Submitted by the Discovery Islands Forest Conservation Project April 4, 2023
Logging of a rare stand of old forest at Hummingbird Lake on Quadra Island. The top photo was taken during logging in 2019; the bottom photo was taken from the same point in 2020.
1. Old forest on Quadra Island has reached a critically low level (~4 percent).
2. The Vancouver Island Land Use Plan created Special Management Zone 19 (SMZ 19) in 2000 to ensure conservation of biodiversity associated with old and mature forest on Quadra Island.
3. The failure to complete landscape level planning has left Quadra Island without any spatially-designated old growth management areas, putting all remaining old forest at greater risk of being logged or degraded.
4. Establishing 11 woodlot tenures in SMZ 19 after it had been created effectively undid the land use planning provisions related to conservation of old forest on 5470 hectares in the zone.
5. TimberWest is degrading small patches of old forest in its TFL 47 on Quadra Island, both inside and outside SMZ 19.
6. TimberWest has no effective strategy for meeting the old seral stage targets implied by the VILUP Higher Level Plan Order. If those targets were included in TimberWest’s planning, it would have very little room left to log on Quadra Island.
7. TimberWest is not abiding by the strategies recommended by the Vancouver Island Summary Land Use Plan for managing concentrations of veteran trees in its tenure.
8. TimberWest’s strategy for sustaining forest ecosystem structure and function within cutblocks is ineffective because it doesn’t retain forest within cutblocks.
9. Woodlot 2031 is logging old forest despite stating in its woodlot plan that it would retain existing old forest, even “scattered small patches of old forest”.
10. Woodlot 2032 is logging old forest for roads and degrading old forest by removing trees 250 years of age and younger. Substantive changes made to its woodlot plan in 2019 illustrate how old forest reserves in a woodlot can be changed without any notice being given to the ministry or the public.
11. We respectfully request that the Forest Practices Board investigate these matters.
The lay of the land: 11 woodlot licence tenures and a TFL crammed into a special management zone on a small island
The failure to implement landscape level planning on Quadra Island after the Vancouver Island Land Use Plan established Special Management Zone 19 in 2000, coupled with the awarding or expansion of 11 woodlots inside the special management zone, has left rare stands and small patches of old forest open to logging. Since the area of old forest on Quadra Island is now down to about 4 percent of the Crown forested land base, risk of biodiversity loss is extremely high and getting worse. Urgent action by government is necessary to conserve all remaining old forest to protect biodiversity and other values.
 In July 2022, the Forest Practices Board released its investigation report, “Government Enforcement of Old Tree Harvesting on a Quadra Woodlot.” The report contained factual errors about how many trees were removed and why they were removed. The Discovery Islands Forest Conservation Project reported on those errors.
 After we published our report, Forest Practices Board Director of Investigations Chris Oman wrote to us and suggested, “If you have concerns about whether the harvesting of other trees complied with [Forest and Range Practices Act], you are welcome to file a complaint with the Board.”
 This submission is, in part, our project’s response to that suggestion. But rather than focussing our complaint on just the question of whether or not the Compliance & Enforcement Branch and Forest Practices Board had failed to thoroughly investigate the logging of old forest that had occurred at Hummingbird Lake on Quadra Island—that logging being just a symptom of a larger problem—we provide below a detailed description of the underlying circumstances that have allowed continued logging of old forest on Quadra Island, including at Hummingbird Lake.
 The Discovery Islands Forest Conservation Project is conducting ongoing surveys of old forest on each island in the Discovery Islands group. On Quadra Island we have so far identified approximately 176 widely dispersed fragments of old forest that in area total 655 hectares. As mentioned above, that amounts to approximately 4 percent of the current Crown forested land base.
 The low level of old forest on Quadra Island has been blamed on fires that occurred in 1919, 1921, 1922, 1924 and 1925. But this is only partly true. Logging began in the 1880s and by 1925 much of Quadra’s old forest had been logged. That history in no way excuses continued logging of the remaining old forest. Instead, the critically low level of old forest should have guided the Ministry of Forests to more urgently consider the need to protect all that remains.
 Unfortunately, the cutting of productive old forest continues. This loss is occurring for two main reasons:
 First, because of the absence of landscape level planning—promised 23 years ago but never delivered—no legal old growth management areas (OGMAs) have been established on the approximately 11,000-hectare Quadra Island portion of TFL 47.
 Second, 11 different woodlot licences were located on Quadra Island on 5,470 hectares of Special Management Zone 19 ( (SMZ 19) after the zone had been established by the Vancouver Island Land Use Plan (VILUP) in 2000. Since the Forest and Range Practices Act does not require woodlot licensees to meet the seral stage objectives established by the VILUP, old forest can be legally logged within those 5,470 hectares unless a licensee’s woodlot plan stipulates that it won’t log old forest.
 One of the errors made in the report mentioned above at  reflects an assumption made by Forest Practices Board investigators that Quadra Island had undergone landscape level planning, and that management of old forest on the island was governed by a landscape level plan.
