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  • Is the Draft Framework on Biodiversity and Ecosystem Health something new? Or just more talk and log?


    BC’s exhausted forests may be about to undergo a generational shift in management paradigm. We hope so. But based on its recent poor record of settling First Nations’ land claims, applying ecosystem-based management and conserving biodiversity, it’s just as likely that government is taking us into a new phase of talk and log.

     

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    Clearcut logging of old forest near the Mahatta River on Vancouver Island in the territory of Quatsino First Nation. The NDP government’s recent record of forest management in BC has been so controversial that it may be trying to change its spots. Should the proposed Biodiversity and Ecosystem Health Framework initiative be taken seriously? (Photo by TJ Watt)

     

    JANUARY 31 is the deadline for public comment on the BC government’s proposed “Biodiversity and Ecosystem Health Framework”. My intention here is not to provide you with a summary of that document, which you can read for yourself. Instead, I offer a number of criticisms of the framework based on the current government’s recent record on three of the central propositions of the framework: One, that the provincial government is serious about conserving biodiversity; second, that a declaration of “ecosystem-based management” will slow or stop biodiversity loss; and, third, that the current government is genuinely interested in reconciling with First Nations over land claims. We always need to hold government accountable for what it has done, not so much for what it says it will do.

    The draft Biodiversity and Ecosystem Health Framework doesn’t even mention the Tripartite Framework Agreement on Nature Conservation (the Nature Agreement) recently signed with the federal government, but the objectives of the two initiatives dovetail closely with each other: both are intended to conserve biodiversity and both call for First Nations to play a leadership role in the process of establishing that protection.

    The Nature Agreement commits the Province to have 30 percent of BC’s land and water under some form of conservation status by 2030 and creates a $1.2 billion fund to accomplish that. That the relationship between the two initiatives has not been spelled out in the Biodiversity and Ecosystem Health Framework is puzzling. What happens if the Liberal government is defeated in the next federal election and Pierre Poilievre’s Conservatives defund the Nature Agreement? Is that possibility the reason the connection is left unclear?

    As well, in October 2023, Premier David Eby announced a $300 million “Conservation Funding Mechanism” to “fund new conservation measures that are led or supported by First Nations, lasting environmental protection measures, capacity building for First Nations, stewardship and guardian programs, and support for low-carbon economic opportunities.” Would that money support the Biodiversity and Ecosystem Health Framework? Is that $300 million different money than the $600 million BC would contribute under the Nature Agreement?

    Without actually saying it, the Biodiversity and Ecosystem Health Framework is poised to establish what forest “conservation” would mean in BC. But forest conservation is not an abstraction. Unless it takes place on the land, it isn’t happening. The Biodiversity and Ecosystem Health Framework, then, although it says nothing yet about which places would be conserved, would eventually have to define where—geographically—conservation would take place. And we can’t talk about “where” without considering the Nature Agreement, which says that 30 percent of the province needs to be in some form of a conservation area. So the comments below intertwine the two initiatives.

     

    This government has been good at protecting rock and ice. That won't conserve biodiversity.

    The primary objective of the federal-provincial Nature Agreement is to protect biodiversity—the myriad forms of life that live here. To do that will require shifting more of BC’s terrestrial, freshwater and marine ecosystems into some form of conservation status. Right now, approximately 14.4 percent of BC is in some form of conservancy, ecological reserve or protected area. To bring that to 30 percent, another 14.74 million hectares of the province will need to be shifted into some form of conserved area or protected area by 2030. There is, of course, a growing global movement—“Half for Nature”—supporting conservation of 50 percent of the world’s terrestrial, marine and freshwater ecosystems. But first we have to try for 30 percent.

    The most recent example in BC of the government saying they are making this necessary shift was the establishment of the Incomappleux Conservancy in 2023. The on-the-ground details of that conservancy are worthy of our close attention. They show why the Incomappleux Conservancy—if it was used as a model for conservation in the rest of BC—would severely constrain the conservation of actual biodiversity. But the details also point in the direction of how to get BC on the right track.

    Before the declaration of the Incomappleaux Conservancy, the immediately controllable threat to biodiversity there was the harm that would be done by logging in the remaining old forests of Block 2 of TFL 23. The licence to log that area was held by Interfor. In the agreement to establish a conservancy, Interfor gave up the right to log in the valley in exchange for $3.75 million, according to the Valhalla Wilderness Society.

    (Note: By “old forest”, I mean primary forest. However, not all primary forest is “old”. If that’s confusing, see this definition of “primary forest”.)

    Here’s part of the problem: The vast majority of the area of the new conservancy consists of biodiversity-scarce ice and rock, which, obviously, were not directly threatened by logging. Only a small fraction of the conservancy consists of old forests containing high levels of biodiversity that were threatened by logging.

