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  • Investigations

    Yves Mayrand
    The BC Conservation Financing Mechanism, the Tripartite Framework Agreement on Nature Conservation, and the Draft BC Biodiversity and Ecosystem Health Framework have all been introduced just before federal and provincial elections. How advanced are they and what would need to happen before they could be implemented?
    Executive Summary
    This comment on the three recent announcements from the B.C. government is not intended to disparage what has been or could potentially be achieved through the BCCFM, the Tripartite Agreement, the BEHF, or the pursuit of their respective goals, but rather to point out clearly what steps remain to be taken and the issues that still need to be addressed by Canada, B.C., the First Nations of British Columbia and other parties in order to accomplish the stated goals and the actual implementation of the measures contemplated in these announcements, including fully committed and budgeted funding, firm timelines for the anticipated new conservation initiatives, and a clear commitment to legislative action following the upcoming election in British Columbia.
    The BCCFM
    There are significant uncertainties on what will be actually achieved through the BCCFM, and in what timeframe.
    It is apparent that the B.C. government is still not prepared to commit to the immediate implementation of Recommendation No.6 in the report of the Old Growth Strategic Review Panel (“OGSRP”) released more than 3 years ago, or the specific recommendations of the Old Growth Technical Advisory Panel (“OGTAP”) released more than two years ago respecting the immediate protection from logging of all the 2.6 million hectares of high-priority at-risk old growth forest areas identified, delineated and mapped by the OGTAP pursuant to Recommendation No.6 of the OGSRP.
    It is also apparent that the B.C. government is not prepared to immediately commit to, budget and disburse public funding for the permanent protection of the high-priority at-risk old growth forest in B.C. within a clear timeline, and that it intends to make any actual B.C. government funding commitments contingent on the raising of matching money from the general public and private donors.
    The B.C. government clearly signals that the BCCFM may be used in the future not just for old growth forest protection and conservation projects, but also for yet to be determined “low carbon economic opportunities”.
    The B.C. government has the ability to move quickly with actual legislation to address without any further delay the protection from logging of all the high-priority at-risk old growth forest areas without impinging on the rights and interests of First Nations in B.C., or disregarding B.C.’s Declaration on the Rights of Indigenous Peoples Act (“DRIPA”), as proposed in the outline of a Bill attached to this comment in the Appendix.
    The Tripartite Agreement
    The Tripartite Agreement is a statement of non-binding general intentions by the three Parties (Canada, B.C., and the First Nations Leadership Council [“FNLC”]), one of which (the FNLC) cannot bind First Nations, and which any of the three Parties can end at any time by notice to the other Parties.
    Despite the fact that the Tripartite Agreement is clearly non-binding on the three Parties, the language used throughout this agreement is vague, putative, and non-binding as well.
    The actual public funding contemplated by both levels of government in furtherance of the Tripartite Agreement over its target term of 6 years and 5 months is neither firmly committed nor budgeted at this time, nor is there any deadline set for this to happen.
    The terms and conditions, matching fund mechanism, funding criteria, and timetable for actual funding by both levels of government, third parties and the private sector have yet to be determined and agreed upon by the Parties.
    The terms of reference, actual composition, and appointment of members for the setting up of an interim Tripartite Nature Committee to coordinate activities under the Tripartite Agreement have yet to be determined and agreed upon by the Parties, and other organizations may be formed at an undetermined time in the future to assist with the implementation of the agreement.
    Other interested parties, organizations, and the general public should insist on the need for firm commitments by the Parties respecting transparency, accountability, and public reporting on nature conservation initiatives to be pursued in the future within the ambit of the Tripartite Agreement, the sources of their respective funding from public and private sector contributors, their respective terms and conditions, and their actual progress over the duration of the Tripartite Agreement.
    The Tripartite Agreement also does not include a firm commitment by the B.C. government on a clear timetable or deadline to actually implement Recommendation No. 6 of the OGSRP report published more than 3 years ago, or the interim or permanent protection from logging of all the 2.6 million hectares of high-priority at-risk old growth forest in British Columbia, as recommended and mapped in the OGTAP report more than 2 years ago.
    The Tripartite Agreement raises significant new concerns with respect to the listing, legal protection and enforcement measures that will be available going forward with respect to species at risk and their habitat in B.C. under federal law (SARA).
    The Draft BEHF
    The draft BEHF heralds yet another multi-step non-binding pathways approach that involves general objectives and intentions with no set timeframe or deadlines for their implementation or legislative action.
    While published twelve days after the signing of the Tripartite Agreement by the B.C. government, the draft BEHF does not mention any of the objectives contemplated in the Tripartite Agreement with respect to habitat and ecosystem conservation and protection, habitat enhancement and restoration, and species at risk protection and recovery. This omission is particularly significant with respect to Part 8.0 of the Tripartite Agreement, which heralds an intention to dilute the existing federal law (SARA) respecting the listing, protection, and enforcement measures for the protection of species at risk and their habitat in B.C.
    Also omitted in the draft BEHF is the impact of the most damaging practices of the resource extraction industries on biodiversity and ecosystem health in B.C., and the urgent necessity to change them, including the continued timber harvesting by the forest industry of high-priority at-risk old growth forests, which are a vital and irreplaceable habitat for species at risk such as the Marbled Murrelet and the Spotted Owl.
    The B.C. government should commit in principle to tabling before the Legislative Assembly of British Columbia the following Bills within a specific timeline following the next provincial election:
     a Bill for the protection of biodiversity, ecosystem health, species at risk and their habitat under provincial law;
     a Bill for the immediate and permanent protection from logging of all the high-priority at-risk old growth forest areas identified, delineated, and mapped by the B.C government’s own experts in the report of the Old Growth Technical Advisory Panel publicly released on November 3, 2021, as well as the most intact watersheds for each region and ecosystem identified on Map 6 in this report;
     a Bill to formally recognize and give effect to Tribal Parks, Indigenous Protected and Conserved Areas (IPCAs), and First Nation Guardianship under provincial law;
     a Bill to consolidate and modernize the forests statutes of British Columbia, including specifically the Forest Act3, the Forest and Range Practices Act4, and the Ministry of Forest and Range Act5; and
     a Bill to enact the statutory mandate of the Ministry of Water, Lands and Resource Stewardship with a duty and the necessary powers to protect biodiversity, ecosystem health and nature conservation in British Columbia.
    Getting the Outstanding Issues Addressed During the Provincial Election Year
    In our democratic system of government, outstanding public policy issues have to be addressed through a clear legislative agenda, with the tabling of Bills to amend existing laws and to pass new laws required to make the necessary changes and actions happen. The actual preservation of primary and old growth forests remaining in British Columbia, ecosystem health, natural carbon sinks, intact watersheds, biodiversity, the natural habitat of species at risk, and genuine reconciliation with First Nations still lies in the balance.
    1. Introduction
    In its most recent instalment of media releases respecting further action on old growth forest protection in British Columbia, the B.C. government announced on October 26, 2023, the launching of a provincial made-in-B.C. conservation tool called the B.C. Conservation Financing Mechanism (“BCCFM”) (https://news.gov.bc.ca/29736). It was followed on November 3, 2023, with an announcement by the B.C. government on the conclusion of a tripartite framework agreement on nature conservation between Canada, British Columbia, and the First Nations Leadership Council (FLNC) for British Columbia (“Tripartite Agreement”) (https://news.gov.bc.ca/29800), and with a further announcement by the B.C. government on November 15, 2023, on a draft biodiversity and ecosystem health framework (“BEHF”) (https://new.gov.bc.ca/29861).
    Although these three announcements, released between October 26 and November 15, 2023, do not all involve the same parties or initiatives, they are interrelated, and they share some common characteristics (a basic framework, statements of general intentions, non-binding goals and objectives, pathways, approaches, multiple steps, and open timeframes with no firm deadlines). They have been generally welcomed as a positive development for strengthening conservation efforts provincewide in British Columbia, heralding a new approach to consultation and cooperation between Canada, B.C., and First Nations on nature conservation initiatives and funding, promoting reconciliation with First Nations consistent with the United Nations Declaration on the Rights of Indigenous Peoples (“UNDRIP”), and supporting the achievement of Canada’s national goals to protect 25% of terrestrial areas by 2025 (“25 by 25”) and 30% of terrestrial areas by 2030 (“30 by 30”).
    These announcements show however a growing web of interrelated non-binding general frameworks, pathways, approaches, and multi-step processes, with implementation plans, committed government funding, and legislation to be further explored and developed at some undetermined time in the future.
    Our comment on these three recent announcements from the B.C. government is not intended to disparage what has been or could potentially be achieved through the BCCFM, the Tripartite Agreement, the BEHF, or the pursuit of their respective goals, but rather to point out clearly what steps remain to be taken and the issues that still need to be addressed by Canada, B.C., the First Nations of British Columbia and other parties in order to accomplish the stated goals and the actual implementation of the measures contemplated in these announcements, including fully committed and budgeted funding, firm timelines for the anticipated new conservation initiatives, and a clear commitment to legislative action following the upcoming election in British Columbia.
    2. The BCCFM
    The BCCFM announced by the B.C. government on October 26, 2023, involves the creation of a matching fund between funds to be provided by the province up to $150 million, and funds to be raised by the BC Parks Foundation (“BCPF”) from non-government sources up to $150 million, for a potential total of $300 million over the duration of this funding mechanism, which has yet to be specified.
    The media release states that “Together, this $300 million will be used to fund new conservation measures that are led or supported by First Nations, lasting environmental protection measures, capacity building for First Nations, stewardship and guardian programs, and support for low- carbon economic opportunities”. The scope of this initiative and related funding target is therefore significantly broader than the protection from logging of high-priority at-risk old growth forest areas in B.C.
    The fund will be managed by the BCPF and “... overseen independently from government by a special committee made up of experts, half of whom will be First Nations”. The actual size of this committee, its mandate, powers, and appointees have yet to be determined and publicly announced.
    The BCPF is a private not-for-profit society constituted under the laws of British Columbia. It is not a part of B.C. Parks or a B.C. government ministry. It has already started soliciting donations from the general public and other potential donors from the private sector through its website6 but it has not as yet publicly reported on the terms of its agreement with the B.C. government for the BCCFM, its fund-raising targets and milestones, the aggregate amount of donations that it has received, or the sources of these donations.
