David Broadland

A summer moonrise over Texada Island. The south end of Cortes Island is on the left, Quadra Island’s Rebecca Spit is on the right. (Photo by David Broadland) Library: Conservation of forests is needed to protect biodiversity Library: Conservation of forests is needed to mitigate climate change Library: Logging and plantations create higher forest fire hazard Library: Indigenous title and rights

Tsilhqot'in Nation v. British Columbia 2014.pdf

Delgamuukw v. British Columbia (1997).pdf

Sparrow decision.pdf

Calder decision.pdf

ABSTRACT: This is the opinion and order (2019) made by a US District Court in Oregon in a case brought against the US Bureau of Land Management by Oregon Wild. In it, analysis of BLM's record of conduct regarding a specific clearcut makes evident that BLM was aware that, following logging, a higher fire hazard would exist for 40 years. Although independent scientists studying the issue have found that logging increases fire risk, this is one of very few examples in which the record of a land manager admitting this relationship has been made public. Cascadia Wildlands v. Bureau of Land Management (2019).pdf

By Harold S. J. Zald and Christopher J. Dunn ABSTRACT: Many studies have examined how fuels, topography, climate, and fire weather influence fire severity. Less is known about how different forest management practices influence fire severity in multi-owner landscapes, despite costly and controversial suppression of wildfires that do not acknowledge ownership boundaries. In 2013, the Douglas Complex burned over 19,000 ha of Oregon & California Railroad (O&C) lands in Southwestern Oregon, USA. O&C lands are composed of a checkerboard of private industrial and federal forestland (Bureau of Land Management, BLM) with contrasting management objectives, providing a unique experimental landscape to understand how different management practices influence wildfire severity. Leveraging Landsat based estimates of fire severity (Relative differenced Normalized Burn Ratio, RdNBR) and geospatial data on fire progression, weather, topography, pre-fire forest conditions, and land ownership, we asked (1) what is the relative importance of different variables driving fire severity, and (2) is intensive plantation forestry associated with higher fire severity? Using Random Forest ensemble machine learning, we found daily fire weather was the most important predictor of fire severity, followed by stand age and ownership, followed by topographic features. Estimates of pre-fire forest biomass were not an important predictor of fire severity. Adjusting for all other predictor variables in a general least squares model incorporat- ing spatial autocorrelation, mean predicted RdNBR was higher on private industrial forests (RdNBR 521.85 18.67 [mean SE]) vs. BLM forests (398.87 18.23) with a much greater proportion of older forests. Our findings suggest intensive plantation forestry characterized by young forests and spatially homogenized fuels, rather than pre-fire biomass, were significant drivers of wildfire severity. This has implications for perceptions of wildfire risk, shared fire management responsibilities, and developing fire resilience for multiple objectives in multi-owner landscapes. Severe fire weather and intensive forest management increase fire severity in a multi-ownership landscape (2018).pdf

By Curtis M. Bradley, Chad T. Hanson et al ABSTRACT: There is a widespread view among land managers and others that the protected status of many forestlands in the western United States corresponds with higher fire severity levels due to historical restrictions on logging that contribute to greater amounts of biomass and fuel loading in less intensively managed areas, particularly after decades of fire suppression. This view has led to recent proposals—both administrative and legislative—to reduce or eliminate forest protections and increase some forms of logging based on the belief that restrictions on active management have increased fire severity. We investigat- ed the relationship between protected status and fire severity using the Random Forests algorithm applied to 1500 fires affecting 9.5 million hectares between 1984 and 2014 in pine (Pinus ponderosa, Pinus jeffreyi) and mixed-conifer forests of western United States, accounting for key topographic and climate variables. We found forests with higher levels of protection had lower severity values even though they are generally identified as having the highest overall levels of biomass and fuel loading. Our results suggest a need to reconsider current overly simplistic assumptions about the relationship between forest protection and fire severity in fire management and policy. Does increased forest protection correspond to higher fire severity in frequent-fire forests of the western United States? (2016).pdf

ABSTRACT: Wildfires across western North America have increased in number and size over the past three decades, and this trend will continue in response to further warming. As a consequence, the wildland–urban interface is projected to experience substantially higher risk of climate-driven fires in the coming decades. Although many plants, animals, and ecosystem services benefit from fire, it is unknown how ecosystems will respond to increased burning and warming. Policy and management have focused primarily on specified resilience approaches aimed at resistance to wildfire and restoration of areas burned by wildfire through fire suppression and fuels management. These strategies are inadequate to address a new era of western wildfires. In contrast, policies that promote adaptive resilience to wildfire, by which people and ecosystems adjust and reorganize in response to changing fire regimes to reduce future vulnerability, are needed. Key aspects of an adaptive resilience approach are (i) recognizing that fuels reduction cannot alter regional wildfire trends; (ii) targeting fuels reduction to increase adaptation by some ecosystems and residential communities to more frequent fire; (iii) actively managing more wild and prescribed fires with a range of severities; and (iv) incentivizing and planning residential development to withstand inevitable wildfire. These strategies represent a shift in policy and management from restoring ecosystems based on historical baselines to adapting to changing fire regimes and from unsustainable defence of the wildland–urban interface to developing fire-adapted communities. We propose an approach that accepts wildfire as an inevitable catalyst of change and that promotes adaptive responses by ecosystems and residential communities to more warming and wildfire. Adapt to more wildfire in western North American forests as climate changes (2016).pdf

By John L. Campbell, Mark E. Harmon and Stephen R Mitchell It has been suggested that thinning trees and other fuel-reduction practices aimed at reducing the probability of high-severity forest fire are consistent with efforts to keep carbon (C) sequestered in terrestrial pools, and that such practices should therefore be rewarded rather than penalized in C-accounting schemes. By evaluating how fuel treatments, wildfire, and their interactions affect forest C stocks across a wide range of spatial and temporal scales, we conclude that this is extremely unlikely. Our review reveals high C losses associated with fuel treatment, only modest differences in the combustive losses associated with high-severity fire and the low-severity fire that fuel treatment is meant to encourage, and a low likelihood that treated forests will be exposed to fire. Although fuel-reduction treatments may be necessary to restore historical functionality to fire-suppressed ecosystems, we found little credible evidence that such efforts have the added benefit of increasing terrestrial C stocks. (2012) Can fuel-reduction treatments really increase forest carbon storage in the western US by reducing future fire emissions?.pdf

By David B. Lindenmayer et al ABSTRACT: Does logging affect the fire proneness of forests? This question often arises after major wildfires, but data suggest that answers differ substantially among different types of forest. Logging can alter key attributes of forests by changing microclimates, stand structure and species composition, fuel characteristics, the prevalence of ignition points, and patterns of landscape cover. These changes may make some kinds of forests more prone to increased probability of ignition and increased fire severity. Such forests include tropical rainforests where fire was previously extremely rare or absent and other moist forests where natural fire regimes tend toward low frequency, stand replacing events. Relationships between logging and fire regimes are contingent on forest practices, the kind of forest under consideration, and the natural fire regime characteristic of that forest. Such relationships will influence both the threat of fire to human life and infrastructure and biodiversity conservation. We therefore argue that conservation scientists must engage in debates about fire and logging to provide an environmental context to guide considered actions. Effects of logging on fire regimes in moist forests David B. Lindenmayer (2009).pdf

By Solomon Z. Dobrowski et al Expanding the global protected area network is critical for addressing biodiversity declines and the climate crisis. However, how climate change will affect ecosystem representation within the protected area network remains unclear. Here we use spatial climate analogs to examine potential climate-driven shifts in terrestrial ecoregions and biomes under a +2 °C warming scenario and associated implications for achieving 30% area-based protection targets. We find that roughly half of land area will experience climate conditions that correspond with different ecoregions and nearly a quarter will experience climates from a different biome. Of the area projected to remain climatically stable, 46% is currently intact (low human modification). The area required to achieve protection targets in 87% of ecoregions exceeds the area that is intact, not protected, and projected to remain climatically stable within those ecoregions. Therefore, we propose that prioritization schemes will need to explicitly consider climate-driven changes in patterns of biodiversity. (2021) Protected-area targets could be undermined by climate change-driven shifts in ecoregions and biomes.pdf

By Karen Price, Rachel Holt, and Dave Daust The Province has appointed a task force to investigate the state of BC’s old growth forest. The panel will report to government in April 2020. The old growth task force website1 shows a map of the old growth forest in BC — and says “Based on government’s working definition, old-growth forests comprise about 23% of forested areas, or about 13.2 million hectares”. We have written this report because old growth cannot be portrayed by a single number or map. Old forest comes in many forms. We have used publicly available provincial data and definitions to examine the status of different types of old forest found across the province in different ecosystems (biogeoclimatic variants) and productivity classes. These distinctions matter because while all forms of old growth have inherent value, different types provide tremendously different habitat, functional, cultural, spiritual and timber values. BC’s globally rare high productivity forests have particular value for their high biomass, structural complexity and stable carbon storage. Our analysis concludes the following: The provincial total area of old forest (~13.2 million hectares) matches our total. The vast majority of this forest (80%) consists of small trees: › ~5.3 million hectares have site index2 5–10m; another ~5.3 million hectares have a site index 10–15m. › Small trees characterize many of BC’s natural old forest types, including black spruce bog forests in the northeast, subalpine forests at high elevation, and low productivity western redcedar forests on the outer coast. › Large areas of this old forest type remain because the trees are too small to be worth harvesting (under today’s prices). In contrast, only a tiny proportion of BC’s remaining old forest (3%) supports large trees: › ~380,000 hectares have a site index 20–25m, and only ~35,000 hectares of old forest have a site index greater than 25m. › These types of forests match most people’s vision of old growth. They provide unique habitats, structures, and spiritual values associated with large trees. › Productive old forests are naturally rare in BC. Sites with the potential to grow very large trees cover less than 3% of the province. Old forests on these sites have dwindled considerably due to intense harvest so that only 2.7% of this 3% is currently old (see pie chart). These ecosystems are effectively the white rhino of old growth forests. They are almost extinguished and will not recover from logging. › Over 85% of productive forest sites have less than 30% of the amount of old expected naturally, and nearly half of these ecosystems have less than 1% of the old forest expected naturally. This current status puts biodiversity, ecological integrity and resilience at high risk today. A Last Stand For Biodiversity (2020).pdf

By Alana R. Westwood et al British Columbia has the greatest biological diversity of any province or territory in Canada. Yet increasing numbers of species in British Columbia are threatened with extinction. The current patchwork of provincial laws and regulations has not effectively prevented species declines. Recently, the Provincial Government has committed to enacting an endangered species law. Drawing upon our scientific and legal expertise, we offer recommendations for key features of endangered species legislation that build upon strengths and avoid weaknesses observed elsewhere. We recommend striking an independent Oversight Committee to provide recommendations about listing species, organize Recovery Teams, and monitor the efficacy of actions taken. Recovery Teams would evaluate and prioritize potential actions for individual species or groups of species that face common threats or live in a common area, based on best available evidence (including natural and social science and Indigenous Knowledge). Our recommendations focus on implementing an adaptive approach, with ongoing and transparent monitoring and reporting, to reduce delays between determining when a species is at risk and taking effective actions to save it. We urge lawmakers to include this strong evidentiary basis for species recovery as they tackle the scientific and socioeconomic challenges of building an effective species at risk Act. (2018) Protecting biodiversity in British Columbia- Recommendations for developing species at risk legislation.pdf

By Julia R. Chandler, Sybille Haeussler, Evelyn H. Hamilton, Michael Feller, Gary Bradfield, Suzanne W. Simard Forests are being clearcut over extensive areas of western North America, but plant community response to harvesting and slashburning under varying climatic conditions in central British Columbia, Canada is still largely unknown. Evaluation of resilience is hampered by the short history of logging, lack of long-term experiments and methodological limitations. To test the effect of clearcut logging, prescribed burning and reforestation on forest resilience, we recorded vascular plant cover repeatedly after treatment between 1981 and 2008 in 16 permanent research installations in three biogeoclimatic zones: Engelmann Spruce- Subalpine Fir, Interior Cedar-Hemlock and Sub-Boreal Spruce. We created a plant-trait dataset for the 181 recorded species to define plant functional types representing groups of plants that behave in similar ways and/or produce similar ecological outcomes. These plant functional types, along with taxonomic analysis of diagnostic and indicator species, were then used to evaluate plant community response to disturbance. Twenty years post-treatment, species diversity increased in all zones and plant abundance was greatest in the Interior Cedar-Hemlock. Cover of understory plant functional types associated with mature conifer forests increased in all zones, constituting a significant proportion (> 40%) of the vegetation community by year 20. Response patterns varied by zone and with time. Understory species diagnostic of mature forests were present in all zones by year 20, but we identified indicator species sensitive to slashburning or requiring more time for recovery, including white-flowered rhododendron (Rhododendron albiflorum) and devil’s club (Oplopanax horridus). Overall, loss of compositional or functional diversity following harvest and site remediation was not detected, suggesting that montane and subalpine forests in British Columbia are resilient to this treatment. However, because these forests can be slow to recover from disturbance, the post-disturbance assessment window of this study may not have been long enough to detect diminishment of ecosystem resilience. (2017) Twenty years of ecosystem response after clearcutting and slashburning in conifer forests of central British Columbia, Canada (2017).pdf

