David Broadland

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

The map below may take a few moments to load. Below the map is a spreadsheet showing the project’s detailed account of the timber harvesting land base in Woodlot 2031.

Talking and negotiating in person with logging companies about where they cut and what they cut has little, if any, positive effect beyond minor adjustments to cutblock boundaries or the timing of when a forest stand is cut. That’s partly because oversight of BC’s logging industry shifted from a system of government regulation and operational oversight to a regime of professional reliance in 2003 when Gordon Campbell’s government gutted the BC Forest Service. That shift replaced much of the operational oversight that the Forest Service had performed with oversight conducted by professional foresters employed by logging companies. In effect, regulation and operational oversight of logging on publicly owned land was privatized. Gordon Campbell’s big idea was that it would be better for the foxes to guard the chickens. Over 20 years of experience with professional reliance in action has shown that this change was better only for industry. The experience of Sonora Islanders Tavish Campbell, Jodi Eriksson and Farlyn Campbell (no relation to the former premier) enduring repeated failures by TimberWest’s foresters to meet the company’s legal and ethical obligations under the Great Bear Rainforest Agreement highlight the overall failure of professional reliance to protect old forest on the Discovery Islands. The video below, created by the Sonora Island community, captures the gist of the problem—in painful detail. The lesson? Don’t expect that talking with private logging companies will have any real influence on what they do. At the very least, make sure that all your communications with logging company’s are in writing and copied to the district forester and your MLA. Otherwise, it’s just talk ’n log. Better still, join with other islanders and work together for greater conservation of forests on the Discovery Islands, including full protection for at least 30 percent of the Discovery Islands by 2030.

Submitted by the Discovery Islands Forest Conservation Project April 4, 2023 Logging of a rare stand of old forest at Hummingbird Lake on Quadra Island. The top photo was taken during logging in 2019; the bottom photo was taken from the same point in 2020. Summary 1. Old forest on Quadra Island has reached a critically low level (~4 percent). 2. The Vancouver Island Land Use Plan created Special Management Zone 19 (SMZ 19) in 2000 to ensure conservation of biodiversity associated with old and mature forest on Quadra Island. 3. The failure to complete landscape level planning has left Quadra Island without any spatially-designated old growth management areas, putting all remaining old forest at greater risk of being logged or degraded. 4. Establishing 11 woodlot tenures in SMZ 19 after it had been created effectively undid the land use planning provisions related to conservation of old forest on 5470 hectares in the zone. 5. TimberWest is degrading small patches of old forest in its TFL 47 on Quadra Island, both inside and outside SMZ 19. 6. TimberWest has no effective strategy for meeting the old seral stage targets implied by the VILUP Higher Level Plan Order. If those targets were included in TimberWest’s planning, it would have very little room left to log on Quadra Island. 7. TimberWest is not abiding by the strategies recommended by the Vancouver Island Summary Land Use Plan for managing concentrations of veteran trees in its tenure. 8. TimberWest’s strategy for sustaining forest ecosystem structure and function within cutblocks is ineffective because it doesn’t retain forest within cutblocks. 9. Woodlot 2031 is logging old forest despite stating in its woodlot plan that it would retain existing old forest, even “scattered small patches of old forest”. 10. Woodlot 2032 is logging old forest for roads and degrading old forest by removing trees 250 years of age and younger. Substantive changes made to its woodlot plan in 2019 illustrate how old forest reserves in a woodlot can be changed without any notice being given to the ministry or the public. 11. We respectfully request that the Forest Practices Board investigate these matters. The lay of the land: 11 woodlot licence tenures and a TFL crammed in a special management zone on a small island TimberWest/Mosaic map of SMZ 19 (pink boundary) and age classes of forest cover on Quadra Island Introduction The failure to implement landscape level planning on Quadra Island after the Vancouver Island Land Use Plan established Special Management Zone 19 in 2000, coupled with the awarding or expansion of 11 woodlots inside the special management zone, has left rare stands and small patches of old forest open to logging. Since the area of old forest on Quadra Island is now down to about 4 percent of the Crown forested land base, risk of biodiversity loss is extremely high and getting worse. Urgent action by government is necessary to conserve all remaining old forest to protect biodiversity and other values. The problem [1] In July 2022, the Forest Practices Board released its investigation report, “Government Enforcement of Old Tree Harvesting on a Quadra Woodlot.” The report contained factual errors about how many trees were removed and why they were removed. The Discovery Islands Forest Conservation Project reported on those errors. [2] After we published our report, Forest Practices Board Director of Investigations Chris Oman wrote to us and suggested, “If you have concerns about whether the harvesting of other trees complied with [Forest and Range Practices Act], you are welcome to file a complaint with the Board.” [3] This submission is, in part, our project’s response to that suggestion. But rather than focussing our complaint on just the question of whether or not the Compliance & Enforcement Branch and Forest Practices Board had failed to thoroughly investigate the logging of old forest that had occurred at Hummingbird Lake on Quadra Island—that logging being just a symptom of a larger problem—we provide below a detailed description of the underlying circumstances that have allowed continued logging of old forest on Quadra Island, including at Hummingbird Lake. [4] The Discovery Islands Forest Conservation Project is conducting ongoing surveys of old forest on each island in the Discovery Islands group. On Quadra Island we have so far identified approximately 176 widely dispersed fragments of old forest that in area total 655 hectares. As mentioned above, that amounts to approximately 4 percent of the current Crown forested land base. [5] The low level of old forest on Quadra Island has been blamed on fires that occurred in 1919, 1921, 1922, 1924 and 1925. But this is only partly true. Logging began in the 1880s and by 1925 much of Quadra’s old forest had been logged. That history in no way excuses continued logging of the remaining old forest. Instead, the critically low level of old forest should have guided the Ministry of Forests to more urgently consider the need to protect all that remains. [6] Unfortunately, the cutting of productive old forest continues. This loss is occurring for two main reasons: [7] First, because of the absence of landscape level planning—promised 23 years ago but never delivered—no legal old growth management areas (OGMAs) have been established on the approximately 11,000-hectare Quadra Island portion of TFL 47. [8] Second, 11 different woodlot licences were located on Quadra Island on 5,470 hectares of Special Management Zone 19 ( (SMZ 19) after the zone had been established by the Vancouver Island Land Use Plan (VILUP) in 2000. Since the Forest and Range Practices Act does not require woodlot licensees to meet the seral stage objectives established by the VILUP, old forest can be legally logged within those 5,470 hectares unless a licensee’s woodlot plan stipulates that it won’t log old forest. [9] One of the errors made in the report mentioned above at [1] reflects an assumption made by Forest Practices Board investigators that Quadra Island had undergone landscape level planning, and that management of old forest on the island was governed by a landscape level plan. [10] The Board’s report included a map of the “Quadra Landscape Unit” and this statement: “For the Quadra landscape unit (Figure 1), which covers the woodlot licence and tree farm licence 47, this means that the holder of the tree farm licence addresses the legal requirements to manage old-growth forests under their forest stewardship plan. Again, the woodlot licensee is exempt from following government’s objectives for the retention of old-growth forests.” [11] The assumption by the Forest Practices Board that landscape level planning had occurred is understandable. Landscape level planning for Quadra Island was given “high priority” in 2000 when the VILUP designated approximately 15,800 hectares of the island as SMZ 19. But, for unknown reasons, that planning never occurred. The “Quadra Landscape Unit” exists only as a line drawn around the island on a map. [12] We would also note that the Forest