TIMBER SUPPLY REVIEW 2023
The BC Chief Forester will soon decide on an Annual Allowable Cut (AAC) for the Sunshine Coast Forest District within the Timber Harvesting Land Base. These watersheds are located from Bute Inlet to Howe Sound. The new AAC will set logging levels for the next ten years. The Chief Forester will base his decision on the Timber Supply Review, First Nations, and Public Comment.
The public comment period is mandatory and the Public Discussion Paper complex. If you care about the future of our forests this may seem unfair to have meaningful engagement. Below you will find a plain language summary, problems, and asks of the TSR Discussion Paper from qathet Old Growth. Feel free to use that information in your emails of concern.
* YOU can make a difference by making a comment *
Jillian Tougas engageSunshineCoastForestDistrict@gov.bc.ca
Cc
Bruce Ralston Minister of Forests bruce.ralston.mla@leg.bc.ca
Nicholas Simons MLA nicholas.simons.mla@leg.bc.ca
Hegus John Hackett Tla’amin Nation john.hackett@tn-bc.ca
Denise Smith Tla’amin Lands and Resources denise.smith@tn-bc.ca
qathet Old Growth qathetog@gmail.com
Deadline for comments: May 1, 2023
NDP Commitments to Old Growth
Since 2020 the NDP have consistently claimed to be adopting the recommendations in the Strategic Old Growth Review, including a paradigm shift in managing forests for ecosystem health and resilience, and immediate response to ecosystems at very high risk.
The baseline AAC calculation is outlined in the Timber Supply Review (TSR) Analysis Discussion Paper and there is more information about the process on the BC government webpage.
qathet Old Growth knows that our forest ecosystems are already at high risk levels in many of our forest types based on recommendations from the Old Growth Strategic Review and Government Forest Inventory Data.
qathet Old Growth believes there are serious problems with the TSR still based on forest plantation models that do not account for the direction that the current BC government is taking with respect to Old Growth and Forest Ecosystem Function and Resilience.
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Ask that: All remaining Old Growth forests are removed from the THLB. This will result in AAC reduction of only 0.4%
*The TSR targets cutting remaining old growth in the next 10 years.
The Discussion Paper does not reflect the provincial government policy for a “paradigm shift” in forestry practices regarding Old Growth. It does not incorporate into the analysis any of the 14 recommendations in the policy paper “A New future for Old Forests”
Quote from “A New Future for Old Forests”
p. 71 “ Our ever-expanding understanding of forest behavior and management, as well as the effects of climate change, have made it clear that we can no longer continue to harvest timber and manage forests using the approaches we have in the past while also conserving the forest values we cherish. We therefore have to be honest with ourselves and collectively and transparently make the difficult choices necessary to ensure future generations of British Columbians can enjoy and benefit from our magnificent forests, as we have done.”
According to the Old Growth Strategic Review there needs to be an immediate response to:
Defer development in Old Forests where ecosystems are at very high and near-term risk of irreversible biodiversity loss and bring management of Old Forests into compliance with existing provincial targets and guidelines for maintaining biological diversity.
On p. 15 Figure 1. of the TSR Analysis Discussion Paper shows how much wood will be cut over time, for 300 years. The colours represent the age of the forests cut each decade. Dark blue is Old Growth, over 200 years old.
This graph shows that almost all the Old growth in the Timber Harvesting Land Base will be cut in the next 20 years. Cutting the remaining pockets of ‘productive’ mountain hemlock/yellow cedar is not consistent with the recent government commitments to retain Old Growth.
p. 2 “These forests have a long harvesting history and, as a result, there are rapidly maturing second-growth forests located on the lower elevation, more accessible, and higher productivity growing sites. Nearly 60 percent of the stands on the Timber Harvesting Land Base are between 21 and 100 years of age.”
References to Increase in Size of Allowable Cut
p. 11 The Discussion Paper shows there has been a steady increase in the total allowable cut since 1993 with the maximum being 1.205 million cubic metres/year in 2013 when the last allowable cut was set.
p. 28 The Discussion Paper describes scenarios where in the initial years there would be an allowable cut of between 1.27 and 1.56 million cubic metres/year.
