To: Jennifer Peschke RPF, TimberWest Forest Corp, jennifer.peschke@mosaicforests.com

cc Lesley Fettes RPF, Campbell River District Manager, Lesley.Fettes@gov.bc.ca

cc Chief Ronnie Chickite, We Wai Kai First Nation, ronnie.Chickite@WeWaiKai.com

Dear Jennifer,

In the comments below, we refer to “TimberWest” rather than “Mosaic Forest Management”. TimberWest Forest Corp appears to be the legal licence holder of TFL 47, as shown by the most recent publicly available licence (2010), management plan (2012), timber supply review (2014) and TFL boundary change (2016). Please let me know if legal ownership of TFL 47 has changed.

The Discovery Islands Forest Conservation Project offers the following comments:

[1] Inaccurate mapping

The map for Sonora Island provided in the proposed forest stewardship plan (FSP) does not acknowledge the existence of the Thurlow Special Forest Management Area. This 324-hectare area was deleted from TFL 47 in 2016. It has since been reserved for a future ecological reserve. This boundary change came after several years of lobbying by Sonora Islanders. While TimberWest’s information package includes a map of TFL 47’s boundaries on Sonora Island, that map shows the future ecological reserve as still being part of TFL 47. This error raises questions about the accuracy and completeness of all the other information TimberWest has provided.

[2] The ecological sensitivity of small islands

A significant area of the forest in the Johnstone Strait portion of TFL 47 is spread over 4 relatively small islands: Sonora, East Thurlow, West Thurlow and Hardwicke. Small islands are ecologically fragile. It has taken thousands of years for their ecosystems to develop—including discovery of and habitation by plant, animal, lichen and fungi species—and for the populations of these species to come into equilibrium. Because they are surrounded by waters rich with food, they are naturally biologically rich. At the same time, those watery boundaries make it difficult for certain species to survive events that cause rapid and large losses of habitat, such as fire and logging.

Rapid logging of these small, ecologically fragile islands degrades and fragments habitat and many species are now in danger of local extirpation. Over the 27-year period between 1990 and 2015, for example, 3818 hectares of 8133-hectare West Thurlow Island were logged. That is equivalent to 47 percent of the entire area of the island. Most of that (3369 hectares) occurred in the 19 years between 1997 and 2015. The worst damage—by far—was caused by TimberWest.

We invite you to watch time-lapse satellite photography of logging on Hardwicke, West Thurlow, East Thurlow and Sonora which took place 1984-2020. Keep your eye on West Thurlow Island in particular (near the centre of the screen, below), especially the two waves of logging that started first in 1997 and then again in 2011.

It is not possible to remove 47 percent of the forested area of a small island over a 27-year period without causing local extirpation of certain species. TimberWest’s approach to logging on islands needs to be rethought to take into consideration a rate of logging that will not cause local extirpations. If TimberWest can’t evenly spread out its logging on these ecologically sensitive islands over a much longer period of time—a rotation period of 120 years would be more appropriate—then it shouldn’t be logging on these islands at all.

[3] Red- and blue-listed animal species

In its proposed FSP, TimberWest acknowledges the Great Bear Rainforest Order requirements for certain wildlife (grizzly and black bear) and red- and blue-listed plant communities and states that it will abide by those GBR objectives. TimberWest also acknowledges the Forest and Range Practices Act requirements for red- and blue-listed animal species. In the case of the Queen Charlotte Goshawk, Northern Red-Legged Frog, and Keen’s Long-Eared Myotis, however, the proposed FSP simply states that since an order has been issued establishing wildlife habitat areas (WHAs) for each of these species, “a result and strategy is not required”. But no WHAs have been established for the Northern Red-Legged Frog, Keen’s Long-Eared Myotis or any other red- or blue-listed animal (aside from the goshawk). It is a 100 percent certainty that these species have occurred in this portion of TFL 47, yet TimberWest is taking no action to protect their habitat.

[4] Queen Charlotte Goshawk

On Sonora Island, East and West Thurlow Islands and Hardwicke Island, four WHAs have been mapped, totalling 760 hectares. These WHAs have been established to protect nesting sites of the red-listed Northern Goshawk liangii subspecies. Unfortunately, a high percentage of these islands’ old and mature forest—required by goshawks for year-round foraging—has been degraded or fragmented by logging companies—mainly by TimberWest.