 The Board’s report included a map of the “Quadra Landscape Unit” and this statement: “For the Quadra landscape unit (Figure 1), which covers the woodlot licence and tree farm licence 47, this means that the holder of the tree farm licence addresses the legal requirements to manage old-growth forests under their forest stewardship plan. Again, the woodlot licensee is exempt from following government’s objectives for the retention of old-growth forests.”
 The assumption by the Forest Practices Board that landscape level planning had occurred is understandable. Landscape level planning for Quadra Island was given “high priority” in 2000 when the VILUP designated approximately 15,800 hectares of the island as SMZ 19. But, for unknown reasons, that planning never occurred. The “Quadra Landscape Unit” exists only as a line drawn around the island on a map.
 We would also note that the Forest Practices Board, in carrying out its investigation, may have been under the impression that Quadra Island hosted only one Woodlot Licence tenure. The report mentioned only one. But, as noted above, there are 11, each of which, as the Board put it, “is exempt from following government’s objectives for the retention of old-growth forests.”
 Although woodlots are required to reserve 8 percent of their area as “wildlife tree retention areas”, in practice this requirement produces little certainty that remaining areas of old forest will be protected, as we will show below.
 Moreover, in the absence of landscape level planning, TimberWest, the tenure holder of TFL 47, has defaulted to the position that old forest in its portion of SMZ 19 is subject only to the 2004 Order Establishing Provincial Non-Spatial Old Growth Objectives. That order puts the old forest retention target for the CWH biogeoclimatic zone, natural disturbance interval type 2 (Quadra Island) at “>9 percent”. TimberWest handles remaining concentrations of old trees by leaving trees older than 250 years of age but logging all the younger trees between them (more on this later).
 When the result in  is combined with the result in , a very different outcome for SMZ 19 than was intended by the VILUP has been produced. Based on aerial and ground surveys of old forest conducted by the Discovery Islands Forest Conservation Project over the past five years, we estimate the current extent of old forest to be at about 4 percent of the Crown forested area, and falling. This is highly problematic for conservation of biodiversity on Quadra Island and represents a failure of government to abide by its own land use planning.
 In a 2021 Forest Practices Board investigation of a complaint about logging in Special Management Zone 13 in the Nahmint Valley, the Board criticized BC Timber Sales for failing to meet the obligations imposed by the VILUP. In that case, the Board stated: “The public needs to be confident that objectives established in land use plans will actually be carried through and implemented in forestry operations.”
 Below, we will first outline what the intended outcome for old forest in SMZ 19 was. We will then address the question of whether TimberWest has advanced a credible strategy for old forest management in SMZ 19 and whether it is carrying through with that strategy. Finally, we will provide detailed examples of how old forest loss is occurring in both Block 12 of TFL 47 and two of the woodlots in SMZ 19.
What outcome was intended for seral stage distribution in SMZ 19?
 First, the intended management objective for distribution of old seral stage forest was to be at least 9 percent of the SMZ’s “contributing area”. The Vancouver Island Summary Land Use Plan defined that as the “timber harvesting land base” (THLB). To the extent that there wasn’t enough old forest to meet that target, mature forest suitable for old forest recruitment would need to be identified. Second, the intended objective for mature seral stage distribution in SMZ 19 was for at least 25 percent of the zone’s “contributing area” (again, defined as the “timber harvesting land base”) to be “mature”.
 How were these intentions to be carried out in practice? First, the VILUP was to be followed by landscape level planning. As you know, landscape level planning was designed to establish spatially-designated old growth management areas (legal OGMAs) and non-legal OGMAs that could be located in protected areas. The provincial government created legal OGMAs for the purpose of conserving the biological diversity associated with old forests.
 If landscape level planning had been conducted for Quadra Island, legal OGMAs and non-legal OGMAs would have been established for the entire Crown forested land base on the island. We estimate there would be approximately 1280 hectares of legal OGMAs associated with SMZ 19, and about 160 hectares of legal OGMAs associated with the area of Crown forest not in SMZ 19. Instead, no legal OGMAs have been created and all remaining old forest and concentrations of veteran trees not in protected areas are at risk of being logged or being exposed to logging.
 It should be noted that the 8 to 9 percent targets for old forest mentioned throughout this submission are from 1990s-era forest management understanding. Those targets should be much higher now given the new science-based understanding about stand-replacing disturbance intervals for Quadra Island. In 2000, that interval was thought to be about 200 years. It is now estimated to be about 700 years. To keep the risk of biodiversity loss due to logging at a “low” level, at least 49 percent of the Crown forest base on Quadra Island should be old forest. So the 8 to 9 percent old forest targets mentioned throughout this submission are wholly inadequate to keep the risk of biodiversity loss to a manageable level.
How will the seral stage targets for SMZ 19 be met?
