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.

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.

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?

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.

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.

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

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

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

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

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

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

The Wilderness Committee has learned that TimberWest is spraying glyphosate this summer on Sonora Island, East and West Thurlow Island, Hardwicke Island and other parts of TFL 47. Most of the cutblocks being sprayed on the Discovery Islands are described by TimberWest as being “no limitations” spraying. No spraying is planned for Quadra Island or those islands not in TFL 47. A map of the cutblocks TimberWest intends to spray can be viewed at the bottom of this page. Read more about glyphosate spraying at Stop the Spray BC. Below is the full release about the spraying from the Wilderness Committee: Toxic glyphosate to be sprayed over Ma’amtagila Nation territory In areas around Johnstone Strait hit hard by past logging, herbicide spraying on nearly 10,000 hectares of recovering forest further threatens biodiversity BC forest management plans show scheduled spraying of glyphosate, a herbicide that kills plants, fungi and bacteria, on forests throughout the territory of the Ma’amtagila and neighbouring Nations. In total, 9,840 hectares of land — equivalent to the area of 24 Stanley Parks — are scheduled to be sprayed this summer. The spraying will happen mostly on Ma’amtagila territory including areas adjacent to Johnstone Strait, spanning from Sonora Island, northwest to Cracroft Island and north to Heydon Bay and Glendale Cove. Glyphosate is a probable carcinogen and has been shown to impact species at risk, bees and amphibians. In the logging industry, it’s used by companies to help grow cash-crop commercial species and kill non-profitable ones. Often these non-commercially profitable species are native plants important for wildlife, traditional food, medicine and ecosystem health. “When I think about the spraying it pains me to know that all of that traditional medicine is being destroyed. This practice is banned in Quebec, yet we’re still spraying it here in BC. There must be transparency about the true impacts of glyphosate because we’re the ones that suffer when we’re not consulted in good faith as First Nations people,” said Gigame Mak’wala, Chief Rande Cook of Ma’amtagila First Nation. “It’s time to stop stealing from ecosystems and start healing them.” A “notice of intent to treat plan” was shared by a logging company with a member of an impacted First Nation community after they asked the government for the plans. This plan showed 500 cutblocks, covering almost 10,000 hectares, were set to be sprayed. Notice of intent to treat plans show the exact locations where spraying will occur are made yearly. But these maps are only available to the public or First Nation communities if companies or the government decide to share them, but they are not required to. Pest management plans are publically available and are only issued every five years. These plans do not show the areas to be sprayed, they show the larger boundary of the area. Because of this spraying often happens in areas without public knowledge. The only requirement a company must do to notify of the specific spraying is to put up a sign near the area after it was sprayed. “This is a public health risk. Glyphosate is a probable carcinogen and biodiversity killer. Communities deserve to know at the very least exactly where spraying is occurring and when,” said Charlotte Dawe, conservation and policy campaigner for Wilderness Committee. “There is no avenue within the Integrated Pest Management Act that automatically allows a First Nation community or public member access to spray plans, they’re only revealed if the government or industry voluntarily decide to hand them over. That’s a disgrace.” Consultation on glyphosate spray plans occurs once every five years when the pest management plan is created. If the public misses that consultation window, the next five years of spraying can happen under secrecy and without consideration and input on issues regarding community health, wildlife and wilderness concerns. However, even if the public does give input, logging companies have no legal obligation to consider any opposition nor do they need to agree to provide any annual notifications. “Government has said that the traditional users cannot build roads, cannot build trails but industry is in there doing all those things, even through our trap line,” said Gigame Pudlidagame, Chief Brian Wadhams of Ma’amtagila First Nation. “Industry can build roads, rip down trees, and poison the land and the government turns a blind eye but when it comes to standards for First Nation users they’re strictly enforced.” Earlier this year, the Wilderness Committee, Awi’nakola Foundation and members of Ma’amtagila Nation conducted site visits to some of the areas about to be sprayed to document the plants and wildlife. The groups documented diverse wildlife within the spray boundaries. Many documented plant species within the spray boundaries are of significance for traditional food and medicinal purposes, such as elderberry, salmonberry, huckleberry, cherry and thimbleberry. Also within the landscape set to be sprayed were species essential to ecosystem recovery, including alder and fungi. When glyphosate is used, these species are harmed or killed, depending on concentration. “The area they are spraying are traditional gathering lands, going back past my grandfather, past traplines and pre-European contact,” said Wadhams. “I grew up on these lands and they hold irreplaceable value when it comes to traditional medicines, foods, clam digging, prawn fishing and hunting, essential to family and community health.” The groups are calling for a ban on glyphosate in forestry uses, and for the government to update their outdated pest management plan process so all mapping is publicly available and consultation and consent seeking occurs yearly. The government should align their pest management plan with the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP) to require free prior and informed consent so other ecosystem values are considered over logging profits. Chiefs Cook and Wadhams are requesting an emergency meeting for the territories around Call Inlet and are demanding the province and companies seek permission prior to any further spraying or logging activities to uphold UNDRIP, trapline rights and respect the inherent rights of Kwakwaka’wakw people to safely access harvesting grounds. They are requesting a consistent and transparent approach throughout all of Kwakwaka’wakw territory. In the map below, cutblocks TimberWest plans to spray are numbered and outlined with a purple boundary and purple diagonal hatching (click to enlarge image).