    The areal extent of the Incomappleaux Valley that’s now in the conservancy that was considered suitable for logging—see Interfor’s map of its timber harvesting land base in blue in the image below—was only 3600 hectares. To “protect” the biodiversity that remained in that area the provincial government established a 58,000-hectare conservancy. So for each hectare of land in the conservancy that once supported a high level of biodiversity and could be or had already been logged, over 15 hectares of unthreatened, low-biodiversity rock and ice were included in the conservancy.

     

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    The light green area over this satellite image shows the extent of the Incomappleux Conservancy. The light blue areas show Interfor’s mapping of the area it considered suitable for logging (the THLB) before the conservancy was declared.

     

    If that 15 to 1 ratio of unthreatened rock and ice to threatened forest area in the Incomappleux Valley Conservancy is used as a model for “protecting” the rest of the province, then instead of protecting 14 million hectares of threatened biodiversity, the Nature Agreement would protect less than 1 million hectares of land that is actually threatened by logging. That tendency of government to “protect” ice and rock in BC is one aspect of the problem. But in terms of protecting existing pools of high biodiversity in the conservancy area, the creation of the conservancy provides an even smaller benefit.

    Of those 3600 hectares that were threatened by future logging—much of which had already been logged once—little of that area still contains high levels of biodiversity: a mere 273 hectares. That’s the area of old forest, as mapped by the Old Growth Strategic Review’s Technical Advisory Panel (shown in dark green in the image below) that overlaps with Interfor’s mapped timber harvesting land base.

     

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    Interfors mapping of areas suitable for logging (blue) in part of the Incomappleux Conservancy. TAPs mapping of priority deferral areas are shown in dark green. Areas where the blue overlaps the dark green were the only remaining areas of old forest that were still threatened by logging.

     

    So to protect 273 hectares of highly biologically productive old forest, the BC government has created a conservancy that’s 58,000 hectares in size. At that rate, 14.74 million hectares of new protected areas and conservancies would only conserve 70,000 hectares of the most biologically productive land in BC that hasn’t already been logged. That outcome would be an utter failure to meet the Nature Agreement’s primary objective of conserving biodiversity.

    The government and industry may argue that since “restoration” or “rehabilitation” of logged land is possible, it’s okay to include clearcuts in conservancies and protected areas. But in BC’s forested ecosystems, only old forests contain high levels of biodiversity. The great amount of time and money that would be needed to restore clearcuts to old forest put such an approach far outside both the budget and the limited timeframe we have left to prevent irreversible biodiversity loss.

    By the way, the Incomappleaux Conservancy is not protected from mining or private development of recreational infrastructure, which are permitted in a provincial “conservancy”. All of the existing mineral claims in the conservancy have been left intact. And although climate change threatens to bring change to the entire conservancy, labelling an area as a “conservancy” or a “protected area” will have no affect on how climate change degrades ecosystems there.

    That, then, is the most recent record of the current NDP government at creating a conservation area to protect biodiversity. While the draft Biodiversity and Ecosystem Health Framework promises a paradigm shift in managing for biodiversity in BC, the government’s record suggests that promise could be just a more sophisticated form of talk and log.

     

    A non-business-as-usual approach to conservation is possible

    There are, however, a couple of aspects of the Incomappleaux Conservancy that suggest a direction that could lead to greater success. To understand where hope may lie, we first need to consider the budgetary restraints of the Nature Agreement.

    The Nature Agreement commits the federal government to contribute about $600 million to finance conservation and requires BC to contribute a matching $600 million, for a total of $1.2 billion. That’s the budget.

    As mentioned above, the Valhalla Wilderness Society estimates Interfor was paid $3.75 million for giving up its right to log in the Incomappleaux River watershed—most of which, as mentioned above, has already been logged.

    According to government records, that compensation required Interfor to give up—in perpetuity—the right to log 36,300 cubic metres of wood each year from Block 2 of TFL 23 forests. Using Valhalla’s estimate of what Interfor was paid—$3.75 million—that works out to $103 for each cubic metre of allowable annual cut taken back by the province. This number allows us to estimate how much biodiversity-threatening logging could be permanently reduced across BC using the $1.2 billion budget of the Nature Agreement: 11.7 million cubic metres per year, in perpetuity.

    Is that a lot or a little? In 2023, logging on public land in BC removed 36 million cubic metres. So the $1.2 billion Nature Agreement budget could finance reduction of logging across the province by about 33 percent (relative to 2023), in perpetuity. But who should be compensated for that reduction? The logging companies whose allowable annual cut is reduced? Or the actual owners of the land? I will come back to this question later.