 In this section we will examine the question of whether TimberWest has responsibility for meeting the seral stage targets for all of SMZ 19. We include targets for both old and mature forest in this discussion since the VILUP implied targets for both of these seral stages in SMZ 19.
 For clarity, we will note that the Vancouver Island Summary Land Use Plan described SMZ 19 as the land that “comprises all provincial Crown forest on Quadra Island outside of protected areas, excluding the northern portion (north of Small Inlet), as well as the southern, mostly private portion” (emphasis added).
 Clearly, it was the intention of the planners that the protected areas on Quadra Island could not be used to meet the seral stage objectives for SMZ 19. Let’s briefly review what those objectives were, and where they came from.
 The biodiversity emphasis option chosen for SMZ 19 by the Vancouver Island Summary Land Use Plan was “Intermediate.” According to the provincial Biodiversity Guidebook current at the time VILUP was ordered, the recommended target for distribution of seral stages for the “Intermediate” biodiversity emphasis option in Natural Disturbance Type 2 areas (Quadra Island) was as follows: Mature + old: >34 percent; Old: >9 percent; Mature: >25 percent.
 When SMZ 19 was created in 2000, approximately 15,800 hectares of Quadra Island were in the zone and subject to the seral stage targets described above. The areal extent of the zone has not changed.
 Did locating eleven woodlots in SMZ 19 mean that the targets for old and mature forest are no longer applicable? If that was the case, years of careful land use planning would have been undone by the ministry’s own ill-considered action of establishing woodlots in SMZ 19 before completing landscape level planning. We don’t believe anyone should settle for that outcome. Instead, we believe the responsibility for meeting the overall targets for the 15,800-hectare SMZ 19 has shifted, or should be shifted, to that portion of TimberWest’s TFL 47 that’s in the SMZ.
 As noted above at , the Forest Practices Board found that “the holder of the tree farm licence addresses the legal requirements to manage old-growth forests under their forest stewardship plan.” The Board seemed to be implying that TimberWest had the sole responsibility for meeting the seral stage objectives set for SMZ 19 (and, indeed, the entire “Quadra landscape unit”).
 Even if the Board did not mean that TimberWest has such a legal responsibility, Section 9 (Proportional Objectives) of the Forest and Range Practices Act gives the Minister of Forests the power to “establish targets, in specified proportions between or among the holders of forest stewardship plans, for sharing the responsibility to obtain results consistent with objectives set by government.”
 In this case, to ensure the overall objectives for seral stage distribution in SMZ 19 are met, TimberWest should be given 100 percent of the share of “responsibility to obtain results consistent with objectives set by government.”
 Such an approach would ensure the intentions of land use planning were carried through by government, and would satisfy the public interest highlighted by the Board in the Nahmint SMZ 13 case, namely that: “The public needs to be confident that objectives established in land use plans will actually be carried through and implemented in forestry operations.”
 This would have important implications for TimberWest’s operations in SMZ 19. The table below summarizes TimberWest’s own assessment of the current age class distribution in its portion of SMZ 19. Note that the total for the centre column is 7084 hectares.
 Since old plus mature forest needs to cover at least 34 percent of the forested area of TFL 47’s portion of SMZ 19, about 2408 hectares needs to be older than 80 years of age. By TimberWest’s own estimate, 3060 hectares currently meet that requirement. That leaves TimberWest with a buffer of 652 hectares within which it can log.
 If TimberWest is responsible for meeting the full SMZ 19 target for old forest, however, it must also incorporate a reserve to cover at least 9 percent of the 5470 hectares covered by woodlot tenures, which are not required to meet seral stage objectives. That would add an additional 492 hectares to TimberWest’s old forest responsibilities, and would further reduce the area within which TimberWest could log to 160 hectares.
 The strategies for meeting seral stage objectives that TimberWest has included in its successive forest stewardship plans suggest that it is aware of its responsibility to cover the full seral stage distribution obligations that arise from objectives 1.A and 1.B set by the VILUP Higher Level Plan Order for SMZ 19.
 For example, in its 2022 forest stewardship plan, TimberWest’s stated strategy for objective 1.A was: “In concert with other harvesting licence holders operating in the Special Management Zone, the holder of this FSP will ensure that planned development and harvesting activities will not result in the proportion of mature forest area dropping below 25% in the FDU [forest development unit].”
 Why would TimberWest’s strategy for meeting its own mature seral stage target involve looking outside of its own TFL boundaries for help to ensure its “harvesting activities will not result in the proportion of mature forest area dropping below 25% in the FDU”?
 Although the language seems a bit jumbled, the principle at work is clear enough. TimberWest is responsible for ensuring that the overall target for the mature seral stage in SMZ 19 does not fall below 25 percent. Therefore it can count the area of mature forest in the woodlots to meet its legal requirement.
 But this same principle must also apply to the >9 percent old seral stage target for SMZ 19. And since old forest covers only about 4 percent of SMZ 19—well below the target of at least 9 percent—TimberWest is responsible for managing for the missing 5 percent of old seral stage forest, too.