    The media release characterizes the creation of the BCCFM as “... one of B.C.’s actions underway to accelerate old-growth protection, as recommended by the Old Growth Strategic Review”. It states that the BCCFM “... joins new Forest Landscape Planning that is replacing existing forest stewardship plans and establishes clear objectives for the long-term management of old growth, biodiversity, climate change and wildfire risk”. It also states that “New forest landscape plans reflect the generational shift in forestry, where we can depend on a strong and sustainable industry that also safeguards biodiversity and long-term ecosystem health”.
    The media release further states that “As a result of significant collaboration between First Nations, the forest industry and the Province, deferrals have now been implemented on approximately 2.4 million hectares of old growth in B.C., including 1.23 million hectares of the most at-risk old growth identified by the Old Growth Technical Advisory Panel”.
    Finally, the media release states that “As recommended in the Old Growth Strategic Review, logging deferrals are a temporary measure to prevent irreversible biodiversity loss, while developing the new, long-term approaches to forest management through Forest Landscape Plans”.
    Key Elements Missing in the Media Release
    There is no specific mention in the media release of the OGSRP’s Recommendation No. 6, which clearly states the following:
    “Until a new strategy is implemented, defer development in old forests where ecosystems are at a very high and near-term risk of irreversible biodiversity loss”7.
    Also, there is no specific mention in the media release of the OGTAP’s recommendations. The OGTAP report8 states the following:
    “In principle, all old growth forest is irreplaceable in a human timeframe, and possibly in any timeframe given the climate crisis. However, some types of old growth forest (see Appendix 1 for details) currently face higher near-term risk. These types are most important to defer. All the forest types recommended and mapped for deferral are rare, at-risk, and irreplaceable.” (Page 3) (emphasis by the authors of the report).
    In furtherance of Recommendation No. 6 of the OGSRP, the OGTAP report clearly states the following:
    “To support urgent conversations between Provincial and First Nations governments, we recommend the following:
    • Defer harvest (i.e. no development or harvesting) in all mapped highest-priority at- risk old forests (priority big-treed old growth, ancient forest, remnant old ecosystems) while development of a new approach to forest management is underway. Unprotected highest-priority at-risk forests cover approximately 2.6 million ha:
    Ensure no new logging permits are approved in priority areas and no planning for future harvesting occurs until the new management system identifies what can be logged and how it can be logged. Some of the identified at-risk old forests already have some form of conservation designation. Where harvest is prohibited or generally prohibited ensure such prohibition is maintained. Avoid deferring harvest where forests are not at-risk to ensure meaningful deferrals. • Defer harvest in the most intact watersheds for each region and ecosystem. Deferral of harvest in intact watersheds is critical to maintain or recover landscape resilience (Map 6). Smaller intact areas should be identified in highly impacted areas of the province, as large areas are unavailable.” (Page 5) (emphasis by the authors of the report).
    The OGSRP report was sent to the B.C. government on April 30, 2020, well before being made public on September 11, 2020. The OGTAP report was sent to the B.C. government in October 2021 and made public on November 3, 2021.
    The B.C. government has subsequently decided that temporary old growth forest protection may be pursued through a variety of means, including short-term logging deferral orders on designated areas under the authority of B.C.’s Forest Act, temporary forbearance from the advertising and issuance of timber sales licences by the Ministry of Forests pursuant to the BC Timber Sales program (“BCTS”), and temporary logging deferral commitments to be concluded with individual First Nations and forest tenure holders on a case-by-case basis and on a voluntary basis.
    The B.C. government has yet to provide comprehensive, detailed, and up-to-date information on which old growth forest areas are actually protected temporarily, their location and extent, how they intersect with the high-priority at-risk old growth forest areas mapped by the OGTAP, the type of protection involved, or the duration of this protection for each area concerned. This lack of comprehensive, detailed, and up-to-date information continues with the general statement contained in the media release that “As a result of significant collaboration between First Nations, the forest industry and the Province, deferrals have now been implemented on approximately 2.4 million hectares of old growth in B.C., including 1.23 million hectares of the most at-risk old growth identified by the Old Growth Technical Advisory Panel”.
    The media release includes a fudging factor, with claimed logging deferrals for 1.1 million hectares of additional “old growth” that is admittedly not high-priority at-risk old growth mapped by the OGTAP. When aggregated with the claimed logging deferrals for the high- priority at-risk old growth component of 1.23 million hectares, this unspecified additional old growth component makes up for the total of 2.4 million hectares claimed by the B.C. government to be subject to logging deferrals, still short of the aggregate number that the OGTAP has identified and mapped specifically and only for high-priority at-risk old growth forest areas.
    Meanwhile, clearcut logging activities continue to take place in high-priority at-risk old growth forest areas, as evidenced through the reporting tool set up by the Stand.earth NGO, using satellite imagery, remote sensing, and government data to detect logging and road-building in the most rare and at risk old growth forests.
    The B.C. government decided to table without prior public consultations and to speedily pass Bill 2310 through the Legislative Assembly of British Columbia on November 25, 2021 in order to substantially amend the Forest and Range Practices Act (“FRPA”), with a view to providing for the gradual replacement of forest tenure holders’ forest management plans by new forest landscape plans (“FLPs”) on new forest landscape areas (“FLAs”) over a period of 8 to 10 years. The implementation of these amendments requires a lengthy case-by case process controlled and managed by the Minister of Forests and the Chief forester, and there are no binding obligations or deadlines set in the FRPA, as amended, for the conclusion of agreements between the B.C. government and the governing bodies of individual First Nations respecting the adoption of these new plans.
    The media release on the BCCFM shows that the B.C. government intends in practice to continue delaying the actual implementation of the key recommendations made by its own independent experts with respect to the immediate protection from logging of all the high- priority at-risk old growth forest areas remaining in British Columbia. It also confirms that the B.C. government’s overriding strategy is to implement its new multi-year case-by-case forest landscape planning system without actually committing to the temporary or permanent protection from logging of all the high-priority at-risk old growth forest areas in British Columbia identified and fully mapped by its own experts more than two years ago.
    As mentioned above, the B.C. government signals in the media release that with the new forest landscape plans, “... we can depend on a strong and sustainable industry that also safeguards biodiversity and long-term ecosystem health”. This should be seen as a continuation of the old industry reliance model for B.C. forestry, which has allowed the continued extraction of old growth forest timber in British Columbia through clearcutting over the last two decades.
    Given the speedy enactment of Bill 2311 and Bill 2812 in November 2021, and more recently the speedy enactment of Bill 4113, it should be noted that the B.C. government has the ability to move with lightning speed on legislative changes on forestry matters when it chooses to do so, instead of the glacial speed at which it continues to approach the permanent legal protection of the remaining high-priority at-risk old growth forest areas in British Columbia.
    With the necessary political will, the B.C. government can and should table a Bill in the next session of the Legislative Assembly of British Columbia following the upcoming provincial election to be held in 2024. Such a Bill would actually establish the Old Growth Nature Fund with committed B.C. capital funding to be budgeted in the province’s next fiscal year, incorporate by reference all the high-priority at-risk old growth forest areas already identified, delineated and mapped by the B.C. government’s experts in the OGTAP report published more than two years ago, and provide for First Nations to opt-in on the permanent protection of these areas within their respective traditional territories in return for financial compensation from the B.C. government. An outline of a Bill to achieve this urgently needed result is attached as an Appendix.
    The upcoming provincial elections in 2024 provide an opportunity for all political parties and all individuals running for elected office as MLAs to commit in principle to such a Bill and to state their position on how it should be drafted, tabled, discussed, and voted upon during the first session of the newly elected members of the Legislative Assembly of British Columbia.
    There are significant uncertainties on what will be actually achieved through the BCCFM, and in what timeframe.
    It is apparent that the B.C. government is still not prepared to commit to the immediate implementation of Recommendation No.6 in the report of the Old Growth Strategic Review Panel (“OGSRP”) released more than 3 years ago, or the specific recommendations of the Old Growth Technical Advisory Panel (“OGTAP”) released more than two years ago respecting the immediate protection from logging of all the 2.6 million hectares of high-priority at-risk old growth forest areas identified, delineated and mapped by the OGTAP pursuant to Recommendation No.6 of the OGSRP.
    It is also apparent that the B.C. government is not prepared to immediately commit to, budget and disburse public funding for the permanent protection of the high-priority at-risk old growth forest in B.C. within a clear timeline, and that it intends to make any actual B.C. government funding commitments contingent on the raising of matching money from the general public and private donors.
    The B.C. government clearly signals that the BCCFM may be used in the future not just for old growth forest protection and conservation projects, but also for yet to be determined “low carbon economic opportunities”.
    The B.C. government has the ability to move quickly with actual legislation to address without any further delay the protection from logging of all the high-priority at-risk old growth forest areas without impinging on the rights and interests of First Nations in B.C., or disregarding B.C.’s Declaration on the Rights of Indigenous Peoples Act (“DRIPA”), as proposed in outline of a Bill attached to this comment in the Appendix.
    3. The Tripartite Agreement
    The full text of the Tripartite Agreement can be found on the website of the government of Canada.
    The stated purpose of the Tripartite Agreement is to “...establish a framework to achieve a more integrated and collaborative landscape-based approach to ecosystem health and biodiversity conservation...”.
    The Tripartite Agreement is structured along seven broad principles to guide further work and the implementation of future initiatives, seven goals to guide the implementation of the Agreement, and four objectives to achieve these stated goals, which are habitat and ecosystem conservation and protection, habitat enhancement and restoration, species at risk protection and recovery, foundational knowledge, and information sharing.
    The Tripartite Agreement is not legally binding and therefore does not create legal rights or obligations. It will remain in force until March 31, 2030, unless terminated earlier by any Party 90 days after providing written notice to the other Parties.
    Preamble N states that “The FNLC is not a title or rights, or treaty rights, holder and cannot engage in processes to establish and provide free, prior, and informed consent on behalf of individual First Nations, and engagement with the FNLC under this Agreement does not in any way fulfill, replace, or displace Canada or B.C.’s obligations to consult and cooperate with First Nations title and rights holders”.
    Preamble X states that “This Agreement does not define the legal status, nature, scope, content or geographic extent of any particular First Nation’s rights, including title and self-government, or how those rights co-exist with those of the Crown or other First Nations”.