IN HIS 2011 WOODLOT PLAN, the licensee stated that wildlife trees could be removed from wildlife tree retention areas to provide “access to adjacent stands.” But provincial government mapping of existing logging roads shows that there were existing alternative routes (orange dashed lines in image below) that would have avoided the two wildlife tree reserves. These roads were built circa 1983. The licensee has stated that “adverse grades” on these routes made it necessary to build new roads through the two wildlife tree retention areas at issue. The route indicated by yellow dots has been added by the Discovery Islands Forest Conservation Project and that route does not involve “adverse grades”. In fact, a nearby route had been used for logging in 1983. This small amount of additional road building should have sufficed to meet the licensee’s need for access to forest for logging.

THE IMAGES in the first section below are representative of the forest type and trees growing in the two wildlife tree retention areas west of Darkwater Lake that were established by the original 2011 woodlot plan for WL 2032. In 2018 and 2019 the licensee built two roads through these areas. An “amendment” to the woodlot plan eliminated these two wildlife tree retention areas and replaced them with an area of forest on the southwest flank of Darkwater Mountain. Photographs of the latter are in the second section below. The Discovery Islands Forest Conservation Project contends that the amendment decreased the nature and quality of wildlife trees and the wildlife tree retention areas and, because of those circumstances, such an amendment required approval by the Ministry of Forests, according to the Woodlot Planning and Practices Regulation. The Ministry of Forests has been unable to provide any record that shows that such approval for this amendment was sought by the licensee or granted by the ministry. 1. Individual trees and forest type in the two original wildlife tree retention areas west of Darkwater Lake The two previously approved wildlife tree retention areas (outlined in green below) are located southwest of Darkwater Lake on the slope down to Discovery Passage: The short video below shows an area of Douglas fir-leading old forest that includes the smaller, eastern reserve shown in the image above. This 16.5-hectare area of old forest—which can be seen to the east of the new road in the image immediately above—would make a much better biodiversity reserve than the replacement area on Darkwater Mountain chosen by the licensee. Read more about this area of rare primary forest here. Below are photographs of trees and the forest types in the previously approved wildlife tree retention areas. The road building resulted in the removal of old trees in the reserves. This is the log that came off the stump above. A ring count showed it was at least 380 years old when cut. The lower reserve had been selectively logged in the past. 2. Trees and forest in the proposed wildlife tree retention area on the southwest flank of Darkwater Mountain The proposed wildlife tree retention area (outlined in green below) is located on the southwest flank of Darkwater Mountain: The short video below provides an overview of the area of lodgepole-pine-leading forest which the woodlot licensee intended—through an amendment to its woodlot plan—to replace two previously approved areas of Douglas-fir-leading old forest as part of the woodlot’s biodiversity conservation strategy. Below are photographs of trees and the forest types of the proposed replacement wildlife tree retention area. The replacement area contains scattered old Douglas fir vets at the end nearest to Darkwater Lake. Not far from the lake the forest becomes a mix of hemlock and lodgepole pine. Most of the area of the proposed reserve is covered by forest with thin, dry soils and bare rock supporting a sparse growth of lodgepole pine, western hemlock and Douglas fir. Near the top of the reserve the extreme dryness of the proposed reserve is indicated by the occurrence of Hairy Manzanita.