 This is, however, a moving target. If additional old forest is logged in the woodlots, TimberWest would be required to set aside even more of TFL 47 to manage for the old seral stage target.
 The Forest Practices Board seems to agree with this premise. In an investigation about logging of old forest in a woodlot on Quadra Island, as noted above at , the Forest Practices Board found that “the holder of the tree farm licence addresses the legal requirements to manage old-growth forests under their forest stewardship plan.”
 As in the case of acting “in concert with other harvesting licence holders operating in the Special Management Zone” with regards to mature seral stage targets, TimberWest should be acting in concert with the woodlots regarding meeting SMZ 19 targets for old forest.
 There is no evidence in the current woodlot plans of the 11 woodlot licensees that there is any planning “in concert” with TimberWest. And, as we will show below, at least two of the woodlots are logging old forest. Both of these circumstances suggest that TimberWest is not following through with its limited strategy to meet the seral stage distribution objectives that flow from the VILUP.
TimberWest is not following the recommended strategy for managing old forest set out in the VILUP
 Although TimberWest has committed in its forest stewardship plans to not log old forest in its portion of SMZ 19, it has logged small patches of old forest. In those cases it leaves the trees that are greater than 250 years of age but cuts away all younger trees between the old trees. This is not the strategy outlined for SMZ 19 by the VILUP.
Objective: General Biodiversity Conservation Management
Strategies: to the extent that old seral forest retention will be required within the contributing land base portions of the landscape unit, such retention should be concentrated within the SMZ-portion of the landscape unit; maintain existing old forest in the zone, as well as second growth with high portion of veteran trees; manage to replace old forest in the long term (>150 years) in accordance with old seral targets for intermediate BEO; focus old seral replacement in CWHxm2, concentrated along riparian areas and, where possible, adjacent to existing old seral forest; recruit old seral habitat blocks with higher priority on forest interior conditions than on old seral connectors; maintain harvest opportunity in second growth by identifying some old growth recruitment areas in early seral forest; recruit mature forest in the mid (>50 years) term, building gradually towards a mature seral target of 25%; actively create mature and old seral forest attributes through suitable management strategies, such as variable density thinning or partial cutting silvicultural systems.
 We interpret the stated strategy—“maintain existing old forest in the zone, as well as second growth with high portion of veteran trees”—as meaning that concentrations of veteran trees should be left undisturbed.
 However, TimberWest is not abiding by that strategy. Below are photographs of three such instances in TFL 47 in the special management zone.
 We have been advised by forest ecologist Rachel Holt and forester Herb Hammond that such a practice does little to conserve the biodiversity associated with old forest, which is the basis for the above recommended strategy outlined in VILUP for SMZ 19.
Three photos below: TimberWest leaves trees older than 250 years but logs everything around them.
TimberWest’s strategy regarding Objective A.1.(b) is ineffective
 Objective A. 1. (b) of the VILUP Higher Level Plan Order (HLPO) states: “Sustain forest ecosystem structure and function in SMZs, by… retaining within cutblocks, structural forest attributes and elements with important biodiversity functions…”
 In its current forest stewardship plan, TimberWest states that it will comply with Objective A. 1. (b) of the VILUP HLPO by: “(1) Retaining wildlife trees as specified in Section 66 of the Forest Planning and Practices Regulation (FPPR)”.
 Section 66 of FPPR states, in part: “(1) If an agreement holder completes harvesting in one or more cutblocks during any 12 month period beginning on April 1 of any calendar year, the holder must ensure that, at the end of that 12 month period, the total area covered by wildlife tree retention areas that relate to the cutblocks is a minimum of 7% of the total area of the cutblocks.”
 TimberWest’s strategy for “retaining within cutblocks, structural forest attributes and elements with important biodiversity functions…” utilizes a “group retention” approach whereby the full annual 7 percent retention area is accounted for as an area, or areas, of unlogged forest somewhere on Quadra Island. This has two problems.
 First, this approach defeats the intention of Objective A. 1. (b) of the VILUP HLPO. The order specifically uses the language “retaining within cutblocks…” and a footnote elaborates : “Within cutblocks: generally means non-contiguous with cutblock boundaries”. We take that to mean that retention areas should be like “islands” within cutblocks. Yet none of TimberWest’s wildlife tree retention areas occur within cutblocks.
 Second, mapping of these retention areas on Quadra Island shows that they often end up being logged later or do not contain mature trees (see image below). Or inoperable areas where logging wouldn’t have occurred in any case are designated as stand-in wildlife tree retention areas. Neither of these approaches helps to “sustain forest ecosystem structure and function…within cutblocks…”
Some of TimberWest’s mapped “wildlife tree retention areas” on Quadra Island (areas outlined in green with oblique lines through them) are areas that have been clearcut or do not contain mature trees (marked above with red dots). See more wildlife tree retention areas on Quadra here.
