Allowable annual cut level reduced for Tree Farm Licence 8

Before celebrating too much about TFL 8's reduced AAC, here are a few of things to keep in mind.

• There are two primary reasons for the cut reduction, neither of which have much, if anything to do with protection of the ecological integrity and resilience of the forests, reducing the growing effects of climate change, slowing loss of biodiversity, and protection of watersheds. The two reasons: management measures that address Indigenous interests and the accumulation of unharvested volume in the TFL.

• Indigenous interests, from the standpoint of the Chief Forester, likely mean providing First Nation's with forestry tenures to enable logging/forestry businesses in First Nations' communities.  That does not lower the overall level of cut, it just moves it around.  This kind of activity is reconciliation, NDP and COFI style.
• According to the Chief Forester, there is 115,987 m3 of "unharvested and uncommitted volume accrued between 2006 and 2019" in TFL 8.  The Forest Act provides the province with the authority to "dispose" of this undercut by means of various short-term tenures that grant rights to log the undercut.  The province has stated that there are three options available:
  • Not to dispose of any of the undercut. This option comes into play if the unharvested volume is found "in constrained terrain (read steep, sensitive, or difficult to access terrain) or low value timber types".  So, where this decision is made, it becomes proof that the timber supply has been high-graded, taking the best and most accessible timber first (Perhaps to invest profits outside of BC, and/or in preparation for leaving BC).
  • Dispose of some of the undercut.
  • Dispose of all of the undercut.

Unfortunately, the AAC reduction likely has much more to do with running out of high quality, cheap to access timber than to moving forestry practices toward an ecological health paradigm.  These AAC reductions shine a bright light on just how unsustainable industrial forestry is in BC.

That said, I would encourage anyone to lobby government for the "Not to dispose of any of the undercut" option and to put those forests into secure protected status to help mitigate the ongoing effects of climate change, reduce biodiversity loss, and contribute to vital forest benefits, like pure air and clean water in moderate flows throughout the year.

If you are looking for support for your efforts, check out the wealth of material on this Evergreen Alliance website.

Herb

Herb, your comments are right on. This report contains lots of biased flaws and expectations. However Chief Forester Diane Nicholls somehow believes that her “expectations” will be honoured and met by Interfor without any valid reasons to support such beliefs. Interfor has NOT met the expectations she listed in her previous TSR paper. Why should they do so now? She has no valid reason to base any part of her AAC determination on the chance that they will be honoured and fulfilled when they very likely won’t. 

 I have completed a quick review of the TFL-8 AAC determination paper and will do a more in-depth analysis shortly and report on same.

While there are several aspects that indicate an inappropriate bias towards keeping the AAC as high as possible for as long as possible—three aspects are especially relevant. These are:

1. Re making allowances for climate change—the chief forester’s statement in this regard is: “I have not accounted for them in this AAC determination”.

2. A formal cumulative effects report for the entire Boundary area was completed in 2019. The chief forester’s statement in this regard is: “No analysis of cumulative effects was conducted as part of this timber supply analysis.”   

These positions completely ignore the minister’s direction statements which said that the chief forester should ensure the “TSR process incorporates the best available information on climate change and the cumulative effects of multiple activities on the land base and explores management options that align with established climate change strategies, adaptation and mitigation practices”.

Clearly these requests made by the minister of forests represent the public interest in these areas, yet the chief forester ignored them.  How can she ethically do this?

3. Provincial log specs vs. Interfor’s log specs: Concerns were stated that Interfor’s log specs varied significantly from the provincial ones and hence were illegal and these differences should be fully considered in the AAC determination. In response to these concerns Interfor stated that: “....operationally, top size utilization is market driven and set by the licensee.” And, even though this statement actually meant that “top size utilization is an economic decision and hence profit driven and set by the licensee,” the chief forester accepted it!

It should also be noted that Interfor's Code of Ethics states that:

• We conduct ourselves with honesty and integrity.

• We act in a manner that reflects our company’s high ethical standards.

• We comply with the law and conduct business that protects and enhances our company’s reputation.

Hmmm?  Obviously some anomalies exist.  

Lots of other comments/examples to follow; however these three provide an indication of the entire thrust of this document which supports Interfor’s over-riding objective relative to their TFL—i.e. to keep the AAC as high as possible for as long as possible regardless of the risks involved. And to do so notwithstanding what they say in their Code of Ethics. And the chief forester’s AAC determination obviously supports the attainment of Interfor’s objectives.

Obviously, the TSR AAC determination process needs mega changes. Yet formal requests to appoint an independent 3-person panel to formally review this process and recommend changes have been ignored.