Practices Board, in carrying out its investigation, may have been under the impression that Quadra Island hosted only one Woodlot Licence tenure. The report mentioned only one. But, as noted above, there are 11, each of which, as the Board put it, “is exempt from following government’s objectives for the retention of old-growth forests.” [13] Although woodlots are required to reserve 8 percent of their area as “wildlife tree retention areas”, in practice this requirement produces little certainty that remaining areas of old forest will be protected, as we will show below. [14] Moreover, in the absence of landscape level planning, TimberWest, the tenure holder of TFL 47, has defaulted to the position that old forest in its portion of SMZ 19 is subject only to the 2004 Order Establishing Provincial Non-Spatial Old Growth Objectives. That order puts the old forest retention target for the CWH biogeoclimatic zone, natural disturbance interval type 2 (Quadra Island) at “>9 percent”. TimberWest handles remaining concentrations of old trees by leaving trees older than 250 years of age but logging all the younger trees between them (more on this later). [15] When the result in [13] is combined with the result in [14], a very different outcome for SMZ 19 than was intended by the VILUP has been produced. Based on aerial and ground surveys of old forest conducted by the Discovery Islands Forest Conservation Project over the past five years, we estimate the current extent of old forest to be at about 4 percent of the Crown forested area, and falling. This is highly problematic for conservation of biodiversity on Quadra Island and represents a failure of government to abide by its own land use planning. [16] In a 2021 Forest Practices Board investigation of a complaint about logging in Special Management Zone 13 in the Nahmint Valley, the Board criticized BC Timber Sales for failing to meet the obligations imposed by the VILUP. In that case, the Board stated: “The public needs to be confident that objectives established in land use plans will actually be carried through and implemented in forestry operations.” [17] Below, we will first outline what the intended outcome for old forest in SMZ 19 was. We will then address the question of whether TimberWest has advanced a credible strategy for old forest management in SMZ 19 and whether it is carrying through with that strategy. Finally, we will provide detailed examples of how old forest loss is occurring in both Block 12 of TFL 47 and two of the woodlots in SMZ 19. What outcome was intended for seral stage distribution in SMZ 19? [18] First, the intended management objective for distribution of old seral stage forest was to be at least 9 percent of the SMZ’s “contributing area”. The Vancouver Island Summary Land Use Plan defined that as the “timber harvesting land base” (THLB). To the extent that there wasn’t enough old forest to meet that target, mature forest suitable for old forest recruitment would need to be identified. Second, the intended objective for mature seral stage distribution in SMZ 19 was for at least 25 percent of the zone’s “contributing area” (again, defined as the “timber harvesting land base”) to be “mature”. [19] How were these intentions to be carried out in practice? First, the VILUP was to be followed by landscape level planning. As you know, landscape level planning was designed to establish spatially-designated old growth management areas (legal OGMAs) and non-legal OGMAs that could be located in protected areas. The provincial government created legal OGMAs for the purpose of conserving the biological diversity associated with old forests. [20] If landscape level planning had been conducted for Quadra Island, legal OGMAs and non-legal OGMAs would have been established for the entire Crown forested land base on the island. We estimate there would be approximately 1280 hectares of legal OGMAs associated with SMZ 19, and about 160 hectares of legal OGMAs associated with the area of Crown forest not in SMZ 19. Instead, no legal OGMAs have been created and all remaining old forest and concentrations of veteran trees not in protected areas are at risk of being logged or being exposed to logging. [21] It should be noted that the 8 to 9 percent targets for old forest mentioned throughout this submission are from 1990s-era forest management understanding. Those targets should be much higher now given the new science-based understanding about stand-replacing disturbance intervals for Quadra Island. In 2000, that interval was thought to be about 200 years. It is now estimated to be about 700 years. To keep the risk of biodiversity loss due to logging at a “low” level, at least 49 percent of the Crown forest base on Quadra Island should be old forest. So the 8 to 9 percent old forest targets mentioned throughout this submission are wholly inadequate to keep the risk of biodiversity loss to a manageable level. How will the seral stage targets for SMZ 19 be met? [22] In this section we will examine the question of whether TimberWest has responsibility for meeting the seral stage targets for all of SMZ 19. We include targets for both old and mature forest in this discussion since the VILUP implied targets for both of these seral stages in SMZ 19. [23] For clarity, we will note that the Vancouver Island Summary Land Use Plan described SMZ 19 as the land that “comprises all provincial Crown forest on Quadra Island outside of protected areas, excluding the northern portion (north of Small Inlet), as well as the southern, mostly private portion” (emphasis added). [24] Clearly, it was the intention of the planners that the protected areas on Quadra Island could not be used to meet the seral stage objectives for SMZ 19. Let’s briefly review what those objectives were, and where they came from. [25] The biodiversity emphasis option chosen for SMZ 19 by the Vancouver Island Summary Land Use Plan was “Intermediate.” According to the provincial Biodiversity Guidebook current at the time VILUP was ordered, the recommended target for distribution of seral stages for the “Intermediate” biodiversity emphasis option in Natural Disturbance Type 2 areas (Quadra Island) was as follows: Mature + old: >34 percent; Old: >9 percent; Mature: >25 percent. [26] When SMZ 19 was created in 2000, approximately 15,800 hectares of Quadra Island were in the zone and subject to the seral stage targets described above. The areal extent of the zone has not changed. [27] Did locating eleven woodlots in SMZ 19 mean that the targets for old and mature forest are no longer applicable? If that was the case, years of careful land use planning would have been undone by the ministry’s own ill-considered action of establishing woodlots in SMZ 19 before completing landscape level planning. We don’t believe anyone should settle for that outcome. Instead, we believe the responsibility for meeting the overall targets for the 15,800-hectare SMZ 19 has shifted, or should be shifted, to that portion of TimberWest’s TFL 47 that’s in the SMZ. [28] As noted above at [10], the Forest Practices Board found that “the holder of the tree farm licence addresses the legal requirements to manage old-growth forests under their forest stewardship plan.” The Board seemed to be implying that TimberWest had the sole responsibility for meeting the seral stage objectives set for SMZ 19 (and, indeed, the entire “Quadra landscape unit”). [29] Even if the Board did not mean that TimberWest has such a legal responsibility, Section 9 (Proportional Objectives) of the Forest and Range Practices Act gives the Minister of Forests the power to “establish targets, in specified proportions between or among the holders of forest stewardship plans, for sharing the responsibility to obtain results consistent with objectives set by government.” [30] In this case, to ensure the overall objectives for seral stage distribution in SMZ 19 are met, TimberWest should be given 100 percent of the share of “responsibility to obtain results consistent with objectives set by government.” [31] Such an approach would ensure the intentions of land use planning were carried through by government, and would satisfy the public interest highlighted by the Board in the Nahmint SMZ 13 case, namely that: “The public needs to be confident that objectives established in land use plans will actually be carried through and implemented in forestry operations.” [32] This would have important implications for TimberWest’s operations in SMZ 19. The table below summarizes TimberWest’s own assessment of the current age class distribution in its portion of SMZ 19. Note that the total for the centre column is 7084 hectares. [33] Since old plus mature forest needs to cover at least 34 percent of the forested area of TFL 47’s portion of SMZ 19, about 2408 hectares needs to be older than 80 years of age. By TimberWest’s own estimate, 3060 hectares currently meet that requirement. That leaves TimberWest with a buffer of 652 hectares within which it can log. [34] If TimberWest is responsible for meeting the full SMZ 19 target for old forest, however, it must also incorporate a reserve to cover at least 9 percent of the 5470 hectares covered by woodlot