 Moreover, Section 67 of FPPR states: “An agreement holder must not harvest timber from a wildlife tree retention area unless the trees on the net area to be reforested of the cutblock to which the wildlife tree retention area relates have developed attributes that are consistent with a mature seral condition.”
 As noted above, in those cases where TimberWest leaves veteran Douglas fir trees as wildlife trees, it immediately removes the younger trees around them from the potential wildlife tree retention area, contrary to Section 67 of FPPR. The photos below are typical of TimberWest cutblocks on Quadra. All three are in the Long Lake area.
Logging of old forest in the woodlots
 Between 2003 and 2011, after SMZ 19 had been created, nine new woodlots were established on Quadra Island in the special management zone, and the two pre-existing woodlots were expanded into the zone.
 The rational course of events, after the establishment of SMZ 19, would have been to conduct landscape level planning, establish legal OGMAs—and only then establish Woodlot Licences.
 Because of the differences in requirements for old forest retention in legal OGMAs as compared with Woodlot Licence tenures, there was a dramatic decline in the level of protection of remaining old forest in the area occupied by the woodlots.
 While 18 percent of Quadra Island is in provincial parks, only a fraction of the remaining old forest is in those protected areas. And since no legal OGMAs have been created, much of the remaining old forest—which is mostly in TFL 47 and four of the 11 woodlots—is at risk. This worsens an already high risk of biodiversity loss.
 One consequence of the Ministry of Forests’ lack of coordinated planning for old forest on Quadra Island is that it is still being logged. The Forest Practices Board’s 2022 investigation report involving Woodlot 2031 illustrates how and why this is happening: Ministry of Forests personnel have too few resources to be able to assess what’s on the ground, plan for conservation and then monitor the state of old forest on Quadra, and some woodlot tenure holders are taking advantage of that lack of attention.
 In the text below, we will address the particulars of two different cases in which old forest has being logged on Quadra Island in spite of the high risk of biodiversity loss. Each case helps to illustrate the problems that have arisen due to the lack of implementation of landscape level planning.
Logging of old forest in Woodlot 2031
 With little or no resources for the Ministry of Forests to monitor what is being logged on woodlots, some Quadra Island woodlot tenure-holders are taking advantage of the situation and are logging old forest. Woodlot 2031 was established in 2011 and lies entirely within SMZ 19. The tenure is held by Okisollo Resources Ltd. Below is our account of logging of old forest in 2019 in Woodlot 2031:
 The Discovery Islands Forest Conservation Project visited Hummingbird Lake with a drone in July 2018, one year before the logging took place. We returned again in July 2019 while the logging was taking place and a third time in June of 2020, after logging had been completed.
Hummingbird Lake and surrounding forest in July 2018, as seen from a drone flying east.
This photo taken in 2018 shows the approximate area of old forest (left side of photo) north of Hummingbird Lake that was logged in 2019.
 On each visit, we photographed the area, both on the ground and using a drone for aerial views of the forest and lake. Over the past five years the Discovery Islands Forest Conservation Project has been surveying forests at dozens of locations on Quadra Island where it seems possible or likely that old-growth forest could be logged before it has been properly identified and reserved.
 On our 2018 visit, we could find no stumps or other evidence that would indicate the forest on the north side of Hummingbird Lake had ever been logged. The BC government’s record of road building in the province shows the north side of Hummingbird Lake had never been roaded before Okisollo Resources began logging in 2014. A forest fire in 1925 had lightly burned through the area, leaving the old trees intact. About 5 years after that fire, hemlock began to grow back—naturally—in the shade of the remaining big trees.
 All the evidence suggested that the north side of Hummingbird Lake was rare primary forest with big, old trees growing at a density that was at least equal to any other old forest we have surveyed on Quadra Island.
 When we visited the logging operation in July 2019, roads had been built. There was a completed cutblock near the southwest corner of the lake where four old-growth Douglas firs still stood. Ten full-length tree trunks were lying beside the road into the second cutblock—all old-growth Douglas firs that had been removed to make way for the road.
The new logging road built along the north side of Hummingbird Lake in July 2019.
 In a second cutblock on the north side of the lake, smaller-diameter hemlock and fir were in the process of being machine-felled (photo below). There were numerous large, old-growth Douglas firs and a few old cedars standing amongst the younger trees. It was unclear whether the dozens of old firs would be left standing or be felled. We had never seen so many big trees in the middle of a Quadra Island logging operation.
Above: Okisollo Resources’ logging of old forest north of Hummingbird Lake in July 2019.
Below: The same view in 2020.
 The project revisited the area in June 2020. Logging had been completed in the cutblock on the north side of Hummingbird Lake. Most of the old trees had been felled in both cutblocks. Along an edge of the northern cutblock, about 15 old vets still stood, testimony to the density of the grove that had just been cut.
In 2020, a line of old-growth Douglas fir vets was left along the edge of Okisollo Resource’s clearcut on the north side of Hummingbird Lake.
