Powell River Parks and Wilderness Society (1992)
Box 345
Powell River, BC
Canada
V8A 5C2
October 29, 2013
Re: Management Plan #9
Mr.
Mike Davis
TFL Management Plan
Western Forest Products Inc.
#118-1334 Island Highway
Campbell River, BC
V9W 8C9
TFL Management Plan
Western Forest Products Inc.
#118-1334 Island Highway
Campbell River, BC
V9W 8C9
Dear
Mr. Davis:
I
am writing to you on behalf of the Board of the Powell River Parks and
Wilderness Society (1992).
First,
I would like to thank you and Stuart Glen for your efforts to answer my
questions and to provide the necessary background materials to enable me to get
a historic sense and a means of comparison of the annual allowable cut in Block
1, as well as the other blocks of TFL 39. In particular I appreciated your
patience, and willingness to meet with me, and my fellow board members of the
Powell River Parks and Wilderness Society.
We
reiterate that we support the forest industry as we have stated and shown
through our actions for over twenty years. The forest industry will remain an
important part of our local economy, especially if we treat the resource with
respect and hold the long view, rather than rapid liquidation. We know and
accept that as participants in recreation and tourism initiatives we operate in
a working forest, but we prefer it to be in a first class working forest where
recreation and the tourism industry can thrive in concert with the forest
industry through the use of adequate buffers at the interface between
recreational/tourism facilities and logging.
Recreation/tourism
contributes significantly to the well being of Powell River. Not only does it
support local workers and business owners through visitors’ expenditures, but
it also attracts new people into the area who decide to become permanent,
contributing members of our community who pay taxes that provide services we
all enjoy.
As
a group of volunteers dedicated to promote and protect the local environment
and accessible trails as a world-class destination, we seek certainty, security
and protection for our key nature tourism assets, the Sunshine Coast Trail, the
Powell Forest Canoe Route, and the alpine areas. Powell River and its visitors
enjoy amenities that have come about through the investment valued in the
millions of dollars and tens of thousands of hours of volunteer labour. We want
the recreation infrastructure investments to be preserved and enhanced because
they are increasingly important economic generators. Like logging, tourism also
needs an operational base that will allow it to grow now and into the future.
All
of TFL 39, Block 1 is still crown land in which a variety of industries
operate. It’s not just a “working forest” where only the loggers get to work
and recreation and tourism initiatives are tolerated at best. In protecting a
small fraction of the TFL for the use of recreation and tourism we are at the
same time creating additional jobs in the forest resource. Having a fixed trail
corridor also contributes to increased biodiversity values. Moreover, tourism
activities are sustainable. Year after year, on the same defined area (trail
and huts), tourism activities generate wealth within the region, and taxes that
will compete or outperform the wealth generated by a one-time harvest over the
same period of time of a 60 to 80 year rotation.
Blocks
2, 3, 4, and 5 up-Island and mid-Coast enjoy recreation and biodiversity
objectives enshrined in the VILUP and SCCO. Block 1, Powell River did not get
its legally established objectives re the Sunshine Coast Trail (contained in
the Recreation Zone) transferred from the Code FSP to the new FRPA FSP. This
left these values vulnerable and exposed to accelerated harvesting.
I
have read your draft management plan with great interest. Your recommendation
states in the Timber Supply Analysis that...
“The
primary objective of this report is to estimate reasonably achievable timber
flows for consideration by the Provincial Chief Forester in making the
determination of the allowable annual cut for the term of Management Plan #9.
More specifically:
1.
The management of non-timber values such as fish and wildlife habitat,
biodiversity, visual quality, and terrain stability is accounted for.
Protection of non-timber values will be satisfied by land base reserves,
rate-of-harvest constraints and/or by maintaining a percentage of the land base
in older stands.
2.
Timber flow is estimated by considering harvestable inventory, growth potential
of present and future stands, silvicultural treatments, potential timber
losses, and operational and legislative constraints.
3.
Impacts of declining timber flow on community stability and employment are to
be lessened by keeping rates of decline per decade as low as possible without
inducing undue impacts on other values or long-term timber sustainability.”
Within
these primary objectives we see opportunities for achieving a balance in an
integrated management system, where recreation and tourism are also accounted
for, up front, and not as an afterthought, where old growth is logged
sustainably, not liquidated for the exclusive benefit of the current generation
of forestry workers and shareholders, where jobs are not exported, but nurtured
intelligently in the region through an assured wood supply for the development
and manufacture of value-added products.
