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  • The ministry of denialism


    David Broadland

    BC's ministry of forests is actively creating an alternative reality about the impact its policies and actions have on the climate and biodiversity crises.

    October 6, 2020

     

    IN RESPONSE TO THE CLIMATE AND BIODIVERSITY CRISES, BC’s ministry of forests has fallen into a pattern of denialism. We all know what climate denial is: refusing to accept scientifically verifiable evidence. Denialism goes beyond denial. Denialism is the purposeful construction of an alternative version of reality. The ministry of forests, in cooperation with other members of the forest-industrial complex, is creating an alternative reality about the role forest loss plays in these two crises, and an alternative reality about how they should respond. Why? Likely because acknowledging the evidence about how industrial forestry contributes to both crises—and the ministry’s lack of an effective response—would result in the loss of social licence to continue doing what they are doing. That would mean reducing the size of the industry and a subsequent loss of revenue that keeps both the ministry and the industry operating. For them, it’s a matter of their own survival.

    Let me offer a few examples of this pattern of denialism, large and small:

    First. BC taxpayers have subsidized the largely unregulated forest industry to the tune of $1 million a day for the past ten years. Yet the ministry has purposefully hidden this subsidy by never making public a balance sheet that shows its revenues and expenses.

    Second. After years of pressure to conserve the remaining 415,000 hectares of productive old-growth forests to protect biodiversity, the ministry announced in September short-term logging deferrals on 352,739 hectares. When examined closely, though, the deferrals only delayed logging on about 32,500 hectares of productive old growth. The ministry knew it was including mostly ice, rock and low productivity old growth and second growth in its deferrals.

    Third. For employment statistics about the forest industry, ministry reports defer to an out-of-date 2016 Council of Forest Industries analysis instead of statistics derived from income tax returns that have been adjusted for the most recent mill closures and curtailments. In effect, the ministry has credited the industry with jobs that don’t exist.

    Fourth. Chief Forester Diane Nicholls’ advisory “Leadership Council” is composed entirely of forest industry insiders.

    Fifth. The forests ministry has made no public assessment of the impact of forest management on climate change or biodiversity loss, or how these are playing out in each of its management units, or how it intends to address these issues in a way that would make a substantial difference. The provincial GHG inventory for 2018 shows that forest management contributed 237 megatonnes of CO2-equivalent emissions (emissions from all other sources in BC were 68 megatonnes). BC has 1807 species of plants and animals at risk of extinction. 

    The ministry’s responses to both the climate and biodiversity crises have been shaped by the primary need of an economically marginal industry: to cut down publicly-owned forest at a rate as high as the market can bear, at the lowest cost. That includes using mechanized clearcut logging throughout the province, almost exclusively, and exporting raw logs. Any evidence that’s presented that the ministry’s policies and practices are making the climate and biodiversity crises worse is met with stony silence, straight-up denial, or fictions about the rosy-green future of mass timber construction and bioenergy.

    Below, I explore in detail a single streak of this pattern of denialism.

    In a recent story, “Forestry isn’t sustainable, folks,” I noted that between 2010 and 2019, the forest industry has been logging BC’s publicly owned forests at an unsustainable rate. The ministry of forests’ own timber supply reviews for 28 Interior timber supply areas determined that the sustainable cut level is about 12 million cubic metres per year lower than the current allowable annual cut (AAC). I acknowledged that one of the main factors in this imbalance was the loss of stands of Lodgepole Pine to the Mountain Pine Beetle.

    The story included the concerns of foresters Anthony Britneff and Martin Watts, who have provided detailed analyses which argue that the determinations of allowable annual cut and mid-term cut by BC’s chief forester are deeply flawed and skewed towards overestimating the future availability of wood from forests.

    One critical response to this story stood out. Atmo Prasad, who identified himself in a comment on this website as the “former manager for the analysis section of the Forest Analysis & Inventory Branch of the Ministry of Forests,” dismissed the highly detailed concerns of Britneff and Watts. He provided no argument or evidence to support his position. He simply asserted, “I am confident that the AAC set for each is sustainable.”