tenures, which are not required to meet seral stage objectives. That would add an additional 492 hectares to TimberWest’s old forest responsibilities, and would further reduce the area within which TimberWest could log to 160 hectares. [35] The strategies for meeting seral stage objectives that TimberWest has included in its successive forest stewardship plans suggest that it is aware of its responsibility to cover the full seral stage distribution obligations that arise from objectives 1.A and 1.B set by the VILUP Higher Level Plan Order for SMZ 19. [36] For example, in its 2022 forest stewardship plan, TimberWest’s stated strategy for objective 1.A was: “In concert with other harvesting licence holders operating in the Special Management Zone, the holder of this FSP will ensure that planned development and harvesting activities will not result in the proportion of mature forest area dropping below 25% in the FDU [forest development unit].” [37] Why would TimberWest’s strategy for meeting its own mature seral stage target involve looking outside of its own TFL boundaries for help to ensure its “harvesting activities will not result in the proportion of mature forest area dropping below 25% in the FDU”? [38] Although the language seems a bit jumbled, the principle at work is clear enough. TimberWest is responsible for ensuring that the overall target for the mature seral stage in SMZ 19 does not fall below 25 percent. Therefore it can count the area of mature forest in the woodlots to meet its legal requirement. [39] But this same principle must also apply to the >9 percent old seral stage target for SMZ 19. And since old forest covers only about 4 percent of SMZ 19—well below the target of at least 9 percent—TimberWest is responsible for managing for the missing 5 percent of old seral stage forest, too. [40] This is, however, a moving target. If additional old forest is logged in the woodlots, TimberWest would be required to set aside even more of TFL 47 to manage for the old seral stage target. [41] The Forest Practices Board seems to agree with this premise. In an investigation about logging of old forest in a woodlot on Quadra Island, as noted above at [8], the Forest Practices Board found that “the holder of the tree farm licence addresses the legal requirements to manage old-growth forests under their forest stewardship plan.” [42] As in the case of acting “in concert with other harvesting licence holders operating in the Special Management Zone” with regards to mature seral stage targets, TimberWest should be acting in concert with the woodlots regarding meeting SMZ 19 targets for old forest. [43] There is no evidence in the current woodlot plans of the 11 woodlot licensees that there is any planning “in concert” with TimberWest. And, as we will show below, at least two of the woodlots are logging old forest. Both of these circumstances suggest that TimberWest is not following through with its limited strategy to meet the seral stage distribution objectives that flow from the VILUP. TimberWest is not following the recommended strategy for managing old forest set out in the VILUP [44] Although TimberWest has committed in its forest stewardship plans to not log old forest in its portion of SMZ 19, it has logged small patches of old forest. In those cases it leaves the trees that are greater than 250 years of age but cuts away all younger trees between the old trees. This is not the strategy outlined for SMZ 19 by the VILUP. [45] The recommended strategy for protecting old forest on Quadra Island, as stated in the Vancouver Island Summary Land Use Plan was this: Objective: General Biodiversity Conservation Management 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; recruit old seral habitat blocks with higher priority on forest interior conditions than on old seral connectors; maintain harvest opportunity in second growth by identifying some old growth recruitment areas in early seral forest; recruit mature forest in the mid (>50 years) term, building gradually towards a mature seral target of 25%; actively create mature and old seral forest attributes through suitable management strategies, such as variable density thinning or partial cutting silvicultural systems. [46] We interpret the stated strategy—“maintain existing old forest in the zone, as well as second growth with high portion of veteran trees”—as meaning that concentrations of veteran trees should be left undisturbed. [47] However, TimberWest is not abiding by that strategy. Below are photographs of three such instances in TFL 47 in the special management zone. [48] We have been advised by forest ecologist Rachel Holt and forester Herb Hammond that such a practice does little to conserve the biodiversity associated with old forest, which is the basis for the above recommended strategy outlined in VILUP for SMZ 19. Three photos below: TimberWest leaves trees older than 250 years but logs everything around them. TimberWest’s strategy regarding Objective A.1.(b) is ineffective [49] Objective A. 1. (b) of the VILUP Higher Level Plan Order (HLPO) states: “Sustain forest ecosystem structure and function in SMZs, by… retaining within cutblocks, structural forest attributes and elements with important biodiversity functions…” [50] 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)”. [51] 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.” [52] TimberWest’s strategy for “retaining within cutblocks, structural forest attributes and elements with important biodiversity functions…” utilizes a “group retention” approach whereby the full annual 7 percent retention area is accounted for as an area, or areas, of unlogged forest somewhere on Quadra Island. This has two problems. [53] First, this approach defeats the intention of Objective A. 1. (b) of the VILUP HLPO. The order specifically uses the language “retaining within cutblocks…” and a footnote elaborates : “Within cutblocks: generally means non-contiguous with cutblock boundaries”. We take that to mean that retention areas should be like “islands” within cutblocks. Yet none of TimberWest’s wildlife tree retention areas occur within cutblocks. [54] Second, mapping of these retention areas on Quadra Island shows that they often end up being logged later or do not contain mature trees (see image below). Or inoperable areas where logging wouldn’t have occurred in any case are designated as stand-in wildlife tree retention areas. Neither of these approaches helps to “sustain forest ecosystem structure and function…within cutblocks…” Some of TimberWest’s mapped “wildlife tree retention areas” on Quadra Island (areas outlined in green with oblique lines through them) are areas that have been clearcut or do not contain mature trees (marked above with red dots). See more wildlife tree retention areas on Quadra here. [55] Moreover, Section 67 of FPPR states: “An agreement holder must not harvest timber from a wildlife tree retention area unless the trees on the net area to be reforested of the cutblock to which the wildlife tree retention area relates have developed attributes that are consistent with a mature seral condition.” [56] As noted above, in those cases where TimberWest leaves veteran Douglas fir trees as wildlife trees, it immediately removes the younger trees around them from the potential wildlife tree retention area, contrary to Section 67 of FPPR. The photos below are typical of TimberWest cutblocks on Quadra. All three are in the Long Lake area. Logging of old forest in the woodlots [57] Between 2003 and 2011, after SMZ 19 had been created, nine new woodlots were established on Quadra Island in the special management zone, and the two pre-existing woodlots were expanded into the zone. [58] The rational course of events, after the establishment of SMZ 19, would have been to conduct landscape level planning, establish legal OGMAs—and only then establish Woodlot Licences. [59] Because of the differences in requirements for old forest retention in legal OGMAs as compared with Woodlot Licence tenures, there was a dramatic decline in the level of protection of remaining old forest in the area occupied by the woodlots. [60] While 18 percent of Quadra Island is in provincial parks, only a fraction of the remaining old forest is in those protected areas. And since no legal OGMAs have been created, much of the remaining old forest—which is mostly in TFL 47 and four of the 11 woodlots—is at risk. This worsens an already high risk of biodiversity loss. [61] One consequence of the Ministry of Forests’ lack of coordinated planning for old forest on Quadra Island is that it is still being logged. The Forest Practices Board’s 2022 investigation report involving Woodlot 2031 illustrates how and why this is happening: Ministry of Forests personnel have too few resources to be able to assess what’s on the ground, plan for conservation and then monitor the state of old forest on Quadra, and some woodlot tenure holders are taking advantage of that lack of attention. [62] In the text below, we will address the particulars of two different cases in which old forest has being logged on Quadra Island in spite of the high risk of biodiversity loss. Each case helps to illustrate