 We photographed the northern block where several large-diameter logs had been left beside the road. The growth rings of a recently live tree showed it had been 370 years old when it was cut. Several dead snags had also been cut and were stacked or scattered across the cutblock.
Above: This Douglas fir had 370 annual growth rings.
Below: A stump showed approximately 380 years of growth.
 To determine how many old firs had been logged in the northern cutblock, the project searched for satellite images taken in mid-August 2019. The image below shows logging in progress in the second cutblock on August 15, 2019. At least 50 old-growth trees remained standing on this day. The smaller-diameter hemlock had all been cut, stacked and were being removed.
 The satellite image below was taken a few weeks later. Of the 50 old-growth trees that had been standing in the cutblock (see photo above), only 15 remained.
 The project’s photographs and notes, when combined with the satellite images, show that of approximately 64 old trees in the two cutblocks and the road, at least 49 were cut. The 3-hectare cutblock north of the lake had contained at least 55 live, old-growth trees and an unknown number of standing snags.
 In 2021 a Quadra Island resident filed a complaint about this logging with the Compliance & Enforcement Branch. A complaint was then filed with the Forest Practices Board. The Forest Practices Board found that 10 old trees had been cut and “the old trees were not set aside from logging. The licensee removed the trees to build a road and for safety reasons.”
 In response to questions sent by this project to Chantal Blumel, a registered professional forester and a principal of Okisollo Resources, Ms Blumel stated: “We removed some of the old trees during the harvest of the second growth stands, for safety and access purposes.”
 There is no dispute that some old trees were removed for building logging roads. Above, we estimated that at least 10 had been removed because they were in the way of the road. But was “safety” actually an issue for the other 35-40 old trees that were logged? The Occupational Health and Safety Regulation of BC’s Workers Compensation Act states: “If work in a forestry operation will expose a worker to a dangerous tree, the tree must be removed.”
 At the cutblock north of Hummingbird Lake, all of the younger, smaller-diameter trees had already been removed several days before approximately 35 larger old-growth Douglas firs were felled. That can be seen in the satellite images. Those old trees did not have to be logged for either “safety” or “access” purposes.
 The original complaint by a Quadra Island resident was based on the belief that the 2001 Vancouver Island Land Use Plan prohibited logging of old forest in SMZ 19 on Quadra Island. In fact, it had been, until Woodlot 2031 was established in 2011.
 Although section 52 (1) c of the Woodlot Planning and Practices Regulation requires woodlot license tenures to designate, in their woodlot plans, 8 percent of the area of the woodlot as “wildlife tree retention areas”, this designation does not have to be applied to actual areas of old forest. But in the case of Woodlot 2031, which contains several areas of old forest and concentrations of veteran trees, the licensee made written promises in its woodlot plan to retain existing old-growth stands.
 The wording in the licensee’s woodlot plan regarding existing old forest had apparently made a strong impression on Forest Practices Board investigators.
 The Board’s report stated: “In their [woodlot plan], they committed to setting aside all of the existing old-growth stands by designating them as wildlife tree retention areas.” In another section, the report stated, “the licensee chose to set aside the existing old-growth stands to provide wildlife habitat and conserve biodiversity even though it did not have to. The licensee did this in consideration of the community’s desire to protect old-growth forests on Quadra Island.” In the “Conclusions” section, the report stated “the woodlot licensee chose to set aside all of the existing old-growth forests because they recognized the community’s desire to protect the remaining old-growth forests on Quadra Island.”
 The Board could have been referring to the section in the licensee’s legally binding woodlot plan on “Wildlife Tree Retention Strategy”, which stated: “The wildlife tree retention strategy for woodlot licence W2031 involves: retaining the existing old growth stands (>250 years) and recruiting around them to enlarge existing and future old growth forests…”
 Or the Board might have been referring to the section in the legally binding woodlot plan that addressed “Areas where timber harvesting will be avoided”. That section contained this statement: “Retaining the existing old growth forests is key to maintaining the biodiversity values of forests in the CWHxm biogeoclimatic subzone. Maintaining these reserves, and recruiting around them to enlarge existing and future old growth forests is one of the strategies to meet the biodiversity objectives set out in the VILUP for SMZ 19.”
 Whichever part, or parts, of Okisollo Resource’s woodlot plan the Board was referring to, it is clear that the strategy specified in the woodlot plan to retain existing old growth stands, and the stated strategy on how the licensee would conserve biodiversity, convinced the Board that Okisollo Resources “committed to setting aside all of the existing old-growth stands by designating them as wildlife tree retention areas.”
 We believe the Board understood the plain meaning of the statements made in Okisollo Resources’ legally-binding 2011 woodlot plan, and that this meaning was also communicated to the approving authority and the local community when Okisollo Resources’ plan was put out for public comment in 2011.
 Section 21(1) of the Forest and Range Practices Act states: “The holder of a forest stewardship plan or a woodlot licence plan must ensure that the intended results specified in the plan are achieved and the strategies described in the plan are carried out.”