    Preamble Y states that “Nothing in this Agreement alters or supersedes any Party’s obligations under existing legislation, treaties, agreements, or other constructive arrangements, nor does it alter or replace any ongoing negotiations on the recognition and implementation of rights between First Nations, Canada, and B.C., or preclude new nature-related initiatives that may be initiated outside the scope of this Agreement. Furthermore, references to specific federal and provincial legislation, programs and policies does not imply their approval or endorsement by FNLC or First Nations”.
    Also, the Preamble clearly states that the Tripartite Agreement is concluded by the Parties
    “...without prejudice to their respective powers and authorities”.
    Despite the fact that the Tripartite Agreement is clearly non-binding on the three Parties, the language used throughout this framework agreement is generally vague, putative, and non- binding as well.
    Finance and Funding
    The Tripartite Agreement contemplates public funding to be directed respectively by Canada and the province of British Columbia to support future initiatives in furtherance of the agreement. The funding model to be pursued is however not only based on the matching of funds between the two levels of government, but also on the leveraging of matching funds from the private sector.
    Both levels of government are contemplating the creation of a new Old Growth Nature Fund (“OGNF”), with matching fund contributions of $50 million each and potential funding from third-party organizations. The federal government proposed its $50 million matching fund contribution target over two years ago, but the B.C. government had not contemporaneously confirmed its own matching fund contribution target. Federal-provincial negotiations ensued until the signing of the Tripartite Agreement on November 3, 2023. It appears that federal- provincial negotiations are still on-going with a view to setting up the actual matching fund mechanism and the terms and conditions for the oversight, operation, management, and funding criteria for the new OGNF.
    The media release states that “To support the commitments in the Tripartite Framework Agreement on Nature Conservation (the Framework Agreement), the Government of Canada is investing up to $500 million over the life of the Framework Agreement, which matches commitments from the Government of British Columbia”.
    The up to $500 million overall public funding target contemplated by Canada for the anticipated 6-year and 5-month duration of the Tripartite Agreement encompasses not only the new OGNF, but also several already existing federal funding programs.
    The media release states in the “Quick Facts” section that “B.C. is supporting the implementation of the Framework Agreement with matching investments through existing programs and conservation initiatives that are advancing the province’s commitment to protect at least 30 percent of terrestrial areas by 2030, ecosystem health and biodiversity, and better outcomes for wildlife and species at risk including Modernized Land Use Planning, Forest Landscape Planning, Old Growth Strategic Review, Species at Risk Recovery, Together for Wildlife, Collaborative Indigenous Stewardship Framework, Indigenous Guardian programs, and the Province’s creation of a new Conservation Financing Mechanism”.
    However, there is no mention of the specifics in the Tripartite Agreement for the overall $500 million matching target of the B.C. government and its components listed in the “Quick Facts section of the media release, other than the $50 million B.C. target contribution to the OGNF, and the creation of the provincial-scale conservation financial mechanism announced previously on October 26, 2023.
    The Parties intend to seek “... alignment with contributions of funding flowing through this Agreement to leverage provincial and third-party investments into conservation financing”. This general statement in the Tripartite Agreement indicates that the funding structure contemplated by the Parties is essentially based on three-way matching requirements between the two levels of government and the private sector without specifying the matching formula, terms and conditions, and milestones at this time. It indicates that matching funding from the two levels of government will essentially come from a broad spectrum of existing programs. Finally, for the B.C. government’s part, the existing programs apparently include previously ongoing run-of-the mill activities of various government Ministries.
    The transfer of government funds from Canada and from B.C. in furtherance of the Tripartite Agreement is expressly made subject to actual commitments and conditions being set in future contribution agreements to be signed by Canada and B.C. The agreements and partnerships to support the implementation of the Tripartite Agreement through the raising of funds from third parties and the private sector have yet to be explored in the future.
    The Tripartite Agreement contemplates the establishment of an interim Tripartite Nature Committee comprised of representatives from each of the three Parties to coordinate activities under the Agreement. The Terms of Reference for this interim committee are to be developed within 12 months of signing (i.e. presumably by November 2, 2024). There is no indication of a timetable for the actual appointment of the members of this interim Committee, their expertise, or who they will represent, nor is there any indication of the composition of, and timetable for, a more definitive oversight Committee. The Tripartite Agreement mentions a general intention to pursue the creation of as yet undefined further mechanisms and bodies complementary to the role of the interim Committee.
    Information and Data Sharing, Accountability and Reporting
    Part 9.0 of the Tripartite Agreement dealing with First Nations foundational knowledge and information sharing between the Parties introduces the concept of “First Nations data sovereignty” and the upholding of this concept by the Parties. The origins, scope and legal effect of this concept are not detailed or explained in the Tripartite Agreement.
    Canada and B.C. declare their intention to “... assume an approach that values all forms of knowledge and ways of knowing, applying them in a manner that builds from the strengths of each towards a harmonized system of stewardship. Canada and B.C. will also work to ensure that federal and provincial data related to this Agreement are openly accessible to First Nations to support them in this partnership.
    The Tripartite Agreement provides that “The Parties acknowledge that data and information collected by the Parties could be subject to legal requirements respecting disclosure of that data and information, such as the federal Access to Information Act or the provincial Freedom of Information and Protection of Privacy Act, and that data and information pertaining to or generated by First Nations will be handled in a manner consistent with the principles of ownership, control, access and possession OCAP)30, with a footnote stating that these are First Nations principles, without referring however to where these principles are stated and can be consulted by interested parties and the public.
    The Tripartite Agreement states that “Canada and B.C., in consultation and cooperation with First Nations, will develop and release a data and information collection plan within 12 months of signing this Agreement, that will provide the information necessary to evaluate and report upon the progress under this Agreement, and a data and information sharing agreement in support of Agreement implementation and annual reporting”. It further states that “Canada and B.C. will work together to implement and adhere to the principles of open government data, in consideration of First Nations data sovereignty, within this Agreement and publish data according to these principles32.
    In Part 12.0 on reporting, engagement and communications, the Tripartite Agreement states that “To ensure public transparency and to support broad credibility, understanding and accountability regarding progress and outcomes of the Agreement, the Parties will develop a first joint report and agree on performance indicators within 12 months of signing the Agreement and thereafter annual reports. Public reporting practices will be streamlined, standardized, aligned, and integrated with existing reporting commitments to report sites in CPCAD33, and monitoring mechanisms”.
    The Tripartite Agreement also states that “The Parties will strive to minimize reporting requirements related to this Agreement. Reporting metrics and performance measures will be designed to focus on progress toward conservation outcomes, greenhouse gas emissions reductions, and community benefits. It further states that “The Parties will jointly communicate on this Agreement and associated milestones, including with First Nations or other partners as appropriate”.
    Nature conservation involves a broad spectrum of interested parties and organizations at the international, national, provincial, regional, and local levels, not just the government of Canada, the B.C. government, and the governing bodies of individual First Nations of British Columbia. In this regard, the Tripartite Agreement only states that “Canada and B.C. will also engage with local governments and stakeholders on opportunities for input and involvement in the implementation of the Agreement.
    Other interested parties, organizations, and the public should therefore insist on the need for firm commitments by the Parties respecting transparency, accountability, and public reporting on nature conservation initiatives to be pursued in the future within the ambit of the Tripartite Agreement, the sources of their respective funding from public and private sector contributors, their respective terms and conditions, and their actual progress over the duration of the Tripartite Agreement. They should also be concerned with the shortcomings of the access to information process under federal and provincial legislation, which is known to be reactive rather than proactive, as well as often protracted and obfuscating, rather than forthcoming with timely, true, plain, and full disclosure pursuant to the objectives and requirements of that legislation.
    Effect of the Tripartite Agreement on the Protection of High-Priority At-Risk Old Growth Forests in B.C.
    Preamble P states that “B.C. has undertaken an Old Growth Strategic Review and intends to co- develop with First Nations legislation to prioritize ecosystem health and biodiversity as an overarching priority for all sectors”. As part of the objectives on habitat and ecosystem conservation and protection, Section 6.4.3 of the Agreement states that “Canada and B.C. will establish the Old Growth Nature Fund, with matching funding of $50 million each and potential funding from third-party organizations, and work in partnership with First Nations to permanently protect and conserve 4,000 to 13,000 km2 of high-priority at-risk old growth forests in the coastal western hemlock, coastal douglas-fir, or interior cedar-hemlock biogeoclimatic ecosystem classification (BEC) zones that overlap with biologically diverse and productive habitats for species at risk or migratory birds, and contribute to Canada’s commitment to protect 25% of terrestrial areas by 2025 and Canada’s climate target.”
    There is no specific mention in the Tripartite Agreement of Recommendation No. 6 made in the OGSRP’s report sent to the B.C. government on April 30, 2020, and finally published on September 11, 2020, nor is there any specific mention or acknowledgement in the Tripartite Agreement of the recommendations in the OGTAP report sent to the B.C. government in October 2021 and published on November 3, 2021.
    The Tripartite Agreement does not give any clear indication of the actual location and geographical extent of the 4,000 to 13,000 square kilometres (i.e. 400,000 to 1.3 million hectares) of old growth forest that would eventually be permanently protected, where and to what extent the areas considered for such protection overlap, or do not overlap, with the 2.6 million hectares (i.e. 26,000 square kilometres) of high-priority at-risk old growth forest areas already mapped by the TAP for urgent logging deferral, or where and to what extent these potential new protection areas overlap with “biologically diverse and productive habitats for species at risk or migratory birds” that “contribute to Canada’s commitment to protect 25% of terrestrial areas by 2025 and Canada’s climate target”, as no maps or links to maps with their location have been provided along with the announcement.
    There is no indication in the Tripartite Agreement of the timetable for the setting up of the Old Growth Nature Fund. The transfer of funds by Canada and British Columbia of their respective matching funds of up to $50 million for the Old Growth Nature Fund is subject to sections 11.2 which states that “... contribution agreements are required to transfer funds”, “... More specific commitments and additional conditions for the transfer of funds may be anticipated”, and section 11.3 which states that “...contribution agreements will be subject to the respective priorities, authorities, and budgetary constraints of Canada and B.C.” Furthermore, the B.C. government has not clarified whether its eventual contribution of up to $50 million for the Old Growth Nature Fund is entirely distinct from, or included in whole or in part with, the money pegged for the creation of the BCCFM funding mechanism announced eight days earlier.