    In response to my observation of the substantial difference between the current aggregate AAC for timber supply areas and the aggregate of their mid-term cut levels—which Prasad appears to be in part responsible for estimating—he said, “The higher short-term harvest level found in most Interior TSAs is usually composed of wood killed by the mountain pine beetle or by the recent fires. The timber supply in these TSAs is expected to decline to the sustainable level after the salvage of dead timber is over. Construing the current AAC which includes dead wood as unsustainable is just pain [sic] wrong.”

    I have fact-checked Prasad’s contention that the “higher short-term harvest level” in Interior TSAs is “usually” the result of salvage of beetle- or fire-killed wood. Let me give you one example where, on the surface, what Prasad claims is correct. Then I’ll show you four examples where Prasad’s claim is disproven by the ministry of forests’ own data. I will provide some real-life consequences of timber supply analysts overestimating how much logging can occur. These examples also illustrate the pattern of denialism that appears to be the ministry of forests’ default operational setting.

    Focus used the ministry of forests’ Harvest Billing System to determine the total cut over a 10-year period in 12 of the Interior’s 28 timber supply areas. Using that publicly accessible system, we also determined how much dead lodgepole pine was salvaged and how much live lodgepole pine was removed in “sanitation” logging. What’s sanitation logging? It’s a euphemism for a program to preemptively log healthy lodgepole pine that could be attacked by the Mountain Pine Beetle. The data we downloaded also included fire-killed lodgepole pine. The data allowed us to determine the total volume logged over 10 years, and it provides a good estimate of how much of that was beetle- or fire-killed, and how much was sanitation logging.

    Let’s start with the example that supports Prasad’s take on what happened. The diagram below summarizes the case for the Prince George TSA. It covers 10 years of harvesting between 2010 and 2019 inclusive.

     

    23026556_PrinceGeorgeovercut2010to2019_001.thumb.jpeg.2239105c7c9e7fa7ded8e58b984ec5eb.jpeg

     

    What does the data for Prince George demonstrate? It shows that the volume of live trees logged (indicated by light orange above) was less than Prasad’s office estimated could be cut. This undercut amounted to 8.4 million cubic metres over the 10 years between 2010 and 2019, inclusive. The evidence supports Prasad’s contention.

    Keep in mind, however, the concerns Britneff and Watts have expressed about the mid-term cut level, the volume of logs that can be extracted from the forest on a sustained basis. They have noted that the models used by Prasad’s office to predict future growth and yield in BC forests provide inaccurate, overly-optimistic and unreliable estimates. Moreover, the models do not account for climate change. Britneff told Focus, “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.”

    So while it can be shown, on paper, that in certain timber supply areas the rate of cut of live, healthy trees over the past ten years has not been above the theoretical rate of mid-term sustainability, there’s good reason to doubt the validity of that theoretical level.

    The reader may also want to keep in mind that when we use the term sustainable cut,” we are not talking about ecological sustainability. We are using the only metric considered by the ministry of forests—volume of logs cut per year—to determine whether logging can theoretically continue at a certain rate into the future.   

    Let’s move south to the Kamloops TSA. The diagram below summarizes 10 years of harvesting there.

     

    606307970_Kamloopsovercut2010to2019_001.thumb.jpeg.70f93b18ff38c0ca050f995a89008bd1.jpegIn this TSA, Prasad’s assertion is challenged. When the salvage and sanitation logging are removed from the ledger, the ministry’s records show logging exceeded the theoretical mid-term sustainable cut level by 3.4 million cubic metres. That overcut resulted in about 9800 hectares of publicly-owned land being clearcut beyond what BC timber analysts believe to be sustainable.

    Immediately to the east of the Kamloops TSA is the Okanagan TSA. The diagram below summarizes 10 years of harvesting.