IN JULY AND AUGUST 2019, a contractor working for the license-holder of Woodlot 2031 cut old forest on a 3-hectare cutblock on the north side of Hummingbird Lake. In April 2023, the Discovery Islands Forest Conservation Project submitted a complaint about the logging to the BC Forest Practices Board. We initially estimated at least 33 trees with ages greater than 250 years had been cut. As part of the evidence that these were healthy, old-growth trees that were growing at a density great enough to qualify as a stand of “old forest”, we photographed and measured the stump of each felled tree (not including snags) that had a diameter greater than 100 centimetres (3.3 feet). According to the Guidelines to Support Implementation of the Great Bear Rainforest Order with Respect to Old Forest and Listed Plant Communities (which is applicable, for example, on Sonora Island, about 9 kilometres north of Hummingbird Lake) a density of 10 veteran overstorey trees per hectare is enough to give the maximum score of 3.0 points under the Forest Attribute Score methodolgy used to determine whether a stand of old forest qualifies for conservation. In the 3-hectare cutblock at Hummingbird lake, we found: • 17 veteran overstorey trees had been retained by the licensee • 38 stumps with diameters greater than 3.3 feet • at least one stump with a diameter greater than 3.3 feet had been buried under a burn pile (not measured) • an estimated 4 such stumps had been buried under the roads in the cutblock, which cover approximately 10 percent of the area of the cutblock Based on those numbers, there had been—before roadbuilding and logging occurred—approximately 60 old-growth Douglas firs and cedars growing in the area that was logged. The density of veteran overstorey trees was, therefore, approximately 20 stems per hectare, twice as high as necessary for the stand to receive the highest points possible under the Forest Attribute Score. The stand had also contained many standing snags and abundant large downed trees on the forest floor, both necessary attributes to qualify the stand as “old forest” suitable for conservation status. Below are photographs of those 38 stumps within the 3-hectare cutblock that had diameters greater than 3.3 feet and whose cut surfaces were visible. Of the 38 stumps, rot was visible in 6 cases: 1. Douglas fir stump, diameter 5.0 feet, tree was sound 2. Douglas fir stump, diameter 3.9 feet, tree had some rot at core 3. Douglas fir stump, diameter 3.7 feet, tree was sound 4. Douglas fir stump, diameter 4.4 feet, tree was sound 5. Douglas fir stump, diameter 5.2 feet, tree was sound 6. Douglas fir stump, diameter 4.6 feet, tree was sound 7. Douglas fir stump, diameter 5.0 feet, tree was sound 8. Douglas fir stump, diameter 4.0 feet, tree was sound 9. Douglas fir stump, diameter 5.7 feet, tree was sound 10. Douglas fir stump, diameter 5.7 feet, tree was sound 11. Douglas fir stump, diameter 5.8 feet, tree was sound 12. Douglas fir stump, diameter 4.7 feet, tree was sound 13. Douglas fir stump, diameter 4.8 feet, tree was sound 14. Douglas fir stump, diameter 5.3 feet, tree had some rot at core 15. Douglas fir stump, diameter 4.1 feet, tree was sound 16. Douglas fir stump, diameter 5.2 feet, tree was sound 17. Douglas fir stump, diameter 4.6 feet, tree was sound 18. Douglas fir stump, diameter 5.4 feet, tree was sound 19. Douglas fir stump, diameter 5.2 feet, tree was sound 20. Douglas fir stump, diameter 4.7 feet, tree was sound 21. Douglas fir stump, diameter 4.2 feet, tree was sound 22. Douglas fir stump, diameter 4.7 feet, tree was sound 23. Douglas fir stump, diameter 4.7 feet, tree was sound 24. Douglas fir stump, diameter 4.9 feet, small area of rot at core 25. Douglas fir stump, diameter 3.6 feet, tree was sound 26. Douglas fir stump, diameter 3.9 feet, tree was sound 27. Douglas fir stump, diameter 4.4 feet, tree was sound 28. Douglas fir stump, diameter 4.2 feet, tree had rot at core and out to one side 29. Douglas fir stump, diameter 4.2 feet, tree had some rot at core 30. Douglas fir stump, diameter 4.5 feet, tree was sound 31. Red cedar stump, diameter 6.3 feet, tree had rot at core 32. Douglas fir stump, diameter 3.9 feet, this appears to have been a standing snag 33. Douglas fir stump, diameter 5.1 feet, tree was sound 34. Douglas fir stump, diameter 3.9 feet, tree was sound 35. Douglas fir stump, diameter 3.0 feet, tree was sound 36. Red cedar stump, diameter 6.1 feet, tree was sound 37. Douglas fir stump, diameter 4.4 feet, tree was sound 38. Douglas fir stump, diameter 4.5 feet, tree was sound

