Comments submitted to Chief Forester Diane Nicholls by Martin Watts RPF, March 4, 2022

It is unfortunate that Teal-Jones chose not to respond to 8 questions asked on February 18, 2022 (see questions below) to clarify some items in Management Plan #5. It is more than a bit disconcerting that some of the issues related to the questions asked had not already been identified by Ministry of Forests, Lands, Natural Resource Operations and Rural Development (“Ministry”) staff during the draft base case scenario review.

1. In the last Allowable Annual Cut (AAC) determination for TFL 46, one of the harvest flow objectives was to harvest at least 200,000 cubic metres per year from second-growth stands. In Management Plan #5 this objective has been changed to harvesting a maximum of 180,000 cubic metres per year from old- growth stands.

Based on the current and proposed AAC of 380,000 cubic metres per year, the difference between the harvest flow objectives is meaningless. Where it could have meaning is if the Chief Forester reduces the AAC. For illustrative purposes, suppose the Chief Forester reduced the AAC to 250,000 cubic metres per year. The previous harvest flow objective would only allow 50,000 cubic metres per year of old-growth stands to be harvested, whereas the proposed harvest flow objective would allow 180,000 cubic metres per year to be harvested from old-growth stands.

More importantly, the change in the harvest flow objective signals Teal-Jones’ intent to liquidate the old-growth stands as quickly as possible, before the government has finalized its plans on old-growth. Figure 4.3 on page 12 of the Timber Supply Analysis Technical Report (Appendix C) indicates most of the old-growth available for harvest will be harvested within the first 15 years.

Given that there appears to be sufficient second growth to harvest over the first few years of the period covered by this AAC determination, it seems reasonable to simply delay the harvest of old-growth stands that have not already been deferred from harvesting until the government has completed its work with First Nations and finalized plans on old-growth.

2. Section 9.2.5 (Fisheries-Sensitive Watersheds) of the Information Package sets maximum clearcut equivalent areas (ECAs) for fisheries-sensitive watersheds (Hatton Creek—42%; Hemmingsen Creek—25%; Gordon River—30%).

There is no mention of a watershed assessment in the documentation provided by Teal- Jones. I ask the Chief Forester to review how the maximum ECA limits were determined for the fisheries-sensitive watersheds. If a hydrological assessment was used, whether the assessment follows the new guidelines for Watershed Assessment and Management of Hydrologic and Geomorphic Risk in the Forest Sector.

The timber supply analysis has used a stand height of 9.0 m for full hydrological recovery (zero percent of the area contributing to ECA). Current coastal hydrological recovery curves have a stand height of 36.0 m for full hydrological recovery.

The current hydrological recovery curves for the coast indicate a stand height of 9.0 m represents 33.7 percent hydrological recovery, with 66.3% of the area contributing to the ECA and not zero as used in the analysis.

Given that Teal-Jones would not provide a response, I ask the Chief Forester to review whether maximum ECA limits are exceeded in fisheries-sensitive watersheds when the correct hydrological recovery curves are used and if so, to make any necessary adjustments in the AAC determination.

3. The timber supply analysis defines existing managed stands as stands 65 years of age or younger as of 2020. Stands older than this are defined as existing natural stands. Yields for managed stands are derived using TIPSY and yields for natural stands are derived using VDYP7.

Section 4.2.1 (Phase II Statistical Adjustment) of the Information Package provides the statistical adjustment ratios used in the analysis. Appendix B of the Information Package provides the 2013 VRI Phase II Statistical Adjustment Report that Section 4.2.1 is based on.

Based on Appendix B, the adjustment ratios for new merchantable volume in Section 4.2.1 are the adjustment ratios for site index and not net merchantable volume. I ask the Chief Forester to confirm that the correct adjustments were made to net merchantable volume for the timber supply analysis.