For example, 3819 hectares of 8133-hectare West Thurlow Island were logged between 1989 and 2015. As mentioned above, that’s 47 percent of the entire area of the island. The Forest Practices Board has estimated that, on the coast, a pair of Northern Goshawks require up to 3700 hectares of home range for foraging. Not surprisingly, 3 goshawk nests on West Thurlow were recorded by the BC Conservation Data Centre (CDC) to be inactive in 2014.

The CDC mapped a goshawk nest on Hardwicke Island in 2004. The area of the island is 7633 hectares, barely large enough to support one or two breeding pairs of goshawk. TimberWest began logging on Hardwicke Island in 2003. By 2005 the CDC reported the nest and nest tree had disappeared. In 2006 the area in which the nest tree stood was logged by TimberWest. In the 20 years since 2004, TimberWest has logged 2029 hectares of the island—27 percent of the entire area of the island.

TimberWest’s proposed FSP may meet the legal requirements of a forest stewardship plan, but its actual logging practices do not meet government promises and public expectations that species at risk will be protected.

[5] Red- and blue-listed plant species

TimberWest sprays glyphosate on logged cutblocks in the Johnstone Strait portion of TFL 47. This practice ensures the eventual eradication of all red- and blue-listed plant species in those sprayed areas. Because of the extensive nature of logging in TFL 47, there has likely been a high level of local extirpation of red- and blue-listed plant species following TimberWest’s logging and subsequent glyphosate spraying. Yet there is no mention in the FSP about TimberWest’s use of glyphosate spraying. The ecological impacts of glyphosate spraying on red- and blue-listed plant species and its impact on eradicating fire-resistant deciduous trees such as red alder need to be addressed in a revised FSP.

[6] Red- and blue-listed plant communities

TimberWest states in its proposed FSP that it will “Protect each occurrence of a red-listed plant community during a primary forest activity in accordance with Schedule N”. Unfortunately, the proposed FSP contains no “Schedule N”, so we have no idea what TimberWest is actually proposing to do regarding listed plant communities. Notably, TimberWest’s logging on West Thurlow Island has overlapped all four areas that have been mapped by the CDC as containing red-listed plant communities. TimberWest’s actual logging record in areas containing listed plant communities suggests there is no “Schedule N” used to guide its operations.

[7] Species at Risk

The proposed FSP acknowledges federally-listed species at risk but provides no mapping of the critical habitat of those species, which includes the Marbled Murrelet. What mapping of critical habitat that does exist shows that TimberWest has logged into designated critical habitat on Hardwicke Island, East and West Thurlow Islands, Sonora Island and the mainland portion of TFL 47.

[8] Old forest

TimberWest’s proposed FSP, under “Objectives for old forest maintenance and recovery” contains this sentence: “(1) Maintain landscape level biodiversity as follows: (a) for each site series group in the order area, maintain a distribution of forest stand ages that will achieve the old forest representation targets listed in Column A in Schedule G by no later than 2264;”

What’s wrong with this? First off, there is no “Schedule G” provided in the FSP. So the public has no idea of what the “targets listed in Column A” are. The only thing we know for sure, is that TimberWest has 240 years to meet that target. Talk about kicking the can down the road.

That 240-year planning horizon is the equivalent of the colonial government of Canada establishing in the year 1784 targets for the distribution—by 2024—of British Loyalists flooding into Cape Breton as a result of the American Revolution. That would have been a strange exercise in futility then, and the inclusion of a 240-year planning horizon for old forest in this FSP in the midst of the current biodiversity and climate crises is equally strange.

TimberWest and other logging companies have already logged old forest on the islands in Johnstone Strait to below the “high risk” level of 10 percent, a critical level set out in the Gorley-Merkel report A New Future For Old Forests. According to the current mapping of old forest priority deferral areas, the entire area of Hardwicke Island is down to 8 percent old forest, East Thurlow and West Thurlow Islands have both been reduced to 6 percent, and Sonora is down to 4 percent. Gorley and Merkel’s recommendation #6 (page 56) implied an immediate deferral on logging of old forest in the CWHxm2 biogeoclimatic zone variant in the Thurlow Landscape Unit, which covers most of the land in the Johnstone Strait portion of TFL 47. The final FSP should acknowledge the current old forest deferral areas and indicate whether or not they have been approved.