    To do this would require convincing political decision-makers that spending scarce public resources on “protecting” or “conserving” rock and ice is nonsensical if the objective is to conserve biodiversity. BC’s vast expanses of rock and ice are under little or no threat from development and contain minimal biodiversity.

    Common sense, then, should dictate that all of the Nature Agreement’s budget should go to protecting land that is actually under imminent threat from logging or other forms of large-scale, biodiversity-threatening industrial development, like large mineral mines and natural gas and oil fields. Except in the northeastern corner of BC, the only controllable, widespread threat to biodiversity is logging, including road-building. So we know where the emphasis for conservation needs to occur: in forests, particularly old forests.

    But how should government decide which old forests that are threatened by logging should be protected?

     

    What should be protected?

    The draft Biodiversity and Ecosystem Health Framework initiative flows out of the recommendations of the Old Growth Strategic Review conducted by Gary Merkel and Al Gorley, both professional foresters. Recommendation #2 of their report was to “Declare the conservation and management of ecosystem health and biodiversity of British Columbia’s forests as an overarching priority and enact legislation that legally established this priority for all sectors.”

    Note the emphasis on “forests”. Gorley and Merkel were not recommending conservation of rock and ice. The details for recommendation number #2 make it clear that it applied “particularly” to “old forest” rather than, say, managed plantations. Following release of the review’s report in 2020, a technical advisory panel (TAP) was constituted and that group identified 2.6 million hectares of “priority areas for deferral” around the province. TAP was responding to Gorley and Merkel’s recommendation #6, which was: “Until a new strategy is implemented, defer development in old forests where ecosystems are at very high and near-term risk of irreversible biodiversity loss.”

    While TAP’s mapping of “old forest” wasn’t always accurate (as it had predicted), it established that, except in a few cases, remaining highly productive old forest generally occurred in relatively small areas spread thinly around the province, a condition that is almost entirely the result of the relentless logging of primary forests in BC since the late nineteenth century. In many cases, the areal extent of old forest remaining in a given biogeoclimatic zone had fallen below the critical level of 30 percent of the area of the zone. TAP called these “high-risk forests”.

    There should be no question, then, that those “priority areas for deferral” must be included in conservation and protected areas nominated for the Nature Agreement, just as Merkel and Gorley recommended. Yet the draft Biodiversity and Ecosystem Health Framework doesn’t even mention “old forest”, except when referring to the name of Gorley and Merkel’s report.

    While protecting old forest needs to be at the centre of any framework intended to address biodiversity loss in BC, the remaining patches of the most biologically productive old forest are small and wouldn’t necessarily make viable “protected areas” all on their own. There are literally thousands of these small patches and turning them all into “protected areas” could make for a difficult-to-administer protected areas system.

    One possible solution to this dilemma would be to not conserve small areas of old forest as formal protected areas or conservancies. Instead, forest-related legislation could be amended to simply make it illegal to log old forest in these areas, including a suitable buffer of surrounding recruitment forest in those biogeoclimatic zones where old forest has fallen below 30 percent.

    Even though there is no specific mention in the Biodiversity and Ecosystem Health framework of how old forest would be conserved, by highlighting “ecosystem-based management”, the authors seem to be pointing to that as the approach government would use to resolve the contentious old forest issue in BC.

     

    Would ecosystem-based management provide protection for what needs to be protected?

    The draft Biodiversity and Ecosystem Health Framework seems to depend heavily on the hope that an “ecosystem-based” forest management paradigm would result in conservation of the old forest identified by TAP. What is ecosystem-based management? The draft framework offers few specifics. It defines it as “an adaptive approach to managing human activities that seeks to ensure the coexistence of healthy, fully functioning ecosystems and human communities. The intent is to maintain those spatial and temporal characteristics of ecosystems such that component species and ecological processes can be sustained, and human well-being supported and improved.”

    The draft Biodiversity and Ecosystem Health Framework promises that “ecosystem-based management” (EBM) will be applied across British Columbia, but will this promise—by itself—result in the conservation of old forest identified by TAP? The framework states that “Implementation of EBM will look different across BC (spatially and temporally)…”. The framework also states “It is expected that there will continue to be areas of more intensive development to accommodate population growth and increasing demands for food, fiber, and energy…”.

    I take the term “intensive development” to include logging as well as oil and gas development.

    In other words, the framework recognizes that ecosystem-based management could create a result anywhere between slightly restrained clearcut logging and a protected area.

    The concept of EBM was developed in BC beginning around 2000. By 2004 an EBM Planning Handbook had been created along with much supporting science and a management framework. There are examples where EBM had been implemented in 2007, and based on that record, there’s little evidence that simply introducing EBM to an area made any difference over business-as-usual forest management.

