. The licensee should have left—within cutblocks—a minimum of 7% of the area of the cutblocks it logged as wildlife tree retention areas in order to meet the legal requirements of Objective A. 1. (b) of the VILUP Higher Level Plan Order. I return now to the second point I raised above, that Buttle Lake Resources has not adhered to the visual quality objectives set out for Bold Point Road. (2) Buttle Lake Resources has contravened the “Retention” visual quality objective set out for Bold Point Road The draft woodlot plan acknowledges that Bold Point Road (formerly Village Bay Lake Road) has a “Retention” visual quality restriction attached to it. However, the Ministry of Forests’ RESULTS-Openings database (and a drive along the road) shows that this 100-metre wide corridor has been cut into in four places by Buttle Lake Resources. Buttle Lake Resources has logged into the “Retention” visual quality objective corridor along Bold Point Road in four locations as indicated by the white dots The Ministry of Forests’ guidance on the “Retention” level visual quality objective is “Alteration is difficult to see, small in scale, and natural in appearance.” The four incursions into this corridor by Buttle Lake Resources do not meet this guidance. Since this is the main public gateway to Main Lake Provincial Park, these are serious degradations of the corridor and it will take many years to recover this corridor to the visual quality that was intended by the Vancouver Island Summary Land Use Plan. Woodlot 1898’s promise in its 2013 woodlot plan of “only minimal views of a clearcut forest floor from a passing car” has not been met. Note that one of the primary objectives established for SMZ 19 were “3. Visual qualities, esp. in association with shoreline, major road corridors and high recreation use areas, as well as maintenance of coastal wildlife habitats.” (Page 80, Vancouver Island Summary Land Use Plan) “Timber”, on the other hand, was identified as a “Secondary objective.” This land use planning is still in force and must be respected. Given the incursions that have already occurred, we ask that Buttle Lake Resources not thin or eliminate any of the remaining forest in the corridor. (3) The AAC for this woodlot has been set too high While, strictly speaking, consideration of Buttle Lake Resources’ application through its new draft management plan to raise the allowable annual cut for the woodlot is not part of the draft woodlot plan, I include comments on this matter since the provisions of a woodlot management plan, especially the proposed AAC, have a fundamental bearing on whether or not the stated strategies and objectives of a woodlot plan can, in practice, be accomplished. The Discovery Islands Forest Conservation Project has analyzed the Crown land (Quadra Island) portion of this woodlot and the comments below apply only to that area. Based on your maps of voluntary reserves included in the proposed woodlot plan, The mandatory and voluntary reserves and visual quality objectives that apply to the proposed woodlot plan for Woodlot 1898. The boundaries of the woodlot are marked by dotted red lines. Riparian management zones are solid red and voluntary reserves are marked in transparent yellow. Note the 100-metre-wide “Retention” visual quality reserve along Bold Point Road, approximately one-third the width of which applies to WL 1898. Other areas subject to visual quality objectives are shown as solid yellow or light green. The blue areas are old-growth deferral areas. Areas coloured in darker green indicate riparian management zones where as much as 100 percent of trees may be cut. your estimate of the eventual area of roads and landings, existing visual quality objectives and our own analyses of satellite imagery for rock and inoperable areas, we make the following estimate of the areas of voluntary reserves and necessary exclusions from the overall area of the woodlot and arrive at an estimate of the net timber harvesting land base: 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 Estimated AAC at an average mean annual increment (MAI) of 7.3 cubic metres per hectare: 1710 cubic metres per year. (This is the average MAI used by TimberWest in its last timber supply analysis for all of TFL 47.) As we understand it, the current AAC is set at 2393 cubic metres per year. Buttle Lake Resources is proposing a new AAC of 3232 cubic metres per year, 35 percent higher than the current level. On only 20 years of experience, Buttle Lake Resources is convinced that third-growth trees are growing faster than did the second growth trees it is logging. This reflects a long tradition of the BC logging industry over-estimating its future prospects. In 2004, then BC Chief Forester Jim Snetsinger predicted in The State of British Columbia’s Forests (page 34) that BC’s annual timber supply from Crown land would be about 75 million cubic metres in 2023. The actual cut in 2023 will be closer to 36 million cubic metres, approximately half of Snetsinger’s prediction. The optimism bias at work in the logging industry is legendary and Buttle Lake Resources’ prediction of future growth continues that tradition. Both the ministry and industry have failed for many years to realistically include in their timber supply analyses the expected impacts of global heating on the size and frequency of droughts, forest fires and insect infestations. Note that increasing the AAC for this woodlot would be contrary to the stated recent policy direction change of the Ministry of Forests, as outlined to Forests Minister Bruce Ralston by Premier David Eby in his December 2022 letter of expectations. At that time Eby directed Ralston to “Accelerate the transition of our forestry sector from high-volume to high value production, with fewer log exports, more innovative wood products manufactured locally, and support to mills to transition to second and third growth trees.” Increasing the AAC of this woodlot would result in younger, less valuable trees being logged instead of allowing them to grow older, contain a lower percentage of sapwood, be more free of knots and be tighter grained—wood that is more able to contribute to the transition to higher value that Premier Eby has directed the ministry to accelerate. Moreover, BC has committed to protect 30 percent of land and water by 2030. In 2023, only 18 percent of the land area of Quadra Island has any form of conservation status. The best use of the area occupied by this woodlot, adjacent as it is to a beloved provincial park and Village Bay, is not as a site for more intense industrial development but as a more protected area, possibly as an Indigenous protected and conserved area. For all these reasons the Discovery Islands Forest Conservation Project strenuously objects to an increase in the AAC for Woodlot 1898. Thank you for taking the time to read this submission. I look forward to your response to the issues raised above. Sincerely, David Broadland for the Discovery Islands Forest Conservation Project
  12. David Broadland
    Hi Debbie. Thanks for registering, and for your question. As this moment I don't have an answer for you. Most of the issues we have raised about these two plans have also been raised in our April complaint to the Forest Practices Board regarding WL 2031, 2032 and TFL 47. Until an investigation report has been issued by that body, these issues remain unresolved.