 The possibility that the owners of Okisollo Resources were not fully aware of where old-growth forest in the woodlot existed when they created their legally binding 2011 woodlot plan cannot be allowed to undo the commitments they made in writing to retain existing old forest. In any case, the licensee stated that even “scattered small patches of existing old forest” not specifically identified in the plan would be retained. We believe this commitment would apply to the area of old forest logged in 2019.
 We are asking the Forest Practices Board to investigate Woodlot 2031’s logging of old forest in 2019, as described above, and to explain why that logging did not contravene the results and strategies stipulated in the tenure’s legally binding woodlot plan.
Logging of old forest in Woodlot 2032
 Woodlot 2032 was established in 2011 and lies entirely within SMZ 19. The tenure is held by Younger Brothers Holdings.
 In 2019, Younger Brothers Holdings built logging roads through two areas of old forest the company had mapped in its 2011 woodlot plan as “old-growth” reserves. This logging would have been prohibited without a properly made amendment to the plan. The approximate boundaries of the reserves are shown in the image below:
 To ascertain whether the Ministry of Forests had determined whether such an amendment to the legally binding 2011 woodlot plan had been properly made, an FOI was filed in late 2021 by the Discovery Islands Forest Conservation Project. The FOI requested all communications between the Ministry of Forests and the principals of Woodlot 2032—including the woodlot’s registered professional forester—back to the beginning of January 2017. The records released to us suggested—by the absence of any records relating to an amendment of the woodlot plan—that there had been no written communication between the woodlot tenure holders and the ministry about a major amendment of the woodlot plan.
 Asked directly about this change, Younger Brothers’ forester provided the Discovery Islands Forest Conservation Project with a letter he told us was sent to the Campbell River District Manager in February 2019. The letter described changes to the 2011 plan that involved removing reserves of old forest above Discovery Passage (the areas outlined in green in the image above) and replacing those areas with an area of younger, sparser forest running up to the top of Darkwater Mountain (the area outlined in green in the image below). In the amendment, the replacement area and a pre-existing logging road were named the “Manzanita Mountain Recreation Area” and an old logging road was named the “Manzanita Mountain Trail.”
 The letter stated that the new reserve area was “created to provide recreational opportunities (hiking trail established) and to provide protection for the rare Manzanita plant (arctostaphylos columbiana) which is observed in the area.”
 Access to Darkwater Mountain (the name for the mountain used by Cape Mudge Forestry, which is operated by We Wai Kai First Nation) by old logging roads predates development of Woodlot 2032. Hairy Manzanita is not “rare.” It can be found in many high areas on Quadra Island and is NOT on the BC Red Blue List.
 As mentioned above, the letter provided to us by Younger Brothers’ forester was not included by the Campbell River office of the Ministry of Forests in the record of communications between the Ministry of Forests and Younger Brothers that were obtained by FOI. Recently, the Discovery Islands Forest Conservation Project asked the Campbell River District Manager for an explanation for why the amendment letter had not been included in the FOI release. Subsequently, the District Stewardship Forester indicated to us that this letter could not be found at the District office and there was no record of a response from the District office to Younger Brother’s letter of amendment. Later, District Manager Lesley Fettes sent us an email which stated, in part: “I encourage you to report your concerns by making a ‘Report of Natural Resource Violation’ using the online form. This is government’s process to have potential non-compliances investigated.”
 When we asked Younger Brothers’ forester for a copy of the email to the District notifying them of the 2019 amendment, the forester explained, “As this amendment was 3 years ago, I no longer have the email.”
 When asked about the switching of reserves from an area of old forest to an area of younger trees, Younger Brothers’ forester stated that “Minor revisions to retention strategies are acceptable providing the total area under reserve is not reduced.”
 But the Woodlot Licence Planning and Practices Regulation states that an amendment is only considered “minor” if it does not “decrease the nature or quality of wildlife trees or wildlife tree retention areas.” In this case, the amendment replaced areas of old forest containing some large trees with an area of mostly younger, sparser forest at the top of a rocky, dry hill where Hairy Manzanita was growing. We contend that this change constituted a decrease in the nature and quality of both individual wildlife trees and the wildlife retention area as a whole. Yet there is no record in the Campbell River District office that Younger Brothers’ forester even sought approval for this amendment. In other words, the amendment appears to be “wrongly made”.
A view of the forest in one of the two 2011 wildlife tree retention areas that had roads built through them in 2019. This photo was taken from the road.
 Under Section 22 (“Minor amendments wrongly made”) of the Woodlot Licence Planning and Practices Regulation, the forests minister may “declare the amendment to be without effect” and may “require the holder to suspend operations that are not authorized in the absence of the amendment”.
 This is a serious matter. Under Section 52 (2) (“Wildlife tree retention”) of the Woodlot Licence Planning and Practices Regulation, “A woodlot licence holder must not cut, damage or remove wildlife trees or trees within a wildlife tree retention area except in accordance with the wildlife tree retention strategy prepared under section 11”.