    Effect of the Tripartite Agreement on the Conservation and Protection of Habitat and Species at Risk
    The Tripartite Agreement contains three parts dealing respectively with habitat and ecosystem conservation and protection (Part 6.0), habitat enhancement and restoration (Part 7.0), and species at risk protection and recovery (Part 8.0). 
    Part 6.0 on habitat and ecosystem conservation and protection sets the general tone for future measures respecting habitat and ecosystem conservation and protection in B.C. With respect to funding requirements, this part of the Tripartite Agreement includes a specific caveat of the B.C. government that, in addition to the free, prior, and informed consent of appropriate First Nations title and rights holders, B.C. Cabinet and Treasury Board approval will be required “... to address existing tenures and mitigate socio-economic impacts”. Also, Part 6.0 outlines eight general objectives, including the future establishment of the Old Growth Nature Fund (“OGNF”).
    Part 7.0 on habitat enhancement and restoration is clearly focussed on ex post future restoration and enhancement measures, as opposed to ex ante effective protection measures before significant damage is done and restoration measures become necessary. The Tripartite Agreement is silent on the urgent necessity to change the most damaging current practices of the oil, gas, mineral, and timber resource extraction industries on wildlife habitat in British Columbia. Finally, it appears that Part 7.0 leaves mainly to Canada the financial responsibility to fund new habitat restoration activities in the future for the duration of the Tripartite Agreement.
    Part 8.0 on species at risk protection and recovery demonstrates that the B.C. government continues to have no real plans to pass a provincial law for the protection of species at risk and their habitat in British Columbia. Advocates of effective legal protection for species at risk and their habitat in the province should be further concerned with the intent by both B.C. and Canada to “... help mitigate the need for regulatory orders under federal legislation”.
    Also of significant concern is the stated objective that “Canada and B.C. will consult and cooperate with First Nations to take conservation actions early that address threats and may obviate the need for listing under the Species at Risk Act (SARA) and improve the prioritization of foundational knowledge to better inform federal listing decisions. This new objective, which heralds a dilution of the existing federal law respecting the listing, protection and enforcement measures for the protection of species at risk and their habitat in B.C., is amplified by another of the nine stated objectives, which provides that “Canada and B.C. will advance existing species listing and recovery pilots to ensure that listing decisions in SARA are fully informed with respect to First Nations knowledge and perspectives and socio-economic implications, and to explore recovery approaches where species are in decline due to broad scale cumulative impacts rather than localized habitat loss...”. This does not address the urgent need for change to the ongoing negative impact of the most damaging practices of the resource extraction industries in B.C., such as clearcutting.
    These new objectives in the Tripartite Agreement come on the heels of the recent controversy surrounding the protection of the Spotted Owl’s old growth forest habitat in B.C. The federal Minister of the Environment and Climate Change recommended the issuance of a federal emergency order under the authority of SARA, which led to active lobbying by the B.C. government to have the proposed emergency order finally nixed by the federal cabinet. The alleged rationale for this controversial federal cabinet decision is reflected in another of the nine objectives in Part 8 of the Tripartite Agreement stating that “Canada will support B.C. and First Nations actions toward the recovery of Spotted Owl caurina including a SARA-compliant action plan, augmenting captive breeding capacity, control of competitive species, release of owls, and monitoring and adaptive management of both species (e.g., Spotted Owl and Barred Owl) and habitat protection, conservation, and recruitment of owls. There is no mention about limiting further old growth forest clearcutting in this endangered species’ habitat.
    The Tripartite Agreement is silent on two significant pending legal actions seeking to compel Canada and B.C. to take protective and enforcement actions for species at risk listed in SARA and their habitat, and whether Canada and B.C. will continue to devote legal resources and government money to fight these actions. The Friends of Fairy Creek Society is seeking a declaratory judgement from the Supreme Court of British Columbia to confirm that Canada and B.C. are obligated to protect the natural old growth forest habitat of the Marbled Murrelet, a listed species at risk under SARA, pursuant to the Convention on Migratory Birds signed by Canada, the Migratory Birds Convention Act (Canada), and SARA46. The NGO Ecojustice, representing the Wilderness Committee and Sierra Club BC, applied to the Federal Court of Canada to seek a ruling that Canada is obligated to protect the critical habitats of at-risk migratory birds across Canada under SARA, including the Marbled Murrelet in B.C.
    The Tripartite Agreement is a statement of non-binding general intentions by the three Parties, one of which (the FNLC) cannot bind First Nations, and which any of the three Parties can end at any time by notice to the other Parties.
    Despite the fact that the Tripartite Agreement is clearly non-binding on the three Parties, the language used throughout this agreement is vague, putative, and non-binding as well.
    The actual public funding contemplated by both levels of government in furtherance of the Tripartite Agreement over its target term of 6 years and 5 months is neither firmly committed nor budgeted at this time, nor is there any deadline set for this to happen.
    The terms and conditions, matching fund mechanism, funding criteria, and timetable for actual funding by both levels of government, third parties and the private sector have yet to be determined and agreed upon by the Parties.
    The terms of reference, actual composition, and appointment of members for the setting up of an interim Tripartite Nature Committee to coordinate activities under the Tripartite Agreement have yet to be determined and agreed upon by the Parties, and other organizations may be formed at an undetermined time in the future to assist with the implementation of the agreement.
    Other interested parties, organizations, and the general public should insist on the need for firm commitments by the Parties respecting transparency, accountability, and public reporting on nature conservation initiatives to be pursued in the future within the ambit of the Tripartite Agreement, the sources of their respective funding from public and private sector contributors, their respective terms and conditions, and their actual progress over the duration of the Tripartite Agreement.
    The Tripartite Agreement also does not include a firm commitment by the B.C. government on a clear timetable or deadline to actually implement Recommendation No. 6 of the OGSRP report published more than 3 years ago, or the interim or permanent protection from logging of all the 2.6 million hectares of high-priority at-risk old growth forest in British Columbia, as recommended and mapped in the OGTAP report more than 2 years ago.
    The Tripartite Agreement raises significant new concerns with respect to the listing, legal protection and enforcement measures that will be available going forward with respect to species at risk and their habitat in B.C. under federal law (SARA).
    4. The draft Biodiversity and Ecosystem Health Framework
    The media release publishing the draft BEHF for comments on November 15, 2023, under the title “B.C. prioritizing ecosystem health, biodiversity” states that “The framework is another action the Province is taking as part of ongoing work to improve stewardship of B.C.’s lands, forests and water, to implement the recommendations of the Old Growth Strategic Review and to honour B.C.’s commitments under the Declaration on the Rights of Indigenous Peoples Act”. It further states that “The framework is expected to be finalized in early 2024, following consultation. B.C. will co-develop new or update existing legislation to achieve the vision and intent of the framework”.
    The deadline for comments from members of the public, originally set for January 15, 2024, was extended to January 31, 2024. Our detailed submission on the draft BEHF dated January 30, 2024, is already on file with the Ministry of Water, Land and Resource Stewardship.
    The draft BEHF heralds yet another multi-step non-binding pathways approach that involves general objectives and intentions with no set timeframe or deadlines for their implementation or legislative action.
    While published twelve days after the signing of the Tripartite Agreement by the B.C. government, the draft BEHF does not mention any of the objectives contemplated in the Tripartite Agreement with respect to habitat and ecosystem conservation and protection, habitat enhancement and restoration, and species at risk protection and recovery. This omission is particularly significant with respect to Part 8.0 of the Tripartite Agreement, which heralds an intention to dilute the existing federal law (SARA) respecting the listing, protection, and enforcement measures for the protection of species at risk and their habitat in B.C.
    Also omitted in the draft BEHF is the impact of the most damaging practices of the resource extraction industries on biodiversity and ecosystem health in B.C., and the urgent necessity to change them, including the continued timber harvesting by the forest industry of high-priority at-risk old growth forest trees, which are a vital and irreplaceable habitat for species at risk such as the Marbled Murrelet and the Spotted Owl.
    The B.C. government should commit in principle to tabling before the Legislative Assembly of British Columbia the following Bills within a specific timeline following the next provincial election:
    a Bill for the protection of biodiversity, ecosystem health, species at risk and their habitat under provincial law;
    a Bill for the immediate and permanent protection from logging of all the high-priority at-risk old growth forest areas identified, delineated, and mapped by the B.C government’s own experts in the report of the Old Growth Technical Advisory Panel publicly released on November 3, 2021, as well as the most intact watersheds for each region and ecosystem identified on Map 6 in this report;
    a Bill to formally recognize and give effect to Tribal Parks, Indigenous Protected and Conserved Areas (IPCAs), and First Nation Guardianship under provincial law;
    a Bill to consolidate and modernize the forests statutes of British Columbia, including specifically the Forest Act, the Forest and Range Practices Act, and the Ministry of Forest and Range Act; and
    a Bill to enact the statutory mandate of the Ministry of Water, Lands and Resource Stewardship with a duty and the necessary powers to protect biodiversity, ecosystem health and nature conservation in British Columbia.
    5. Getting the outstanding issues addressed during the provincial election year
    In our democratic system of government, outstanding public policy issues have to be addressed through a clear legislative agenda, with the tabling of Bills to amend existing laws and to pass new laws required to make the necessary changes and actions happen. The actual preservation of primary and old growth forests remaining in British Columbia, ecosystem health, natural carbon sinks, intact watersheds, biodiversity, the natural habitat of species at risk, and genuine reconciliation with First Nations still lies in the balance.
    A provincial election must be called in 2024. In the circumstances, is should be expected that the incumbent provincial government will make various announcements to set public narratives on outstanding public policy issues while leaving all its options open and delaying any firm commitments. Yet, the provincial election provides a unique window of opportunity for constituents, organizations, First Nations, and the media to press for explicit, and binding commitments from the incumbent government, the provincial political parties, and all the individual candidates running for elected office as members of the Legislative Assembly of British Columbia.
    We hope that our document will contribute to a better understanding and informed discussion of the public policy issues still outstanding in British Columbia with respect to the permanent protection of primary and high-priority at-risk old growth forest areas, biodiversity, ecosystem health, species at risk and their habitat, the effective conservation of 25% of the land base by 2025 and 30% of the land base by 2030, First Nations stewardship on their unceded traditional territories, and the provincial legislation that needs to be tabled, debated, and passed by the newly elected members of the Legislative Assembly of British Columbia following the provincial election to be called in 2024.