Where
possible I have tried to compose my comments through the lens of your
objectives above. I have addressed them sequentially, numbered 1 through 3. At
the end of my letter I have added some general comments.
Initially,
I found the draft management plan difficult to understand and to make the
connections. It required a lot of flipping back and forth, and on the whole I
don’t think it is a very user-friendly document. It seems to be aimed at
satisfying the needs of the chief forester perhaps, but not the general public,
which under FRPA’s framework is supposed to play an important part through its
input, a role we are playing. That said, with your generous help I have
acquired an understanding that allows me to make some measured observations on
your recommendations.
1. Management of
Non-timber Values:
The management of non-timber values such as fish and wildlife
habitat, biodiversity, visual quality, and terrain stability is accounted for.
Protection of non-timber values will be satisfied by land base reserves,
rate-of-harvest constraints and/or by maintaining a percentage of the land base
in older stands.
A. The Sunshine Coast Trail
We want the Sunshine Coast Trail to be accounted for and have its
own measurable objectives.
Powell River is the most populous community next to any of the
five blocks of TFL 39 and it’s the most isolated. People living in Powell River
have to take ferries to enjoy some of the amenities others on Vancouver Island
take for granted because they don't have to pay the high transportation cost to
get there. Thus it’s important for the citizens of our community to have good access
to the amenities of the local forests.
Nature-based recreation and tourism are
playing an increasingly important part in making this community survive and
grow attractive. The Sunshine Coast Trail is Powell River’s pre-eminent tourist
attraction. We request that within the next ten years the Sunshine Coast Trail
be established in its final location. We realize that during this time there
may be need for adjustment. In Objective 1 you state that you will meet
non-timber values through land-based reserves. We request that the Sunshine
Coast Trail have a 30 m buffer on each side, and be part of a land-based
reserve. That’s about a tree length of a mature hemlock. You have the capacity
to make this happen if you so decide. Your recreation allocation is startlingly
underused in Powell River.
We did the math together when we met at your office, and figured
out we would only be looking at 150 ha for an increased recreation allocation
which with a 30-metre buffer a side would cover roughly 25 km out of the total
50 km of the SCT that lie within TFL 39, Block 1. 150 ha are not even a third
of what was secured for Block 2 (Sayward at 531 ha) and it would enhance and
protect the SCT. It would ensure a quality experience for the hikers who will
want to come back and hike the rest of the trail. We do want repeat visitors.
They will bring more business to this community, and they will tell their
friends. Word of mouth and the social media have brought a spike in
visitations, since we have built the free huts, but especially this year, now
that the word has gotten out that we are Canada's longest hut-to-hut hiking
trail. It would also continue to provide habitat for wildlife and keep the
mushroom pickers happy.
You have defended the practice of not allocating any additional
recreation net-downs for Block 1 on top of the existing inadequate 11 ha by
putting recreation areas inside other constrained areas. That’s fine, but where
we can't have the trail in constrained areas (OGMAs, WTRAs, riparian zones,
etc) we want a buffer. The folks who are now coming from all over Canada and
around the globe do not like having to hike through clear cuts. Further, areas
that are currently restrained may be altered or removed in the future.
Your suggestion of a survey to gather more than the anecdotal data
that we are accumulating in our logbooks at the SCT huts, and through emails
and conversations with hikers, is a good suggestion and we will do a survey.
But to go on record for this submission, anecdotally, in the logbooks visitors
write about the beauty of the trail, but also about the regretful lack of
buffers, and the large number of cutblocks south of Tin Hat and Walt Hill.
In Block 1 there is some inaccurate information on recreation
trails. A couple of trails that are not in the TFL are included in the count as
if they were (Lang and Suicide creek trails - totalling roughly 10 km).
B. The Powell Forest Canoe Route
Further, to bring recreation net-downs more in line with those in
Block 2 we suggest that additional hectares should be set aside so that there
will be no more logging too close to the portages, as there was at Windsor Lake
WL-907, and again near Beaver Lake. The current legal objective for the Powell
Forest Canoe Route buffers is a mere 5 m buffer on either side of the centre
line. This is entirely unsatisfactory. Ten times as much would be good. A 50 m
buffer on either side would provide the feel of being in the interior of a
forest. We also request that some of the buffers between the lakes and the
logging mains should be widened to diminish the sound and the dust of logging
trucks and other vehicles driving by. Of course this is not possible
everywhere, but should be implemented wherever possible, for now and into the
future.