By Nick M. Haddad et al We conducted an analysis of global forest cover to reveal that 70% of remaining forest is within 1 km of the forest’s edge, subject to the degrading effects of fragmentation. A synthesis of fragmentation experiments spanning multiple biomes and scales, five continents, and 35 years demonstrates that habitat fragmentation reduces biodiversity by 13 to 75% and impairs key ecosystem functions by decreasing biomass and altering nutrient cycles. Effects are greatest in the smallest and most isolated fragments, and they magnify with the passage of time. These findings indicate an urgent need for conservation and restoration measures to improve landscape connectivity, which will reduce extinction rates and help maintain ecosystem services. (2015) Habitat fragmentation and its lasting impact on Earth’s ecosystems.pdf

The logging industry—and its government facilitators—don’t want the BC public to know how wasteful the industry is, but it’s hard to hide. The economic costs of that waste are enormous. Teal Cedar Products Ltd’s cedar shake and shingle mill beside the Fraser River in Surrey. About half of the cedar logs that go through the mill end up in the pile on the right. TEAL CEDAR PRODUCTS LTD, the company in the news over its logging of old-growth forests on southern Vancouver Island, knows something that it doesn’t want you to know: About one-half of the ancient forest Teal cuts in TFL 46, trucks to its log sort at Duke Point, and then booms across the Salish Sea and up the Fraser River to its mill in Surrey, spends time as a pile of sawdust and wood chips on its way to a pulp mill or a bag of garden mulch or some other low value product. About half. According to data published by the BC ministry of forests, approximately 52 percent of the logs removed from BC forests become wood chips or sawdust. Teal’s mill is no different. The image above shows its shake and shingle mill on the Fraser River. That big pile of sawdust on the right? That’s the destination of approximately half of the old-growth cedar logs it removed from TFL 46 near Port Renfrew. Like the wood waste from any other mill in BC, the sawdust and wood chips are then transported to a pulp or pellet mill and turned into short-lived products like newsprint, toilet paper, burnable pellets or garden mulch. But the extent to which the forest is wasted when it’s logged is actually much worse than this, whether it’s old growth or second growth. What can’t be seen in the mill image is the slash left behind in the clearcuts after logging: The stumps and roots, the non-merchantable tops, the branches, parts of the tree that were broken during felling, the rotten parts of the trees, smaller unmerchantable trees, standing dead snags, and woody debris on the forest floor. Oh, and the understory plants and the underground mycorrhizal network. Approximately one-half of the total biomass of a forest that is killed by logging stays in the clearcut until it burns or decomposes and then passes into the atmosphere. Yes, this would all happen over time, naturally. But logging unnaturally shrinks the time frame within which that occurs, and, in the developing climate emergency, accelerating the process of returning forest carbon to the atmosphere could be suicidal. Logging slash left after clearcut logging of old-growth forest in the Klanawa River Valley on southern Vancouver Island (Photo by TJ Watt) The wasted biomass left in the clearcut, along with the piles of sawdust and wood chips at the mill, account for 75 percent of the original biomass that was in an old-growth stand before it was logged. That’s not a typo. Seventy-five percent. In BC, of the remaining 25 percent that gets turned into lumber, plywood, veneer, panels, shakes, shingles and poles, about 80 percent of that is exported, mostly to the USA, China and Japan. That means that only about 5 percent of the total forest biomass that is killed in BC each year by logging is actually used here as a product that could store carbon for more than a couple of years. Five percent. The other 95 percent is the forest industry’s big, dirty secret. This matters because there is a climate emergency. Killing forests means killing the most effective way to remove carbon dioxide from the atmosphere and safely store it for hundreds of years. Over the past 20 years in BC, mainly as a result of logging, the province’s forests have lost over 90 percent of their annual capacity to sequester atmospheric carbon. It also matters because killing forests means killing the wildlife that lived in those forests. As a consequence of logging, BC is experiencing an unprecedented decline in wildlife populations. The greatest cause of biodiversity collapse is loss of habitat. And it also matters because British Columbians are subsidizing this colossal forest-wasting exercise: By paying for the forest management necessary for the gargantuan scale of logging involved to meet export market demand, by subsidizing the industry’s electrical energy usage, and by failing to tax the immense carbon emissions and loss of carbon sequestration capacity caused by the forest industry. As awareness of these facts grows, both the ministry of forests and industry are desperately trying to create counter arguments about the damage the industry is doing to climate stability and wildlife. On the government side, provincial and federal forest mandarins are scrambling to promote initiatives that make it appear they are on the verge of mitigating the harms to climate and biodiversity. “Innovations” like “collecting harvest residuals” to make “bioenergy” and “mass timber construction” to store carbon are being promoted as climate friendly reasons why forest conservation is unnecessary. These initiatives—eviscerated by serious scientists—only address the symptoms, not the disease itself, which is too much logging. Worse, these unproven initiatives likely will have no impact at actually reducing the harm, and instead provide only the appearance of “We’ve got this.” The forests ministry’s own account of “fibre flows” shows (diagram below) how little of what they call “harvest residuals” is actually being collected. In 2019, approximately 800,000 cubic metres of residuals were collected of the approximately 50 to 60 million cubic metres of biomass left in clearcuts—just over 1 percent.