    For example, in the Thurlow Landscape Unit portion of TimberWest’s TFL 47, where EBM was supposed to be practiced as a result of the 2007 South Central Coast Order, we see that EBM—at least in the hands of TimberWest—looks very much like logging does under the slight constraints of the Forest Planning and Practices Regulation.

     

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    TimberWest’s EBM logging in the Thurlow Landscape Unit, part of the Great Bear Rainforest (Photo by Tavish Campbell)

     

    A 2015 investigation conducted by the Forest Practices Board regarding a complaint by Sonora Islanders about logging in the Thurlow Landscape Unit found that “TimberWest did not manage the forests consistent with the spirit and intent of EBM.” Seen from space, EBM clearcuts on the northern Discovery Islands look exactly like anywhere else in the timber harvesting land base of BC, even though old forest in the area has fallen to critically low levels.

     

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    Left to right: Hardwicke Island, West Thurlow Island and East Thurlow Island, all supposedly managed under “ecosystem-based management.”

     

    So it remains doubtful that further implementation of EBM—coupled with the existing regime of professional reliance in which the foresters employed by a profit-driven logging company are expected to restrain the company from profiting too much at the expense of nature—can be counted on to conserve remaining old forest, even in an area where it has fallen below 10 percent.

     

    What would be needed for ecosystem-based management to conserve old forest?

    The short answer here is: A prohibition of logging in old forest. But that’s not a complete answer.

    The fundamental weakness of ecosystem-based management is that, in practice, it blends the science of ecological risk with the politics of human need (and greed). But politics has a history of thwarting the adoption of science in forest management in BC.

    For example, the Coast Information Team—and others—told government 20 years ago that natural disturbance return intervals in many BC forested ecosystems were much greater than had been previously understood. That meant that, naturally, much more of BC would be covered by old forest than the forest management regime in BC was allowing for in its policies and practices. In turn, that meant there would be a higher risk of irreversible biodiversity loss under that management regime. That 20-year-old science has just recently resurfaced in the Interim Assessment Protocol for Forest Biodiversity in British Columbia (2020). BC’s Old Growth Forest: A Last Stand for Biodiversity (2020) provided a graphic illustration of this risk relationship. None of this knowledge is currently being applied by government or logging companies in forest management practices.

     

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    Risk to ecological function, biodiversity and resilience based on the amount of an ecosystem remaining relative to natural amounts. (From BC’s Old Growth Forest: A Last Stand for Biodiversity )

     

    Instead, the forest management paradigm in operation throughout BC has been based on an imposed political condition that forest conservation measures should not impact timber supply for human use by more than 6 percent, province-wide. Why “6 percent”? This was an arbitrary choice that reflected a political priority in 2003. The government of the day thought it could attract more investment to BC’s struggling logging industry by making it a reliable player in the export of wood products to the global market. Now 80 to 90 percent of the forests cut in BC are exported as wood products and raw logs. There was never a non-economic understanding backing that 6 percent “balance”. It was purely political.

    As a result, in those 20 years, millions of hectares of old forest were logged that wouldn’t have been if science had been the priority instead of politics. Many of the forests logged were a thousand or more years in the making. They can’t be “restored” as long as the human need for timber supply is being artificially “balanced” against the needs of nature, especially when that balance has been set at 94 for timber and 6 for nature. It’s not for nothing that Premier Eby has described BC forests as “exhausted”.

     

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    Photo by TJ Watt

     

    For ecosystem-based management to have any chance of conserving old forest—or even recruitment forest for future old forest—the “balance” in the timber harvesting land base of BC needs to be based on the most current scientific consensus regarding natural disturbance interval and the ecological risk of deviating from the long-term natural occurrence of old forest. And, of course, the development of a society-wide consciousness that only a low risk of biodiversity loss is acceptable. After all, nature is the most essential life support system we have, supplying us with habitat for wildlife, clean water, oxygen, flood control, spiritual sustenance, fire hazard management, carbon storage for climate stability, and so forth.

    Does anybody think such a transformation could happen by 2030?

     

    The best insurance against high-risk politicians is protected areas

    The best—if not the only—insurance against the tendency of governments to accept a higher level of risk of irreversible biodiversity loss for political reasons is to create hard protective boundaries around areas of old forest, boundaries that are resistant to changes in government. But, as the record on creating the Incomappleaux Conservancy shows, government is prone to shooting us in the foot by puffing up such protected areas with large amounts of land that are under no imminent threat.

    To protect 30 percent of the most biologically productive terrestrial areas of BC means protecting 30 percent of its most biologically productive forests. Where should those protected areas be located?

    BC began developing a “Protected Areas Strategy” in the early 1990s when there was a push to raise protection of special areas of land from 6 to 12 percent. A system of ecosystem classification has been under development since 1985, and that system identifies how much of each of the 139 terrestrial and marine ecosections in BC have been protected. Ecosections are “areas with minor physiographic and macroclimatic or oceanographic variations”. Each is slightly different, biodiversity-wise, from its neighbour ecosections.