the problems that have arisen due to the lack of implementation of landscape level planning. Logging of old forest in Woodlot 2031 [63] With little or no resources for the Ministry of Forests to monitor what is being logged on woodlots, some Quadra Island woodlot tenure-holders are taking advantage of the situation and are logging old forest. Woodlot 2031 was established in 2011 and lies entirely within SMZ 19. The tenure is held by Okisollo Resources Ltd. Below is our account of logging of old forest in 2019 in Woodlot 2031: [64] The Discovery Islands Forest Conservation Project visited Hummingbird Lake with a drone in July 2018, one year before the logging took place. We returned again in July 2019 while the logging was taking place and a third time in June of 2020, after logging had been completed. Hummingbird Lake and surrounding forest in July 2018, as seen from a drone flying east. This photo taken in 2018 shows the approximate area of old forest (left side of photo) north of Hummingbird Lake that was logged in 2019. [65] On each visit, we photographed the area, both on the ground and using a drone for aerial views of the forest and lake. Over the past five years the Discovery Islands Forest Conservation Project has been surveying forests at dozens of locations on Quadra Island where it seems possible or likely that old-growth forest could be logged before it has been properly identified and reserved. [66] On our 2018 visit, we could find no stumps or other evidence that would indicate the forest on the north side of Hummingbird Lake had ever been logged. The BC government’s record of road building in the province shows the north side of Hummingbird Lake had never been roaded before Okisollo Resources began logging in 2014. A forest fire in 1925 had lightly burned through the area, leaving the old trees intact. About 5 years after that fire, hemlock began to grow back—naturally—in the shade of the remaining big trees. [67] All the evidence suggested that the north side of Hummingbird Lake was rare primary forest with big, old trees growing at a density that was at least equal to any other old forest we have surveyed on Quadra Island. [68] When we visited the logging operation in July 2019, roads had been built. There was a completed cutblock near the southwest corner of the lake where four old-growth Douglas firs still stood. Ten full-length tree trunks were lying beside the road into the second cutblock—all old-growth Douglas firs that had been removed to make way for the road. The new logging road built along the north side of Hummingbird Lake in July 2019. [69] In a second cutblock on the north side of the lake, smaller-diameter hemlock and fir were in the process of being machine-felled (photo below). There were numerous large, old-growth Douglas firs and a few old cedars standing amongst the younger trees. It was unclear whether the dozens of old firs would be left standing or be felled. We had never seen so many big trees in the middle of a Quadra Island logging operation. Above: Okisollo Resources’ logging of old forest north of Hummingbird Lake in July 2019. Below: The same view in 2020. [70] The project revisited the area in June 2020. Logging had been completed in the cutblock on the north side of Hummingbird Lake. Most of the old trees had been felled in both cutblocks. Along an edge of the northern cutblock, about 15 old vets still stood, testimony to the density of the grove that had just been cut. In 2020, a line of old-growth Douglas fir vets was left along the edge of Okisollo Resource’s clearcut on the north side of Hummingbird Lake. [71] We photographed the northern block where several large-diameter logs had been left beside the road. The growth rings of a recently live tree showed it had been 370 years old when it was cut. Several dead snags had also been cut and were stacked or scattered across the cutblock. Above: This Douglas fir had 370 annual growth rings. Below: A stump showed approximately 380 years of growth. [72] To determine how many old firs had been logged in the northern cutblock, the project searched for satellite images taken in mid-August 2019. The image below shows logging in progress in the second cutblock on August 15, 2019. At least 50 old-growth trees remained standing on this day. The smaller-diameter hemlock had all been cut, stacked and were being removed. [73] The satellite image below was taken a few weeks later. Of the 50 old-growth trees that had been standing in the cutblock (see photo above), only 15 remained. [74] The project’s photographs and notes, when combined with the satellite images, show that of approximately 64 old trees in the two cutblocks and the road, at least 49 were cut. The 3-hectare cutblock north of the lake had contained at least 55 live, old-growth trees and an unknown number of standing snags. [75] In 2021 a Quadra Island resident filed a complaint about this logging with the Compliance & Enforcement Branch. A complaint was then filed with the Forest Practices Board. The Forest Practices Board found that 10 old trees had been cut and “the old trees were not set aside from logging. The licensee removed the trees to build a road and for safety reasons.” [76] In response to questions sent by this project to Chantal Blumel, a registered professional forester and a principal of Okisollo Resources, Ms Blumel stated: “We removed some of the old trees during the harvest of the second growth stands, for safety and access purposes.” [77] There is no dispute that some old trees were removed for building logging roads. Above, we estimated that at least 10 had been removed because they were in the way of the road. But was “safety” actually an issue for the other 35-40 old trees that were logged? The Occupational Health and Safety Regulation of BC’s Workers Compensation Act states: “If work in a forestry operation will expose a worker to a dangerous tree, the tree must be removed.” [78] At the cutblock north of Hummingbird Lake, all of the younger, smaller-diameter trees had already been removed several days before approximately 35 larger old-growth Douglas firs were felled. That can be seen in the satellite images. Those old trees did not have to be logged for either “safety” or “access” purposes. [79] The original complaint by a Quadra Island resident was based on the belief that the 2001 Vancouver Island Land Use Plan prohibited logging of old forest in SMZ 19 on Quadra Island. In fact, it had been, until Woodlot 2031 was established in 2011. [80] Although section 52 (1) c of the Woodlot Planning and Practices Regulation requires woodlot license tenures to designate, in their woodlot plans, 8 percent of the area of the woodlot as “wildlife tree retention areas”, this designation does not have to be applied to actual areas of old forest. But in the case of Woodlot 2031, which contains several areas of old forest and concentrations of veteran trees, the licensee made written promises in its woodlot plan to retain existing old-growth stands. [81] The wording in the licensee’s woodlot plan regarding existing old forest had apparently made a strong impression on Forest Practices Board investigators. [82] The Board’s report stated: “In their [woodlot plan], they committed to setting aside all of the existing old-growth stands by designating them as wildlife tree retention areas.” In another section, the report stated, “the licensee chose to set aside the existing old-growth stands to provide wildlife habitat and conserve biodiversity even though it did not have to. The licensee did this in consideration of the community’s desire to protect old-growth forests on Quadra Island.” In the “Conclusions” section, the report stated “the woodlot licensee chose to set aside all of the existing old-growth forests because they recognized the community’s desire to protect the remaining old-growth forests on Quadra Island.” [83] The Board could have been referring to the section in the licensee’s legally binding woodlot plan on “Wildlife Tree Retention Strategy”, which stated: “The wildlife tree retention strategy for woodlot licence W2031 involves: retaining the existing old growth stands (>250 years) and recruiting around them to enlarge existing and future old growth forests…” [84] Or the Board might have been referring to the section in the legally binding woodlot plan that addressed “Areas where timber harvesting will be avoided”. That section contained this statement: “Retaining the existing old growth forests is key to maintaining the biodiversity values of forests in the CWHxm biogeoclimatic subzone. Maintaining these reserves, and recruiting around them to enlarge existing and future old growth forests is one of the strategies to meet the biodiversity objectives set out in the VILUP for SMZ 19.” [85] Whichever part, or parts, of Okisollo Resource’s woodlot plan the Board was referring to, it is clear that the strategy specified in the woodlot plan to retain existing old growth stands, and the stated strategy on how the licensee would conserve biodiversity, convinced the Board that Okisollo Resources “committed to setting aside all of the existing old-growth stands by designating them as wildlife tree retention