In the last two years, the cost of hidden subsidization of BC’s logging industry has been greater than the industry’s contribution to BC’s GDP. And it's going to get worse. IN 2020 I WROTE A STORY titled “Forestry doesn’t pay the bills, folks.” It looked at the costs and revenues of the ministry of forests over a 10-year period and found that, over that time, the ministry spent about a million dollars a day more than it took in through stumpage revenue and the BC Logging Tax. While many people appreciated that analysis, others found it flawed. The skeptics noted that costs were based on entire ministry costs, not just forest-related costs. The Ministry of Forests, Lands, Natural Resource Operations and Rural Development, they believed, had many costs that were not related to forest management. Take those out and the picture would change, they hoped. Others noted that my analysis didn’t include export, corporate or municipal taxes paid by forestry companies or the income taxes paid by forestry workers, and so forth. Others observed that the analysis didn’t include costs such as the $24 million paid by the community of Peachland, which needed to install an expensive water treatment facility to take out the sediment that clearcut logging has introduced to its watershed; it didn’t include the estimated $100 million cost to the community of Grand Forks where flooding attributed to logging in the Kettle and Granby watersheds has cost people their homes and overturned their lives. Nor did it include the cost of fisheries lost as a result of increased sedimentation and rising water temperatures caused by clearcutting over 250,000 hectares of forest each year. And so on. In other words, there were two kinds of objections: 1. You didn’t credit the forest industry for all the revenue it provides for government, and 2. You didn’t include all the costs. This is an update of my first analysis, starting with the objections about not including all the revenue to government that the forest industry generates. I am interested in your objections to this report. I’ll include them when I update this story down the road. So let’s start with a brief reexamination of the numbers in my first report. The forest management subsidy Although the ministry publishes an Annual Service Report that provides generalized breakdowns of costs and revenues, it doesn’t specify which are forest-related expenses and revenues. So I filed FOIs with the Ministry of Forests, Lands, Natural Resource Operations and Rural Development aimed at clarifying what ministry revenue and expenses were forest-related. The documents released (attached at end of story) show the vast majority of its expenses are forest-related. The ministry’s account of its forest revenues increased the value of those revenues slightly over what I had estimated from their Annual Service Plans. In the graph below I show the net deficit for each year, 2010 to 2019. The cumulative operating deficit of the ministry over 10 years was $3.44 billion rather than the $3.65 billion identified in my earlier story. That works out to $942,466 a day. Taxes paid by workers and corporations don’t pay ministry bills, they pay for services used So what about the question of the personal income taxes paid by forestry workers and the municipal and corporate taxes paid by forest companies? Shouldn’t those be included, somehow, in determining whether “forestry pays the bills”? The ministry of forests, of course, doesn’t include corporate or municipal taxes paid by forestry companies or the income taxes paid by forestry workers in its reckoning of revenue, and for good reason. In each case, the taxes collected by some level of government, like municipal taxes collected from a sawmill operating within a municipality, or income taxes collected from a feller-buncher operator in Quesnel, go to pay for a host of services provided by that government that have nothing to do with the ministry of forests. These are services that are consumed, in part, by that sawmill or that feller-buncher operator. For example, the healthcare services provided to residents of a community with a mill operating in it are paid for by such revenue streams as corporate and income taxes. When the feller-buncher operator needs a hip replacement as a result of a work-related injury, the cost of that surgery is paid for by such government revenue streams. When the home of the head sawyer at the local sawmill is burglarized, the police that investigate are paid for by such revenue streams. The mill manager’s children are educated in a school that is partly funded by property taxes collected by the municipality, including from the mill. Forestry workers, and the companies they work for, aren’t just paying for government services through their taxes. Like the rest of us, they are also consumers of those services. Their taxes pay for their own use of myriad government services, just like every other kind of taxpayer. By the way, for various reasons, people who live in forestry-dependent communities have notoriously high health costs compared with urban populations. In general, all the arguments from the forest industry and its supporters about how much they contribute to the provincial economy are half true; they always fail to include in their analysis all the costs to government that are incurred to keep them housed, warm, fed, clothed, educated, employed, policed, healthy, mobile, governed and defended from enemies, both internal and external. The same principle applies to corporate income taxes. Those taxes go to pay for a host of government services those corporations consume, as well as the cost of the burdens their operations impose on the rest of the community. All workers and corporations in BC pay taxes, not just forest industry workers and corporations. In fact, in 2019, 98.2 percent of the workers in BC who paid taxes were not forest industry workers. Only a tiny fraction of BC companies that paid corporate income taxes were forestry companies. Another aspect of the ministry’s costs that people questioned was the “direct fire management” cost, the cost of fighting forest fires. To what extent is this cost actually attributable to the logging industry? All of BC’s largest fires in 2021 included large areas of clearcuts and plantations. Those clearcuts and plantations raise fire hazard to “high” for up to 30 years. They create fuel conditions in which fires are easier to ignite and harder to control, and so we are experiencing larger fires more frequently than would be the case had there been no logging. Moreover, much of the money spent fighting those fires is paid to logging companies and allied businesses. The logging industry needs to man-up and acknowledge its role in causing and benefitting from these fires. Forest fires destroy structures, damage community economies, harm human health and kill people. None of those costs have been included in the ministry’s accounting of “direct fire management costs,” and so attributing all of the ministry’s cost of fighting forest fires to the logging industry is likely a significant undercount of the true costs. Now let’s consider some of the costs I left out of my first analysis. Here, there’s plenty of room for improvement over my previous assessment. What constitutes a subsidy? First off, let’s define the term “subsidy.” The World Trade Organization does that in detail. Here, I paraphrase that organization’s definition of “subsidy.” A subsidy is deemed to exist when a government makes a direct transfer of funds; or government revenue that is due is foregone or not collected; or a government provides goods or services other than general infrastructure; or a government makes payments to a private body to carry out the type of functions that would normally be vested in government; and, as a result of any or all of these circumstances, a benefit is thereby conferred to an industry. The “forest management subsidy” illustrated in the graph above is an example of government revenue that is due but not collected. The BC government sets stumpage rates, yet those stumpage rates—even after all other sources of forest revenue are included—consistently do not cover the ministry’s operational costs for managing the industry’s operations on public land. As a result of the BC government’s failure to require the logging industry to pay for the cost of managing forest removal on public land, a benefit is conferred to the industry. That constitutes a public subsidy of the industry. Public subsidization of the forest industry’s consumption of electricity Now let’s consider other benefits conferred on the forest industry, starting with public subsidization of the electricity it consumes. Over the 10-year period for which we gathered data, the public subsidization of the cost of electricity used by forest companies amounted to $5.1 billion. You won’t find a record of this public subsidy anywhere in the forest industry’s or the ministry of forests’ public accounts of their operations. It occurs entirely as a result of BC Hydro’s inequitable rate structure. Here’s how we calculated it: Residential consumers of electricity in BC—who, as a class, are BC Hydro’s largest customer—pay a two-tiered rate for electricity. If a residential customer keeps their consumption to less than 675 kilowatt-hours per month, they pay 9.3 cents per kilowatt-hour. If they go over 675 kilowatt-hours, they pay 13.94 cents per kilowatt-hour. The principle applied to residential consumers is this: If you consume more than a set amount, you pay a higher rate. BC Hydro uses this strategy in order to encourage consumers to conserve electricity. Why? Because supplying additional capacity is very expensive. Consider the estimated $16 billion cost of Site C to understand just how expensive supplying additional capacity can be. But this principle of applying a higher rate for higher consumption is flipped on its head when it comes to forest industry consumers of electricity. BC Hydro’s current rate for “Large General Service” users—those customers whose average monthly consumption is at least 45,833 kilowatt-hours, and that would include all BC pulp and paper mills and virtually all sawmills and veneer/panel mills—is currently 5.96 cents per kilowatt-hour, no matter how much electricity is consumed. If a mill uses less than 45,833 kilowatt-hours, they pay a higher rate. Why wouldn’t the same principle of higher rates for higher levels of consumption be applied to the forest industry if the rationale for higher rates for consumers is to get them to conserve expensive capacity? Over the last 5 years, the forest industry has consumed an average of 6000 gigawatt-hours per year of BC Hydro’s output. Site C will generate 5100 gigawatt-hours of electricity per year. If the forest industry consumes the equivalent of Site C’s capacity, why aren’t there rates in place that would encourage industry consumers, like residential consumers, to conserve? And why should the industry pay less in any case? This preferential treatment amounts to a public subsidy. The magnitude of the subsidy can be determined from the difference in the rates for residential consumers and forest industry consumers. Since BC Hydro does not apply the same principle to forest product mills as it applies to residential consumers, the forest industry is being subsidized by BC Hydro residential consumers. That subsidy amounted to 4.81 cents per kilowatt-hour in 2010 and rose to 7.98 cents per kilowatt-hour by 2020. We obtained records through an FOI request for BC Hydro records that show the electrical energy consumption of BC forest industry companies for 5 years in that 10-year period (attached at the end of the story). Based on those numbers, and other data that allowed extrapolation for the years we didn’t have, we calculated that the public subsidization of the forest industry’s use of electricity amounted to $5.1 billion. Some of you will question whether the lower electricity rates given to the forest industry by publicly owned BC Hydro can actually be considered a public subsidy. You might point to WTO rulings in the Softwood Lumber Dispute regarding US claims that two BC forest companies were paid excessive rates for electrical energy they sold to BC Hydro. Those claims were rejected by the WTO, but not because differences in electricity rates can’t constitute a subsidy. The resolution of that issue by the WTO, in fact, confirms that electrical rates can constitute a subsidy. But the WTO’s mandate isn’t to consider the public interest. It’s only interest is in promoting international trade. For the average British Columbian, who has long been told by the industry and its promoters that “forestry pays the bills, folks,” the important issue is how much of the logging industry’s electricity bills are actually being paid by the excessively high rates of ordinary folks. Over the past ten years that has amounted to $5.1 billion. Public subsidization of the forest industry’s release of forest carbon emissions When an area of BC forest is clearcut, it is immediately transformed from being a carbon sink into a carbon source. While the forest industry and its supporters argue that the carbon in all forests will eventually return to the atmosphere anyway, the acceleration of this return caused by clearcutting creates an immense surge in carbon emissions that would never have occurred naturally, especially in the time frame in which this is occurring. Moreover, turning primary forests into plantations, where the intention is to log the plantation in 45 to 80 years, creates a large carbon debt that will never be repaid. Carbon that enters the atmosphere as a result of the forest industry’s activities has the same physical effect as carbon coming from a car’s tailpipe; they both cause global heating. In response to the climate emergency, the BC government introduced a carbon tax in 2008 which applied only to fossil fuels. The BC government acknowledged that carbon emissions needed to be reduced in order to avoid damage that could be expected as the result of climate change. They were thinking of such events as those that overwhelmed BC in mid November 2021, in which communities were flooded and transportation infrastructure was badly damaged. The fires in the summer of 2021 caused similar losses, with Lytton burned to the ground. These events will be very costly to BC taxpayers. By not applying the Carbon Tax to the forest industry’s forest-removal activities—which cause far greater carbon emissions than the burning of hydrocarbon fuels in BC—a financial benefit was conferred on the forest industry. That is, the public is subsidizing the forest industry’s carbon emissions. For the period 2010 to 2020, that subsidy is shown in the graph below: We calculated this subsidy based on the rate of the Carbon Tax for each year and the estimated biomass of forest removed in each of those years. We used the ministry of forests’ Harvest Billing System to determine the volume of logs removed from public land for each of the 10 years, and used the results of a scientific study conducted by Suzanne Simard and Jean Roach to estimate the original forest biomass those logs came from. The summary of how that biomass was estimated can be found here. We determined the value of annual forest carbon emissions by using the value of the BC Carbon Tax that was applicable in each of the 10 years. The total 10-year value of carbon emissions subsidization was $31.5 billion, or an average of $3.15 billion per year. In 2019, the BC Carbon Tax was $40 per metric tonne. Since the carbon tax is set to increase to $170 per tonne by 2030, this annual subsidy will rapidly increase in size. Public subsidization of the loss of carbon sequestration capacity caused by the forest industry Lastly, we calculated the subsidy related to the loss of carbon sequestration capacity caused by logging in the period 2010 to 2019. To calculate this subsidy we used the Province’s own account of net carbon sequestration capacity loss and the applicable level of the Carbon Tax for each of those years. Through the 1990s the province’s carbon sequestration capacity—the net amount of carbon BC forests could take out of the atmosphere each year—held relatively steady at about 90 million tonnes of CO2-equivalent. Beginning in 1999, as a result of logging and forest loss from other causes, the capacity of BC forests began to fall. The Province has estimated that capacity each year. Here’s what that decline looks like: To calculate the cumulative amount of this loss, we used the difference between the level in the 1990s and the level estimated by the Province for each year between 2010 and 2019. We then calculated a dollar value for the carbon sequestration that didn’t occur each year, using the value of the Carbon Tax that was applicable in each of those years. That totalled close to $22 billion over 10 years. How much of this should be attributable to logging and how much to the Mountain Pine Beetle and forest fires? We compared the volume of forest lost to each since 1999 and found that logging accounted for about 60 percent of the total forest loss. To be on the conservative side, we dropped this to 50 percent. So we attributed one-half of the cumulative monetary cost of carbon sequestration loss over the period 2010 to 2019 to logging—$11 billion. For those of you who don’t think this is a real cost, consider the efforts of Carbon Engineering, the Squamish-headquartered clean tech company that has created a machine that removes carbon dioxide from the atmosphere—like trees do—and turns that into a hydrocarbon fuel. The goal of the company is to build equipment that can do that at a cost of $100 per tonne. The company’s efforts have attracted investors and media attention from around the planet. The function of Carbon Engineering’s machine amounts to what trees do naturally—for free. In our calculation of the value of lost carbon sequestration capacity, we used Carbon Tax values ranging from $20 in 2010 to $40 in 2019. But at $100 per tonne—Carbon Engineering’s ultimate target—the cost to the forest industry for causing the loss of just this one forest function would be valued at $36 billion over a 10-year period. As noted above, the carbon tax is set to increase to $170 per tonne by 2030, so like the carbon emissions subsidy, the annual carbon sequestration subsidy will rapidly increase in size. If someone destroyed one of Carbon Engineerings’ privately-owned machines, there would be a huge bill to pay. But a logging company destroying a publicly-owned forest that provides exactly the same function? Well the public is paying the logging companies, through the various subsidies outlined here, to do just that. The total cost of all these subsidies is astounding. The graph below shows the total cost by year. The cumulative cost of just these four subsidies is $50.6 billion over those 10 years. The last thing to show you is how the total cost of these subsidies compares with the GDP of the forest industry, which is calculated by the provincial government. You can see in the graph below that in the last two years, the cost of the subsidies is actually greater than the industry’s contribution to BC’s GDP. This may now be a permanent condition since the largest of these subsidies are based on the value of carbon, which is rapidly rising. In 2019 it was $40 per tonne. By 2030 this will rise to $170 per tonne. At that point public subsidization of the forest industry will far exceed the industry’s contribution to GDP. Unless, of course, the provincial government’s approach to managing BC forests begins to recognize the role BC’s forests must play in mitigating climate change. The bottom line, though, is that forestry doesn’t pay the bills, folks. You pay the logging industry’s bills. In the next iteration of this story, we will consider the cash subsidies taxpayers provide the logging industry—like the Bridge to Retirement program and the BC Forest Enhancement Society—as well as offer an estimate of the cost of damage done to communities and public infrastructure by the floods and fires that have been, in part, caused by BC’s over-exploitation of its forests. David Broadland has lived on Quadra Island since 1981. Read more about the Double-Crested Cormorant.pdf