May 12, 2023 I bring the following issues to the attention of North Island Natural Resource District Manager Lesley Fettes, copied to the licensee and the Forest Practices Board. Please include these comments in any record of public comments included in the proposed Woodlot Plan. [1] The woodlot’s allowable annual cut is based on a flawed timber supply analysis. The foundational management plan, which this tenure has been operating under since July 13, 2011, relies on a 2007 timber supply analysis performed for the Ministry of Forests by a private consultant, Econ Consulting. Econ referenced the 2004 Strathcona TSA timber supply review as the basis for some of the assumptions made in its analysis. Our own analysis shows that Econ overestimated the timber harvesting land base for this woodlot. The allowable annual cut (AAC) that was calculated for the woodlot is, therefore, too high. Econ’s map, included with its analysis, shows that other than some reduction for areas of bare rock that occur on steep terrain, it did not reduce the area available for logging due to areas made inoperable by steep slopes (>40 percent in several areas) and cliffs. These are found on the north side of the valley that runs from the north end of Clear Lake northeast to Okisollo Channel, the east side of Wolf Mountain, the east side of Wolf Lake, and on the north side of Mount Yeatman. Econ also failed to remove areas of lodgepole pine from the timber harvesting land base. Our review of the the Ministry of Forests’ Harvest Billing System record of logging on Quadra Island shows there is no commercial market for lodgepole pine. Moreover, sites on which lodgepole pine grow on Quadra Island have generally thin, poor soils where—if logging did occur—trees would not grow back in a reasonable period of time. As was done in the timber supply review for the Strathcona Timber Supply Area (which Econ referenced in its analysis), Econ should have excluded 100 percent of the areas dominated by lodgepole pine from the timber harvesting land base. Below we itemize our determination of what we believe is a more realistic timber harvesting land base that should be used to calculate the AAC. Note that we have not excluded any area for wildlife tree retention areas (WTRAs), which, as you know, are legally required to cover 8 percent of the woodlot area. That 8 percent would be covered by the legally required riparian retention areas, the legally required visual quality retention area on Okisollo Channel, inoperable areas, low productivity areas, swamp and areas of lodgepole pine. We note that in choosing discretionary areas to set aside as WTRAs, the licensee has left unprotected many areas of old forest that aren’t in a legally required riparian zone. Instead, the licensee has chosen areas—including stands of lodgepole pine—at the tops of mountains that would, in any case, be difficult and costly to build roads to and log. The licensee’s discretionary WTRAs seem designed to have the least positive impact on biodiversity conservation and the least negative impact on AAC. Here is our calculation of the timber harvesting land base: Total area of Woodlot 2031 = 715 hectares Non-forested area (lakes, wetlands) = 38.3 ha Bare rock = 7.4 ha Existing roads, trails and landings = 30.3 ha Total Forest Management Land Base = 639 ha Reductions Inoperable areas = 19.5 ha Problem forest types (Lodgepole pine) = 91.9 ha Low productivity sites (not including Lodgepole Pine) = 13.6 ha Lakeshore riparian areas = 6.4 ha Stream riparian areas = 3.3 ha Swamp areas = 1.5 ha Area where VQO is “retention” = 4.5 ha Total of reductions to the Forest Management Land Base: 140.7 ha Timber Harvesting Land Base (Forest Management Land Base minus reductions) = 498.3 ha. Any areas where two or more reduction types overlap have been netted down. See the map and spreadsheet on this page for more details on the reductions that should have been made. A timber harvesting land base of 498.3 hectares is 7 percent less than Econ estimated. We estimate that a more appropriate AAC would be at least 7 percent lower than the AAC used since 2011. Note that the above analysis of the timber harvesting land base does not include any areas of old forest in the woodlot except