areas.” [86] We believe the Board understood the plain meaning of the statements made in Okisollo Resources’ legally-binding 2011 woodlot plan, and that this meaning was also communicated to the approving authority and the local community when Okisollo Resources’ plan was put out for public comment in 2011. [87] Section 21(1) of the Forest and Range Practices Act states: “The holder of a forest stewardship plan or a woodlot licence plan must ensure that the intended results specified in the plan are achieved and the strategies described in the plan are carried out.” [88] The possibility that the owners of Okisollo Resources were not fully aware of where old-growth forest in the woodlot existed when they created their legally binding 2011 woodlot plan cannot be allowed to undo the commitments they made in writing to retain existing old forest. In any case, the licensee stated that even “scattered small patches of existing old forest” not specifically identified in the plan would be retained. We believe this commitment would apply to the area of old forest logged in 2019. [89] We are asking the Forest Practices Board to investigate Woodlot 2031’s logging of old forest in 2019, as described above, and to explain why that logging did not contravene the results and strategies stipulated in the tenure’s legally binding woodlot plan. Logging of old forest in Woodlot 2032 [90] Woodlot 2032 was established in 2011 and lies entirely within SMZ 19. The tenure is held by Younger Brothers Holdings. [91] In 2019, Younger Brothers Holdings built logging roads through two areas of old forest the company had mapped in its 2011 woodlot plan as “old-growth” reserves. This logging would have been prohibited without a properly made amendment to the plan. The approximate boundaries of the reserves are shown in the image below: [92] To ascertain whether the Ministry of Forests had determined whether such an amendment to the legally binding 2011 woodlot plan had been properly made, an FOI was filed in late 2021 by the Discovery Islands Forest Conservation Project. The FOI requested all communications between the Ministry of Forests and the principals of Woodlot 2032—including the woodlot’s registered professional forester—back to the beginning of January 2017. The records released to us suggested—by the absence of any records relating to an amendment of the woodlot plan—that there had been no written communication between the woodlot tenure holders and the ministry about a major amendment of the woodlot plan. [93] Asked directly about this change, Younger Brothers’ forester provided the Discovery Islands Forest Conservation Project with a letter he told us was sent to the Campbell River District Manager in February 2019. The letter described changes to the 2011 plan that involved removing reserves of old forest above Discovery Passage (the areas outlined in green in the image above) and replacing those areas with an area of younger, sparser forest running up to the top of Darkwater Mountain (the area outlined in green in the image below). In the amendment, the replacement area and a pre-existing logging road were named the “Manzanita Mountain Recreation Area” and an old logging road was named the “Manzanita Mountain Trail.” [94] The letter stated that the new reserve area was “created to provide recreational opportunities (hiking trail established) and to provide protection for the rare Manzanita plant (arctostaphylos columbiana) which is observed in the area.” [95] Access to Darkwater Mountain (the name for the mountain used by Cape Mudge Forestry, which is operated by We Wai Kai First Nation) by old logging roads predates development of Woodlot 2032. Hairy Manzanita is not “rare.” It can be found in many high areas on Quadra Island and is NOT on the BC Red Blue List. [96] As mentioned above, the letter provided to us by Younger Brothers’ forester was not included by the Campbell River office of the Ministry of Forests in the record of communications between the Ministry of Forests and Younger Brothers that were obtained by FOI. Recently, the Discovery Islands Forest Conservation Project asked the Campbell River District Manager for an explanation for why the amendment letter had not been included in the FOI release. Subsequently, the District Stewardship Forester indicated to us that this letter could not be found at the District office and there was no record of a response from the District office to Younger Brother’s letter of amendment. Later, District Manager Lesley Fettes sent us an email which stated, in part: “I encourage you to report your concerns by making a ‘Report of Natural Resource Violation’ using the online form. This is government’s process to have potential non-compliances investigated.” [97] When we asked Younger Brothers’ forester for a copy of the email to the District notifying them of the 2019 amendment, the forester explained, “As this amendment was 3 years ago, I no longer have the email.” [98] When asked about the switching of reserves from an area of old forest to an area of younger trees, Younger Brothers’ forester stated that “Minor revisions to retention strategies are acceptable providing the total area under reserve is not reduced.” [99] But the Woodlot Licence Planning and Practices Regulation states that an amendment is only considered “minor” if it does not “decrease the nature or quality of wildlife trees or wildlife tree retention areas.” In this case, the amendment replaced areas of old forest containing some large trees with an area of mostly younger, sparser forest at the top of a rocky, dry hill where Hairy Manzanita was growing. We contend that this change constituted a decrease in the nature and quality of both individual wildlife trees and the wildlife retention area as a whole. Yet there is no record in the Campbell River District office that Younger Brothers’ forester even sought approval for this amendment. In other words, the amendment appears to be “wrongly made”. A view of the forest in one of the two 2011 wildlife tree retention areas that had roads built through them in 2019. This photo was taken from the road. [100] Under Section 22 (“Minor amendments wrongly made”) of the Woodlot Licence Planning and Practices Regulation, the forests minister may “declare the amendment to be without effect” and may “require the holder to suspend operations that are not authorized in the absence of the amendment”. [101] This is a serious matter. Under Section 52 (2) (“Wildlife tree retention”) of the Woodlot Licence Planning and Practices Regulation, “A woodlot licence holder must not cut, damage or remove wildlife trees or trees within a wildlife tree retention area except in accordance with the wildlife tree retention strategy prepared under section 11”. [102] Under Section 11 (c) (d) (e) (“Wildlife tree retention strategy required”) of the Woodlot Licence Planning and Practices Regulation, the strategy must include “the conditions under which individual wildlife trees may be removed” and “the conditions under which trees may be removed from within a wildlife tree retention area” and “how trees removed…will be replaced.” [Withdrawn]. [103] Younger Brothers Holdings, by building roads through two wildlife tree retention areas that it had mapped in its approved 2011 woodlot plan (as mentioned above in [96]), has cut and damaged trees in what had been wildlife tree retention areas. Did the swapping of the areas of old forest with an area that Younger Brothers had not previously mapped as old forest constitute a “wrongly made” amendment? [104] Again, this is a serious matter. Under Section 90 (“Offences”) of the Woodlot Licence Planning and Practices Regulation, contravening Section 52 is “an offence and is liable, on conviction, to a fine not exceeding $500,000 or to imprisonment for not more than 2 years or to both”. [105] These circumstances illustrate how, over time, a woodlot tenure holder can unilaterally “amend” their woodlot plan and remove areas that they had previously established as an “old-growth reserve”. Without a motivated watchdog looking out for the public interest, no questions would be asked and stands of old forest—which are commercially more valuable—would be logged or degraded. [106] As per the district manager’s suggestion, the Discovery Islands Forest Conservation Project has filed a complaint with the Compliance and Enforcement Branch. [107] This woodlot contains one of the largest areas (16.5 hectares) of primary forest remaining on Quadra Island, including one of the old-forest reserves the tenure holder’s 2019 amendment removed from its wildlife tree retention reserve. According to the licensee’s draft plan, logging in this area is imminent (see photo on next page). [108] The tenure holder of Woodlot 2032 has committed to not cut any trees older than 250 years of age, as has become the practice on Quadra Island, but all other trees between those older trees can be logged. As mentioned above, we have been advised by a forest ecologist and a forester that this practice does not protect biodiversity. [109] Moreover, the Woodlot Planning and Practices Regulation does not allow any logging to occur in wildlife tree patches, so asserting that these