THERE ARE FOUR MEANINGS INTENDED by the use of “plantation failure”: First, there is the failure of government to insure that clearcuts have been replanted at a rate matching that at which forests are being logged. Second, there is the failure of computer modelling to accurately predict the growth and yield of managed plantations. Third, there is the large-scale destruction of conifer plantations by fires, insects and disease. And fourthly—and perhaps most importantly: There has been a failure to recognize that widespread industrial clearcutting, followed by plantations, does not emulate any known natural disturbance; the belief that it does comes from hubris rather than knowledge or wisdom. All of the impacts of these miscalculations are increasing in size as the area logged each year grows. According to the ministry’s own records, between 2000 and 2017, 1.2 million more hectares were logged than were planted. This number does not reflect the backlog of unplanted logged area that had accumulated previous to 2000. Just how bad this problem actually is depends on which ministry record of how much logging has occurred is used: the one made publicly available (below in black), or the one based on the ministry’s best, but still incomplete, data (red). This fact—that the ministry is not ensuring that logged areas are being replanted—undoes the ministry’s and industry’s contention that logging in BC is not deforestation. In a recent press briefing attended by BC Chief Forester Diane Nicholls, a media reporter asked, “How will the COP 26 resolution about deforestation affect BC?” Nicholls responded that “deforestation” was not occurring in BC. But her ministry’s own data shows this is not true. There are many strong indicators that logging in BC is not sustainable and the large replanting deficit is just one of them. Not only are clearcuts not being replanted at the rate they are being logged, but predictions of the rate of growth and yield of managed plantations, which are used to determine how much forest can be cut each year, have been shown to be based on corrupt and inaccurate data that hasn’t incorporated the likely impacts of climate change. In 2018, Anthony Britneff and Martin Watts, both registered professional foresters, made a 134-page joint submission to a panel of forest scientists and professionals assembled to investigate concerns Britneff had expressed in writing to then forests minister Doug Donaldson. In their submission, Watts and Britneff challenge a claim made by various chief foresters in many timber supply reviews that the “best available information” is used in coming to a determination of allowable annual cut. Britneff and Watts provided evidence in the case of the Bulkley Valley Timber Supply Area review, for example, that shows the “best available information” included data that an independent consultant had determined did not meet “Ministry Standards” on several counts. They also note that a major source of uncertainty in computer modelling is “ineffective data management,” and recount how, throughout the 1990s and 2000s, the Forest Analysis and Inventory Branch (FAIB) struggled to effectively manage forest growth-and-yield data, which, as a consequence, had become “corrupted.” The result, say Watts and Britneff, is that “any studies or models using FAIB sample plot data prior to 2017 are suspect.” That would impact most existing timber supply reviews and the corresponding allowable annual cut determination (AAC). A wildly optimistic timber supply forecast made in the 2004 State of the Forests report signed by then Chief Forester Jim Snetsinger. Using faulty growth and yield models, the ministry of forests predicted timber supply in 2020 would be about 50 percent higher than it has turned out to be. In 2004, the ministry was expecting the Mountain Pine Beetle to have a greater impact on timber supply than it actually has had, so the beetle was not the cause of the optimism bias. Watts and Britneff believe the growth and yield models themselves are problematic and cite numerous ways in which the models provide inaccurate and unreliable estimates. For example, consecutive versions of the models produce different results from the same data, and the difference is significantly greater than the timber supply review process reflects in its consideration of uncertainty. As well, an FOI request showed FAIB had no record of the actual data used to calibrate one of the computer models central to estimating timber volume in natural stands. Watts and Britneff also point out that the growth and yield models lack the sophistication needed to reflect actual forest complexity. All of those factors create a level of uncertainty about the growth and yield estimates for managed plantations used in ACC determinations that, Watts and Britneff say, create serious doubts about projected mid-term harvest levels. Astonishingly, the models cannot account for climate change. On this point, Britneff says, “scientists within the forests ministry have reported and published that our Interior managed forests will most likely experience increased tree mortality, reduced growth and reduced utilization as a result of an increase in forest health issues due to climate change.” Yet, because the models cannot accommodate climate change, none of the climate-related effects that are expected to reduce growth and yield are included in the timber supply reviews that determine AAC. Next on our list of the ways in which plantations are failing is their growing impact on forest fires, insects and disease. Plantations on the scale they are being created in BC—about 250,000 hectares each year on public and private land—are creating a much higher risk of each of these problems occurring at large scales. Let’s start with fire. Of the four general configurations of forest found in BC—primary forest, mature naturally-regenerated second growth, clearcut and plantation—the latter has the highest fire hazard (followed by clearcuts), especially in the first 25 years of a plantation’s life. The higher fire hazard of clearcuts and plantations is entirely a matter of the ease with which fuels in them can be ignited and the difficulty in controlling such fires once they start. A high level of fire hazard can be expected to persist for about 20 to 25 years following planting. When fires do occur in plantations, the damage is often severe. One group of US scientists studying fires in Douglas fir plantations found that the most severe burning occurs 12 years after planting. The prevalence of clearcuts and plantations has been growing. The ministry of forests’ record of the extent of logging on publicly owned land shows there has been a large increase over the last 50 years. In the first five years of the 1970s, an average of 105,000 hectares of Crown land were being cut each year. In the 5-year period ending with 2018, that had risen to 240,000 hectares each year, a 230 percent increase. It’s that growing prevalence of clearcuts and plantations that’s worrisome. Lightning strikes in those areas will be more likely to ignite and the resultant fires will be more difficult to control than in mature forest. Lightning is the most common cause of forest fires in BC. Obviously, then, if there’s more land where fires are easier to ignite, more fires will occur. If fires are initially more difficult to control, they are more likely to grow. And once a fire grows large enough to start encountering multiple areas of higher-hazard fuels—like clearcuts and plantations—the fire becomes more and more difficult to control. If the area of the province that’s subject to this higher fire hazard is growing—and it is—then larger fires will become more numerous. That’s exactly what we are seeing. Most big fires in BC, like the 2017 Elephant Hill Fire (above), now involve thousands of hectares of highly-flammable clearcuts and plantations. Once plantations reach 25-30 years of age they have a higher chance of surviving a fire. Before that, they are the most flammable feature on BC’s highly logged landscapes. A burned plantation is a failed plantation. But there are other factors causing widespread plantation failure. In southeastern BC, for example, forest scientists studied monoculture lodgepole pine plantations that had replaced cedar-hemlock primary forests. They found that 44 percent of the trees had unacceptable levels of damage from western gall rust, with the result that one-third of the plantations could not be considered “free growing.” Yet ensuring that a plantation reaches a free-growing state is a legal requirement for companies who obtain permits to log public land in BC. In northwestern BC, the choice of monoculture lodgepole pine plantations to replace primary forest has run up against Dothistroma needle blight. In primary forests, damage from dothistroma has historically been low. But replacing primary forests with monoculture lodgepole pine plantations has resulted in extensive defoliation and mortality in those plantations. Lastly (at least until someone points out a fifth way in which plantations are failing), let’s consider the fundamental but flawed assumption underpinning plantations: After clearcutting, new forests can simply be regrown by replanting whatever species most reliably satisfies the legal but short-term requirement to reach a free growing state. In 2020, forest ecologist Suzanne Simard wrote briefly about this fallacy in a submission to the Haida Gwaii Management Council. She was commenting on a proposed determination of allowable annual cut in the Haida Gwaii Timber Supply Area. Simard wrote: “Reforestation practices for clearcuts of Haida Gwaii, based on personal observations, have followed the industrial model of planting nursery-grown plug stock of cedar, spruce and lodgepole pine. In primary forests of Haida Gwaii, cedar naturally reproduces primarily by layering, where gap phase disturbances facilitate regeneration of cedar around parent trees. These saplings grow up in the neighbourhood of their elders, where they are protected and their growth facilitated. The industrial approach of planting cedar plugs in clearcuts does not emulate these natural processes. Moreover, the planting of lodgepole pine in the clearcuts of Haida Gwai appears to be geared at achieving early free-growing, and we should expect these trees to decline with age past free-to-grow age even more so than has been observed in the interior rainforests. “Furthermore, the changes clearcutting brings to the hydrology of forests will cause a redistribution of water in the soil profile, likely with saturation at depth and surface drying, and this could serve to amplify drought-related die-backs among planted stock. For these reasons, the industrial approach of clearcutting and planting does not emulate natural disturbance regimes and regeneration dynamics on Haida Gwaii. With climate change, the second-growth forests will likely severely underperform relative to primary forests as measured in permanent sample plots.” The Forest Practices Board, which is ostensibly independent from the ministry of forests, echoed Simard’s concerns about plantations in an investigation of similar issues the Board conducted for a different area of BC in September 2021. The investigation focussed on plantations in the Kamloops, Okanagan, Merritt and Lillooet TSAs, as well as the Cariboo-Chilcotin Natural Resource District. The report was politely—but firmly—damning. The investigation into the health of plantation regrowth on cutblocks in the Interior Douglas-fir biogeoclimatic zone found that “[64] percent of the cutblocks examined were in poor and marginal condition and licensees may not be creating/regenerating resilient stands, which may have negative implications for future timber and non-timber values.” Of this opening, the investigation noted: “A cutblock where a strip selection silviculture system was used, was not site prepared and was left to naturally regenerate, resulting in very little regeneration due to grass competition.” Amongst other findings, the investigation found “an over-reliance on clearcutting” in the Interior Douglas-fir zone, and noted that clearcutting “is not appropriate for dry-belt-fir stands, as young trees do not regenerate well without the shade and shelter of overstory trees.” Echoing another concern expressed by Britneff and Watts, the Board recommended to the ministry that it “re-assess the long-term reforestation objectives for the dry IDF [zone], and update them based on the likely consequences of climate change.” The entire premise of liquidating BC’s primary forests was based on the assumption that humans could replace the natural processes that created those primary forests with their own, artificial and industrialized processes. Now the extent to which that decision was based in hubris is evident in the serial catastrophes overtaking BC’s plantation fantasy. You, no doubt, have additional issues with plantations. We welcome your comments below or in the forum on this issue.

In this randomly selected, typical aerial view of Crown forest on Quadra Island, the permanent, ballasted logging roads occupy 8.2 percent of the area of the recent clearcuts. LOGGING IN BC has required the construction of an extensive, expensive road network. At approximately 700,000 kilometres long, these industrial-duty roads have gouged out a vast area of previously productive forest and covered it over with blasted rock and gravel. The public has paid for these roads through reduced stumpage payments. They’re poor, if not impossible places for trees to grow and have a wide range of further negative impacts. In BC, logging roads and landings are allowed to occupy up to seven percent of the area of a cutblock, but the actual loss may be higher. A recent report at The Narwhal by Sarah Cox described a study in Ontario that examined the extent of such forest loss in that province. Cox reported that researchers there found “logging scars created by roads and landings…occupied an average of 14.2 percent of the area logged.” So our province’s seven percent restriction could well be an underestimation of the forest base that’s being lost. But let’s use seven percent and calculate how much forest has been lost. Sierra BC’s recent report, Clearcut Carbon (document at end of story), put the total area logged in BC between 2005 and 2017 at 3,597,291 hectares, which included private land on Vancouver Island. If seven percent of that area was covered with roads and landings, the area of forest lost over that 13-year period would be 251,810 hectares. That’s an area larger than Vancouver Island’s largest protected area, Strathcona Park. Besides the sheer amount of forest lost to logging roads, road building results in many negative, sometimes cascading consequences for wildlife, aquatic health, and the ecological integrity of the forest. You cannot build a road without compacting soils. Soil compaction, which can last for decades, restricts root growth and greatly minimizes the nutrients available to vegetation in these areas. Soil compaction also reduces the oxygen and water available to vegetation and negatively effects the microorganisms found in the soil. The loss or disturbance of organic layers that is also a consequence of building these roads, affects mycorrhizal fungi, which are important to many tree species in accessing nutrients. Damage to the fungi network can lead to trees suffering from moisture stress and reduced growth rates; to difficulty getting seedlings established; to negative impacts for long-term forest resilience. Increased, excessive rates of soil erosion are another consequence of logging roads. The erosion leads to sedimentation of nearby water courses, thereby impacting the aquatic systems of the forest. Because roads break up the existing soil and remove the ground cover that assists in the natural distribution of rainfall and runoff, high volumes of sediment flow into these watersheds. Aquatic species dependent on clean, clear water are naturally impacted. We know that the survival rates of many fish species significantly decrease as fine sediment levels increase. Deposited on the stream bed, fine sediment degrades spawning areas, reduces pool refuge habitat, decreases winter refuge areas for juveniles, and impedes feeding visibility. Likewise, sensitive amphibian and invertebrate species are also adversely affected by increased sediment loads, decreasing in abundance and diversity as sediment levels rise. Because invertebrates, amphibians, and fish are important prey species for many mammals, birds and bats, these too are affected by logging roads. The whole biological integrity of the forest is thereby impacted. The construction of logging roads can also change natural streamflow patterns and alter stream channel morphology. Roads, ditches, and newly created gullies form new, large networks of flow paths across the landscape. These logged areas sustain much higher discharge volumes after a storm event than they ever did when the forest was intact—and have proven far more likely to suffer from major landslides and erosion events (which again deposit abnormally high levels of sediment into area streams). Fragmentation of the landscape is also a problem stemming from the building of roads. Roads function as barriers for wildlife dispersal and migration. Many species are unable to cross these barriers and therefore have their range and distribution altered, often leading to drastic consequences on a local scale. Finally, logging roads, in allowing humans greater access to previously inaccessible landscapes, increase the risk of forest fires—humans are the cause of a significant portion of forest fires. The accessibility also allows for the introduction of non-native species, dramatically altering the natural balance of the forest ecosystem. Roads also serve as vectors for the spread of disease by allowing easier access for a potential threat than would otherwise exist.