 Under Section 11 (c) (d) (e) (“Wildlife tree retention strategy required”) of the Woodlot Licence Planning and Practices Regulation, the strategy must include “the conditions under which individual wildlife trees may be removed” and “the conditions under which trees may be removed from within a wildlife tree retention area” and “how trees removed…will be replaced.” None of Woodlot 2032’s woodlot plans have included these required elements for its wildlife tree retention strategy.
 Younger Brothers Holdings, by building roads through two wildlife tree retention areas that it had mapped in its approved 2011 woodlot plan (as mentioned above in ), has cut and damaged trees in what had been wildlife tree retention areas. Did the swapping of the areas of old forest with an area that Younger Brothers had not previously mapped as old forest constitute a “wrongly made” amendment?
 Again, this is a serious matter. Under Section 90 (“Offences”) of the Woodlot Licence Planning and Practices Regulation, contravening Section 52 is “an offence and is liable, on conviction, to a fine not exceeding $500,000 or to imprisonment for not more than 2 years or to both”.
 These circumstances illustrate how, over time, a woodlot tenure holder can unilaterally “amend” their woodlot plan and remove areas that they had previously established as an “old-growth reserve”. Without a motivated watchdog looking out for the public interest, no questions would be asked and stands of old forest—which are commercially more valuable—would be logged or degraded.
 As per the district manager’s suggestion, the Discovery Islands Forest Conservation Project has filed a complaint with the Compliance and Enforcement Branch.
 This woodlot contains one of the largest areas (16.5 hectares) of primary forest remaining on Quadra Island, including one of the old-forest reserves the tenure holder’s 2019 amendment removed from its wildlife tree retention reserve. According to the licensee’s draft plan, logging in this area is imminent (see photo on next page).
 The tenure holder of Woodlot 2032 has committed to not cut any trees older than 250 years of age, as has become the practice on Quadra Island, but all other trees between those older trees can be logged. As mentioned above, we have been advised by a forest ecologist and a forester that this practice does not protect biodiversity.
 Moreover, the Woodlot Planning and Practices Regulation does not allow any logging to occur in wildlife tree patches, so asserting that these patches only need trees that are 250 years and older to be viable at supporting species associated with old forest is not supported by the legislation applicable to woodlots.
Foreground: Part of the area of old, mainly primary forest southwest of Darkwater Lake, which contains large, old trees—now a very rare ecosystem on Quadra Island. The small reserves in this area that the 2011 plan created have now been moved to the top of Darkwater Mountain (in background).
 We request that the Forest Practices Board investigate whether Woodlot 2032’s amendment was properly made or not (we have filed a complaint with Compliance and Enforcement but have not heard from them as of April 4, 2023). We are also providing these details to assist the Board in understanding the ways by which remaining old forest on Quadra Island, already at a critically low level, will continue to disappear unless changes are made. Without change, antagonism in the community over this issue will continue to grow. As you know, land use planning and creation of SMZ 19 was intended to end such conflict.
 If TimberWest does have the sole responsibility to ensure the full targets for old forest in SMZ 19 are met, perhaps a more effective arrangement for conserving old forest on Quadra Island would be for TimberWest to cooperate with the woodlots on a commercial basis that compensates the woodlots with work or wood in exchange for conserving old forest on their woodlots. If that’s not possible, what other solutions does the Board recommend?
 The extent of old forest on Quadra Island is currently at about 4 percent. TimberWest puts that number at 3.8 percent for that part of its tenure that is in SMZ 19. This situation poses what forest ecologists Dr. Karen Price and Dr. Rachel Holt and others have termed “high risk” for loss of ecological function, biodiversity and resilience.
 The Old Growth Strategic Review Panel has called for an immediate pause to logging of old forest in landscape units with less than 10 percent of old forest remaining. (Although the “Quadra Landscape Unit” has no plan, its areal extent has been defined.)
 Throughout BC, mapping of old-growth deferral areas has depended on the use of the Ministry of Forests’ Vegetation Resources Inventory (VRI). That mapping is notoriously inaccurate for locating actual old forest, and those deferrals on Quadra Island that have been mapped by the Technical Advisory Panel do not accurately reflect where old forest is on Quadra Island.
 The Discovery Islands Forest Conservation Project has identified 176 fragments of old forest and concentrations of veteran trees that amount to approximately 655 hectares in areal extent. We are in the final stages of confirming these on the ground, and our mapping is ongoing
 Given the circumstances outlined in this submission, we request that the Forest Practices Board determine the most practical approach to conserving the remaining old forest on Quadra Island given the existing legislation, regulations and land use planning.
The Discovery Islands Forest Conservation Project is conducting its research on the unceded traditional territories of the Wei Wai Kai First Nation, Kwiakah First Nation, Homalco First Nation, Klahoose First Nation, the K’ómoks First Nation and the traditional territory of the Tla’amin Nation. It is our intention to work with these nations to increase the general level of settler knowledge about the land and our connection to it.