patches only need trees that are 250 years and older to be viable at supporting species associated with old forest is not supported by the legislation applicable to woodlots. Foreground: Part of the area of old, mainly primary forest southwest of Darkwater Lake, which contains large, old trees—now a very rare ecosystem on Quadra Island. The small reserves in this area that the 2011 plan created have now been moved to the top of Darkwater Mountain (in background). [110] We request that the Forest Practices Board investigate whether Woodlot 2032’s amendment was properly made or not (we have filed a complaint with Compliance and Enforcement but have not heard from them as of April 4, 2023). We are also providing these details to assist the Board in understanding the ways by which remaining old forest on Quadra Island, already at a critically low level, will continue to disappear unless changes are made. Without change, antagonism in the community over this issue will continue to grow. As you know, land use planning and creation of SMZ 19 was intended to end such conflict. [111] If TimberWest does have the sole responsibility to ensure the full targets for old forest in SMZ 19 are met, perhaps a more effective arrangement for conserving old forest on Quadra Island would be for TimberWest to cooperate with the woodlots on a commercial basis that compensates the woodlots with work or wood in exchange for conserving old forest on their woodlots. If that’s not possible, what other solutions does the Board recommend? Conclusion [112] The extent of old forest on Quadra Island is currently at about 4 percent. TimberWest puts that number at 3.8 percent for that part of its tenure that is in SMZ 19. This situation poses what forest ecologists Dr. Karen Price and Dr. Rachel Holt and others have termed “high risk” for loss of ecological function, biodiversity and resilience. [113] The Old Growth Strategic Review Panel has called for an immediate pause to logging of old forest in landscape units with less than 10 percent of old forest remaining. (Although the “Quadra Landscape Unit” has no plan, its areal extent has been defined.) [114] Throughout BC, mapping of old-growth deferral areas has depended on the use of the Ministry of Forests’ Vegetation Resources Inventory (VRI). That mapping is notoriously inaccurate for locating actual old forest, and those deferrals on Quadra Island that have been mapped by the Technical Advisory Panel do not accurately reflect where old forest is on Quadra Island. [115] The Discovery Islands Forest Conservation Project has identified 176 fragments of old forest and concentrations of veteran trees that amount to approximately 655 hectares in areal extent. We are in the final stages of confirming these on the ground, and our mapping is ongoing [116] Given the circumstances outlined in this submission, we request that the Forest Practices Board determine the most practical approach to conserving the remaining old forest on Quadra Island given the existing legislation, regulations and land use planning. The Discovery Islands Forest Conservation Project is conducting its research on the unceded traditional territories of the Wei Wai Kai First Nation, Kwiakah First Nation, Homalco First Nation, Klahoose First Nation, the K’ómoks First Nation and the traditional territory of the Tla’amin Nation. It is our intention to work with these nations to increase the general level of settler knowledge about the land and our connection to it.

This November 2021 report provides basic information about the old growth deferral process, including the different types of old-growth forest. You can download the report from the file below or read it directly on this page. See mapping of priority old growth deferral areas on the Discovery Islands on this page. Techical_Advisory_Panel_background_and_technical_appendices.pdf

The Discovery Islands Forest Conservation Project submits the following observations about—and objections to—the renewal of Woodlot Licence 2032 and the proposed Woodlot Plan: A. The tenure holder appears to have wrongly amended its legally binding 2011 Woodlot Plan in 2019 and the Ministry of Forests has no written record of the amendment. (1) In 2019, Younger Brothers Holdings built logging roads through two areas of old forest the company had mapped in its 2011 Woodlot Plan as “old-growth reserves” in Woodlot 2032. This logging would have been prohibited without an approved amendment to the plan. The approximate boundaries of the reserves are shown as green lines in the image below: Old-growth reserves (outlined in green), established by the original 2011 Woodlot Plan, had roads built through them in 2019. (2) To determine whether the Ministry of Forests had given permission to Younger Brothers for this apparent amendment to the legally-binding 2011 Woodlot Plan, and if so, why, an FOI was filed in late 2021 by the Discovery Islands Forest Conservation Project. The FOI requested all communications between the Ministry of Forests and the principals of Woodlot 2032—including the woodlot’s registered professional forester—back to the beginning of January 2017. The records released to us suggested—by the absence of any records relating to an amendment of the Woodlot Plan—that there had been no written communication between the woodlot tenure holders and the ministry about an amendment of the Woodlot Plan. (3) Asked directly about this change, Younger Brothers’ forester recently provided the Discovery Islands Forest Conservation Project with a letter apparently sent to the Campbell River District Manager in February 2019. The letter described changes to the 2011 plan that involved removing reserves of old forest above Discovery Passage (the areas outlined in green in the image above) and replacing those areas with an area of much younger, sparser forest running up to the top of Darkwater Mountain (the area outlined in green in the image below). Some of the replacement area appears to have been logged in the past. In the amendment, the replacement area and a pre-existing logging road were named the “Manzanita Mountain Recreation Area” and the old logging road was named the “Manzanita Mountain Trail.” The replacement area (outlined in green) on Darkwater Mountain is mainly young forest, some of which has been previously logged (4) The letter stated that the new reserve area was “created to provide recreational opportunities (hiking trail established) and to provide protection for the rare Manzanita plant (arctostaphylos columbiana) which is observed in the area.” (5) Access to Darkwater Mountain (the name for the mountain used by Cape Mudge Forestry, which is operated by We Wai Kai First Nation) by old logging roads predates development of Woodlot 2032. Hairy Manzanita is not “rare.” It can be found in many high areas on Quadra Island and is NOT on the BC Red Blue List. (6) As mentioned above, the letter provided to us by Younger Brothers’ forester was not included by the Campbell River office of the Ministry of Forests in the record of communications between the the Ministry of Forests and Younger Brothers that were obtained by FOI. Recently, the Discovery Islands Forest Conservation Project asked the Campbell River District Manager for an explanation for why the amendment letter had not been included in the FOI release. Subsequently, the District Stewardship Forester indicated to us that this letter could not be found at the District office and there was no record of a response from the District office to Younger Brother’s letter of amendment. Later, District Manager Lesley Fettes sent an email which stated, in part: “I encourage you to report your concerns by making a ‘Report of Natural Resource Violation’ using the online form. This is government’s process to have potential non-compliances investigated.” (7) Younger Brothers’ forester, when asked for an email showing that he had sent the amendment to the District office, stated by email, “As this amendment was 3 years ago, I no longer have the email.” (8) When asked about the switching of reserves from an area of old forest to an area of much younger trees, Younger Brothers’ forester stated that “Minor revisions to retention strategies are acceptable providing the total area under reserve is not reduced.” The replacement area is virtually the same size as the two areas of old forest it replaces. (9) But the Woodlot Licence Planning and Practices Regulation states, in effect, that an amendment is only considered “minor” if it does not “decrease the nature or quality of wildlife trees or wildlife tree retention areas.” In this case, the amendment replaced areas of old forest with an area of mostly younger, sparser forest that appears to have been previously logged. And there is no record in the Campbell River District office that Younger Brothers’ forester sought approval for this amendment. In other words, the amendment appears to be “wrongly made”. A view of the forest in one of the two 2011 wildlife tree retention areas that had roads built through them in 2019. This photo was taken from the road. (10) Under Section 22 (“Minor amendments wrongly made”) of the Woodlot Licence Planning and Practices Regulation, the