The exploitation forest economy brings dwindling forest-related employment. IN THE YEAR 2000, there were 101,000 direct jobs in BC’s forest industry: 35,500 in forestry, logging and support services; 47,800 in wood product manufacturing; and 17,700 in pulp/paper manufacturing. By 2019, only 16,100 jobs were left in forestry, logging and support services; 21,000 in wood product manufacturing; and 9,000 in pulp/paper manufacturing. Half of all jobs in the forest industry disappeared in just 20 years. To understand where BC needs to look to increase forest-related employment, we really need to understand why that large decrease in forest-related jobs occurred, and in which direction the level of employment is likely to go if the business-as-usual course is continued by BC’s government. By “business as usual,” I mean the continued destruction of primary forests by large corporations like Canfor, West Fraser and Western Forest Products. When we mash all three sectors of the industry together, its record of direct employment looks like this: To begin with, we know that half of all the jobs didn’t disappear as a result of cutting half as much forest. The chart below shows how the actual harvest has changed since 2000. In the first 5 years of that period, the harvest averaged 76 million cubic metres per year. In the last 5 years it averaged 65 million cubic metres. That’s a drop of about 14 percent in the average volume cut per year, yet half of the jobs disappeared. The logging industry’s view on job loss was captured in a 2017 editorial in a BC Truck Logger’s Association newsletter. It attributed the job loss to three sources: Manufacturing productivity gains accounted for 38 percent; logging productivity gains 27 percent; less manufactured wood products 22 percent; reduced harvest 10 percent; and log exports 4 percent. Those “productivity gains” were all a result of technological change. For example, many individual fallers with chainsaws were replaced by feller-bunchers. Sawmills became bigger and more automated. Since that direction is likely to continue as artificial intelligence and industrial robots seep into the industry, employment derived from industrial forestry is likely to decline even further as a result of future “productivity gains.” This machine allows more forest to be cut by less people The Truck Logger’s Association account of “less manufactured wood products” pointed to the decline in the use of paper. Younger generations use the internet for information and services that their grandparents found in telephone books and newspapers. That change will accelerate as younger people increasingly make choices informed by the need to respond to climate change. A clear sign that this trend is continuing is the recently announced permanent closure of the paper mill at Powell River, which began operations in 1912. Another change that will continue to have a profound impact on the number of jobs in logging is the shrinking availability of primary forest. Chris Harvey, a forester and spokesperson for the Teal Jones Group, noted in 2016 that “old growth is an absolutely essential part for us to harvest. We can’t be economically viable if we log 100 percent second growth. And this is true for other companies as well.” While some companies don’t want to let go of cutting primary forest, others are even more primitive in their outlook about what’s possible. In 2020, a spokesperson for Mosaic, the joint management company for both Island Timberlands and TimberWest, stated that without being able to export raws logs, its operations would not be economically viable. If we take these companies at their word, logging is only viable if it can continue to accelerate climate change, destroy ancient forested ecosystems, and damage our economy. These harms will become increasingly indefensible as the planet gets hotter and forest employment dwindles further. The movement to protect the remaining primary forest in BC is getting stronger, not weaker, and has a solid scientific underpinning that links loss of primary forest to biodiversity collapse and climate change. Why would the tiny number of jobs remaining in the primary-forest-dependent logging industry outweigh the urgent need to protect our life support systems? By 2019, jobs related to this destruction amounted to only 1.8 percent of BC’s total workforce. Whether an industry with nothing to harvest but second-growth trees would be economically viable is unknown, but significantly smaller trees will mean a higher degree of mechanical harvesting will be possible, likely reducing employment further. The lumber from younger, smaller-diameter trees with a higher percentage of sapwood will be less valuable as a construction material, thus lowering demand for BC wood products. Moreover, it is now clear that the growth and yield of second-growth plantations has not measured up to the predictions of BC’s timber supply analysts. All over BC, timber supply is falling. Predictions made in 2004 now appear to have been far too optimistic. A wildly optimistic timber supply forecast made in the 2004 State of the Forests report. Using faulty growth and yield models, the ministry of forests predicted timber supply in 2020 would be about 50 percent higher than it has turned out to be. In 2004, the ministry was expecting the Mountain Pine Beetle to have a greater impact on timber supply than it actually has had, so the beetle was not the cause of the optimism bias. All of these factors point toward continued falling employment in the logging-milling industry. The fall-down in pulp and paper production in BC means the largest market for the most voluminous product of BC logging—wood chips and sawdust—is collapsing. The only alternative, so far, for getting rid of all that low value waste is to compress it into pellets and send it overseas where it is burned for heat, a process that creates more carbon emissions per unit of thermal energy produced than coal does. The shear backwardness of BC’s forest industry is unlikely to attract young people looking for long, meaningful careers. Pellet-making is more likely to be seen as a dirtier job than mining coal than greenwashed “bioenergy.” Indeed, the forest industry, for all its attempted greenwashing, is having difficulty filling available jobs. In Ontario, one forestry company has begun experimenting with remote-controlled logging trucks due to the shortage of drivers. It seems likely, then, that the halving of employment over the past 20 years will continue through the next 20 years. Given the industry’s already small contribution to overall employment in BC, what political leverage will 25,000 workers have? Industry employment has already reached such a diminished state that, given the huge public subsidization of the industry, it would be less costly for BC taxpayers to provide employment supports as a way of transitioning current forestry workers into less subsidized employment. The Province, through its Bridge to Retirement program, has already headed in that direction. A far more appropriate kind of forest-related job will emerge, one far more suited to getting through the climate emergency and reversing the biodiversity collapse. What will be needed in the future is expertise and a workforce for protecting forests from fire, disease and insect infestations. Forests are already more valuable standing than as lumber, sawdust and forest fire fuel. Our hired bean-counters just aren’t thinking clearly. While engineers elsewhere try to design and build expensive equipment for removing carbon dioxide from the atmosphere, BC already has the “equipment” to do that: Its remaining primary and mature second-growth forests. Those irreplaceable assets just need to better protected. Restoring and regenerating BC’s forests will also restore their hydrological function of cleaning and cooling water and controlling its flow over the land. In the future, how much will it be worth to former logging-dependent communities to feel safe again from the flooding and forest fires they once experienced that were attributable to over-exploitation of nearby forests? BC will always need some forest products, and there will be employment generated by that need. But as reconciliation with First Nations advances and final treaties are completed, the control of forests should go back to Indigenous people. The courts have already decided that. British Columbians would be in a better place—ethically, economically and ecologically—if Indigenous leaders made the decisions about how many jobs the forests could provide and who gets to fill them. Read more about the Pacific Sideband Snail.pdf

Logs being loaded onto a ship in Northumberland Channel near the Harmac pulp and paper mill, Vancouver Island IT HAS LONG BEEN ARGUED IN BC that the export of raw logs should be reduced—or even banned—because the practice amounts to exporting forest-product manufacturing jobs out of BC. In this view, the value of such jobs is seldom questioned and is never measured against the full costs of the required logging. That conventional economic argument is countered with an opposing conventional economic argument that log exports actually raise the value of logs taken from public land, thus conferring some benefit on the public. This view, too, never considers the full costs of the required logging. By “full costs” I mean both economic and environmental costs. It’s a mystery why these arguments have gone unchallenged for so long. How can we understand whether log exports are better than a ban on log exports, or vice versa, if we don’t consider the full costs of the logging that’s done in order to meet the demand for log exports. Below, we’ll consider those costs. First, however, let’s review the conventional economic arguments as understood by one of BC’s most distinguished resource economists. In a 2019 op-ed in the Vancouver Sun, Peter Pearse argued that restrictions on BC log exports “don’t make a lot of sense.” Pearse outlined the two conflicting economic arguments, starting with the argument for jobs: “The often confusing debate usually centres on jobs. Opponents of exports argue foreign buyers of logs reduce the raw material available to our domestic sawmills and pulp mills, and thereby diminish local employment opportunities (as summarized in the slogan “Export logs = Export jobs” on road signs along the Malahat Highway). This view is widely held, especially by those engaged in manufacturing forest products.” Pearse then contrasted that with the argument that log exports support jobs and a greater public interest: “Proponents of free trade in logs, however, point out access to foreign markets hikes the demand and value of logs, which increases employment in forestry and timber production. In addition, logs are exported only when they bring prices higher than domestic sales, so exports advance the public interest in the economic return on our forest resources.” Which side does Pearse come down on? He wrote: “Restrictions on exports obviously constrain the demand for our logs, depress their domestic market price and hence also the quantity produced. So the direct beneficiaries are the local buyers, mainly sawmills and pulp mills and their employees and shareholders. But, for the same reason, those involved in producing logs suffer from the reduced production and value of their product. In effect, the loss suffered by log producers serves as a subsidy to manufacturers.” Since a large proportion of BC’s “log producers” are the same companies that manufacture wood products like lumber, pulp and paper, we might ask ourselves why this is a problem. Pearse gives us an answer. He says that the real losers created by restrictions on log exports are BC taxpayers: “However, there is another, often forgotten, player in this industry, namely the owners of the timber. In BC, where most of the timber is harvested on public land, the government sells timber to logging companies for a ‘stumpage price,’ calculated as the difference between the market value of the logs and the cost of harvesting them. Export restrictions depress the value of logs, so stumpage revenues are reduced accordingly, shifting the ultimate burden of log export restrictions onto us, the hapless taxpayers.” Pearse comes down on the side of unrestricted log exports because, he believes, with restrictions logs would have a lower price and so BC taxpayers would get a lower return from the liquidation and sale of publicly-owned forests. The existence of such a linkage between the level of exports and the stumpage the Province would collect is crucial to the pro-no-restrictions position. This is easy to test by comparing the average stumpage collected in a year that had a high rate of log export to one that had a lower rate of export. In 2014, 10.1 percent of the volume cut in BC was exported as raw logs. That year the public received an average of $7.62 per cubic metre. The very next year, exported logs dropped to 8.3 percent of the total volume. By Pearce’s reasoning, the average stumpage collected by the public should have been reduced. But it wasn’t. It increased to $8.03 per cubic metre. Evidently, there isn’t a smoothly working linkage between the level of log exports and the public interest, at least not in the direction Pearce asserts. You might think, “You are just cherry picking one case that happened to not support Pearse’s reasoning.” Okay, let’s look at the two years before the year Pearse wrote his op-ed. In 2017, 9.0 percent of the total volume cut in the province was exported as raw logs, almost all of it from the coast. The average stumpage collected by the Province was $12.34 per cubic metre. In 2018, exported logs fell to 8.0 percent of the cut. Did this reduction in log exports result in a decrease in stumpage? No, stumpage jumped up to $18.78. Why? Mainly because the ministry of forests raised stumpage rates in BC. What does that show? It demonstrates that BC taxpayers don’t really need log exports to get a higher return on its forests; it just needs government to set higher stumpage rates. In my view, those who argue for restrictions based on the need for more jobs—and those who argue for no restrictions based on getting a higher return for the public resource—are both overlooking most of the real costs associated with exporting raw logs. Yet it’s only by rigorously examining the full economic and environmental costs of logging in BC that we’ll be able to have a clear sense of the impacts of log exports—or the export of any wood product from BC. This includes the net loss to taxpayers arising from the fact that stumpage and other forest-related revenue don’t even cover the cost of the ministry of forests’ management of the resource. It must also include indirect subsides the industry receives, like a reduced rate for consumption of electrical energy. Much worse than those economic omissions is the failure to examine the environmental harms created by logging, milling and exporting raw logs, lumber, pulp and paper. None of these costs are included in considerations of whether the over-exploitation of BC forests—which is the sole driver of log exports—is good for the broad public interest. All that economists like Pearse consider in looking at log exports and other forest product exports are the numbers associated directly with the logging industry and its downstream partners. This is actually only a minuscule slice of the real costs. Consider, for example, one cost that is never considered when the economic benefits of exporting logs is reckoned: the carbon emissions associated with a year’s worth of logging for raw log exports. We are in the midst of a growing climate emergency and ignoring this cost would be foolish—just look at what happened in BC starting on November 12, 2021. This cost applies equally to all forest products, but let’s confine our consideration to the export of raw logs. In 2019, the year in which Pearse penned the above analysis, 8.5 percent of the volume of forest cut in BC was exported as logs, mainly to China. That amounted to 4.7 million cubic metres of logs. But those logs represent only about one-half of the forest biomass that was killed by the logging required to obtain those logs. By international convention, the carbon emissions associated with the decomposition of that forest biomass are attributed to the year in which the cut took place. When we convert the total forest biomass that was killed to equivalent greenhouse gas emissions, we find that logging for the export log market produced 7.7 million tonnes of CO2 equivalent emissions in 2019 that could have been avoided. To put that number in context, not cutting those forests for log exports would have been the equivalent of taking 80 percent of all light trucks and passenger cars in BC off the road for a year. Can we put an economic value on the emissions that would have been avoided? We can. In 2019, the BC Carbon Tax put a cost of $40 per tonne on carbon emissions. The atmosphere can’t tell the difference between a carbon dioxide molecule that comes from burning fossil fuels or one that comes from decomposing or burning wood. They both have the same effect on global heating. All forest carbon will, over time, return to the atmosphere. But by accelerating that return by several decades, or even centuries, we are having the same effect on climate change as we would by burning fossil fuels with the equivalent carbon content. So, if we’re being realistic, 2019’s 7.7 million tonnes—priced at $40 per tonne—should have cost the log producers $308 million. How much of that was actually collected and added to the public purse? Not a single penny. Over the years 2008 to 2019, the uncollected tax on 96 million tonnes of carbon emissions associated with producing logs for export amounted to $2.97 billion. That’s not the only real cost associated with log exports that isn’t being counted by either Pearce or the job seekers. For example, the loss of forest carbon sequestration capacity—the ability of mature forests to absorb carbon from the atmosphere, isn’t included in any reckoning of the cost of exporting raw logs. Logging also dramatically raises forest fire hazard in the area logged for 30-40 years. Forest fires can destroy communities and local economies, yet the resource economists never include those costs when they perform their analyses. Fires fill the air with particulates that can cause serious health problems, and those problems come with both high social and economic costs. Nor are the carbon emissions from those fires included. Likewise, logging can affect the timing and peak flows of BC rivers and cause catastrophic flooding in BC communities. Look at what happened to Merritt, Princeton and the Fraser Valley in mid-November 2021. Increased sedimentation and warming of water caused by clearcut logging degrades salmon habitat, lowering the salmonid productivity of BC streams and rivers. Yet such impacts never appear in the economic analyses that argue whether the 10 percent of BC logging that occurs for log exports is good for the public interest or not. Nor does the impact clearcut logging has on the huge potential BC has for forest-based research and tourism. The problems with both Pearse’s economic analysis supporting log exports and the argument against log exports based on the lost opportunity for more jobs in BC, are the same. They both ignore many of the economic costs associated with this industry and they both ignore all of the environmental costs of the industry.