The graph figure 1. p. 16 refers to the Timber Harvesting Land Base (THLB) which is 43% of the whole Crown Forest Managed Land Base (CFMLB).
Within the CFMLB there are areas managed for old growth, outside the Timber Harvesting Land Base, but there is not enough Old Growth Area.
The land within the Timber Harvesting Land Base is proportionally better land for growing, with highly productivity forests capable of big tree Old Growth.
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Ask that: The Timber Harvesting Land Base is reduced to allow for Old Growth Recruitment. 20% lower or more.
The TSR makes no allowance for setting aside mature forests for future Old Growth in under-represented forest types as reflected by the data provided by the Old Growth TAP on Map 7 - Old Growth Recruitment.
Highly productive forests are dangerously under-represented among our remaining Old Growth. Lower elevation forest types were logged 100 years ago and heavily since then. Mature forests of these types are the most urgently needed as set aside, so that they can become Old Growth.
Old Growth is under-represented in all forest types in qathet Regional District compared to historic levels. The percentages are well into ‘the high risk red zone’ for lower elevation and dryer forest types. (CDFmm, CWHxm, CWHdm)
Table 1. PG 3 GIS Draft Analysis of Forest Cover in qathet Regional District, qathet Old Growth, 2021.
Risk to Ecosystem Function
*Risk to ecological function and resilience is defined as increased likelihood of drought, wildfire, floods, species loss and less resilient watersheds.
Forest types are classified by BEC units. Based on figures from the Provincial Cumulative Effects Framework, as cited in Standards for Assessing the Condition of Forest Biodiversity under British Columbia’s Cumulative Effects Framework (MOE 2020). The CDF figure is sourced from Last Stand for Biodiversity (Price et al. 2020).
Retain mature forest for recruitment toward meeting ecosystem-based old forest targets by Landscape Unit:
Apply ecosystem-based targets for Old Growth (as per Gorley & Merkel 2020, see Table) by Landscape Unit (Large Watershed) and for each BEC sub variant within those Landscape Units.
Where those targets are not currently met, retain sufficient areas of mature forest for recruitment, towards meeting ecosystem-based targets, with >30% historic old growth as a minimum target, and >70% historic old growth as a target in landscape units that support community water supply, fish habitat/spawning, and biodiversity conservation.
Where there is less than 30% of the historic old growth, the forest is at high risk* of losing ecological function and resilience.
Not a single Land Unit Plan has Old Growth management area targets that are not well below the minimum ecosystem-based Old Growth percentages specified by the Old Growth Strategic Review, below which there is high risk of losing ecosystem function and resilience.
The Discussion Paper describes “rapidly maturing second-growth” as valuable for harvesting but not as a source of future old growth.
For more information about ecosystem based targets refer to:
1. New Future for Old Forests; A Strategic Review of How British Columbia Manages for Old Forests Within its Ancient Ecosystems Gorely, Merkel, 2020
2. BC’s Old Growth Forest; A Last Stand for Biodiversity, Price, Holt, Daust, 2020
https://veridianecological.files.wordpress.com/2020/05/bcs-old-growth-forest-report-web.pdf
3. Priority Deferrals an Ecological Approach
4. Estimating the amount of British Columbia’s “big-treed” Old Growth: Navigating Messy Indicators
This 2023 paper by Price, Holt et al. has several policy issues and recommendations related to determining big tree OG, including some specific concerns and recommendations in relation to regional forestry planning.
Net Downs: what is removed from Crown Forest Land Base to get Timber Harvesting Land Base.
The area of this analysis is the Sunshine Coast Forest District Timber Supply Area, Crown Forest Managed Land Base, TSA, CFMLB. The Crown Forest Managed Land Base is 440,792 ha. The Timber Harvesting Land Base is about 43% of that, THLB (190,668a). Inoperable land, unstable terrain, old growth management areas, parks, and other factors are not part of the THLB.
That is what the calculation is for: how many cubic metres of wood can be cut each year from the Timber Harvesting Land Base.
In the public discussion paper a map of the Crown Forest Land Base is on page 3, and a table showing what is not in the THLB is on page 8. What is not in the THLB is often lower quality growing areas. For example Old Growth Management Areas tend to be in inoperable, or difficult terrain. The table is where one can surmise that the best growing land is within the THLB.