    David Broadland
    A flawed Forest Practices Board investigation of logging of “old trees” at Hummingbird Lake on Quadra Island highlights the failure of 20-year-old land use planning that was supposed to resolve ongoing conflict between logging and conservation.
    IN JUNE 2022, the Forest Practices Board released an investigation report into a complaint about old trees being logged on a Quadra Island Woodlot Licence Program tenure. 
    The investigation found that the tenure holder, Okisollo Resources, had complied with the legal requirements of its approved logging plan. The Board praised the logging company for “setting aside all of the existing old-growth stands by designating them as wildlife tree retention areas.”
    However, the investigation report contains serious factual errors, partly the result of the Board’s failure to ground-truth the descriptions of the forest and logging that were at issue. No investigators visited Quadra Island. Not the least among the errors was the Board’s assessment that Okisollo Resources had set aside “all of the existing old growth stands…”
    The report’s failings unintentionally highlight how thoroughly the landmark 2001 Vancouver Island Land Use Plan—which took nearly a decade to complete—has been circumvented by the Ministry of Forests.
    I contacted the Board and Okisollo Resources after the investigation report had been released. Because of the factual errors included in the report it’s difficult to make sense of the Board’s justification of its findings. So let’s begin with some facts I gathered even before a complaint was filed. Then we will compare that with what the Board says are the reasons for its findings.
    It just so happened that I had visited Hummingbird Lake with a drone in July 2018, one year before the logging took place. I 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.
    On each visit, I photographed the area, both on the ground and using a drone for aerial views of the forest and lake. Over the past five years, as part of the Discovery Islands Forest Conservation Project, I have 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.