    To see how much of the ecosection you live in is protected, or to learn which ecosection you live in, go to this page. Twenty-four ecosections already have 30 percent or more of their area protected. But 57 have less than 6 percent protected. A good guide to where additional protected areas ought to go could be based on the goal of protecting 30 percent of each ecosection across the province.

    Mapping of TAP’s priority old-growth deferral areas along with existing protected areas and conservancies on top of ecosections allows for quick identification of ecosections where there is old forest but little existing protection.

     

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    Old growth Douglas fir are protected in Elk Falls Provincial Park (Photo: David Broadland)

     

    First Nations Leadership

    The draft Biodiversity and Ecosystem Health Framework doesn’t provide anything of substance regarding First Nations beyond these good intentions: “The Framework promotes an inclusive, partnership-based approach—founded on upholding Title and Rights of First Nations and advancing reconciliation.”

    The Tripartite Framework Agreement on Nature Conservation (the Nature Agreement) signed with the federal government, states: “The Framework Agreement includes a shared commitment to work toward true and lasting reconciliation with First Nations. This work is based on recognition and respect for shared stewardship responsibilities, the benefits of healthy ecosystems, and the inherent right of First Nations to self-determination and self-government within their territories. Canada and BC recognize that First Nations have been caretakers of the lands and waters in what is now called BC since time immemorial and are leaders in stewarding lands and waters.”

    This all sounds fine, until you consider the actual record of the governments of Canada and BC at signing treaties with BC First Nations. Since the BC Treaty Commission started the process of treaty-making with first Nations in 1992, only six treaties have been completed by the Commission. Those treaties returned a total of 39,778 hectares of land to BC First Nations, an area that is considerably smaller than the Incomappleux Conservancy (the Nisga’a Treaty was negotiated outside of the BC Treaty Commission process).

    Based on the BC government’s account of the population of First Nations who have signed those six treaties, the treaties have returned an average of 8 hectares per Indigenous person to the rightful owners. At that rate, signing treaties that cover the 200,000 members of all BC First Nations would see approximately 1.6 million hectares returned—or 1.7 percent of the area of BC.

    Compare that 8 hectares per person to the area controlled for the economic benefit of the 46,000 people in BC who are directly employed in the logging-forestry-saw-milling-pulp-and-paper complex (2023). In 2024, logging companies have long-term exclusive access to forest resources on about 21 million hectares of the most biologically productive unceded traditional territories of First Nations. That works out to 456 hectares per industry worker.

    Treaties are returning land to First Nations at the rate of 8 hectares per person, but the logging industry has access to 456 hectares per worker. How does this historically disempowering imbalance advance reconciliation?

    The current provincial government continues to fight First Nations who try to use the courts to get some of their traditional territory returned. For example, the province has fought vigorously against Nuchatlaht First Nation’s claim to 200 square kilometres on the north end of Nootka Island—lands that the BC Ministry of Forests has allowed Western Forest Products to decimate with clearcut logging.

    Thirty years of expensive legal negotiations for return of their land—through both the BC Treaty Commission and BC courts—has impoverished many First Nations. Their desperate need for any economic development has pushed many of them into signing “Forest and Range Consultation and Revenue Sharing Agreements” with the BC government. These provide a First Nation with about 3 percent of the stumpage collected by the province from logging on its traditional territory. That works out to between one-half of one percent and 1 percent of the value of the logs before they are milled.

    The province’s commitment to fully consult with First Nations on resource issues is also questionable. The NDP government did pass the Declaration on the Rights of Indigenous Peoples Act in 2019 as a framework for reconciliation with First Nations. But this has provided no comfort to those hereditary chiefs of the Wet’suwet’en First Nation who are resisting construction of the Coastal GasLink pipeline. They did not consent to its construction. As well, the province has recently been taken to court by the Gitxaała Nation. The Nation has challenged the ease with which a mining company, using BC’s Mineral Tenure Act, was able to apply for a claim on the Nation’s territory—without consultation. The specifics of these cases and others strongly suggest a soft commitment on the part of the BC government for consultation with First Nations about what resource development can occur on their traditional territories.

    Given the province’s dismal record on completing treaties, its miserly compensation to First Nations for forestry agreements and its willingness to further impoverish First Nations by fighting in court against their land claims and the requirement for consultation, why would anyone believe the province is serious about First Nations being equal partners—let alone leaders—in an initiative to conserve more of BC’s old forest?