Assume that for a 400 m distance along a lakeshore logging road
there is a 2 year-old 50 metre wide cutblock between the logging main and the
requisite 30 m lake buffer. Right now the paddlers on the lake will see a cloud
of dust and hear the logging truck grinding along. Fast forward 10 years: The
trees are now a vibrant and dense young plantation that will absorb a fair
amount of the dust and noise generated by vehicles as they barrel by. Fast
forward 10 more years: The trees have shot up during that decade, and filled in
and the sounds of vehicles are virtually gone. The question is: How many
hectares does it take to provide a priceless natural experience for the
paddlers on the lake in the vicinity of this stretch of the road? That would be
two hectares of course.
In fact there are a few stretches like that on Dodd and Windsor
lakes that would benefit from less disturbed surroundings by means of wider
sound absorbing buffers. This is one of the major complaints about our Canoe
Route. More generous buffers on the Canoe Route portages and lakes would reduce
this problem. To accomplish this, Management Plan #9 would have to set aside
another 100 mostly riparian hectares.
2. Timber Flow:
Timber flow is estimated by considering harvestable inventory,
growth potential of present and future stands, silvicultural treatments,
potential timber losses, and operational and legislative constraints.
Inventory: The decision to represent age classifications (stand types)
in many of the figures by only four categories seems unnecessarily confusing,
if not unsettling. Looking back at MP #8, a dozen years older, it uses
different categories, categories that have been in use for many decades. For
what reason or purpose was this changed? Why not have the same nine categories
still used elsewhere in draft management plan #9, which would then allow the
reader to make an easier comparison.
Having trees between 140 years and 250 years of age represented as
old growth will give the layperson the impression that there is a far greater
volume of old growth available for harvesting, as illustrated in Figure 3 on
page 9 of the Timber Supply Analysis, than there actually is. This is
misleading. Old Growth is defined as greater than 250 years old on the coast (BC
Ministry of Forests: Old Growth Forests fact sheet, 2003.) The term 'old
growth' is meant to represent forests that have persisted through all the
stages of 2nd growth and have achieved a more or less steady state of
equilibrium between growth and decay, or climax forest. In other words a fully
expressed forested ecosystem. Stands
between 140 and 250 years do not meet the ministry’s, and generally accepted,
definition of Old Growth. The unfortunate perception
the reader must arrive at is that the Base Case is built on this premise. The
Base Case in Figure 3 (Stand Types’ Contribution to Base Case Harvest) shows
that in Decade 1 in excess of 50% of the harvest is contributed by old growth,
while the remainder is contributed by natural second growth.
What is happening to mature timber and what to the many small
dimension immature stems that we see now being logged as well? Is there a
recent accurate inventory, or is it only estimated? When was the last thorough
forest inventory of Block 1 undertaken? If the latter method is the case, it
will appear to the layperson as if there were a far greater volume of old
growth available for harvesting than there really is, such as is illustrated in
Figure 3 on page 9 of the Timber Supply Analysis.
If
a company were to use the Woodstock Model as proposed here, it would appear to
harvest just a small percentage of the new “Old Growth” age class that makes up
more than the 50% shown above, all the while being in a position to liquidate
all the historic, non-conventional old growth (>250 years) worthwhile
harvesting. By means of this re-labelling the age classes the historic Old
Growth can be liquidated quickly, but the books would show that only a small
percentage of old growth (under the new definition of >140 years) has been
harvested, and that lots of old growth is still left in the Timber Harvest Land
Base (THLB).
Truly,
this would be the end of large old growth, and the giants will become a picture
of the distant past, like the old photographs of hand loggers lying in the gaps
of 12-foot diameter giants that we now no longer see, sadly. All the old growth
that will be left is the old growth outside the THLB, and no more big trees
will be left available for harvesting within a couple of decades.
At the time when I brought this up at our meeting you commented
that your choice of conveying your ideas on representing this age class as old
growth was unfortunate, and that you thought it was a mistake and that you
wished you had not put it into the draft. We agree. We think it would be
helpful to the reader if this mistake were edited out of the document. We
recommend that a new draft be written which will also include a
straight-forward rendition in regards to which of the options were chosen to
arrive at the proposed increased AAC.
3. Impacts on
Community:
Impacts of declining timber flow on community stability and
employment are to be lessened by keeping rates of decline per decade as low as
possible without inducing undue impacts on other values or long-term timber
sustainability.”