The ministry of forests has its collective head in the sand about the increase in fire hazard caused by clearcut logging. Meanwhile, the logging industry is feeding on the huge public expenditure of money used to fight the fires. The Doctor Creek fire, the largest in the province in 2020. This BC Wildfire Service photo shows all three fuels BC’s forest fires are burning: Mature forest, plantations and clearcuts. WHY ARE THERE SO MANY LARGE, OUT-OF-CONTROL FIRES burning in BC’s Interior this summer? It’s partly the result of extreme hot weather made worse by climate change, but testimony provided to an Oregon court in 2019 revealed that clearcut logging, followed by replanting, creates fuel conditions that make fires easier to ignite and harder to control. These effects persist for decades. Since the area being logged each year in the Interior has more than doubled since the 1970s, southern BC has become a Molotov cocktail of clearcuts and young plantations ready to explode into flames with the first lightning strikes of summer. The Oregon testimony arose because a land conservation organization, Oregon Wild, sued the US Bureau of Land Management (BLM) for failing to disclose the extent to which logging on public land near an Oregon community would raise forest fire hazard. The Oregon case included written testimony from a BLM fuels specialist, provided under oath, that stated that logging and plantations increase forest fire hazard. Those two fuel conditions make a fire easier to ignite and harder to control. Here’s the relevant testimony by the BLM fuels specialist (we quote from the court judgment record): “The change from a ‘mature’ to an ‘early successional’ stand structural stage would change the associated stand-level hazard from low to moderate/high. The stands would go from a timber model to a slash fuel model with higher predicted flame length, fire duration, and intensity and decreased ability to control a fire, with the greatest risk of a fire start during the first 5 years following harvest. Over the next 10 to 40 years, stands would transition through stages associated with high stand-level fire hazard rating and go from a slash fuel to a brush fuel type, which are more volatile and susceptible to high fire-caused mortality rates. These potential fires would have high flame lengths, rates of spread, and intensity and would be difficult to initially attack and control. Overall fire hazard would increase for 5 to 20 years following planting, then drop from high to moderate after the next treatment.” Logging slash in an Interior clearcut (Photo by Sean O’Rourke/Conservation North) Fire hazard, as referred to in the testimony, isn’t quite what I thought it was, so I should outline the meaning of that term for you. A “fire hazard rating” is an assessment of the fuel comprised of living and dead vegetation in an area—a mature forest or a clearcut or a plantation, for example. The assessment estimates the ease with which a fire can be ignited, and, once ignited, the fire’s resistance to human control. If a fire ignites in a high hazard area, or encounters such an area, it can spread more easily than in mature forest. Fire hazard is independent of weather-related factors like moisture content, humidity, temperature or wind speed—all of which are influenced by climate change. Instead, hazard is all about fuels: the volume, type, condition, arrangement, and location that determines the degree of ease of ignition and the resistance to control. The distinction between climate effects and fuel effects is necessary to make for one important reason. Although the forests ministry can’t directly control climate change, it does have full control of how much of BC’s publicly owned forests are converted from a low fire hazard rating to a medium/high hazard rating each year. Since the early 1970s the ministry has ramped up the production of clearcuts and plantations—and, as a consequence, the fire hazard. The growing prevalence of clearcuts and plantations The ministry of forests’ record of the extent of logging on publicly owned land shows there has been a large increase over the last 50 years. In the first five years of the 1970s, an average of 105,000 hectares of Crown land was being cut each year. In the 5-year period ending with 2018, that had risen to 240,000 hectares each year, a 230 percent increase. Data crunching by David Leversee, based on the ministry of forests’ RESULTS Openings and Consolidated Cutblocks. Over the past 40 years, about 8.5 million hectares of BC’s publicly owned forest have been logged. Based on the BLM fuel specialist’s testimony that the fire hazard associated with a plantation would be higher than the mature forest it replaced for up to 40 years, we can project that as much as 8.5 million hectares of BC now have an elevated level of fire hazard as a consequence of logging and replanting. That means 8.5 million hectares where fires will ignite more easily than mature forest, and 8.5 million hectares where fire will be harder to control. That number doesn’t include logging on private land. It’s that growing prevalence of clearcuts and plantations that’s worrisome. Lightning strikes in those areas will be more likely to ignite and the resultant fires will be more difficult to control than in mature forest. Lightning is the most common cause of forest fires in BC. Obviously, then, if there’s more land where fires are easier to ignite, more fires will occur. If fires are initially more difficult to control, they are more likely to grow. And once a fire grows large enough to start encountering multiple areas of higher-hazard fuels—like clearcuts and plantations—the fire becomes more and more difficult to control. If the area of the province that’s subject to this higher fire hazard is growing—and it is—then larger fires will become more numerous. That’s exactly what we are seeing this summer. One method of judging the prevalence of clearcuts and plantations is to view satellite imagery of Crown land. I highly recommend this to anyone skeptical about the extent to which publicly owned forests have been converted to higher fire hazard clearcuts and plantations across BC. Below is a satellite image of part of the area involved in the Flat Lake Fire: Satellite images show a lot of deceptively green areas. Unless you have been trained to interpret aerial imagery, it can be difficult to know what you are looking at. Many of the green areas in the image above are high-hazard plantations, many of which have now been burned. A better picture of the prevalence of clearcuts and plantations involved in the fires can be obtained by superimposing the ministry of forests’ fire perimeters onto the ministry’s record of logging in these areas. We’ve done that in the images below of four perimeters of 2021’s largest fires, shown as black lines. Past logging is indicated by the red-shaded areas. Each fire’s point of ignition is indicated by a bright red dot. The white areas are remaining primary forest or rangeland. Protected areas, like provincial parks, are shaded green. In each case you will notice that the area of past logging overwhelms the landscape. The August 6 perimeter of the 60,000-hectare Flat Lake Fire (black line) superimposed on top of the BC ministry of forests’ RESULTS Openings record of logging (red-shaded area). The green-shaded area is Flat Lake Provincial Park. August 8 perimeter of the Sparks Lake Fire. On its west side, the fire burned to the edge of the massive 2017 Elephant Hill Fire, which burned through the logging indicated on the left side of the image above. August 8 perimeter of the Tremont Creek Fire southeast of Cache Creek. The August 8 perimeter of the White Rock Fire. The ministry of forests’ record of logging in the RESULTS Openings database misses some of the logging that has occurred. The area within the fire perimeter near Okanagan Lake (right side) has actually been heavily logged. The ministry’s records show that several of BC’s largest fires this summer were ignited in a clearcut or plantation and then quickly grew out of control. The White Rock Lake Fire ignited in an area of logging that was replanted in 2007. The Flat Lake Fire started when lighting struck a clearcut that was logged in 2015. The Sparks Lake Fire began beside a large area logged in the mid-1980s. The Octopus Creek Fire was ignited by lightning in an area logged in 2005 and planted in 2006. The Young Lake Fire was started by lightning in a clearcut logged in 2006 and replanted twice, in 2012 and 2015. And so on. Every one of the big fires in the southern Interior, no matter how they started, consumed thousands of hectares of clearcuts and plantations. The widespread conversion of BC forests from areas of low fire hazard to medium-high hazard by the logging industry is clearly playing a decisive role in the size of forest fires. Patrick Byrne, district manager of the 100-Mile-House Natural Resource District, declined to answer questions about the role clearcuts and plantations are playing in the Flat Lake Fire, but Byrne did note that “the fires burn quite nicely through plantations.” The aggressive behaviour of fires fuelled by clearcut logging slash and plantations puts firefighters in greater danger. BC Wildfire Service fire incident reports filed from the field often note extreme fire behaviour related to the fuel loading in clearcuts. A report from a fire in 2018 warned: “The slash blocks have more fuel loading than the standard slash fuel type, expect higher intensity. This higher intensity can cause fire whirls to develop, this would cause rapid fire growth and increased spotting potential.” Spotting refers to embers travelling downwind and starting new fires. Many incident reports from different fires make similar observations about the impact of the fuel in clearcuts on fire behaviour. A fire whirl in a clearcut fire (Photo by BC Wildfire Service) The impact of clearcut logging on fires will last a very long time Fire hazard rating is, by definition, independent of the moisture content in fuel. Yet the dryness of a clearcut, plantation or area of mature forest has a large influence on the speed with which fire can spread. Clearcutting exposes the land to the full strength of the sun, evaporating ground moisture and lowering humidity, important factors driving increased fire size and severity. Clearcuts also allow drying winds and higher temperatures to more easily penetrate the edges of adjacent forest. BC forester Herb Hammond contends that “clearcuts are clear culprits for heating up and drying out not only the immediate area where they occur, but also the surrounding landscape. They change local and regional weather patterns, and turn former heterogeneous, ecologically resilient stands and landscapes into homogeneous, ecologically vulnerable stands and landscapes. Their vulnerability is well documented in both the rise of insect epidemics, which clearcuts are allegedly meant to suppress, along with wildfire risk.” BC Forester Herb Hammond The drier conditions caused by the widespread use of clearcut logging in BC will persist far longer than the BLM fuel specialist’s predicted “10 to 40 years” of higher fire hazard, as Hammond explains: “Forests, particularly as they grow older, conserve water in large part due to complex, multi-layer canopies, and overall composition and structure that are all geared to slowing the movement of water through the forest, while filtering and storing water at the same time. Clearcuts, on the other hand, expose the land to rapid water loss. After a clearcut in montane Interior forests, 150 to 200 years of natural stand development are necessary to get back to something close to the level of water conservation provided by intact, natural old forests. If one takes into account the development of decayed fallen trees that are needed to store and filter water, that could be doubled to 300 to 400 years. Most of these vital fallen tree structures get destroyed in high-production, mechanized clearcutting.” The dryness of clearcuts and young plantations is evident to anyone who has walked through one on a hot summer day and then stepped into the shade of adjacent mature forest. The difference in temperature and humidity is startling. That difference can even be measured by satellite imaging using microwaves. The top image below shows clearcuts near the Brenda Creek Fire in the Peachland area on July 16. The image below that shows the relative moisture content on the ground that same day. The dark blue areas contain the most moisture and the red areas are the driest. Yes, those red-yellow-orange areas are all clearcuts. (Graphics courtesy of David Leversee) There are several other aspects of how clearcut logging is practiced in BC that have had an impact on fire size. For example, in the Interior, the practice of “managed” forests has evolved to mean managed coniferous forests. Deciduous stands are eradicated, often using glyphosate sprayed from helicopters, so that more commercially valuable coniferous stands can be planted instead. This, too, has made Interior forests more vulnerable to large fires. James Steidle, forest activist, has campaigned against this practice in the Prince George forest district. Steidle observes: “The conifer-dominated forest type we are actively encouraging is highly flammable, while the broadleaf aspen forest type we are actively eliminating is incredibly fire resistant. With a few caveats, the conclusion is undeniable. According to a 2001 study by Steve Cummings et al, pine forests are 8.4 times more likely to burn compared to aspen forests, based on historical data.” With fewer stands of fire-resistant deciduous trees to slow down or stop fires, larger fires are inevitable. Another dubious ministry policy has been “salvage logging” of healthy non-pine forest stands alongside lodgepole pine killed by the Mountain Pine Beetle. Several of the largest fires in the Interior during the last six years have included thousands of hectares of salvage logging. The ministry of forests allowed companies that were awarded salvage logging licences to take not only dead pine, but healthy living trees as well. The ministry’s own records show that only 15 percent of the logging that occurred in BC since 2010 has been dead pine. Hammond is scathing about the salvage program and its consequences: “For a stand to be eligible for salvage stumpage rates, all that was needed was for the stand to have a lodgepole pine component of 3 percent or more. This led to a massive windfall for logging companies, which clearcut thousands of hectares of diverse, mixed species natural forests, many of them old growth, under the guise of ‘pine beetle salvage.’ These were the precise stands on which ecological recovery would have been centred through natural succession. Instead, the bulk of these areas have been converted to young lodgepole pine forests, as that species was the easiest to naturally regenerate and meet ‘reforestation’ requirements by the timber companies. So, the forest industrial complex have simply set up the forest landscape for both more frequent severe fire, and an even larger beetle outbreak—if the trees escape climate disruption.” Hammond predicts the relentless removal of primary forest in the Interior will eliminate essential ecological functions of old forest, and that will lead to more pine beetle epidemics, more “salvage logging,” more giant clearcuts and—inevitably—to more large fires: “Mixed species old-growth forests were once randomly scattered throughout the forest landscapes of much of the Interior. These forests were the home to carnivorous beetles who eat herbivorous beetles—like the Mountain Pine Beetle—and also the home for many cavity nesting birds that prey on herbivorous beetles. So, as long as these forests were found throughout the landscape, they served as important agents to keep bark beetle populations in balance. Along with all of the other benefits of old-growth forests and diverse natural landscapes, these benefits have been eradicated by timber-biased ‘forestry’ that increasingly has no place in BC or anywhere in the world.” Hammond believes the industry and their ministry partners have created a bleak future for BC forests: “The omnipresent danger of fire and ongoing drought, coupled with inhospitable soil and atmospheric moisture and temperature, call into question whether trees in clearcuts will ever grow to merchantable size in many clearcut areas. Indeed, we are already seeing plantation die off, including death by fire. Particularly in the Interior, we may soon begin to see ecosystem shifts, where former forests become degraded shrub ecosystems.” The growth in fire size is having broad impacts, including physical damage to communities and infrastructure, long periods of pervasive, health-damaging smoke, disruption to local economies, loss of large areas of wildlife habitat and loss of protected areas. The fires, partly a symptom of climate change, will worsen it: burned forests and plantations can’t continue to sequester carbon and the fires are releasing immense quantities of carbon to the atmosphere. Those emissions have doubled every 9 years since 1990, an exponential increase. Carbon emissions from forest fires are on track to double every 9 years since 1990. The current 9-year period runs until 2026, but 2021’s fires will likely be all that’s needed. The ministry has its head in the sand With the forest fire problem growing in size at an alarming rate, you would think the BC ministry of forests would have put significant resources and effort into understanding how the higher fire hazard of clearcuts and plantations is fuelling the growth in fire size. But the ministry appears to be avoiding the issue. FOCUS filed an FOI for any technical or scientific reports produced for the ministry between 2010 and 2020 that considered the relationship between logging and forest fire frequency, size, behaviour or intensity. Throughout that period, it was clear that the area being burned in BC during long, hot summers was growing rapidly. Had the ministry investigated? Our FOI request produced a single study (see link at end of story) conducted by the ministry during that period that examined how fire behaviour was affected by man-made changes to forests. The records released show that in 2019, the ministry started the “Fuel Treatment Efficacy Project” to examine how different fuel-reduction treatments, like thinning or broadcast burning, had impacted subsequent forest fire behaviour and fire suppression tactics. The $50,000 internal study considered 17 forest fires, only one of which was in an area that had been “100 percent logged.” The researchers gave that fire “low priority” for further study. The main finding of study, as indicated in the 7-page report, was that there was “a paucity of examples” where forest fire had interacted with fuel treatments. Given the high stakes, it’s difficult to understand why the ministry of forests hasn’t examined the impact of logging and plantations on worsening fire behaviour in BC. Fighting those fires is increasingly costly, as I will describe below. Yet, judging by its response to our FOI, the ministry hasn’t lifted a twig to understand what’s happening. This failure is worrisome, and may stem from the transition of the ministry over the past 30 years from functioning as a regulator of the logging industry to being its primary enabler. It is perhaps unreasonable to expect that an organization that works every day to maximize logging would, at the same time, spend money and effort on digging up evidence that clearcuts and plantations are feeding large forest fires. Besides, the ministry knows that logging slash raises fire hazard. That’s why it requires logging companies to burn hundreds of thousands of slash piles every year in an attempt to lower the fire hazard that fuel poses. BC forester John Waters knows, too. In a 5000-word treatise advising his fellow Woodlot Licence tenure holders what they needed to do to reduce fire hazard after their logging, Waters summed it all up: “Decades of wildfire research and examination of large wildfires shows that wildfire spreads most rapidly in areas where there is an abundance of dry, fine fuel or old unburnt piled slash accumulations.” The ministry is very careful to never explicitly admit the obvious. If lack of fire hazard abatement results in injury, death or property loss, the Province and its industry partners could be held legally responsible for damages. The closest the ministry comes to acknowledging the higher fire hazard caused by logging is contained in its Guide to Fuel Hazard Assessment and Abatement in British Columbia, last updated in 2012. The Guide states: “In some timber harvesting circumstances, it will be impracticable to reduce fuel loads sufficiently so that potential fire behaviour is not increased relative to pre-harvest conditions.” Given the growing size of forest fires and the huge associated economic and environmental costs, we might ask why it would ever be “impracticable” to reduce fuel loads. Surely it should now be clear to the ministry that if reducing fire hazard would be “impracticable,” then logging should never occur in the first place. The Guide, of course, has nothing at all to say about reducing the fire hazard posed by plantations, which have, according to the BLM fuels specialist, the highest fire hazard. No worries. The ministry is already solving that problem. According to the ministry’s own records of the area logged and area replanted between 2000 and 2017, 1.2 million more hectares were logged than were planted. Just how bad this problem actually is depends on which ministry record of how much logging has occurred is used: the one made publicly available (below in black), or the one based on the ministry’s best data (red). Just to be clear, I am not advocating for leaving clearcuts unplanted. I am pointing out that our forests are not in good hands. They are being ransacked, and so is the public purse. The money whirl: Who benefits economically from forest fires? The ministry seems to have in place all of the policies needed to make fires worse and few that would mitigate the risk. One result is that fighting forest fires is costing BC taxpayers a lot more. In the 5 years starting with 2010, fire management cost BC $1.02 billion. In the following five years it more than doubled to $2.12 billion. Indeed, fighting forest fires has become a big business in BC, and much of the economic rewards from that business flow back to the logging industry itself. Of the $2.1 billion spent on fire management by the ministry of forests between 2015 and 2019, just under 70 percent was paid to private companies for services provided in the increasingly difficult battle to contain forest fires. Through an FOI request for records, FOCUS obtained details of payments totalling $1,471,832,630 (see link at end of story for complete list). Fires in 2017 and 2018 accounted for over 70 percent of that cost. Who benefitted? On the ground, fighting big forest fires requires constructing fire breaks and other measures that involve logging company personnel and equipment. So, paradoxically, a company that logged an area that was later involved in a fire could end up being contracted by the ministry to help fight the fire. Tolko Industries, which has created what are among BC’s largest clearcuts, was paid $4.6 million for work it did during the 2017 and 2018 fire seasons. During the five years covered by the records, there were 150 small companies with the word “Logging” in their company name that received, on average, $200,000 each for fire fighting operations during fire season. Seventy-two company names on the list included “Trucking” and 35 contained “Excavating.” Eighty-two companies provided helicopter services and the top 10 helicopter companies alone were paid $148 million. The private business at the very top of the money whirl was Conair, a BC-based company that provides fixed-wing air services for fighting forest fires. Over a five-year period Conair was paid $96,466,895.60. Next on the list were Perimeter Solutions Canada Ltd ($54,703,223.38) and Air Spray (1967) Ltd ($43,670,860.94). Perimeter and Air Spray supply fire retardant and retardant delivery to fires by aircraft. The $100 million spent on those services points to another level of damage that may be occurring as a result of the over-exploitation of BC’s forests. Fire retardants are known to be harmful to aquatic life, especially to stream-type chinook salmon smolts. Many chinook salmon populations in BC are now considered threatened. The growing use of fire retardants to fight BC’s forest fires is just one more threat to the species’ survival. Even transferring money to the over 8600 entities on the fire-fighting money list was expensive for BC taxpayers. For example, use of a Bank of Montreal Mastercard account cost hapless taxpayers $20,607,365.60. Since many of the companies that are receiving payments for fighting fires are the same companies that create the higher fire hazard of clearcuts and plantations in the first place, there is, to say the least, an appearance of a conflict of interest. An air tanker drops a load of fire retardant on a clearcut fire in 2017 (Photo by BC Wildfire Service) Forget Brazil. BC's per capita rate of forest removal is worse than Bolivia's. The response to the growing size and cost of fires from those with an economic stake in continuing logging as usual in BC forests all have one thing in common: No one ever suggests reducing the ongoing production of clearcuts and plantations, the inevitable consequences of logging. Quite the opposite, in fact. Industry and government both know that as time goes on and less and less primary forest is available to be cut, to keep volumes up at mills will require even greater areas of clearcuts and plantations to be created. That’s the ministry’s plan, and that promises an even more catastrophic future for BC. If you’ve come this far in my story, you must be looking for a solution to the mess the mindustry has created. If so, ask yourself these questions: Could the rate at which primary forest is converted to clearcuts and plantations be reduced? Or is the current rate of forest exploitation needed just to meet BC’s own basic need for products derived from forests? Ministry of forests’ data shows that 80 percent of the value of BC forest products comes from exports, and most of those go to China, the USA and Japan. So BC is cutting far beyond meeting its own needs for wood products. The extreme nature of that over-cut becomes apparent when BC’s rate of forest-cover loss is compared with other states that are, like BC, heavily forested. Consider Bolivia. It’s the 8th most heavily forested country in the world. It has an area of 1.099 million square kilometres, just slightly larger than BC’s 944,735. When you do the arithmetic, Bolivia’s forest-cover loss from all causes between 2001 and 2019 amounted to .545 hectares per capita. BC lost 1.66 hectares per capita, more than three times Bolivia’s loss. Yet when we compare per capita income between BC and Bolivia, there’s no question about which country has the greater need to exploit its forests. In 2010, the mid-point of the 20-year period we’re considering, Bolivia’s per capita income was around $1900 per person. BC’s was $41,327. So Bolivia had a vastly greater economic need to exploit its forest resource than BC did. Yet BC’s per capita rate of forest loss was three times as high as Bolivia’s. Keep in mind, too, that BC’s high per capita GDP had little to do with the forest industry, which in 2010 accounted for only 2.5 percent of BC’s GDP, according to the BC government. By 2019, that had fallen to 1.8 percent. By the way, if you take the forest-cover loss attributable to the beetle epidemic and forest fires out of BC’s total and compare that to loss from all causes in other countries, BC still has the worst record, as shown below: Back in the late 1980s, we used to say “BC is the Brazil of the north,” to express our disapproval for what the government and logging industry were doing to BC forests. That’s no longer even remotely appropriate. Now the global forest destruction putdown ought to be, “Bolivia is the British Columbia of the south.” And Brazil? On a per capita basis, Brazilians are forest angels by comparison. It’s evident that the extreme rate of forest removal in BC that’s fuelling large forest fires has, in turn, been fuelled by the high level of exports. That has been supported by a forests ministry that long ago stopped regulating the industry and now whole-heartedly facilitates extreme logging. Successive BC governments have chosen to go along with this, thinking that somehow this must all be good for the economy, and if it’s good for the economy, that’s all that matters to most politicians. Now that choice is having severe consequences. Unless BC breaks away from converting low-hazard primary forests into higher-hazard clearcuts and plantations to service export markets, our province seems fated to burn increasingly out of control. David Broadland writes about BC forests.