those that happen to occur in lakeshore riparian reserves. We will come back to the old forest issue later in this submission. [2] The tenure holder has been logging at a rate much greater than the inflated AAC set out in the management plan. Records from the Ministry of Forests’ Harvest Billing System show that over the 12 years from the beginning of 2011 to the end of 2022, the licensee’s cut amounted to 42,426.86 cubic metres. So over those 12 years, the cut averaged 3536 cubic metres per year. The allowable annual cut committed to by the licensee in its Woodlot Plan was 2890 cubic metres per year. The average annual cut, then, exceeded the allowable annual cut by 646 cubic metres per year. In other words, it was 22.3 percent higher than the AAC to which the ministry and the licensee agreed. It would take 2.7 years of no logging (starting in 2023) for the licensee to get back to the rate of cut it agreed to in 2011. Combined with Econ’s 7 percent over-estimation of the area available for logging as outlined in [1] above, this has resulted in an over-cut of approximately 30 percent per year over 12 years. Logging in this woodlot should be halted until the cut control is back on track and a more reliable timber supply review is conducted, including the use of drone technology and ground-truthing for identifying old forest and other areas of the woodlot that should be excluded from the timber harvesting land base. [3] This license is subject to an active complaint to the Forest Practices Board regarding logging of old forest in 2019. Until this complaint has been investigated by the Forest Practices Board, and its findings made public, review of this licence’s proposed woodlot plan should be postponed. The licensee cut 3 hectares of old forest in 2019, which we believe was contrary to written promises made in the licensee’s legally binding 2011 Woodlot Plan. The licensee’s plan had stipulated that even “scattered small patches of existing old forest” not specifically identified in the Woodlot Plan would be retained. We refer you to the complaint made to the Forest Practices Board for more details about the complaint. We note here that an earlier complaint related to this same logging was made to the Forest Practices Board. The Board found, based on one or more interviews with the licensee, that only 10 old trees had been cut and that they had been cut in order to build a road or for safety reasons. The licensee apparently failed to inform Board investigators that just down the road, it had, in fact, logged at least 35 old-growth trees from a 3-hectare cutblock (19-02). In July 2022, the licensee refused to answer our questions about how many trees greater than 250 years of age had been logged in cutblock 19-02. In the Spring 2022 edition of The Woodland Almanac, the licensee wrote: “Here is a photo of myself with a few of the 17 old growth Fd vets we retained in a 3 ha cut block on our WL. These Fd vets survived a 1920’s wildfire and were scattered in a second growth stand. We retained a majority of the scattered Fd vets because it’s the right thing to do. They’re beautiful.” Cutblock 19-02 had, in fact, contained at least 55 old-growth fir and cedar vets before roadbuilding and logging occurred. The licensee did not tell the truth to the readers of The Woodland Almanac when she claimed “We retained a majority of the scattered Fd vets…” In the context of the licensee’s application to the ministry to amend and renew its plan, we would point out that the licensee chose not to abide by its 2011 plan when it cut old forest in cutblock 19-02, and then, when that was revealed, attempted to hide the fact that it had logged old forest. We therefore question whether the licensee can be trusted to abide by the proposed woodlot plan—or any future woodlot plan. [4] The language in the draft proposed woodlot plan regarding conservation of old forest is unclear. A 2021 Forest Practices Board investigation into logging of old trees determined that in its 2011 Woodlot Plan the licensee had committed to retain all existing old forest in the woodlot. This is our interpretation of the 2011 plan as well. However, the proposed plan has been reworded in such a way that it appears that old forest could now