    Old forest at the peninsula on Hummingbird Lake. Okisollo Resources have reserved the right to log the old forest on the peninsula, yet claim to have reserved all existing old forest.
    On my 2018 visit, I 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 and fir began to grow back—naturally—between the 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 I have surveyed on Quadra Island.
    The centre of the cutblock on the north side of Hummingbird Lake lies within half a kilometre of the boundaries of both Small Inlet Provincial Park and Octopus Islands Provincial Park. In other areas of the woodlot, Okisollo Resources has clear cut right to the edge of the parks.
    When I 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. Every other tenure on Quadra Island leaves these big trees standing. I had never seen so many big trees in the middle of a Quadra Island logging operation.

    Okisollo Resources’ logging of old forest on the north side of Hummingbird Lake in July 2019.

    This photo, taken in 2020, shows the same area as in the photo above.
    I 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.

    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.
    I 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.

    This Douglas fir had 370 annual growth rings.

    To determine how many old firs had been logged in the northern cutblock, I 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 (see photo above), only 15 remained.

    In the cutblock at the southwest end of the lake, at least four old-growth firs that had been standing in the otherwise bare clearcut in July 2019 had been felled by mid-August.
    My 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 50 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.
    The Ministry of Forests’ Harvest Billing System, which records the volume logged and the stumpage paid for trees cut on public land, shows that Okisollo Resources paid at most $3800 in stumpage for the 50-plus old-growth Douglas fir trees it felled in July and August of 2019. That’s roughly $76 per tree.
    That’s what actually happened at Hummingbird Lake in July and August of 2019. Now let’s return to the Forest Practices Board’s investigation report.
    The report gives the following chronological account of who did what and when they did it. The “complainant” was long-time Quadra Island resident Rod Burns:
    “In the spring of 2020, a Quadra Island resident (the complainant) noticed that old trees had been harvested in woodlot licence W2031. The complainant believed that the woodlot licensee was not permitted to harvest old trees, therefore filed a complaint with the Compliance and Enforcement Branch (CEB) of the Ministry of Forests in the spring of 2021. CEB looked into the matter and found that the licensee had harvested the old trees legally. When the complainant learned this, he filed a complaint with the Forest Practices Board on February 14, 2022, asserting that government enforcement was inappropriate.”
    Neither the Compliance and Enforcement Branch or the Forest Practices Board sent investigators to Quadra Island. Nevertheless, the Board released its investigation report in June 2022.

    From a drone, the areas of old forest on Hummingbird Mountain are easily visible. Since this photo was taken in 2020, additional logging has occurred.

    Hidden in plain sight: old-growth forest
    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.”
    This was at odds with what I had seen.
    I asked Chris Oman, the Board’s director of investigations, how investigators had determined that old trees had only been cut “to build a road and for safety reasons.” After all, by the Board’s own admission, no investigator from either the Compliance and Enforcement Branch or the Forest Practices Board had even set foot on Quadra Island. As far as the Board knew, only 10 trees had been cut. How did the Board conclude that those 10 trees were cut “to build a road and for safety reasons”?
    Oman did not answer that question. But it would appear that investigators simply accepted Okisollo Resources’ assurance that this was the case.
    In response to questions I put 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 the roads. Above, I estimated that at least 10 had been removed because they were in the way of the road. But was safety really an issue? 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 Hummingbird Lake cutblock, all of the 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.
    This apparent willingness of Forest Practices Board investigators to parrot the logging company’s position when it had no evidence to do so raises questions about the independent nature of the Board’s other findings.
    For example, consider the question of whether the 50 old trees that Okisollo Resources logged at Hummingbird Lake were under any existing protection from logging as a result of the Vancouver Island Land Use Plan, as Burns had believed. This is a difficult and complex question, one that the Forest Practices Board addressed superficially, but, at the same time, with remarkable creativity.
    The Board’s report dismissed the role the Vancouver Island Land Use Plan has played in guiding protection of old-growth trees and forest on Quadra Island by referencing a speech a forests minister had once made about woodlots. Instead of providing factual information, the Board invented a “Quadra landscape unit” to explain how old growth is managed. I asked the Board to send me any written documentation it had that explained what the “Quadra landscape unit” is. The Board did not acknowledge the request. There is no such thing as the “Quadra landscape unit.” It has long been promised, but has never materialized.
    A more useful consideration of whether the old trees at Hummingbird Lake had any protection would have required a detailed investigation into what Okisollo Resources had committed to in its official, approved Woodlot Plan, and why.
    What had it committed to do? The Forest Practices Board’s reading of Okisollo’s plan led investigators to conclude: “In their [Woodlot Plan], they committed to setting aside all of the existing old-growth stands by designating them as wildlife tree retention areas.”
    Why would Okisollo have done that? A little history is needed.
    A Woodlot Licence Program tenure was awarded to Okisollo Resources in 2011. But 10 years before that, all of the old forest at Hummingbird Lake had been protected under the provisions of Special Management Zone 19, which had been created by the Vancouver Island Land Use Plan. Over 12,000 hectares of public land on Quadra Island had been given that special status. Why had that protection been granted?
    In 2001, it was well known that the area of old-growth forest in the “Coastal Western Hemlock very dry maritime” biogeoclimatic zone (which includes most of the area of the Discovery Islands) had fallen to about 9 percent of the zone’s total area. Forest biologists and ecologists had determined that if the area of old forest fell below 10 percent of the total area of the zone, the risk of biodiversity loss in that biogeoclimatic zone would be high.
    To conserve the remaining biodiversity associated with the Coastal Western Hemlock zone, and to map a course toward restoration of old forest to a higher percentage, the Vancouver Island Land Use Plan recommended a specific strategy for Quadra Island. (Quadra was one of only two of the 19 forest-based special management zones where a strategy for biodiversity conservation was detailed.)
    In practice, that meant protecting all of the remaining “old” forest (defined as greater than 250 years old) since that had fallen below 10 percent, and managing future logging so that there would always be at least 25 percent of the forested area covered with “mature” forest (defined as greater than 80 years old).
    The most critical recommendation in that strategy is captured in a single sentence: “maintain existing old forest in the zone, as well as second growth with [a] high portion of veteran trees...”
    The old trees and old forest that were logged at Hummingbird Lake met both of those descriptions. So as of 2001, the old trees and old forest at Hummingbird Lake had been protected.
    Beginning in 2005, however, the Campbell River district office of the Ministry of Forests began to locate Woodlot Licence Program tenures in Special Management Zone 19. Under forest legislation passed in 2002, woodlots did not need to meet certain objectives established by government. That exemption included objectives like conservation of Quadra’s old forest and second-growth forest that had a high portion of old trees. So establishing woodlots in SMZ 19 would have made it legal to go backward in the effort to conserve old forest and old trees at places like Hummingbird Lake.
    By the way, the 11 Woodlot Licence tenures that were created or expanded in Special Management Zone 19 on Quadra Island, from 2005 onward, were the only woodlots created in any of Vancouver Island’s 19 forest-based special management zones.
    Almost all of the new Quadra Island woodlots choose to honour most of the previous obligations to protect old forest and old trees that had existed before woodlots were dropped on SMZ 19. For example, the official plan for Woodlot 2032, established at the same time as Okisollo Resources’ Woodlot 2031 at Hummingbird Lake, stated that it would avoid logging all old-growth trees and old forest.
    Did Okisollo Resources make that commitment?
    In its Woodlot Licence Plan, its strategy for conserving biodiversity included these words: “Retaining the existing old growth forests is key to maintaining the biodiversity values of forests in the CWHxm biogeoclimatic subzone.”
    That sounds like a commitment to retain existing old growth forests. Indeed, the Forest Practices Board noted—four times—in its investigation report, that “In their WLP, they committed to setting aside all of the existing old-growth stands by designating them as wildlife tree retention areas.”
    The words that a would-be woodlot tenure holder uses in their Woodlot Licence Plan have legal consequences. Section 21(1) of the Forest and Ranges 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.”
    But here’s the problem: Okisollo Resources said it would retain all existing old forest, but its map of where old forest exists doesn’t match where old forest actually exists. Like at Hummingbird Lake.