Slash piles left after clearcut logging in the Klanawa Valley on Vancouver Island. (Photo by TJ Watt) IN THE FACE OF THE CLIMATE CRISIS, BC’s ministry of forests and the forest industry have been working hand-in-hand on a public relations campaign to make clearcut logging seem climate friendly. They know its an uphill slog to sell the biggest emitter of carbon in BC as “climate friendly,” but employees of the ministry depend on continued forest destruction for their jobs, and industry depends on high-volume forest destruction for its profits. For them, the move to conserve forests to mitigate carbon emissions is an existential threat. Thus we increasingly hear in BC of new (publicly subsidized) initiatives that are going to make forest destruction even more “climate friendly.” These initiatives take two forms: First, creating “bioenergy” from logging “residue.” And second, developing “mass building” technology that will lock forest carbon into long-lasting buildings. This greenwashing of the forest industry is happening around the globe. In the US, forest and climate scientists are speaking out about the forest industry’s attempts to climate-wash itself. Two-hundred forest and climate scientists recently wrote the following letter to the US congress: “AS FOREST AND CLIMATE CHANGE SCIENTISTS AND EXPERTS, we are writing to urge you to oppose legislative proposals that would promote logging and wood consumption, ostensibly as a natural climate change solution, based on claims that these represent an effective carbon storage approach, or claims that biomass logging, and incinerating trees for energy, represents renewable, carbon-neutral energy. We find no scientific evidence to support increased logging to store more carbon in wood products, such as dimensional lumber or cross-laminated timber (CLT) for tall buildings, as a natural climate solution. The growing consensus of scientific findings is that, to effectively mitigate the worst impacts of climate change, we must not only move beyond fossil fuel consumption but must also substantially increase protection of our native forests in order to absorb more CO2 from the atmosphere and store more, not less, carbon in our forests (Depro et al. 2008, Harris et al. 2016, Woodwell 2016, Erb et al. 2018, IPCC 2018, Law et al. 2018, Harmon 2019, Moomaw et al. 2019). Furthermore, the scientific evidence does not support the burning of wood in place of fossil fuels as a climate solution. Current science finds that burning trees for energy produces even more CO2 than burning coal, for equal electricity produced (Sterman et al. 2018), and the considerable accumulated carbon debt from the delay in growing a replacement forest is not made up by planting trees or wood substitution (noted below). We need to increase growing forests to more rapidly close the gap between emissions and removal of CO2 by forests, while we simultaneously lower emissions from our energy, industrial and agricultural sectors. In your deliberations on this serious climate change issue, we encourage you to consider the following: The logging and wood products industries suggest that most of the carbon in trees that are logged and removed from forests will simply be stored in CLT and other wood products for buildings instead of being stored in forest ecosystems. However, this is clearly incorrect. Up to 40 percent of the harvested material does not become forest products and is burned or decomposes quickly, and a majority of manufacturing waste is burned for heat. One study found that 65 percent of the carbon from Oregon forests logged over the past 115 years remains in the atmosphere, and just 19 percent is stored in long-lived products. The remainder is in landfills (Hudiburg et al. 2019). Logging in U.S. forests emits 617 million tons of CO2 annually (Harris et al. 2016). Further, logging involves transportation of trucks and machinery across long distances between the forest and the mill. For every ton of carbon emitted from logging, an additional 17.2 percent (106 million tons of CO2) is emitted from fossil fuel consumption to support transportation, extraction, and processing of wood (Ingerson 2007). In fact, the annual CO2 emissions from logging in U.S. forests are comparable to yearly U.S. emissions from the residential and commercial sectors combined. The cumulative climate change impact of logging in the U.S. is even higher, since logging causes substantial reductions in carbon sequestration and storage potential in forests due to soil compaction and nutrient removal, and these combined impacts can often reduce forest carbon storage potential by 30 percent or more (e.g., Elliott et al. 1996, Walmsley et al. 2009). The wood products industry claims that substituting wood for concrete and steel reduces the overall carbon footprint of buildings. However, this claim has been refuted by more recent analyses that reveal forest industries have been using unrealistic and erroneous assumptions in their models, overestimating the long-term mitigation benefits of substitution by 2- to 100-fold (Law et al. 2018, Harmon 2019). The climate impact of wood is even worse if the reduced forest carbon sequestration and storage caused by nutrient loss and soil compaction from logging is included, as discussed above. In countless public communications, and at numerous Congressional hearings, industry representatives have advocated for increased logging in the context of reducing wildland fire and related emissions. While small-tree thinning can reduce fire intensity when coupled with burning of slash debris (e.g., Perry et al. 2004, Strom and Fulé 2007) under very limited conditions, recent evidence shows intensive forest management characterized by young trees and homogenized fuels burn at higher severity (Zald & Dunn 2018). Further, the extremely low probability (less than 1 percent, Schoennagel et al. 2017) of thinned sites encountering a fire where thinning has occurred limits the effectiveness of such activities to forested areas near homes. Troublingly, to make thinning operations economically attractive to logging companies, commercial logging of larger, more fire-resistant trees often occurs across large areas. Importantly, mechanical thinning results in a substantial net loss of forest carbon storage, and a net increase in carbon emissions that can substantially exceed those of wildfire emissions (Hudiburg et al. 2013, Campbell et al. 2012). Reduced forest protections and increased logging tend to make wildland fires burn more intensely (Bradley et al. 2016). This can also occur with commercial thinning, where mature trees are removed (Cruz et al. 2008, Cruz et al. 2014). As an example, logging in U.S. forests emits 10 times more carbon than fire and native insects combined (Harris et al. 2016). And, unlike logging, fire cycles nutrients and helps increase new forest growth.” COUNTERING GOVERNMENT AND INDUSTRY MISINFORMATION about these issues is critical. Both bodies have immense resources at their disposal to develop and perpetuate these myths. A properly informed public is an essential need that must be met in order to fight climate change and use forest conservation as the best form of natural mitigation. Through the resources page (see link below), we intend to provide the latest insights from BC and around the globe to develop public knowledge on this critical issue. You can help increase the level of public knowledge by adding links in the forum to resources that you found helpful in understanding these issues.