be logged. The change in language in the proposed Woodlot Plan, when compared with the language in the original 2011 Woodlot Plan, suggests the licensee does not acknowledge the need to conserve all remaining old forest on the woodlot and/or may not have a reliable understanding of how much and where old forest remains on the woodlot. The licensee now proposes to commit to “maintaining or creating stand structures and forest attributes associated with mature and old forests, subject to the targets in the” Vancouver Island Land Use Plan Higher Level Plan Order. The “target” for old forest in Special Management Zone 19 (SMZ 19) is “greater than 9 percent” of the timber harvesting land base in the woodlot, which, as noted above, is approximately 498.3 hectares. That “9 percent” target would equate to 45 hectares of old forest. The Discovery Islands Forest Conservation Project has conducted a drone survey of woodlot 2031 and we estimate there are approximately 75 hectares of old forest, or forest containing significant concentrations of old trees, on the woodlot, that need to be conserved. Thus the licensee’s commitment—if our interpretation of it is correct—would allow it to log approximately 30 hectares of old forest. This is an issue that the Ministry of Forests must resolve in favour of protecting the remaining old forest on Quadra Island. The provincial Old Growth Strategic Review Panel recommended a moratorium on logging of old forest in any landscape unit in which old forest constituted less than 10 percent of the forested area of the landscape unit. On Quadra Island, it has fallen to approximately 4 percent, creating a high risk of biodiversity loss. The ministry created this problem, following completion of the Vancouver Island Land Use Plan, by failing to create legal old growth management areas on Quadra Island before it established 11 woodlot licences in SMZ 19. Now the ministry needs to find a solution that does not involve further logging of old forest. The licensee’s stated commitment to meet the seral stage distribution targets for SMZ 19 is at odds with the licensee’s description of its proposed “Wildlife Tree Retention Strategy” which states: “Biodiversity Reserves (Brs): retaining the existing old growth stands (>250 years, as per the Timber Supply Analysis Report (2007) in the W2031 Management Plan)…” This passage seems to imply that the licensee intends to conserve only existing old growth stands that were identified in the flawed 2007 timber supply analysis. That analysis, using an outdated methodology, identified only 15.1 hectares of old forest. That estimate does not come close to reflecting the reality on the ground. The licensee’s proposed approach does not meet the need to conserve all existing old forest—whether the licensee is aware of its existence or not. We are happy to share our mapping of old forest with the licensee. (See the map near the bottom of this page.) [5] The proposed plan appears to contain conflicting commitments. The licensee’s apparent new commitment to meet the seral stage distribution targets established for Special Management Zone 19 is incompatible with the licensee’s stated intention (recently confirmed in an email) of logging at a rate of 2890 cubic metres per year. As noted above, on page 5 of the proposed Woodlot Plan, the licensee states, “The Order indicates the following Resource Management Zone (RMZ) Objectives for SMZ 19, and the woodlot licensee commits to the strategies indicated: Objective 1: Sustain forest ecosystem structure and function by: maintaining or creating stand structures and forest attributes associated with mature and old forests, subject to the targets of the Order;” Our interpretation of this section of the Woodlot Plan is that the licensee is agreeing to manage the woodlot subject to the targets of the Vancouver Island Land Use Plan’s Higher Level Plan Order (HLPO) for Special Management Zone 19. Those targets are “greater than 9 percent” of the area of the woodlot is to be covered in old forest and “greater than 25 percent” is to be covered in mature forest. Those are the targets implied by the HLPO. This is not possible given the stated allowable annual cut of 2890 cubic metres. By definition, “mature” implies