    In the absence of progress on the completion of just treaties, some First Nations have already seized the leadership from government on conservation in their territories by declaring Indigenous Protected and Conserved Areas (IPCAs). To date there are at least 17 such declarations that involve nearly 8.7 million hectares of unceded lands. At this point, those IPCAs would cover more than half of the additional land that would be required to bring BC up to 30 percent protected/conserved. There are likely more to come.

    But IPCAs also raise some questions. One declared IPCA is an initiative of the Kaska Dena who have proposed the immense 4-million-hectare (40,000 square kilometres) Kaska IPCA in northern BC. The area has few roads and doesn’t appear to have either loggers or gas frackers knocking on its mainly ice and rock doors. If it is not under imminent threat—unlike so much of southern BC—is there a pressing need for it to be protected? Will the government use these declarations to avoid protecting the more contentious areas that contain priority deferral areas that logging companies want to log in southern BC? The Flathead Valley in southeastern BC, for example, has many old forest priority deferral areas, zero protected areas and a significant level of logging activity. In the short term, the Flathead is far more threatened than the Kaska IPCA. Which should have priority in terms of conserving biodiversity?

    Another potential issue with IPCAs is that the 18 First Nations that have declared them are, in fact, a small subset of the over 200 First Nations in BC. Many First Nations—pushed into economic impoverishment by loss of access to their traditional lands and resources—may be more interested at this time in getting a slice of the logging happening in their territories than they are in conservation. How will the provincial government ensure that the most biodiversity-rich areas of those territories also get protected?

     

    Who should be compensated?

    Who should be compensated for the land taken out of the timber harvesting land base for the purpose of conserving biodiversity?

    In the case of the Incomappleux Valley Conservancy, the only “compensation” mentioned was paid to the logging company Interfor. It might come as a surprise to some people that Interfor was compensated at all. Ever since passage of Bill 28 (the Forest Amendment Act) in 2021, the forest industry and its proxies have been claiming that government could now take back tenure with no compensation. For example, Susan Yurkovich, president of the Council of Forest Industries, told Business in Vancouver in 2021, “People have bought assets over time, including tenure, and Bill 28 now says that you can effectively have an asset removed with no compensation, and that has a chilling effect on investment”.

    But the companies never paid government for those “assets”. They may have paid annual rentals, renewal fees and stumpage to the BC government for the rights to log forests in their tenure or licence on publicly-owned land, but the government always had the legal right to reduce the volume that could be harvested on those tenures.

    So a risk of reduction has long existed. In spite of that risk, logging companies willingly participated with other logging companies in buying and selling their rights to log on publicly owned land in a market that only required government approval of such transfers.

    The fact that logging companies created a market in which tenures were bought and sold does not now mean that the public should compensate these companies if the government decides it needs to reduce the allowable annual cut on that publicly-owned land so that it can be used for some other public interest: Like conservation of biodiversity or providing First Nations with greater access to their own resources.

    Logging companies that also own mills—which are privately-owned assets—have long known of the risk that the volume of logs available to those mills could be reduced by government, and that such a reduction could lower the value of their mills.

    Why, then, should the $1.2 billion budget of the Nature Agreement go toward compensating logging companies for the reduction in allowable annual cut that is necessary for conservation of biodiversity?

    Why not, instead, allocate this budget to the actual owners of the land—BC’s First Nations? For those that are willing to conserve identified areas of old forest in their territories, put them on the list for Nature Agreement compensation. Wouldn’t that foster reconciliation?

     

    Tell the government what you think

    Obviously, I am skeptical about the NDP government’s intention with this initiative. Given the way in which this is being tied to consultation with and agreement by First Nations, and given that a new “Forest Landscape Planning” process has been undertaken that would displace the started-but-never-completed Landscape Level Planning process, I can see this all taking another 20 years before it, too, is replaced with some other initiative. During that time, much more old forest will disappear.

    Independent forest ecologist Rachel Holt—who has been a key player on the technical advisory panel—is not skeptical. She has a different take on the initiative and you will benefit from the information she provides in the powerpoint presentation below.

    You have until January 31 to send in your own comment: biodiversity.ecosystemhealth@gov.bc.ca

     

     


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    Recommended Comments

    Roy Schiesser

    Posted

    Thank you for this detailed review of not only the draft framework, but past and present misrepresentation, manipulation and a general lack of inertia to rectify 150 years of industrial privilege. Roy Schiesser/BFWSS  

    Yudel

    Posted

    "One possible solution to this dilemma would be to not conserve small areas of old forest as formal protected areas or conservancies. Instead, forest-related legislation could be amended to simply make it illegal to log old forest in these areas, including a suitable buffer of surrounding recruitment forest in those biogeoclimatic zones where old forest has fallen below 30 percent."

    This is a great idea. Not only would it solve the problem of how to protect thinly spread-out old growth, it would also solve the problem of the VRI inaccuracies that you pointed out in the other article.