Appendix B indicates that immature are stands less than 81 years old and mature are stands 81 or older. The adjustment ratios for VDYP7 are based on this classification. The classification is different from the definition of existing managed stands (65 years old or younger) with yield curves derived using TIPSY and existing natural stands (older than 65 years) with yield curves derived using VDYP7. I ask the Chief Forester to confirm that the application of adjustments to VDYP7 yields is statistically valid.

4. Section 7.1 (Site Index Adjustments) of the Information Package indicates SIBEC was used for site indices for existing and future managed stands.

Section 4.1 (Spatial Data Input) of the Information Package indicates the 1995 Teal Cedar Terrestrial Ecosystem Mapping (TEM) and the 2020 Provincial Site Productivity Layer (PSPL) were used in the analysis.

It is unclear whether the TEM was used in conjunction with SIBEC or the PSPL was used to obtain the site indices used for existing and future managed stands.

Based on Appendix B of the PSPL documentation3, the TEM (BAPID 5627) is not approved for site index estimation in the timber supply analysis. It has been superseded by the TFL 46 – South Vancouver Island TEM (BAPID 180).

I ask that the Chief Forester confirm that an approved method was used to obtain the site indices for existing and future managed stands.

5. Currently, just under 80% of the timber harvesting land base (THLB) is classified as existing managed stands and will have yield curves derived with TIPSY. The remaining 20% of the THLB will have yield curves derived with TIPSY once it is harvested.

There is no analysis validating TIPSY current yields or future yield projections with measured ground data.

The VRI Phase II Statistical Adjustment Report (Appendix B) used VDYP7 to estimate yields for the immature stands.

Appendix A indicates 92 – 11.28 m radius plots were established in stands 30 to 120 years old for a site index adjustment project. It is most likely that these plots were part of a monitoring program and could be used to validate the TIPSY yields.

It appears that TIPSY yields could have been validated using the VRI and monitoring plots 65 years or younger.

Section 5 (Timber Supply Analysis) of the Proposed Management Plan #5 and Section 6.6 (Minimum Harvest Age) of the Timber Supply Analysis indicate that both the short-term and long-term harvest levels are sensitive to an increase in minimum harvest age:

• Increasing the minimum harvest age by 10 years reduces the short-term harvest level by 5.2 percent and reduces the long-term harvest level by 4.5%

• Increasing the minimum harvest age by 20 years reduces the short-term harvest level by 25.5 percent and reduces the long-term harvest level by 13.4%

Given the effect of minimum harvest age on the AAC and minimum harvest age mainly affects TIPSY yields, not validating managed stand yield adds a great deal of uncertainty to the AAC determination.

I ask that the Chief Forester request a validation of the managed stand yields using available data and a statistically valid methodology.

6. Section 7.9 (Silviculture History) of the Information Package indicates summaries of well-spaced stems were used to initialize TIPSY simulations.

The current methodology used by the Ministry for the TSR for Timber Supply Areas (TSAs) uses total stems from the RESULTS data.

Given the effect of managed stand yields on the AAC, I ask that the Chief Forest review the use of TIPSY in relation to how TIPSY is used in the TSAs.

7. Section 6.4 (Future Stand Yield) of the Timber Supply Analysis is a sensitivity analysis that increases the managed stand yield by 10% and decreases the managed stand yield by 10% to examine the uncertainty associated with managed stand yields.

No rationale is given for the ±10% sensitivity levels and there is no validation of the managed stand yields to base a sensitivity level on.

I ask that the Chief Forester request a validation of the managed stand yields using available data and a statistically valid methodology that will provide a sensitivity level based on the data available, such as analysis of equivalence.

8. Appendix A of the Information Report provides a site index adjustment from 2000. Section 6.8 (Site Index Adjustment) of the Timber Supply Analysis provides a sensitivity analysis using the site index adjustment report estimates of site index for managed stand yield curves instead of the SIBEC site indices.

This leads to an initial harvest that is 14% higher than the base case and a long-term harvest that is 36% higher than the base case.

Site index adjustments such as this are no longer accepted in the TSR for TSAs and should also not be accepted for TFLs.