forest containing trees greater than 80 years old. “Old” implies forest containing trees older than 250 years of age. Let’s leave aside the apparent commitment to maintain at least 25 percent of the woodlot as “mature” forest cover and look at just the impact the old forest target would have on the licensee’s AAC. Above in [1], we estimated the timber harvesting land base to be 498.3 hectares. The areal extent of old forest that is needed to meet the target for SMZ 19 (>9 percent of THLB) is 44.8 hectares. We estimate that 3.5 hectares of old forest would be included by the riparian reserves around Hummingbird Lake and Wolf Lake. That would reduce the additional area of old forest needed to meet the old forest target for SMZ 19 to 41.3 ha. That, in turn, would reduce the THLB to 457 hectares. Given the mean annual increment used by the woodlot’s management plan (5.07 cubic metres/hectare/year), we calculate that the AAC for the woodlot under the commitments outlined above would be approximately 2300 cubic metres per year. But the licensee has said it also intends to apply an AAC of 2890 cubic metres/year. That level of cut is clearly incompatible with conservation of even 41.3 hectares of additional old forest, let alone the full 75 hectares of existing old forest. [6] The licensee has failed to properly assess and characterize forest types in the woodlot and can’t be relied on to identify old forest. An FOI for communications between the licensee and the Ministry of Forests showed that in 2019 the licensee mischaracterized the forest type in proposed cutblock 19-02 when applying for approval to commence logging in the cutblock. In a February 2019 email to the Ministry of Forests’ approving authority, the licensee stated that the forest in proposed cutblock 19-02 “has a vigorous second-growth HwFd(Cw) overstory with a sparse understory. There are scattered Fd and Cw vets in the block, as well as evidence of fire…” In fact, the 3.0-hectare stand had approximately 55 healthy old-growth Douglas fir and redcedar veterans in it before roadbuilding and logging occurred. The oldest live trees were in the neighbourhood of 400 years of age. The stand contained numerous standing snags and abundant woody debris on the forest floor. The area met the requirements for “old forest” as designated by the Forest Attribute Score (FAS) for the Great Bear Rainforest Order. The density of veteran overstory trees was about 18 stems per hectare. The density of snags was 5 or more per hectare. There was moderate vertical canopy differentiation and an abundance of course woody debris on the forest floor. The area had been lightly burned, likely in 1925. This combination of attributes would have given the stand a score of at least 6 on the FAS scale, and designation as “old forest”. The licensee’s failure to properly and professionally assess the true nature of the plant community in cutblock 19-02 should disqualify the licensee from seeking further cutblock approvals without first obtaining a confirmation of forest type from an independent registered professional forester or a forester from the ministry’s district office. [7] The licensee has not followed through with commitments made in its first woodlot plan and therefore can’t be trusted to do so in the future. In its draft 2011 Woodlot Plan, the licensee had stated that harvesting would be modified—meaning not clearcut—in “Areas adjacent to park boundaries, to maintain the integrity of the boundaries. Appropriate methods will be decided concurrent with development, and may include a 25m modified harvest buffer where practical”. In a public comment about the draft plan, a Quadra Island resident expressed concern that “park boundaries are protected from blowdown.” In a written response to that comment, the licensee stated: “Decisions regarding harvesting adjacent to parks will be made in discussion with BC Parks staff.” The records released under an FOI for the communications between the licensee and BC Parks for the years 2014 to 2020 shows that the licensee never undertook such discussions. The licensee did contact BC Parks in 2014 regarding the advisability of installing a gate to block public access to the area. But the records provided by BC Parks don’t