    As policy currently stands, if government doesn't know an old growth stand exists due to VRI inaccuracy, they can't protect it or defer logging there. If a logging company then stumbles upon that old growth stand, they are free to log it.

    But if by default it is illegal to cut down old growth in biogeoclimatic zones/site series that have <30% old growth remaining, then if a company finds an unknown old growth stand in such an area, they would not be able to log it. Instead, the VRI data for that stand would be updated and the stand would be automatically protected.

    Yudel

    Posted

    "The vast majority of the area of the new conservancy consists of biodiversity-scarce ice and rock... The areal extent of the Incomappleaux Valley that’s now in the conservancy that was considered suitable for logging—see Interfor’s map of its timber harvesting land base in blue in the image below—was only 3600 hectares... much of which had already been logged once—little of that area still contains high levels of biodiversity: a mere 273 hectares."

    I think this is misleading. You equate everything outside the timber harvesting land base (THLB) with "rock and ice". But the THLB is simply the forest that is currently economical to harvest. This can be based on proximity to mills and/or current log prices (higher log prices leads to more area being economical to log). Areas outside the THLB might not only be forested, they might also be biodiverse. The fact that old growth forests were mapped outside the THLB supports this (even taking into consideration possible VRI inaccuracies, forested area and THLB are not synonymous since the THLB area itself was constructed using VRI). These old forests outside the THLB may not be as productive or have trees as big as those inside the THLB, but there's no reason to assume they have little biodiversity value, and they certainly shouldn't be called "ice and rock"! 

    Your overall point, that the size of a protected area does not tell us how much old growth was protected inside that protected area, is still true. But you likely underestimated the importance of this conservancy for old growth protection. 

    Yudel

    Posted

    "[T]he Incomappleaux Conservancy is not protected from mining... All of the existing mineral claims in the conservancy have been left intact."

    According to the in-depth Narwhal article on the conservancy (https://thenarwhal.ca/bc-rainforest-protected-area-conservancy/), this isn't true: 

    "Logging, mining and large hydro-electric development will be prohibited in the conservancy... The southern one-quarter of the valley — 17,000 hectares — will receive a special designation under B.C.’s Forests Act to prevent timber harvesting but allow mineral exploration and mining, according to a letter the forests ministry sent to the Regional District of Central Kootenay, a copy of which was reviewed by The Narwhal."

    Yudel

    Posted

    31 minutes ago, Yudel said:

     

     

    Yudel

    Posted

    31 minutes ago, Yudel said:

    "The vast majority of the area of the new conservancy consists of biodiversity-scarce ice and rock... The areal extent of the Incomappleaux Valley that’s now in the conservancy that was considered suitable for logging—see Interfor’s map of its timber harvesting land base in blue in the image below—was only 3600 hectares... much of which had already been logged once—little of that area still contains high levels of biodiversity: a mere 273 hectares."

    I think this is misleading. You equate everything outside the timber harvesting land base (THLB) with "rock and ice". But the THLB is simply the forest that is currently economical to harvest. This can be based on proximity to mills and/or current log prices (higher log prices leads to more area being economical to log). Areas outside the THLB might not only be forested, they might also be biodiverse. The fact that old growth forests were mapped outside the THLB supports this (even taking into consideration possible VRI inaccuracies, forested area and THLB are not synonymous since the THLB area itself was constructed using VRI). These old forests outside the THLB may not be as productive or have trees as big as those inside the THLB, but there's no reason to assume they have little biodiversity value, and they certainly shouldn't be called "ice and rock"! 

    Your overall point, that the size of a protected area does not tell us how much old growth was protected inside that protected area, is still true. But you likely underestimated the importance of this conservancy for old growth protection. 

    The Valhalla Wilderness Society, who apparently did a lot of the campaigning to protect this area, does use the term "rock and ice", but it refers to a much smaller area than you describe. Taken from their press release (https://www.vws.org/incomappleux/)  

    “At 58,000 hectares, the promised new Incomappleux Conservancy is relatively large,” says Pettitt. “VWS is pleased that it takes in the entirety of the Incomappleux unit of our park proposal. The Conservancy is close to twice as large as the Incomappleux unit of VWS’s park proposal; but the extra is mostly clearcuts, inoperable terrain, rock and ice."

    So a little under half of the conservancy is "clearcuts, inoperable terrain, rock and ice." That's very different from 94% being "rock and ice" [(58,000-3,600)/58,000 ha]. 