forests minister may “declare the amendment to be without effect” and may “require the holder to suspend operations that are not authorized in the absence of the amendment”. (11) This is a serious matter. Under Section 52 (2) (“Wildlife tree retention”) of the Woodlot Licence Planning and Practices Regulation, “A woodlot licence holder must not cut, damage or remove wildlife trees or trees within a wildlife tree retention area except in accordance with the wildlife tree retention strategy prepared under section 11”. (12) Under Section 11 (c) (d) (e) (“Wildlife tree retention strategy required”) of the Woodlot Licence Planning and Practices Regulation, the strategy must include “the conditions under which individual wildlife trees may be removed” and “the conditions under which trees may be removed from within a wildlife tree retention area” and “how trees removed…will be replaced.” None of Woodlot 2032’s Woodlot Plans have included these required elements for its wildlife tree retention strategy. (13) Younger Brothers Holdings, by building roads through two wildlife tree retention areas that it had mapped in its approved 2011 Woodlot Plan (as mentioned above in (1)), has cut and damaged trees in what had been wildlife tree retention areas. Did the swapping of the areas of old forest with an area that Younger Brothers had not previously mapped as old forest constitute a “wrongly made” amendment? (14) Again, this is a serious matter. Under Section 90 (“Offences”) of the Woodlot Licence Planning and Practices Regulation, contravening Section 52 is “an offence and is liable, on conviction, to a fine not exceeding $500,000 or to imprisonment for not more than 2 years or to both”. (15) As the Campbell River District office of the Ministry of Forests may have been negligent in its duty to properly file documents and/or determine whether the 2019 amendment was properly or wrongly made, that office should be kept at arms length from any determination of what has occurred. (16) A complaint has been filed with the Forest Practices Board. Until this matter is fully investigated by the Board, the woodlot licence holder should not be permitted to resume operations. A portion of the area of old, mainly primary forest southwest of Darkwater Lake, which contains large, old trees—now a very rare ecosystem on Quadra Island—that would be open to logging if the proposed Woodlot Plan is approved. The small reserves in this area that the 2011 plan created have now been moved to the top of Darkwater Mountain (in the centre background). Note the new logging road in the lower left corner. B. In any case, the proposed Woodlot Plan would be a significant step backward in terms of protection of old forest on Quadra Island. (17) The initial Woodlot Plan that was approved in 2011 was criticized by the Quadra community because it did not fully protect old forest in the woodlot. Since 2011, our understanding of the need to protect all remaining old forest on Quadra Island has grown. Yet the proposed plan would provide even less protection. (18) The 2011 Woodlot Plan identified 56 hectares of “Old Forest Reserves.” The proposed plan now identifies only 20.5 hectares of “Old Forest Reserve”. The Discovery Islands Forest Conservation Project estimates (using drone videography, satellite imagery and on-the-ground confirmation) that there are at least 109 hectares of old forest in this woodlot. That means only 20 percent of the old forest is acknowledged in the “Old Forest Reserve”. The other 80 percent is either not acknowledged in the proposed plan or has been moved into areas newly identified as “Inoperable.” (19) “Operability” is at the discretion of the tenure holder. For the identified “Inoperable” reserves containing old forest, there would be nothing to constrain the tenure holder from deciding later that they are, in fact, operable, and then removing all trees younger than 250 years of age in those areas. (20) Moreover, several areas that had been mapped as old forest in the 2011 plan are no longer identified in any way. This includes 45 hectares of old forest to the southwest of Darkwater Lake on the slope down to Discovery Passage. It also includes 14 hectares of old forest on the western side of Darkwater Mountain. (21) In the 2011 plan, these areas were either old-growth reserves, or areas of old forest where the tenure holder could “modify” the old forest. Each of these had been identified in that plan. (22) In the 2011 plan, for the areas that were to be “modified”, all trees older than 250 years of age were to be retained—unless they posed a danger to worker safety as all the other trees in between the old trees were logged. Forest ecologist Rachel Holt and forester Herb Hammond have advised that his approach would completely defeat the purpose of protecting old forest, which is to conserve biodiversity. Old forest always consists of old trees and an understory of younger trees and plants, not just trees greater than 250 years of age. (23) Furthermore, as mentioned above at (11), under Section 52 (2) of the Woodlot Planning and Practices Regulation, no logging is allowed in wildlife tree patches, so asserting that logging old forest and leaving only the trees 250 years and older supports biodiversity conservation is not supported by the legislation applicable to woodlots. (24) In the nearby Sayward Landcape Unit, no logging—not even single-tree selection—is allowed in pockets of old forest reserved as Wildlife Tree Reserves. (25) The proposed plan would expose even more of the old forest that was clearly reserved in the original Woodlot Plan to this scheme of “modification”. This includes the 45 hectares of old forest to the southwest of Darkwater Lake on the slope down to Discovery Passage. It also includes the 14 hectares of old forest on the western side of Darkwater Mountain. (26) A 16.5-hectare area of primary old forest with big trees—a very rare ecosystem on Quadra Island—just southwest of Darkwater Lake, has no designation whatsoever. This area, along with the old forest north of Darkwater Lake, should be given the highest priority for preservation. Instead, a portion of it has been flagged for logging. The areas of old forest that would be open to logging southwest of Darkwater Lake contain many of Quadra Island’s largest and most ancient Douglas firs. The entire area escaped the 1925 fire. C. The remaining area of old forest on Quadra Island is well below the level required by the provisions of SMZ 19, and TimberWest has committed in its own forest stewardship plan to consult with woodlot tenure holders in SMZ 19 in order to meets its SMZ 19 obligations. (27) Woodlot 2032 is in the area of Quadra Island designated as Special Management Zone 19 by the Vancouver Island Land Use Plan. (28) The target for old forest over the entire area of SMZ 19 is “greater than 9 percent”. (29) The Discovery Islands Forest Conservation Project has established that there are approximately 590 hectares of old forest remaining in the approximately 15,800-hectare area of SMZ 19. That works out to 3.7 percent, far below the target of 9 percent, which itself is an outdated target based on 1990s-era forest management. More current science indicates this would need to be at least 49 percent for a “low risk” of biodiversity loss. (30) Although the 11 woodlots on Quadra don’t necessarily need to meet government objectives for seral stage distribution, TimberWest does. It is legally responsible for ensuring the full 9 percent target for old forest in SMZ 19 is met. To meets its legal responsibility, TimberWest has made a commitment in its forest stewardship plan that it will consult with the woodlot tenure holders to ensure that the seral stage distribution target for SMZ 19 is met. (31) If TimberWest has consulted with Younger Brothers Holdings in an effort to conserve all remaining old forest, for example, there is no evidence of this in Younger Brothers’ proposed Woodlot Plan. (32) The Ministry of Forests is responsible for ensuring that the commitments TimberWest has undertaken in its forest stewardship plan are carried out. Rather than approve the provisions of this Woodlot Plan that would result in logging of old forest, the ministry needs to ensure that TimberWest compensates Younger Brothers for conserving all remaining old forest on Woodlot 2032. This is the only way that TimberWest can meet its own obligation to conserve an area equivalent to at least 9 percent of the total area of SMZ 19 as old forest. D. Renewal of Woodlot 2032 under any plan will result in several unwanted consequences, the cumulative impact of which is much greater than any economic benefits derived from logging in the woodlot. These impacts include: (33) Premature release of carbon emissions, adding to climate instability. For each cubic metre of scaled log volume taken from Woodlot 2032, approximately 1.64 tonnes of CO2-equivalent emissions will be prematurely released to the atmosphere. Since 2011, the accumulated carbon emissions attributable to logging on Woodlot 2032 amount to about 59,000 tonnes. This is equivalent to the emissions created by 12,900 average Canadian passenger vehicles in one year. (34) Loss of carbon sequestration