     

    2009443318_Okanaganovercut2010to2019_001.thumb.jpeg.9c6f0f91f1e0eaf9a1f5eae3c6db8afb.jpegThe Okanagan TSA’s record swerves even further away from Prasad’s account, and the volume of the overcut is 5.4 million cubic metres. That’s roughly equivalent to cutting 15,500 hectares beyond what BC timber supply analysts have assessed is theoretically sustainable. Our analysis showed that salvaging of beetle- and fire-killed lodgepole pine, along with pre-emptive logging of live lodgepole pine, amounted to 6 percent of the total cut. The volume of live, healthy lodgepole pine that was pre-emptively logged so that it couldn’t be killed by beetles was twice the volume of beetle-killed lodgepole pine.

    South of the Kamloops and Okanagan TSAs are the Merritt and Lillooet TSAs, the data for which we grouped together in the diagram below. Again, this summarizes 10 years of harvesting.

     

    1591615123_LillooetMerrittovercut2010to2019copy_001.thumb.jpeg.33a912480ff398ff171d08cd0fad9bb9.jpegIn the Lillooet and Merritt timber supply areas, Prasad’s assertion again fails. The combined cut of live trees in those two TSAs—and this excludes sanitation logging of live lodgepole pine—reached 150 percent of the mid-term sustainable cut level, resulting in over 20,000 hectares of additional clearcuts beyond what BC’s timber supply analysts deemed was sustainable.

    The excessive, unsustainable logging that took place in the Kamloops, Okanagan, Merritt and Lillooet timber supply areas has consequences. If a specific logging practice is problematic, the more logging that employs that practice, the greater the problem that’s created. And in mid-September the Forest Practices Board released a special investigation report about one of those specific problems: reforestation. 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 board’s 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.”

    That finding supports a concern expressed by Britneff and Watts, that computer-model-based predictions of future growth and yield don’t necessarily reflect what’s actually happening on the ground. Yes, clearcuts are being replanted, but they are then failing to grow at the rate used by BC’s timber supply analysts in their determinations of how much cut is—theoretically—sustainable.

    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.”

    The Forest Practices Board also 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.” As noted in my earlier story, Britneff and Watts, in their detailed critiques of the timber supply review and allowable annual cut determination processes, have observed that BC’s current Chief Forester Diane Nicholls has rejected including the likely consequences of climate change as part of her determinations.

    Nicholls wrote, in a 2019 timber supply review for the Lakes TSA, “the potential rate and specific characteristics of climate change in different parts of the province are uncertain. This uncertainty means that it is not possible to confidently predict the specific, quantitative impacts on timber supply.”

    That position, Watts and Britneff say, throws more doubt on the validity of the timber supply analysts’ estimates of future growth and yield. Now the Forest Practices Board has echoed their doubts.

    Nicholls’ statement is another way of saying, “Since I dont know exactly what the impacts of climate change will be on how trees grow in all of BC, I cant make any changes to our practices anywhere.” If the chief forester was intent on responding to the challenges that climate change poses for forests, as is needed, she would never have made such a statement. She has constructed an alternative reality in which uncertainty is used as an excuse for not acting. But the uncertainty of the situation requires the exercise of the precautionary principle: Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation.

     Cast your gaze now on a constellation of seven timber supply areas in the southeast corner of the province, known to the ministry of forests as the Kootenay-Boundary Natural Resource District. The graph below summarizes 10 years of harvesting there.

     

    1107553461_Kootenay-Boundaryovercut2010to2019_001.thumb.jpeg.ee85329abcfaa9c244d5adb2294ce92d.jpeg

    Note the small fraction (0.9 million cubic metres) of logging attributable to Mountain Pine Beetle salvage logging, beetle sanitation logging and fire-killed lodgepole pine salvage. Similar to the case in the Okanagan TSA, the volume of live, healthy lodgepole pine that was logged so that beetles couldn’t kill it is greater than the volume of beetle- and fire-killed pine. In this region, though, the difference is more extreme. Five times as much live, healthy lodgepole pine was pre-emptively logged as there was salvage logging of dead lodgepole pine.