    Okisollo Resources logging in old-growth forest at Hummingbird Lake in 2019.
    A map in Okisollo Resources’ approved Woodlot Plan referenced three small areas that a forester had identified as containing old forest in 2007 using the Ministry of Forests’ notoriously inaccurate Vegetation Resource Inventory. It is notorious because it fails miserably at identifying old-growth forest, and that has been an ongoing problem in BC.
    Okisollo’s map shows only three tiny areas of old forest. The total area of that old forest is a mere 15.1 hectares—only 2 percent of the woodlot’s 715 hectares. If that was an accurate assessment, the amount of old forest left would be at an even lower level than the high-risk 9 percent estimated by forest ecologists for this biogeoclimatic zone in 2001.
    If Okisollo’s map was accurate, the need to “maintain existing old forest in the zone, as well as second growth with [a] high portion of veteran trees...” would be even more urgent.
    In any case, there appears to be nothing in the legislation governing woodlots that would allow a map that fails to indicate accurately where old forest is located to overide a strategy that states existing old forest will be retained. Yet the Board’s findings depended entirely on the faulty map.
    I requested a copy of the inventory used to identify areas of old forest in the woodlot, which Okisollo Resources says had been created for the Ministry of Forests in 2007. Okisollo declined to make the inventory available. 
    Ms Blumel stated that the primary forest her company logged at Hummingbird Lake is not old forest but “scattered old trees” in “second-growth stands.”
    “Second-growth stands” implies an area that has been previously logged. In an old, primary forest on Quadra Island, regrowth of younger trees below the old-growth canopy after a fire is a natural process, no matter how dense or commercially attractive that regrowth appears to be. The regrowth’s presence does not cancel out the biological values of the old forest it’s growing in.
    Blumel did not respond to questions about whether or not, during road building and logging at Hummingbird Lake, the company had encountered any sign—like old stumps and roads—of previous logging.
    So, what is the true nature of the forest that was logged at Hummingbird Lake? Was it old forest?
    Helpfully, the Board’s investigation report included the definition it uses. The report stated: “When we refer to old-growth forests in this report, we mean stands in BC’s coastal forests that are older than 250 years, structurally complex with large old living trees, and that have large dead snags, fallen dead trees and multi-layered canopies.”
    The image below shows what the forest on the north side of Hummingbird Lake looked like in 2018 from above the lake, before logging took place. The forest that is about to be cut is on the right side of the photograph. You can see many living Douglas firs with dead tops, a good indication of great age, a fact confirmed on the ground by growth ring counts of trees cut by Okisollo Resources. There are also standing dead snags visible and a multi-layered canopy with younger hemlock and fir far below the tops of the old-growth. You can’t see them, but on the forest floor are numerous fallen dead trees. On each of my visits I found plants and animals associated with old forest, including Northern Red-legged Frog, Wandering Salamander, Osprey, and One-flowered Wintergreen. This is as “structurally complex” a stand of old-growth forest as I have seen on Quadra Island.

     The west end of Hummingbird Lake in 2018.
    There’s much more of this old forest in Woodlot 2031, none of it identified in Okisollo Resources’ official map. Below is a photograph of Hummingbird Lake looking toward the east end of the lake from just above where Okisollo Resource’s 2019 cutblock ends. Most of the forest visible around the lake is primary forest, including old-growth Douglas fir. None of it has been mapped as old forest.

    The view of Hummingbird Lake and surrounding old forest looking east from approximately where Okisollo Resources’ logging reached in 2019.

    It is also revealing to compare the biological productivity of the extensive existing old forest around Hummingbird Lake with the three small areas Okisollo Resources has mapped as “biodiversity reserves.” 
    The photograph below shows one of those three reserves, this one at the top and on the steep slopes of Wolf Mountain. The forest at the top can’t be logged because it is in a protected viewscape. When the Forest Practices Board praised Okisollo for reserving this forest “even though it didn’t have to,” the Board was wrong. Okisollo had to. But as a biodiversity reserve, how does it compare with the old forest removed by the cutblock at Hummingbird Lake?
    The 5.5-hectare reserve on top of Wolf Mountain is shown in the 2007 inventory as having a site index of 11. That means that because of conditions on the top of that hill, trees would be expected to grow to a height of 11 metres over a 50-year period. On Quadra Island, this is a low productivity site. Such forests support a lower level of biodiversity than more productive forests.

    Wolf Mountain. A portion of the top of the hill and the cliff has been reserved from logging by Okisollo Resources.
    On the other hand, the 2007 inventory estimated that the site index at the Hummingbird Lake cutblock is 24. Site index doesn’t get a lot higher than that on Quadra Island. Such sites are capable of growing big, old trees and they support a higher level of biodiversity. Moreover, big old trees beside a lake support an even higher level of biodiversity, much higher than the small old trees at the top of Wolf Mountain.
    The Forest Practices Board investigation failed to even show up on Quadra Island, let alone carefully consider all the evidence and follow it wherever it might lead. But the deeper failure in this case traces back to the Ministry of Forests’ decision in 2005 to introduce Woodlot Licence tenures into a special management zone. That didn’t happen in any other special management zone created by the Vancouver Island Land Use Plan. It was only by the voluntary compliance of woodlot tenure holders that progress could be made toward meeting the plan’s old forest objectives. Now, at least one of those tenure holders—Okisollo Resources—has decided not to comply. If it is successful at going backward, other tenure holders could follow.
    In a recent 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 Vancouver Island Land Use Plan. 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.”
    At least the Board got that right.

    Related information:
    Forest Practices Board investigation report
    Information about Woodlot 2031
    Vancouver Island Land Use Plan documents

    Ben Parfitt
    In aftermath of a landslide that killed five, experts say government must act now to avoid more “preventable” deaths
    AS 2021 DREW TO A CLOSE, Premier John Horgan said many British Columbians would remember it “as the year that climate change arrived on our doorsteps.” 
    Whether it was the wildfires that made breathing the air a risk and that wiped the town of Lytton off the map, or the unrelenting heat in June and early July that claimed 600 or more lives, or the mid-November rains, floods and landslides that killed at least six people, destroyed homes, farms and businesses and wiped away entire sections of highways and dikes, 2021 was memorable for the chaos unleashed by climatic events. 
    But is it right to ascribe all the devastation to climate change and climate change alone? 
    Yes, more extreme weather appears to be here. And yes, scientists have warned for decades to brace for more as we continue our collective assault on the earth’s atmosphere by relentlessly burning fossil fuels. 
    But climate change alone did not kill Anita and Mirsad Hadzic on November 15 leaving their two-year-old infant daughter an orphan when their car was smashed by a thundering wall of mud, rock and shattered trees on the Duffey Lake Road. 
    Nor is it solely responsible for the death of three others who were unfortunate enough to be on that lonely stretch of road with the Hadzics that night. 
    Where the buck stops 
    The “atmospheric river” that dumped heavy rain on southwest BC last November 14 and 15 may have been the proximate cause, or trigger, of the landslide that took those five lives, but the underlying cause was 730 metres up the mountainside on an abandoned logging road that was not properly deactivated and that failed. 
    Climate change didn’t cause the landslide. Bad land use practices did. 
    To learn more about the devastating landslide, the BC office of the Canadian Centre for Policy Alternatives reached out to geoscientists and engineers, both active and retired, and all with some experience working in or for the provincial government. 
    All three say that while climate change is a clear threat, the more pressing issue is how the government, and in particular the Ministry of Forests, manages key natural resources. They also say that simple things can be done now to set us on a better path:
    Spend a nominal amount of money to rapidly assess what at-risk logging roads are out there.
    Step up inspections of aging infrastructure and prioritize repairs where people are most vulnerable.
    Restore powers to the provincial government to review and approve all logging roads and logging cut-blocks before they happen, rather than relying on industry professionals to make such calls.
    And, use a special stand-alone fund from levies on resource industries to cover the costs of some of that work.
    Failure to do such things, they warn, only courts more death, injury and loss. 
    Not a good place to be 
    It is unlikely that most motorists on the Duffey Lake Road, or any other highway for that matter, know that aging logging roads may be just a short distance away and hidden from view, or that such roads pose risks to those below, especially in mountainous settings. 
    The Hadzics were on one such road not by choice but by necessity. The day before, they had learned that three highways were blocked preventing passage to the populous Lower Mainland. Mudslides and flooding had rendered the Coquihalla Highway between Merritt and Hope, Highway 1 through the Fraser Canyon, and Highway 3 from Hope to Princeton impassable. 
    That left only the Duffey Lake Road (also called Highway 99). The narrow, winding road with its sharp ascents and descents was originally a logging road that later was updated to a highway and features on the website dangerousroads.org. 
    Long-time friends Rob Graham and Brad Beggs were among those on the road that day. The men recall that the further they drove from Lillooet, the worse things got. There were rocks on the road almost everywhere and torrents of muddy water cascading off the surrounding slopes. 