include a single instance where the licensee, over those seven years, engaged in “discussion with BC Parks staff” regarding the licensee’s plans to clearcut six blocks right to the boundaries of Octopus Islands Provincial Park and Small Inlet Provincial Park. Moreover, the licensee apparently didn’t deem it to be “practical” to include the hinted-at “25m modified harvest buffer” in any of those six cutblocks. Again, these circumstances speak to the issue of whether the licensee can be trusted to follow through with the commitments it makes. [8] The 60-year rotation period adapted by the licensee will result in a significant loss in the carbon sequestration capacity of the forest in the woodlot area. The management plan, which is foundational to the Woodlot Plan, states that the AAC is based on a 60-year rotation period. Econ estimated the average site index for the woodlot area at 20 (metres). According to Ministry of Forests’ growth and yield curves for Douglas fir growing on land with a site index of 20, such a short rotation period would result in an approximately 90-percent loss in the carbon sequestration capacity of the forested area of Woodlot 2031 compared with a more natural rotation period of 300 years. Since Canada has declared a climate emergency, it seems foolish for the provincial government to allow such a predictable loss of the ability of BC forests to mitigate climate instability and global heating. Five 60-year rotations on Woodlot 2031 (light green)—compared with a single rotation period of 300 years (dark green)—would result in 90 percent less overall carbon sequestration over a 300-year period. [9] There is no economic justification for allowing a continued over-cut in the woodlot. Over the past 10 years, this woodlot has provided, on average, the equivalent of less than one full-time equivalent job per year. Over that same period, the average stumpage received by the Province from this tenure has been $1.84 per cubic metre, while the average stumpage paid in BC has been $18.33. Most of the trees cut on Quadra Island have been exported as raw logs, which provide no milling or value-added jobs. There is no justifiable socio-economic rationale for allowing this tenure to overcut its ministry-approved AAC by 22.3 percent over that time. [10] This area should be considered for inclusion in the province’s uplift of protected area to 30 percent by 2030. Current official provincial government policy is to expand the level of protected area in BC to 30 percent by 2030, a shorter timeframe than is being considered for the renewal period for this licence. Currently, only about 18 percent of Quadra Island is protected by any form of conservation measure. There are no legal OGMAs anywhere on the island. Since this tenure lies between 3 different provincial parks, contains 2 significant lakes and has, on a percentage basis, the greatest concentration of old forest in the Crown forested area of Quadra Island, it is one of the most likely areas to be involved in a future increase of protected land on the island. Continued logging in this area—especially at the inflated rate that has occurred under the current licensee—will only increase the inevitable restoration costs. The cost of buying back the license now, including the small amount of stumpage that would be forfeited by the Province over the next 10 years, would be much less than the cost of required restoration work and buying back the license in 2030. [11] Recommendations For all of the reasons stated above, we recommend that: 1. Approval of the proposed plan as written not be granted. 2. The Campbell River district office not grant any cutting permits for this licence through 2023, 2024 and 2025 so as to, at the very least, get the licensee’s agreed upon allowable annual cut under control. 3. In the meantime a more reliable timber supply review for the woodlot should be conducted, and 4. That such a review also undertakes to determine, accurately, where there is existing old forest on the woodlot, and 5. That the potential for this area to be added to BC’s protected areas system by 2030 be evaluated by the pertinent BC ministries. Sincerely, David Broadland, on behalf of the Discovery Islands Forest Conservation Project