    David Broadland

    Posted

    6 hours ago, Yudel said:

    "The vast majority of the area of the new conservancy consists of biodiversity-scarce ice and rock... The areal extent of the Incomappleaux Valley that’s now in the conservancy that was considered suitable for logging—see Interfor’s map of its timber harvesting land base in blue in the image below—was only 3600 hectares... much of which had already been logged once—little of that area still contains high levels of biodiversity: a mere 273 hectares."

    I think this is misleading. You equate everything outside the timber harvesting land base (THLB) with "rock and ice". But the THLB is simply the forest that is currently economical to harvest. This can be based on proximity to mills and/or current log prices (higher log prices leads to more area being economical to log). Areas outside the THLB might not only be forested, they might also be biodiverse. The fact that old growth forests were mapped outside the THLB supports this (even taking into consideration possible VRI inaccuracies, forested area and THLB are not synonymous since the THLB area itself was constructed using VRI). These old forests outside the THLB may not be as productive or have trees as big as those inside the THLB, but there's no reason to assume they have little biodiversity value, and they certainly shouldn't be called "ice and rock"! 

    Your overall point, that the size of a protected area does not tell us how much old growth was protected inside that protected area, is still true. But you likely underestimated the importance of this conservancy for old growth protection. 

    Thanks for your comments Yudel.

    You are correct that there is some high elevation alpine forest on the sides of some of the valleys in the conservancy. These are relatively low biodiversity areas compared to the small remaining area of old forest at the bottom of the valleys. As you know, biodiversity declines both with lower temperatures and increasing elevation.

    There are still a lot of relatively untouched high-elevation ecosystems in BC that contain trees because they are not commercially attractive. I highly doubt they ever will be, but you are right, we don't know for sure. Still, right now, they are not under imminent threat of being logged.

    We need to conserve those remaining high productivity forests in valley bottoms, which are now rare. Those ecosystems are the most threatened. They should have the highest priority for protection/conservation.

    If you look at a high-res satellite image of the Incomappleaux conservancy you will see that the vast majority of it is higher elevation ice and rock.

    David Broadland

    Posted

    8 hours ago, Yudel said:

    “At 58,000 hectares, the promised new Incomappleux Conservancy is relatively large,” says Pettitt. “VWS is pleased that it takes in the entirety of the Incomappleux unit of our park proposal. The Conservancy is close to twice as large as the Incomappleux unit of VWS’s park proposal; but the extra is mostly clearcuts, inoperable terrain, rock and ice."

    So a little under half of the conservancy is "clearcuts, inoperable terrain, rock and ice." That's very different from 94% being "rock and ice" [(58,000-3,600)/58,000 ha]. 

    I don't follow the arithmetic that leads you to believe "a little under half of the conservancy" is clearcuts, inoperable terrain, rock and ice. The half of the new conservancy that was in the original Valhalla proposal also included rock and ice.

    Again, look at a high res satellite image. Better to believe your eyes.

    But you are missing the main point which is that the current government has shown that it will include a large fraction of unthreatened ecosystems in its program to conserve biodiversity. This will allow it to make its 30 percent quota without actually conserving much highly productive old forest and the high levels of threatened biodiversity found therein.

    This conservancy has several mining claims in it. In BC a "conservancy is defined by the Park Act as:

    (3.1)Conservancies are set aside

    (a)for the protection and maintenance of their biological diversity and natural environments,

    (b)for the preservation and maintenance of social, ceremonial and cultural uses of first nations,

    (c)for protection and maintenance of their recreational values, and

    (d)to ensure that development or use of their natural resources occurs in a sustainable manner consistent with the purposes of paragraphs (a), (b) and (c).

    Any government can interpret "(d)" to mean whatever they want it to mean, unfortunately.

    Yudel

    Posted

    On 1/28/2024 at 11:15 PM, David Broadland said:

    I don't follow the arithmetic that leads you to believe "a little under half of the conservancy" is clearcuts, inoperable terrain, rock and ice. The half of the new conservancy that was in the original Valhalla proposal also included rock and ice.

    Again, look at a high res satellite image. Better to believe your eyes.

    But you are missing the main point which is that the current government has shown that it will include a large fraction of unthreatened ecosystems in its program to conserve biodiversity. This will allow it to make its 30 percent quota without actually conserving much highly productive old forest and the high levels of threatened biodiversity found therein.

    This conservancy has several mining claims in it. In BC a "conservancy is defined by the Park Act as:

    (3.1)Conservancies are set aside

    (a)for the protection and maintenance of their biological diversity and natural environments,

    (b)for the preservation and maintenance of social, ceremonial and cultural uses of first nations,

    (c)for protection and maintenance of their recreational values, and

    (d)to ensure that development or use of their natural resources occurs in a sustainable manner consistent with the purposes of paragraphs (a), (b) and (c).

    Any government can interpret "(d)" to mean whatever they want it to mean, unfortunately.

    Thanks for the clarification! 



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