capacity, adding to climate instability. Compared to allowing a forest stand to grow for 300 years, logging the same area on short rotations of about 60 years results in a loss of about 75 percent of the area’s carbon sequestration capacity. Loss of 75 percent of BC’s carbon sequestration capacity will worsen growing climate instability. (35) Increase in forest fire hazard. Logging old or mature forest creates clearcuts and plantations, both of which have a higher forest fire hazard associated with them than does the forest before logging. (36) All logging in BC is subsidized by the public, and the hidden costs of that subsidization are far greater than the short-term economic benefits derived from logging employment and public revenue. (37) A large fraction of the logging that takes place on Quadra Island is used to feed TimberWest’s raw log export business. Log exports have the long-term result of the loss of future local wood product manufacturing jobs. (38) Clearcut logging of areas of Quadra Island that have high recreational value, such as the area of Woodlot 2032, provides the lowest long-term economic value to the local community. Visitors do not intentionally come to Quadra Island to view clearcut logging. They come here to experience the island’s scenic beauty, its many lakes and developed tourism amenities. E. In light of Premier David Eby’s commitment to protect 30 percent of BC by 2030, the Ministry of Forests must plan to take back the Crown land on Quadra Island currently tenured to Woodlot 2032. (39) Premier David Eby recently directed Minister of Land Stewardship Nathan Cullen to prepare for protecting 30 percent of BC’s land and water by 2030. (40) Woodlot 2032 is within the Coastal Western Hemlock biogeoclimatic zone, which contains both the greatest species richness of any BC biogeoclimatic zone and the most endangered species. In bringing BC to an overall 30 percent protected, the Coastal Western Hemlock biogeoclimatic zone should be at least 30 percent protected. (41) Since only 18 percent of Quadra Island is currently protected (4913 ha), an additional 3300 hectares—at least— will need to be moved from the timber harvesting land base to protected status by 2030. (42) There are approximately 314 hectares of Crown Land on Quadra Island (Sensitive Areas at Heriot Ridge, Hyacinthe Point and Saltwater Lagoon) that are not in a woodlot or in TFL 47. (43) That leaves a minimum of 3000 hectares that will need to come from Crown land that is either in a Woodlot Licence tenure or from TFL 47. (44) Early consultation with First Nations is required to determine what parts of the timber harvesting land base should be shifted to protected status, or perhaps Tribal Park status. In that context, as well as for all of the reasons noted above, approving an additional 10-year term for Woodlot 2032 at this time would be imprudent. Records released by Ministry of Forests: FOR-2022-22703 Record of communications between Ministry of Forests and Woodlot 2032.pdf For more information about Woodlot 2032, including the proposed Woodlot Plan, see this page. For more information about Darkwater Forest, see this page. For more information about Darkwater Mountain Forest, see this page and this page.

The project will provide a fuller analysis of this important document as soon as possible. In the interim, we note that Appendix 3 (page 52) includes information on stand-replacing natural disturbance return intervals for all biogeoclimatic units in BC and estimates for natural levels of old forest (>250 years). In the Discovery Islands that interval is 700 years for the three predominant variants: CWHxm1, CWHxm2 and CWHdm. The Cumulative Effects Framework has estimated that 70 percent of these forests would have been old forest in their naturally-occurring state. To maintain a “low” risk of biodiversity loss, forest scientists have determined that old forest should not fall below 70 percent of the naturally occurring level. For the Discovery Island biogeoclimatic variants, that would mean no less than 49 percent (.70 x .70) of the forested area of the islands should be old forest. The current forest management regime has resulted in old forest falling below 10 percent in each of CWHxm1, CWHxm2 and CWHdm. Thus the urgent need for a paradigm shift in forest management on the Discovery Islands. You can download this document by clicking on the icon below, or read it here. Standards for Assessing the Condition of Forest Biodiversity under British Columbia’s Cumulative Effects Framework Sept 2020.pdf

Above Yeatman Bay, on the east side of Mount Yeatman, there are extensive areas of old forest. The project has photographed these groves by drone and from Okisollo Channel but has not yet visited these areas on foot. Some of them are in Main Lake Provincial Park, but they are mainly in Cape Mudge Forestry’s Woodlot 1970. In 2022 the company was currently building a logging road into the area, which also contains second-growth forest.

This is a work in progress.

The 2019 the provincial government asked foresters Gary Merkel and Al Gorley to undertake a strategic review of the state of BC’s old-growth forests. Their report led the BC government to seek First Nations’ approval for temporary logging deferrals on 2.6 million hectares of forest that government databases have identified as old forest. (2020) A New Future For Old Forests-Gorley-Merkel.pdf One page of this report that is particularly relevant to the Discovery Islands Forest Conservation Project is the description of the risk to biodiversity in areas that now have low levels of old forest compared to their original state, and the list of biogeoclimatic zones where that risk is high. The list includes the three main biogeoclimatic zone variants that occur in the Discovery Islands. Below is the text from page 31 of the report: "Knowing how much to maintain as forest with old trees is guided by the notion that mimicking nature is the approach that presents the least risk to biodiversity. The concept used to measure this is called 'natural range of variability' (NRV). This is typically based on a description of ecosystems as they existed before major changes brought about by extensive industrial or agricultural activity. Conservation science provides us with a general risk rating, telling us that if we retain 70% or more of the natural abundance of forest with old trees the risk of species loss, compromised ecosystem services, and losing ecosystem resilience is low. If we retain below 30%, the risk is high. At between 30% and 70%, the risk varies by ecosystem. "Consistent with what we heard from several provincial government staff, a recent report submitted to the panel by a group of independent scientists illustrates that we are in situations of high risk to biodiversity in many areas in the province, particularly in high-productivity, low elevation ecosystems. More troubling is the future projection where almost all of the province will be in high biodiversity risk once our current management approach harvests most of the available old forest. The time to complete this transition depends on the available old forest and various industry and economic factors in each region. "Their research also provided the following list of BEC zones that contain less than 10% of their original old forests: CDFmm (all CDF), CWHxm1,2, dm, CHxw, mk3,4, mw1,2,3,4, IDFxc, xh1,2,4, xk, xm, xs, xx2, dc, dk1,2,3,4,5, dm1,2, mw1,2, PPxh1,2,3 (all PP), SBPSmk, SBSwk1,2,3a, and possibly: ESSFxv2, dc1, mh, mv1,2,3,4, wc3,4, wh3, wk1 and wm1,2,3,4. "They note that there is some uncertainty because of potential misclassification of age in some of these units, and also recommend that these areas be deferred from further development until we have brought them back enough to meet current legislated targets. "Several practitioners also raised the issue of our current management system combining old forests and using their aggregated data when making assessments for managing biodiversity risk and planning for old forest retention. One example was parks and protected areas, where an initial net down estimate is removed at the landscape level and then netted out again at the detailed operations level, resulting in double counting. A related concern is that many parks and protected areas contain low-productivity old forests, which are deducted from total old growth aggregate targets without identifying which ecosystem they represent. These types of aggregation calculations overlook distribution and spatial considerations that are crucial in managing for effective ecosystem health." The main biogeoclimatic zone variants in the Discovery Islands are CWHxm1, CWHxm2, and CWHdm, all estimated to have less than 10 percent of the natural level of old forest remaining, thus putting each of these variants at high risk of biodiversity loss.

Okisollo Resources is actively logging in areas of Woodlot 2031 that contain old forest. On Hummingbird Mountain’s southeast side, there remain (as of 2019) two areas of old forest, shown in the image below outlined in green. However, Okisollo did extensive logging in this area in 2020 and may have logged old forest in the outlined area to the left.