  13. David Broadland
    To: Theresa Cleroux, Planning Forester, BC Timber Sales Hi Theresa, The Discovery Islands Forest Conservation Project strongly objects to your proposed plans on the basis that the cutblocks are far too large for a small and ecologically sensitive island like Maurelle Island. The Discovery Islands are one of BC’s hottest biodiversity hotspots and your plans don’t seem to regard Maurelle Island as being any different than a pine plantation in the middle of the Chilcotin Plateau. The cutblocks you are proposing will greatly increase the cumulative area that has been logged along the western side of Maurelle since 2013, and would produce three large conglomerations of clearcuts/young plantations that will not support existing native species of plants and animals and will greatly increase fire hazard and the risk of a large fire. Below is a summary of the cumulative area of each of those conglomerations: Northern area where you are proposing cutblocks 3299 and 3300: 90.9 hectares Middle area where you are proposing cutblock 3298: 76.2 hectares Southern area where you are proposing cutblocks 3301 and 3302: 83.8 hectares The Discovery Islands Forest Conservation Project recommends that your approach on Maurelle should be similar to Quadra Island where cutblocks can be no larger than 5 hectares. As well, BCTS should allow 30 years between the logging of one cutblock and the cutting of an area adjacent to that cutblock. A mosaic of greater areas of old and mature forest and smaller areas of logging slash and young plantations will mitigate the ease with which a fire is ignited in a cutblock or plantation and reduce the rate of spread of a fire, which, as you know, is higher in clearcuts and plantations. This is already a critical issue since climate change is increasing the length and intensity of droughts and creating drier and windier fire weather. Also, your proposed plan does not show the location of wildlife tree retention areas although the [online] Forest Operations Map interface allows for that. Once you have reduced the size of your cutblocks, please resubmit your proposed plan indicating where wildlife tree retention areas would be located. It would be best if you also include the location of existing wildlife tree retentions areas in your new plan. Finally, does BCTS have the equivalent of a management plan for Maurelle Island that shows how an allowable annual cut has been determined, or the volume BCTS believes it can log on Maurelle Island over a given planning period? If so, could you kindly forward that to me, or a link to where I can find it? Sincerely, David Broadland
  14. David Broadland
    More information about "2023-11 Why do 22 tree farm licences in BC—including TimberWest's TFL 47—have no legal old-growth management areas?"
    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
  15. David Broadland
    More information about "Ralph Point Grove not threatened after all"
    THE COVER STORY in the September 15, 2023 Discovery Islander implied that a large Western red cedar in a grove at Ralph Point on Quadra Island was in some way threatened, apparently by logging. In conversations before the story appeared, it emerged that flagging tape near the grove had been interpreted as indicating that logging was imminent near the grove in Woodlot 1970, which is operated by Cape Mudge Forestry. It turns out, though, that it was old flagging tape and no logging is being contemplated near the grove. Forester Gary Gallinger, who works as a consultant with Cape Mudge Forestry, stated in an email: “The area immediately above Ralph Point, as identified in your link, is not being harvested. Some fellow staff met with another Quadra resident yesterday (Monday September 19) who also had concerns that this area was planned for harvest. It was during this discussion that the resident, who is a retired faller, mentioned some old road Right-of-Way ribbon and some scattered Falling boundary ribbon is within the area you identified. We will be removing those old ribbons. There was a previous consulting firm that used to work on the [Cape Mudge] Woodlots, and we understand that this consultant had done some preliminary field engineering in this area and had originally proposed a road location within the area of concern. Once those ribbons are removed, I trust that the concerns brought up regarding Ralph Point will go away.” Gallinger added, “Be aware that the We Wai Kai Nation has done an archaeological assessment of the area around Ralph Point and it has been identified as an area of high potential. That’s why the road and cutblock are at their present locations.” The DI article published the GPS coordinates of the grove. Since the area has high First Nations heritage potential, the Discovery Islands Forest Conservation Project encourages people not to visit the site. Instead, go to this page and visit the grove online. The largest tree in the grove, featured on the cover of the Discovery Islander
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