David Broadland

January 29

January 17, 2024

To: Nigel Ross RPF

Buttle Lake Resources

cc Lesley Fettes RPF, Campbell River District Manager, Ministry of Forests

Hi Nigel,

I hope this finds you well. Thank you for your response to the Discovery Islands Forest Conservation Project’s submission regarding your draft woodlot plan. I appreciate the time and thought you put into your response.

I would like to address some of the points you have made.

First, regarding Objective A. 1. (b) of the Vancouver Island Land Use Plan Higher Level Plan Order for Special Management Zone 19.

Thanks for the list of the efforts you have made “to preserve and enhance biodiversity” on your woodlot. However, I believe your interpretation of the full meaning of this objective falls short of what was intended. In my submission I provided you with a link to the material from the Biodiversity Guidebook that describes the full ramifications of “Sustain forest ecosystem structure and function in SMZs, by... retaining within cutblocks, structural forest attributes and elements with important biodiversity functions…”

I do not believe that the order applies simply to “snags, wildlife trees and downed logs”.

Given the full explanation of “structural forest attributes and elements” in the Guidebook, it is clear to me that the intention of the order was to ensure that, within cutblocks, all of the recommendations would be adhered to, not just retention of course woody debris and the occasional dead snag or live veteran. This would have included leaving undisturbed wildlife tree patches within the area of each cutblock, including “the provision for recruitment of suitable replacement wildlife trees over the rotation period”. Please read the full set of “Recommendations” at the link provided. That section includes “Area and distribution of patches or individual trees”, “Patch and live tree retention characteristics” and “Management principles for wildlife trees”.

I noted that TimberWest has addressed Objective A. 1. (b) by stating in its forest stewardship plan that its strategy for meeting this objective was to meet the requirements of Section 66 of the Forest Planning and Practices Regulation. Including this point in my submission was intended only to provide you with a sense of TimberWest’s interpretation of what Objective A. 1. (b) requires of them. Although woodlots are not subject to the Forest Planning and Practices Regulation, woodlots on Quadra Island are subject to the requirements of Objective A. 1. (b). It appears to me that you—and the other woodlots operators on Quadra Island—are incorrectly interpreting what is required of you to meet that objective.

I didn’t mention it in my submission, but this issue is part of the subject of an active complaint to the Forest Practices Board. That part of the complaint is directed at TimberWest, but it is applicable to all of the woodlots operating in SMZ 19 as well. Your cutblocks should end up looking more like the one near Lake Assu in Woodlot 1969, pictured below:

WTRAwithincutblock(s).jpg.164896c8ab929f5902c6e2b7ffe286d0.jpg

Regarding your explanation of the degradation of the visual corridor along Bold Point Road, I have included a before-and-after image (below) of logging you did in 2019 alongside the road. The RESULTS-Openings ID of the cutblock at issue in this case is #1737238. The satellite image taken before you logged that area shows a minor amount of alder near the road. But the vast majority of the trees you harvested in that section of the retention corridor were second-growth hemlock and fir. The Harvest Billing System report for your logging shows that alder only accounted for 2.6 percent of the 8204 cubic metres you logged in WL 1898 in 2019.

WL1898loggingbesideBoldPointRoad(beforeandafter).jpg.28570b7f036181f3c113f9c40ddb0bd3.jpg

Before and after logging in cutblock #1737238 along the south side of Bold Point Road. The trees in the “Retention” visual quality corridor were predominantly hemlock and fir.

The fact that there are some deciduous trees growing in the retention corridor does not give you licence to ignore the “Retention” visual quality objective. You must abide by the visual quality constraints. If BC Hydro judges that some trees need to be limbed to mitigate risk to power supply lines, that is their business, not yours. We will follow up any subsequent logging in this corridor with a complaint to the Forest Practices Board.

If you disagree with our account of the exclusions from the timber harvesting land base on the Quadra Island portion of your woodlot, please provide details. For your reference, I will copy our summary immediately below.

Total area of woodlot 1898 on Quadra Island: 400 ha

Exclusions from the timber harvesting land base

Voluntary reserves as per proposed woodlot plan: 85 ha

Meadows/wetlands: 37.5 ha

Eventual permanent access structures (as per the licensee’s estimate of 7 percent of total woodlot area): 28 ha

Net impact of “Retention” VQO along Village Bay Lakes Road: 6 ha

Net impact of other VQOs and RMZs: 5 ha

Rock: 2 ha

Unstable slopes/inoperable areas: 2 ha

Total exclusions: 165.5 ha

Net area available for logging: 234.5 ha

My original submission did not include your private land. Like many other woodlot licensees have done, you could withdraw your private land from the woodlot at any time. Our interest, therefore, is constrained to the 400 hectares of publicly-owned land in Woodlot 1898. Again, please let me know if you have specific disagreements with our account of your THLB.