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Ask for: Sensitivity Analysis for managing forests for watershed function and resilience to extreme weather events.
The TSR does not consider the anticipated effects of climate change on forest health, resilience and biodiversity. There appears to be no strategies for mitigation or adaptation to climate change in the Public Discussion Paper. The AAC should protect communities from risks of flooding and forest fires.
Ministry of Forest representatives have not yet answered the questions on this subject that were asked at the public zoom call.
In the Data Package that preceded the public discussion paper, mention was made of running analysis for climate change and proposed Old Growth deferrals. If these tests were run, they are not shown on the table in the public discussion paper.
The Province and the forest industry are not legally required, in most cases, to consider downstream impacts of their activities on communities and cumulative impacts of forestry on watershed health and functioning.
Currently, watershed assessment studies are only required in some situations (fishery sensitive watersheds and community watersheds). When conducted they use an outdated framework which grossly underestimates the risk and scale of impact[1] of cumulative forestry activity (Alila et al. 2009[2], Yu & Alila 2019[3]).
[1] The work of attribution scientists like Prof. Younes Alila from UBC has repeatedly shown that the hydrology of watersheds is much more sensitive to upstream logging than traditionally believed. Several court cases are coming forward, using attribution science, to make their cases in court.
There are two cases that have been settled out of court so far. The Province and forestry companies have not yet incorporated this science into decisions surrounding forestry.
Attribution science has been gaining ground and is extensively used in climate science and climate change court cases globally.
[2] Alila, Y., Kuraś, P. K., Schnorbus, M., and Hudson, R. (2009), Forests and floods: A new paradigm sheds light on age-old controversies, Water Resour. Res., 45, https://agupubs.onlinelibrary.wiley.com/doi/full/10.1029/2008WR007207
[3] Yu, X.J., Alila, Y. (2019). Nonstationary frequency pairing reveals a highly sensitive peak flow regime to harvesting across a wide range of return periods, Forest Ecology and Management, 444.
https://www.sciencedirect.com/science/article/abs/pii/S037811271930271
Out of control: A growing area of high-hazard clearcuts and plantations is fuelling BC's raging forest infernos
https://www.focusonvictoria.ca/forests/90/
Watershed resilience and drinking water protection are not part of the analysis. We would like to see variables associated with climate change and watershed resilience included in the sensitivity analysis.
*Note that managing for watershed function and resilience may be accommodated by using ecosystem-based targets for Old Growth Retention and Recruitment as outlined in Problem 2.
Sensitivity Analysis
The sensitivity analysis table on page 22 of the Public Discussion Paper shows what happens to the average harvest level when variables in the forest computer model are changed. (issue tested column). Most relevant is the ‘current practice’ scenarios, the lower rows.
Of note is the third from last row “ limit harvest of stand over 120 years in age”. The change in average harvest level appears to be small, -0.4 %.
The removal of 10% of the Timber Harvesting Land Base reduces the average harvest level ( m3/year) by around 8.5%.
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Ask: The value to governments in retaining forest for recreation, tourism and health benefits be weighed against the net revenue from logging, including the costs to the provincial government of providing logging infrastructure.
p. 1 “The BC Ministry of Forests undertakes these reviews by examining the impacts of current legal requirements and demonstrated forest management practices on the timber supply, economy, environment and social conditions of the local area and Province.”
The Discussion Paper does not address the problem of the rapid decline in income to the province and forestry worker jobs due to past forest management practices, practices that the paper assumes will continue despite their flaws.
p. 6 “The Timber Harvesting Land Base is derived from forest management practices and assumptions supported by data described in the Data Package.”
The Discussion Paper does not weigh the damage to tourist revenues from accelerated clear cutting of large parts of the qathet Regional District.
Our area draws tourists to the beauty of our back country for hiking, boating, and other forms of recreation. The paper mentions these on p. 4 but does not comment on the conflict between these economic benefits from tourism and clear cut logging.
See article: “Forestry doesn't pay the bills, folks”
https://www.focusonvictoria.ca/forests/forestry-doesnt-pay-the-bills-folks-r24/
To value our productive forests as the lungs of our communities to protect us through increasing fire seasons, cooling temperatures with the greatest potential to draw carbon down in these accelerating times of change.