Climate change helped transport the water from there to here, but the extent of the damage done is mainly the responsibility of BC’s out-of-control logging industry. A short-wave infrared image of this summer’s 20,000-hectare July Mountain Fire (reddish brown area). The Coldwater River snakes along the fire’s lower edge on the left and then punches through the centre of the burn as it heads toward Merritt. LET’S SURVEY SOME OF THE DAMAGE and the circumstances that led to the Lower Mainland being cut off from the rest of Canada and the flooding of Merritt and Princeton in mid November. The Tank Hill Underpass, just east of Lytton, was built in 1957 to allow the newly widened Trans Canada Highway to pass underneath the CPR Railway. In all the years since, there’s no record of the culvert below the highway not having enough capacity to safely transport water under the structure. In February of 1963, for example, the structure survived a 24-hour rainfall of 69.9 millimetres (2.8 inches) that washed out both the highway and railway at a point closer to Lytton. In the “Great Coastal Storm” of 2007 that hit BC, Washington and Oregon in early December, Lytton recorded a 24-hour rainfall of 106.9 millimetres and the underpass was unscathed. But on November 14, the structure washed out after the fall of 61.9 millimetres of rain in the previous 24-hour period. What had changed? The washed out Tank Hill Underpass (Photo: BC Ministry of Transportation) The 807-hectare watershed above the underpass was severely burned during last summer’s 84,000-hectare Lytton Creek Fire. The ministry of forests’ historical record of forest fires shows that watershed had no previous record of fire. This summer’s fire, rather than the quantity of rain that fell, may have determined the underpass’s fate. The hydrological impact of forest fires is well understood. A 2011 study, conducted by US Forest Service scientists, noted: “Basins with high-burn severity, especially those with steep, previously forested terrain, have flashier hydrographs and can produce peak-flows orders of magnitude greater than pre-fire conditions.” (See report attached at end of story.) Note the scientists’ use of the expression “orders of magnitude greater.” As you know, one order of magnitude means 10 times greater. Two orders of magnitude means 100 times greater. And so on. Why would a forest fire have such a large impact on the hydrological function of a forest? Here’s the short answer from those scientists: “This is due to fundamental changes in the hydrology of burnt watersheds, especially in the short term (1-3 years). Consumption of the canopy and forest-floor organic horizon that formerly intercepted precipitation, moderated infiltration, and protected mineral soil, results in decreased evapotranspiration and infiltration, and increased runoff. Further, newly exposed soil surfaces are subject to rain-drop erosion, which may be exacerbated by fire induced soil-water repellency. Though the hydrologic impacts of high-severity wildfire have been well documented in the scientific literature, the socio-political ramifications of a latent, continuous, and highly unpredictable disturbance regime (i.e. post-fire flooding and sedimentation) has not been addressed.” At about the same time as the Tank Hill Underpass was washing out, more serious trouble was brewing 50 kilometres to the east. The Coldwater River began to surge over its banks where it joins the Nicola River at Merritt. The west end of the town was flooded above the level that hydrologists had determined would likely be the worst case scenario—the 200-year flood plain—for future floods from melting snowpack. No one foresaw Merritt being flooded by a mid-fall rainstorm. As many as 7000 residents were forced to evacuate. Yet Merritt itself recorded only 31.4 millimetres of rain (1.2 inches) in the critical 48-hour period on November 14 and 15. By way of comparison, a total of 28 millimetres fell in a 48-hour period on November 24 and 25, 1962 and no flooding was reported. Similarly, 36 millimetres fell on Merritt in a 48-hour period during 2007’s Great Coastal Storm, yet no flooding occurred. The Merritt flood was obviously the result of rainfall, but where did that rain fall? The town is near the junction of the Coldwater and Nicola rivers and just downstream from where Clapperton Creek—which drains the Nicola Plateau—joins the Nicola. Flooding in Merritt, looking southeast across the west end of town. The Coldwater River cuts across the centre of the photo. The smaller Nicola River is in the foreground. One of the town’s mills is visible in the background. Photographs of the Merritt flood posted online show that the Coldwater River was swollen and moving much faster than the meandering Nicola River. While not much rain fell directly on Merritt, precipitation was even lower towards Kamloops. The wave of water, then, likely originated south of Merritt near the headwaters of the Coldwater. That area, too, experienced a large forest fire last summer. The 20,000-hectare July Mountain Fire was contained almost entirely within the Coldwater River’s watershed. The same physical factors associated with severely burned forest that caused the washout of the Tank Hill Underpass were in play in the July Mountain Fire area, but in this case the burned area was 25 times larger. As well, there was a much larger area of recent clearcuts and young plantations in the watershed that had severely diminished the watershed’s natural ability to slow the rate at which water could move over the land before it reached the creeks and rivers that led to Merritt. UBC forest scientists XuJian Joe Yu and Younes Alila have found that removing forest in BC has a much greater impact on flooding than previously believed. They found, for example, that even small rates of logging can double the frequency of flooding and large rates of forest removal can result in up to fourfold increases in the frequency of large floods. Extensive clearcut logging has been allowed throughout the watershed since the early 1980s, but the rate of logging accelerated dramatically after 2009 when the ministry of forests introduced a salvage logging program. The program’s objective was to remove lodgepole pine killed by the Mountain Pine Beetle, but the logging companies were permitted to remove all trees. In the Lillooet and Merritt Timber Supply Areas, only 20 percent of the logging between 2010 and 2019 was related to salvaging dead pine. To make the salvage logging more commercially attractive, companies were permitted to take stands of any species of healthy trees as well. The result was widespread devastation of healthy primary forests and loss of hydrological function in the Coldwater watershed. The time-lapse video below, which runs from 1984 to 2020, shows a portion of the Coldwater River’s watershed that was burned by the July Mountain Fire. Watch for the sudden acceleration in the cut that occurs in 2010. Time-lapse video of logging in the area of the Coldwater watershed that was subsequently burned by the July Mountain Fire (Google Earth Time-lapse generator) Seventy-five kilometres southeast of Merritt, Princeton also flooded. It lies at the confluence of the Similkameen and Tulameen rivers. The town saw 66 millimetres of rain—just over 4 inches—over the 3-day period between November 13 and November 15. The last big flood there occurred in 1972, but that event was dramatically different from the November 14 flood. 1972’s soaking was the result of warm temperatures quickly melting a huge winter snowpack in late May. No record of a November flood ever occurring in Princeton could be found by this reporter. But, like the Coldwater, the Similkameen watershed experienced a large forest fire this past summer, entirely within its watershed—the 15,000-hectare Garrison Lake Fire—and extensive clearcutting has been allowed throughout the watersheds of both the Similkameen and the Tulameen. The time-lapse video below records the logging from 1984 to 2000 in the area of the Similkameen’s watershed that was burned by the Garrison Lake Fire. Time-lapse video of logging in the area of the Similkameen River watershed, 1984-2020, that was subsequently burned by the Garrison Lake Fire in 2021 (Google Earth Time-lapse generator) If forest fires are an important factor in flooding and water damage to infrastructure—and the scientists tell us that they are—then BC is likely in for a hell of a ride in the coming years. The current forest policy of liquidating as much primary forest as is necessary to compete in the export market for wood products—80 to 90 percent of logging in BC is for exports—is creating roughly 250,000 hectares of new clearcuts each year. Clearcuts and plantations have a higher fire hazard than primary forest, and as the fraction of BC that’s covered by clearcuts and plantations grows, forest fires are becoming larger. More and more of BC will be in that state that the forest scientists described as having “flashier hydrographs” and “can produce peak-flows orders of magnitude greater than pre-fire conditions.” More and more of BC will be unable to control movement of water across the landscape, whether it has burned or not. In short, the government’s current obsession with “export competitiveness” is leading directly to hell. You can see where all this is heading, can’t you? The cost of the flooding in Merritt and Princeton alone will likely be in the hundreds of millions. The cost of repairing the highway infrastructure and making it more flood and landslide resistant could be of a similar magnitude or greater. The wise thing to do next—now that we can see how climate change and the current forest management regime in BC are going to synergistically combine to produce physical chaos and social misery—would be to reduce the amount of logging in BC. Let the Chinese and American buyers of BC forests figure out some other way to grow. Instead, the logging companies will keep denuding the land as quickly as the export market will allow. The political class will decide that highways and bridges and flood-prone communities will now need to be reengineered and rebuilt to withstand higher levels of water and sliding hillsides, at whatever great cost. The financial and emotional costs of flooded-out lives will just have to be paid. But who will pay? Not the logging companies who caused it. Not the American or Chinese consumers of our forest products. Not the government officials who allowed it to happen. The cost of mitigating against climate change will become just another part of the immense public subsidization of the logging industry in BC. The blissfully unaware public will pay whatever is needed without even knowing they are paying for it. David Broadland does not consent to the destruction of life on Earth.