By the way, our summary of the net area available for logging on the Quadra Island portion of your woodlot matches very closely that provided in your AAC report by Econ Consulting. By our numbers, the forested area of your woodlot that is under a conservation constraint (including the net effect of visual quality objectives) is 96 hectares. That is 27 percent of the forested area (359 hectares) of the woodlot. Our project supports the notion—which is supported by scientific analysis—that we should leave at least half of the area of Quadra Island’s forests in a natural state in order that logging creates only a low risk of biodiversity loss. If you truly want to be ahead of your time, you only need to find another 83 hectares of forested land to set aside for conservation and then abide fully with the legal constraints applicable to your woodlot.

Thanks again for your response.

Sincerely,

David Broadland for the Discovery Islands Forest Conservation Project

December 18, 2023

On 2023-12-16 at 10:22 AM, Debbie Quigg said:

What is the status of the draft plans for woodlots 1969 and 1970?

Hi Debbie. Thanks for registering, and for your question. As this moment I don't have an answer for you. Most of the issues we have raised about these two plans have also been raised in our April complaint to the Forest Practices Board regarding WL 2031, 2032 and TFL 47. Until an investigation report has been issued by that body, these issues remain unresolved.

April 13, 2023

The Forest Practices Board responded to this complaint—sent by email on April 4—on April 13 with the letter below, sent to the logging companies named in the complaint and copied to me. I will update this page as the Forest Practices Board proceeds.

File: 97250-20 / 23021 April 13, 2023 VIA EMAIL

Aaron Racher, General Manager Operations TimberWest Forest Corp.

David Younger, Younger Brothers Holdings Woodlot 2032

Chantal Blumel, Okisollo Resources Ltd.

Leslie Fettes, District Manager Campbell River Natural Resource District

Re: Notification of Complaint – Logging of old forest on Quadra Island

Dear Participants:

On April 5, 2023, the Forest Practices Board (the Board) received a complaint from David Broadland on behalf of the Discovery Islands Forest Conservation Project (the complainant). TimberWest (Tree Farm License 47), Okisollo Resources Ltd. (Woodlot 2031), and Younger Brothers Holdings (Woodlot 2032) are named in the complaint.

On Quadra Island, the complainant has identified approximately 655 hectares of old forest which it estimates to be 4 percent of the Crown forested land base. The complainant believes that the failure to complete landscape-level planning and to spatially designate old growth management areas, combined with government’s decision to establish or expand 11 woodlots in Special Management Zone 19, has put the remaining old forest at risk of being logged or degraded. The complainant believes that the three licensees named above continue to log old forest on the island.

A summary of the complaint relevant to each licensee appears below. The complete complaint is attached for reference.

TimberWest

• TimberWest is degrading small patches of old forest in TFL 47.

• TimberWest has no effective strategy to meet the old seral stage targets implied by the Vancouver Island Land Use Plan Higher Level Plan Order.

• TimberWest is not abiding by the strategies recommended by the Vancouver Island Summary Land Use Plan for managing concentrations of veteran trees.

• TimberWest’s strategy for sustaining forest ecosystem structure and function within cutblocks is ineffective because it doesn’t retain forest within cutblocks.

Okisollo Resources Ltd.

• Okisollo Resources Ltd. is logging old forest despite stating in its woodlot licence plan (WLP) that it would retain existing old forest, even “scattered small patches of old forest.”

Younger Brothers Holdings

• Younger Brothers Holdings is logging old forest for roads and degrading old forest by removing trees 250 years old and younger.

• Younger Brothers Holdings made substantive changes to its woodlot licence plan in 2019 concerning old forest reserves without any written communication with the ministry about a major amendment to the plan.

The complainant believes that urgent action is required to conserve all remaining old forest to protect biodiversity and other values. For relief, the complainant requests that the Forest Practices Board determine the most effective approach to conserving the remaining old forest on Quadra Island.

The Board must deal with public complaints about a party’s compliance with Parts 2-5 and 11 of the Forest and Range Practices Act. The Board does not represent the complainant, rather it acts as an independent third party. It is possible that after initial investigation, certain aspects of this complaint fall outside the jurisdiction of the Board. More information on the Board’s complaint investigation process is available here.

I would like to emphasize that the Board is interested in resolving complaints wherever possible, and I would appreciate any suggestions you might have to that end.

I will be contacting you soon to begin investigating this complaint. If you have any immediate questions or concerns please contact me at (contact information removed).

Yours sincerely,

Tracy Andrews, RPF Manager of Audits and Investigations

CC: David Broadland,

Discovery Islands Forest Conservation Project Attachment

January 4, 2023

Thanks for sharing your letter to TimberWest with the community, Jim. Logging in this area is again a concern since TimberWest/Mosaic has recently flagged potential logging near the Eagle Ridge Trail.

One thing about TimberWest's planning/community engagement process that seems problematic is captured in this sentence of Chad Iverson's response: "None of the blocks are shared until this is all completed, and a draft map and plan are compiled."

Wouldn't it be better if TimberWest sought out community input before they did any planning? As it is, they invest time and money before seeking input and are obviously going to be reluctant to ditch their investment in planning just because of a little community concern.

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