If the Chief Forester wants to consider this sensitivity, I ask that a table like the one in Section 7.1 (Site Index Assignments) of the Information Package be prepared and compared. A cursory comparison of the site indices from the report to those in Section 7.1 do not seem to support the magnitude of difference shown in the sensitivity analysis, but they are difficult to compare as the site index adjustment report is by species and BEC and Section 7.1 is just by BEC.

Martin Watts MScF, RPF FORCOMP Forestry Consulting Ltd

Questions sent via email from Watts to Teal Cedar Products Ltd that remain unanswered:

I will be submitting some comments on Management Plan #5, but would like to clarify a few items first:

1. In the 2011 AAC determination, it indicates one of the harvest flow objectives was to harvest at least 180,000 m3/year from second-growth stands (age 55-249).

In the current timber supply review, it indicates one of the harvest flow objectives is to limit harvest to 180,000 m3/year from old-growth stands (age 250+).

Are these harvest flow objectives:
a) Voluntary (set by the licensee),
b) A soft partition recommended by the Chief Forester, or c) Something else?

2. The Site Index Adjustment Report (Appendix A of the Information Package) indicates 86- 11.28 metre radius plots were established in 1995 to obtain site index information for stands 21-120 years old.

I assume that these were intended as monitoring plots and include tree measurements that can be used to validate managed stand yield projections. Is this correct?

Have these plots been re-measured since 1995?

3. The VRI Phase II Adjustment Report (Appendix B of the Information Package) indicates volumes from immature (age 30-80 years) plots were compared to VDYP7 estimates.

Section 7.6 (Yield Table Development) of the Information Package indicates TIPSY was used to generate yield curves for managed stands (stands established since 1955).

Is there an analysis available that compared the immature VRI plot volumes to TIPSY estimates and if so, can it be provided?

Is there an analysis available that compares the volumes of the plots established for the site index adjustment to TIPSY estimates and if so, can it be provided?

4. What is the rationale behind using ±10 percent as a sensitivity analysis for managed stand yields?

The VRI statistical analysis indicates managed stand volumes are over-estimated by far more than 10 percent.

5. Section 9.2.5 (Fisheries Sensitive Watersheds) of the Information Package indicates a stand height of 9.0 metres is used for full hydrological recovery (ECA is zero percent).

This appears to be from out-of-date hydrological recovery curves. Current coastal hydrological recovery curves have a stand height of greater than 36.0 metres for full hydrological recovery.

The current hydrological recovery curves for the coast indicate a stand height of 9.0 metres is only 33.7 percent hydrological recovery.

If current hydrological recovery curves for the coast are used, is the maximum ECA in the fisheries sensitive watersheds exceeded in the base case scenario?

6. Table 4.1 of the Information Package indicates TEM is based on a 1995 project conducted by Teal Jones, but also listed the 2020 Provincial Site Productivity Layer (PSPL).

Section 7.1 (Site Index Assignments) of the Information Package indicates SIBEC was used to estimate site index for managed stands (stands that regenerated after 1955).

Was the PSPL or the 1995 TEM and SIBEC tables used to assign the managed stand site indices?

If the 1995 PEM and SIBEC tables were used, are there significant differences in BEC estimation between the PSPL and 1995 PEM?

7. Table 7.1 (Analysis Unit Site Index) of the Information Package lists the area-weighted site indices for the analysis units (the BEC assignment for analysis units is a bit different from that given in table 6.2).

Is there a similar table for the site indices from the site index adjustment project?

The differences in managed stand yields, depending on the source of managed stand site indices, seems high based on a cursory comparison of the differences in SIBEC versus site index adjustment site indices.

8. Section 7.9 (Silviculture History) of the Information Package indicates summaries of well- spaced stems were used to initialize TIPSY simulations.

The current methodology used by FLNRO for the TSR uses total stems from the RESULTS data.

What is the rationale for using well-spaced stems?