TimberWest should state in its forest stewardship plan—just as it has done for the SMZ 19 portion of Quadra Island—that it will not log or degrade any remaining old forest or cut individual old trees on any of the islands in the Johnstone Strait portion of TFL 47. It is known that TimberWest logged old forest (age class 8 near Knox Bay on West Thurlow Island in 2014. It has also done so in other parts of the Johnstone Strait portion of TFL 47, including on Sonora Island. As a first step toward ending logging of old forest in the TFL, TimberWest should release to the public any mapping it had done of old forest in the Johnstone Strait portion of TFL 47, just as it has done for Quadra Island.

[9] Climate change and rate of cut

The proposed FSP states: “The potential effects of climate change have been considered in the development of this FSP and in particular, the development of the stocking standards.” No other details are provided. There is no other mention of climate change in the document.

Climate change is caused mainly by the increasing level of carbon dioxide in Earth’s atmosphere. The logging of old forest and conversion of areas of natural forest into permanent roads and short-rotation plantations results in a dramatic drop in the carbon sequestration capacity of once naturally-forested land in BC. At the same time, the logging industry speeds up the rate at which biogenic carbon is returned to the atmosphere. Climate change is inextricably linked to biodiversity loss, and biodiversity loss is accelerated by the reduction in area and fragmentation of forested habitats.

Climate change is resulting in extended periods of drought, longer periods of extreme fire weather and, as a consequence, creates conditions favourable to the formation of larger forest fires. Logging creates fuel conditions (clearcuts, slash piles and young plantations) that make ignition of fires easier and make fires more difficult to initially control. Logging roads provide easy access to firewood in slash piles and therefore create a greater likelihood of human-caused fires.

Climate change is also expected to increase the frequency and impact of insect infestations and forest-related diseases, which will negatively impact timber supply and increase the potential for forest fires. This was confirmed by Ministry of Forests scientists in 2009 and there is no credible rationale for continuing to ignore the facts 15 years later.

Notably, the proposed forest management plan information package that includes the Johnstone Strait portion of TFL 47 states: “…given the current scientific understanding, it is not yet possible to make reasonable quantitative predictions about the impact of climate change on timber supply. Therefore, the base case will not include specific accounting for climate change projections.”

TimberWest’s position is unrealistic and incautious.

In 2004, then-Chief Forester Jim Snetsinger predicted (page 34) that timber supply in BC in 2024 would be approximately 73 million cubic metres per year. But the current provincial AAC has actually been lowered to 57 million cubic metres per year. In 2023, even while logging companies complained about a “shortage of fibre”, the total provincial cut was only 36 million cubic metres. This dramatic decline in timber supply and industry viability has lately been attributed by the Ministry of Forests to insect infestations and forest fires—both of which have been made worse by climate change. TimberWest’s unwillingness to reduce the rate of cut in TFL 47 as a precautionary response to the known impacts of climate change is foolish and irresponsible.

This is especially true since TimberWest continues to export as raw logs most of what it cuts in TFL 47. TimberWest cannot argue that the need to adjust the cut downward in response to climate change must be balanced against avoiding potential “job loss”. If the company was actually concerned about getting the greatest number of jobs in BC from what is cut in TFL 47, TimberWest would end its heavy reliance on exporting raw logs.

[10] Etcetera

The problems with TimberWest’s proposed FSP don’t end at [9]. We could go on, but won’t other than to say this: The basic problem with a “forest stewardship plan”, in general, is that it is produced for public review only because that is legally required by the Forest and Range Practices Act. It is easy for a well-funded company like TimberWest to create a plan on paper that appears to cover all the bases and that meets the legal requirements for a forest stewardship plan (after all, the rules were written by the logging industry.), but actually provides little indication of the actual state of the forest in a TFL. That’s because a “forest stewardship plan” is actually a logging plan.

There is no legal requirement whatsoever for the licensee to include details about how, over the past 5 years, its practices have degraded ecosystems, exacerbated species loss, contributed to climate change, made the landscape more susceptible to forest fires and reduced forest-related job opportunities. A real forest stewardship plan would require such an acknowledgment of the damage done, and then would inform the public in detail about the measures a logging company would take over the next 5 years to steer away from those unwanted outcomes.

Sincerely,

David Broadland for the Discovery Islands Forest Stewardship Project