On 2/12/2022 at 2:22 PM, Herb Hammond said:

According to the Chief Forester, there is 115,987 m3 of "unharvested and uncommitted volume accrued between 2006 and 2019" in TFL 8.  The Forest Act provides the province with the authority to "dispose" of this undercut by means of various short-term tenures that grant rights to log the undercut.

Herb and Fred, thanks for your comments on TFL 8.

Most readers won’t know that TFL 8 is in the Kettle River’s drainage area and the logging company, Interfor, is named in a class action lawsuit that arose following flooding in Grand Forks in 2017, 2018 and 2020.

Satellite imagery of TFL 8 shows what has happened on the ground:

What does that intense level of logging look like compared to the AAC set for TFL 8 in 2009? Well, believe it or not, the AAC would have allowed even more logging.

I looked at 13 years of ministry of forests’ data for the volume cut in TFL 8 and compared that with the official AAC. That data shows that the TFL has been undercut in those 13 years. The official AAC was 186,000 cubic metres per year (red line in graph below). The actual cut (orange line) gyrated wildly from year to year. The average cut was 160,362 cubic metres (gray line). That is, officially, an “undercut”.

The Harvest Billing System recorded a cut of 2,084,700 cubic metres in those 13 years. If the AAC had been the guide,  2,418,000 cubic metres would have been cut.

When you look at the satellite imagery of this TFL, it’s easy to imagine that, had the AAC been met, there would be little more than clearcuts and plantations remaining.

The general ministry practice of setting the AAC much higher than can be achieved over a prolonged period of time—mainly because the forest doesn't grow that fast—was the subject of a recent story. The current chief forester’s calculation—on paper—that a past “undercut” can be made up years afterward is disturbing. Look at the graph below, which records the AAC, actual cut and a conservative estimate of timber supply for a 20-year period in BC. Will the ministry now decide that an “undercut” occurred all over BC and can now be rectified by additional logging, like in the case of TFL 8?

Seems utterly delusional to me.

Aren't we all getting a little fed up with media just printing government press releases, quoting industry facts, regurgitation instead of investigation, why not question their sources?  I am- so wrote a letter to journalists about it.

https://www.kelownadailycourier.ca/opinion/letters_to_editor/article_3d36557c-94f6-11ec-b5d7-d333b4fe7404.html?utm_source=kelownadailycourier.ca&utm_campaign=%2Fnewsletters%2Fheadlines%2F%3F-dc%3D1645711204&utm_medium=email&utm_content=headline

Timber supply cut may not be what it seems

Dear Editor:

Re: Interfor takes haircut on Boundary harvesting rights (Feb. 12)

Journalists reporting on recent announcements by the chief forester on new allowable annual cuts (AAC) for Interfor’s tree farm licence (TFL) 48, for the Okanagan timber supply area (TSA) and for Canoe Forest Products merely parrot what the chief forester says in a press release without question.

Has the logging actually been reduced in the Kettle River basin as a result of a reduction in the cut for TFL 8 and the Okanagan TSA?

The chief forester provides two reasons for a reduction of the cut in TFL 8: (1) management measures that address Indigenous interests; and (2) the accumulation of unharvested timber volume in the TFL amounting to an undercut of 115,987 cubic metres.

But why the undercut in TFL 8? The likely reason is that Interfor has been high-grading the timber and has run out of high-quality timber.

Is the undercut merely a measure of how plantations — the driver of timber supply — are failing as the Forest Practices Board pointed out for the Okanagan TSA?

“Indigenous interests” likely means the government intends to transfer cut from Interfor to local First Nations. This does not lower the overall cut or rate of logging in the Kettle River basin; it just moves it around on paper. But does the undercut actually exist on the ground?

For decades, scientific studies have shown that industrial forestry through clearcutting and an unsustainable rate of logging in B.C. is:

— Destroying terrestrial and aquatic habitats, extirpating species and driving others to extinction;

— Fouling drinking water for communities; 

— Ravaging soil and the fungal life necessary for forest health;

— Releasing vast amounts of carbon from below and above ground into the atmosphere – more than any other economic sector in B.C.;

— Disturbing large and small watersheds both of which are highly sensitive to clearcut logging resulting in flooding and landslides; and,

— Causing in part the large, rapidly moving and intense wildfires of recent years. 

Why haven’t journalists asked the chief forester how all the preceding harms have been considered in determining an AAC?

To mitigate against these harms, the chief forester and the provincial government will need first to deal with the biggest culprit in B.C., which is the logging industry.

With public safety at serious risk from the twin crises of climate change and biodiversity loss, a concerned and alarmed public needs the assistance of journalists in asking the right questions and in seeking informed answers.

Taryn Skalbania, Peachland

TS Letter Daily-Courier Feb21-22 Final.docx