Declining
flow (3) -
The Annual Allowable Cuts (AACs) of other blocks of TFL 39 are being decreased
while Block 1 (Powell River) has to take up the resulting slack to allow for a
Base Case that is flat as an arrow for the whole of TFL 39 for 250 years. You
recommend that the Annual Allowable Cuts (AACs) of the other four blocks up
island and coast be decreased by these percentages: Sayward –15.2%, Port
McNeill –21.9%, North Broughton and Phillips Arm –64.0%. Meanwhile you
recommend that Powell River, which has already suffered rounds of overcutting
(125%) in the last few years, is going to have to ramp up its cut even more
(16.4%).
We
cannot see how increasing the AAC is going to lessen the impacts of declining
timber flow on community stability. It will only hasten the inevitable
fall-down, and in the meantime it will diminish opportunities for the tourism
industry to establish itself within its own set-aside area of operation inside
the working forest, at a time when we ought to be looking at diversifying our
economy.
The
proposed partition of the non-conventional Timber Harvest Land Base will lead
to the rapid depletion of large sized old growth within a couple of decades, or
less. We do not think this constitutes protection of the public interest. It is
a corporate initiative to increase profits that puts corporate interests ahead
of the interests of the environment, the struggling local economy, as well as
the provincial treasury, which will get little in the way of stumpage. This
policy of liquidation of large old growth would clearly result in an economic
and environmental loss, now and for future generations. These large old growth
trees cannot be replaced within the time frame of a century. Is Powell River
expected to sacrifice its advantages that would help create more work in the
long run, for future generations, while also help diversify its economy
now?
Many
of the trees from the TFL are exported as raw logs to markets in Asia and the
USA. The continued export of raw logs is one of the major reasons for the loss
of forest industry jobs, and the diminishment of the forest resource.
We
note that you have not included any forecast about the possible effects which
climate change might bring to the short and long term health of the THLB of
Block 1. We view the decision not to include the effect of climate change as
flawed. A precautionary approach would be to consider this impact within your
analysis.
These
are significant factors that work against the primary objective of your report
that aims to ‘estimate reasonably achievable timber flows for consideration
by the Provincial Chief Forester in making the determination of the allowable
annual cut for the term of Management Plan #9.’
Perhaps
the timber flow is achievable, but the assumptions made in the draft management
plan have not led me to come to the conclusion that it is sustainable. It is
not in the best interest of Powell River. The current AAC is 408,000 m3/year,
the Base Case being presented is 435,000 m3/year, and the WFP-recommended is
475,000 m3/year. By recommending a smaller AAC instead, WFP as the stewards of
a public resource would ensure that the forests would recover and age again
over time and so would biodiversity, which is being considerably fragmented. We
recommend an extension of the current AAC.
General
Comments:
It appears that some blocks on the island and up coast will have specified
AACs. We recommend that Block 1 should have a specified AAC too with greater
opportunities for public participation than is currently available.
PRPAWS was not alerted to last year’s first round of MP #9 draft, nor
did we get any notification this year. Summers are notoriously the worst season
for getting people’s attention. They are on holidays. They have other things on
their minds. PRPAWS requests to be notified in the future about any initiatives
that propose to bring changes to the practices of harvesting Block 1, TFL 39.
We would like to see WFP begin joint planning and installation with
PRPAWS educational information signs along in certain sections the SCT as we
have previously discussed and agreed to do (Deer Creek riparian trail reroute),
and elsewhere on the SCT and the Canoe Route. The signs can explain WFP’s
sustainable practices to help educate the public about their industry, as well
as highlight the fauna and flora, and recreational features.
We
look forward to working closely with you to find the proper balance needed to
strengthen Powell River’s economy and to provide stable conditions for both
recreation/tourism and forest industries to prosper on the Crown land in Block
1.
Sincerely,
Eagle Walz
President
On behalf of the Board of Powell
River Parks and Wilderness Society
CC: Dave Peterson, BC Chief Forester
Honourable Steve Thomson, Minister
of Forests, Lands and Natural Resource Operations
Rob Thomson, Forest Practices Board
Manager, Audits and Investigations
Paul Tataryn, Regional Manager (Coast)
Recreation Sites & Trails BC
Shannon Janzen, WFP Chief Forester
Mike Davis, WFP Planning Forester
Stuart Glen, WFP Stillwater Planning
Forester
Nicholas Simons, MLA, Powell
River-Sunshine Coast
Norm Macdonald, Opposition Critic of
Forest, Lands and Natural Resource Operations
Dave Formosa, Mayor, Powell River
Colin Palmer, Chair, Powell River
Regional District
Powell River Parks and Wilderness
Society Board of Directors
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