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  • A submission to Teal Cedar Products application for approval of its TFL 46 forest stewardship (logging) plan

    Roger Wiles

    ...including Teal Cedar's response.


    TEAL CEDAR PRODUCTS LIMITED is seeking public consent for the continued liquidation of primary forests within Tree Farm Licence 46 lands. Public interest demands that the BC Government deny them permission to execute these cutting rights. The public interest is not served by the terms of this arrangement for diverse reasons: economic, environmental, and societal. Indeed, the greater public interest is irreparably and profoundly harmed by the terms of this licence tenure.

    Tree Farm Licences are an archaic vestige of a time when government resource policy attempted to cultivate a mutually beneficial alignment of private corporate interests with what was seen to advance the public welfare. In the case of TFL 46, this meant building mill capacity, creating employment, strengthening rural communities, and cooperatively blending forest management on the extensive private forest land base of Vancouver Island in conjunction with adjacent Crown lands. Of course this extension of colonial “enclosure” was politically promoted in the guise of pushing back the frontier to forge a modern industrial society. This social engineering project was conducted while completely ignoring Indigenous cultural land rights. The lands were quite simply confiscated. We are now more than ever keenly conscious of this injustice since the adoption of the United Nations Declaration on the Rights of Indigenous Peoples.

    The TFL 46 landscape has changed over the last 70 years. Its legal boundaries have been added to and subtracted from—mostly subtracted because of private land relinquishment and take-back policy. The contractual conditions have been greatly altered to the advantage and convenience of a very few corporate players and the simultaneous disadvantage of the public interest. The biophysical condition of the TFL 46 land base has markedly declined as a result of roading, clearcutting, and monocultural planting. These extensive alterations have undermined landscape hydrology, ecosystem integrity, and viewscapes. Indeed, over the decades, the health of TFL 46 land has been degraded to such an extent that its ultimate remediation and ecological survival is problematic.

    The accompanying socio-economic exactions have wrought destruction on rural communities. As a former forest industry worker, I am but one collateral casualty among hundreds and understand how wrenching the trauma can be.

    As government policy shifted away from overseeing the TFL framework, it relinquished such requirements as “appurtenancy”—links that connected the forests and local manufacturing. TFL 46 fibre, formerly committed to the Youbou Lumbermill, was suddenly and mysteriously extinguished at the stroke of a Forests Minister’s pen. (Minister Zirnhelt later sheepishly admitted on the steps of the legislature that it was an unwitting blunder. 1)

    The loss of appurtenancy was but one example of the government retreating from its fiduciary responsibility to the public interest. Over time, an increasingly compliant (or complicit—think R.E. Sommers) government buckled to the pressures, blandishments, and/or enticements of industry. The government’s modus operandi was politely termed sympathetic administration” and later “professional reliance. This was an apparent naive trusting that the good folks in the forest industry would treat the public domain honourably and pay their fair share of stumpage into the roadside honesty box.

    Government abnegation from TFL responsibilities was matched by forest industry consolidation, employment contraction, and escalating log exports. Along the way, the forest economy has spiralled down to a ghostly remnant. Forest district office closures and staff reductions mean that local oversight or compliance enforcement is nonexistent. Manufacturing jobs have disappeared and communities have been hollowed out or abandoned entirely. It is estimated that at least 80 manufacturing plants have closed in BC since 2000.

    The Youbou Lumbermill was shuttered in January 2001 and that helped ease the way for TimberWest Forests to freely auction off TFL 46 without public consideration in 2004. Teal Jones was the successful bidder. It seems that their $18 million dollar investment has proven most rewarding though their actual profitability is hidden behind a private company veil.

    Economically, the wage base supported by TFL 46 is now miniscule. Distributed benefits that once accrued to rural communities are no more. Between 2000 and 2020, direct forest industry employment in BC dropped by 50 percent. Recent research definitively shows that the forest industry’s oft-repeated claim that “forestry pays the bills” in this province is a fiction. Not only did forest industry revenue not even cover the cost of forest management, but the public has actually subsidized the industry to the tune of $3.44 billion between 2010 and 2019.

    This economic withering of the forest sector—and its impact on employment and communities—shows that it is time for the government to rethink provincial forest policy. Specifically, in the case of TFL 46, cutting rights held by Teal Cedar should be suspended pending careful reconsideration of the allowable annual cut (ACC). Arguably, a case could be made for allowing a reduced ACC based on existing volumes from second-growth plantations; however, this requires closer examination. Some of these plantation lands may be better utilized for old-growth recruitment. Ecosystem services, biodiversity, landscape connectivity, and carbon storage are far more valuable to the public purse, as these values enhance sustainability and resilience in a timeframe measured not by decades but hundreds of years.

    Critically, government now has more than just socio-economic considerations to recognize and rationalize. The climate has changed and we are in the midst of an environmental emergency. Earth’s biodiversity is in crisis. Natural systems are teetering. Ecosystem services are straining. Species numbers are declining and in some cases genotypes are disappearing. Carbon sequestration is now recognized to be critical if we are to avert the worst of the soaring “greenhouse gas” effect. The UN Secretary-General Antonio Guterres announced that the Intergovernmental Panel on Climate Change’s Working Group Report was nothing less than a “code red for humanity. The alarm bells are deafening, and the evidence is irrefutable.”

    In BC we are not doing all we can to confront this existential threat. Indeed our forestry sector is quite out of step with this present peril. BC forests, as a whole, are now playing a negative role. Their forest carbon sequestration capacity is less than zero. Primary, old-growth and ancient forests are of particular concern to leading ecologists as the work of Price, Holt, and Daust has independently shown. The BC Government did react to public pressure by initiating the Old Growth Management Strategy Report. Among the public submissions was one from the Cowichan Watershed Board. It’s co-chairs wrote about their great concern for the loss of old-growth forests on southern Vancouver Island and the lack of government supervision in monitoring and enforcement. Aside from a timid, temporary deferral on cutting some old-growth polygons, the importance of the OGM recommendations has yet to be consequentially acted upon.

    The liquidation of primary forests (both old growth and other) poses substantive risk to biodiversity and forest carbon sequestration. By continuing to road and cut TFL lands, we undermine our collective resilience to the climate change onslaught. Based on BC Government statistics, the carbon arithmetic makes it very clear that we must immediately commence securing the carbon-fixing capacity of our forests.

    To summarize, our economy, environment, and civil society, and humanity as a whole, require massive consequential changes to BC provincial forest policy. This transformation should commence with an immediate denial of tenure renewal in the case of TFL 46.

    Finally, because this “proposed management plan” is about social licence and not just AAC, I draw your attention to the citizen blockades that have populated this particular TFL at the invitation of Pacheedaht First Nation Elders over recent months. This outcry from such a broad coalition of civil society, conducted with such grace and peaceful dignity, epitomizes the humanistic non-violent tradition of civil disobedience. Their call of “worth more standing” is a clarion appeal to our best nature.

    Roger Wiles has a background in forest land inventory with the Canadian Forest Service and the New Zealand Forest Service in the 1970s. He later worked as a power engineer at the Youbou Sawmill and has lived in the Cowichan Valley for the last 40 years.


    1. May 14, 2003 Cowichan News Leader (Jennifer Mclarty): “Zirnhelt—reached at his home in Beaver Valley yesterday—continues to maintain the loss of Clause 7 was 100 percent inadvertent. ‘It could well be I was advised by staff it was nothing of consequence’ he said, adding ‘under normal circumstances a high level meeting would have been set up. I am not trying to duck out of that at all. We have to stand by what we’ve done.’”


    Teal Cedar’s response to Roger Wiles’ submission:


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