    The 6.0-million-cubic-metre overcut required clearcutting of over 17,000 hectares of forest. One of the possible consequences of that overcut is highlighted in a class-action legal suit against the BC government and several forest industry corporations filed in mid-July 2020 by residents of Grand Forks.

    In May 2018, Grand Forks experienced devastating flooding of the Granby and Kettle Rivers. About 3000 homes and businesses had to be evacuated and over 400 homes and dozens of businesses were flooded.

    In their statement of claim, the plaintiffs allege that the flooding resulted from excessive runoff caused by logging in the Kettle River watershed, which includes the Granby River. The headwaters of the West Kettle River and the Kettle River are in the Okanagan TSA, mentioned above, where the rate of logging also exceeds the sustainable mid-term rate of cut. The West Kettle, Kettle and Granby flow south through the Boundary TSA.

     

    1591697892_KettleRiverValleylogging.thumb.jpg.02d7de91daef413c63a62f905806acdb.jpg

    Logging in the upper Kettle River Valley. The Kettle river can be seen on the left side of the image, the Granby to the right of centre. (Click on the image to enlarge it.)

     

    268794185_LoggingintheGranbyRiverwatershed.thumb.jpg.5857efda8f49da2b8f94837358faba1b.jpg

    The Granby River runs across the the bottom of the aerial photograph above. Note the extensive logging above the river. The Granby flows into the Kettle River at Grand Forks. (Click on the image to enlarge it.)

     

    Specifically, the suit states that the Forest Analyses and Inventory Branch of the ministry of forests overestimated by 20 percent the timber volume in forest stands in the watershed, and this led to an allowable annual cut that was 20 percent too high to be sustainable. The plaintiffs allege that, “This has led to increasing the frequency, duration and magnitude of peak flows. Without sufficient timber regrowth and watershed recovery the result is increased surface runoff, increased sediment transport, increased water quantity and stream channel discharge associated with flooding that caused the major flooding events in the Kettle and Granby river systems resulting in the damages to the Plaintiffs’ and Class Members’ property.”

    Focus examined the ministry of forests’ record of harvesting over the last 11 years in Boundary TSA.  That record (see below) does show a quick increase in the rate of harvesting in the 10 years leading to the flooding in 2018 (this graph does not include logging in that part of the Okanagan TSA within the Kettle River watershed).

    237037507_BoundaryTSAcut_001.thumb.jpeg.cf1c0ea37d30cc8b5ec944b6a7f5ba4e.jpeg

    The suit doesnt allege that the ministry of forests failed to consider the likely consequences of climate change, but it could have. Scientists have been reporting for years that a warming planet means rainstorms will drop more water in a given period of time. A search through the Boundary Timber Supply Areas 2011 timber supply review couldnt find a single reference that would suggest the hydrological function of forests—including their ability to keep the forest floor from becoming saturated and their ability to slow down the melting of snow—was given any consideration in determining what level of cut was sustainable.” (Read a comprehensive account of the Grand Forks civil suit by Ben Parfitt here.)

    The only certain way to reduce the forest industry’s alarming impact on the climate and biodiversity crises is to significantly lower the rate at which the industry is razing publicly owned forests. Yet the working relationship between the ministry of forests and the forest industry is based on maintaining the highest rate of cut, even if that cut exceeds what the ministry has determined can be sustained over time. Unless that is replaced with a relationship in which a robust response to the climate and biodiversity crises is the primary objective, the established pattern of denialism in the ministry will continue, ensuring that both crises will worsen.

    David Broadland started writing about forests, the logging industry and the ministry of forests in 1989.

    Relevant documents:

    Forest Practices Board Investigation Report: Reforestation in Interior Douglas Fir Subzone FPB September 17 2020.pdf

    Statement of Claim of Grand Forks residents class action lawsuit: Grand Forks civil action.pdf


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