    Tons of mud, broken trees and rock carpet Highway 99 last November, the dangerous road where five people lost their lives in a landslide that engineers say was triggered by a failed logging road. Photo: BC Ministry of Transportation and Infrastructure / Flickr
    “It was not a good place to be,” Graham said. Eventually, they found themselves in a long line of cars forced to stop due to debris on the road up ahead. “The impending doom feeling was hanging in the air big time,” he recalled. 
    The men soon heard a “thundering noise” above them. Beggs turned the ignition, gunned the gas, cranked the steering wheel and had just enough room to swerve around and ahead of the car in front of him. Another driver in a vehicle behind them managed to do the same. 
    The people behind that vehicle were hit by the landslide. Some crawled out of cars that had been flipped upside down. Others emerged from the wall of debris “covered head to toe in mud.” 
    “All you saw was their eyes, their mouths open,” Beggs said, adding that he will “never forget” the terrifying speed and sound of the landslide. 
    Inspection and spending shortfalls 
    Ron Jordens was studying to be an engineer at the University of BC in 1965 when he landed a summer job with the BC Forest Service surveying the road to Gold River. The road was later taken over by the Ministry of Highways as a public highway.  
    “At that time, the Forest Service engineering division was very operational, involved in the planning, location, survey, design and construction of main roads,” says Jordens, who would go on to work for the ministry for more than 30 years. “We had a wealth of experience, knowledge and skills to plan, locate, survey, design and maintain fairly high-standard roads, almost but not quite to the standard of highways.” 
    The road Jordens helped survey was at the time a  Forest Service Road, or FSR. They are the most frequently travelled of all logging roads and additionally are sometimes the only vehicular access into remote communities. They are also the most heavily engineered of logging roads. Today, there are more than 58,000 kilometres of such roads in BC—enough to circle the world almost one-and-a-half times. 
    But it is one thing to build such roads, and a different matter to maintain them. 
    BC’s Auditor General found in 2020 that the Ministry of Forests “did not manage safety and environmental risks on FSRs in accordance with its policies,” and that it also did not properly maintain and repair roads and crossing structures such as bridges and major culverts. Many bridge and culvert inspections weren’t done. And of those that were, half turned up problems that required repairs. But chronic ministry underfunding, averaging $35 million per year, meant that two years or more after problems were identified they still were not fixed.
    Woefully inadequate road inventories 
    Even more problematic are hundreds of thousands of kilometres of “resource roads.” These less-travelled roads may experience steady logging truck traffic for a time before being largely abandoned. The road that failed, killing the Hadzics, was one such road. 
    In 2015, the Forest Practices Board, BC’s independent forest watchdog, estimated that more than 600,000 kilometres of such roads existed. Today, that number is closer to 700,000, or enough roads to circle the earth 17 times. 
    “Where these roads occur on steep slopes, they can cause landslides,” the Board noted in its report, adding that the frequency of landslides increases tenfold in logged areas, and that virtually all such landslides are associated with logging roads that fail, especially in steeper terrain. 
    The highly critical report noted that the government’s resource road inventory was 20 years out of date. The government effectively had no information on an estimated 200,000 kilometres of such roads. Worse, many roads identified by the industry as deactivated were either insufficiently deactivated or not deactivated at all. 
    A wakeup call 
    In a self-described “wakeup call” published two years later, the Board reported on 26 different road segments it examined in steep terrain. In 21 cases, a “qualified registered professional” had been involved in the road design or construction. Yet the Board found: 
    In only 10 of the 21 cases where a registered professional was involved were all legal requirements and professional guidelines met.
    In six of the 26 cases, the road segments were deemed to be “structurally unsafe.”
    And five of those six segments were built “in a manner that did not reduce the likelihood of a landslide or ensure protection of the environment.”
    The Board said this underscored the need for stepped-up provincial compliance and enforcement efforts to ensure public and environmental health and safety. 
    Jordens is not surprised by such findings. He remembers hearing the following definition of a perfectly constructed logging road early in his career. 
    “From a logging point of view, you want to spend the least amount of money for the road that will provide you sufficient access to your last load of logs. The best road is the road that falls apart after you get your last load of logs out.” 
    Government oversight must be there to counter industry cost-cutting, Jordens says. But effective oversight is today largely absent. Twenty years ago, the government replaced the much more prescriptive Forest Practices Code Act with the Forest and Range Practices Act, ushering in a new era of “professional reliance.”
    The professional reliance free-for-all 
    “What professional reliance meant was that if a logging company delivered a plan that was signed by a professional, that’s all the ministry needed to see,” Jordens says. “Cut block and road location planning in the forest was not left up to the ministry. It was left up to the industry and ‘reliance on professionals,’ who normally were not in charge of the road building and logging activities on a day-to-day basis. 
    “It makes me wonder if what is on the approved plan is actually being followed on the ground and is there a mechanism that satisfies forest service staff that the conditions of the plan were followed.” 
    In May 2018, lawyer Mark Haddock submitted a report on professional reliance to George Heyman, Minister of Environment and Climate Change Policy. 
    Haddock spent years prior working as an environmental lawyer in non-profit and academic settings as well as at the Forest Practices Board. 
    In his report, Haddock noted many concerns with the professional reliance regime including how it applies to the Forest and Range Practices Act (FRPA). He concluded that it placed public servants on a reactive rather than proactive footing because so little information was actually transmitted to the government by the logging industry before developments occurred. 
    Haddock noted, for example, that Forest Stewardship Plans submitted to the government by logging companies were exceedingly broad and covered large areas of land—in the most extreme cases, two times the size of Vancouver Island. Absent from such plans were specific details on where new roads and logging cut blocks were to be located. 
    What FRPA did, Haddock said, was place “high levels of dependence” on professionals outside of government to make key decisions. Government engineers were effectively cut out of approving where roads and cut blocks were located and a reduced complement of ministry compliance and enforcement staff was left to monitor such developments after the fact. 
    “It took away the ability of ministry professionals to identify or review problems associated with harvesting activities on unstable or sensitive slopes and resolve those problems before the industry went into those areas,” Jordens says.
    “Roads are the worst culprits when it comes to sedimentation, debris torrents and landslides, particularly on the coast. If we want to manage, conserve and protect our forests—which is what we are supposed to do under the Ministry of Forests Act—we need to retain control because it’s questionable whether the current model of professional reliance can achieve that.”  
    A gut feeling 
    During a news conference on November 15 as the scale of flood-related damage became more apparent, Public Safety Minister Mike Farnworth was asked about the plight of motorists stranded on highways cutoff by landslides. 
    “Landslides, as you know, are unpredictable and they happen,” Farnworth said. 
    But two professionals with expertise in landslides and road failures say that landslides and improperly built or decommissioned logging roads go hand in hand, and that tragic outcomes like those on the Duffey Lake Road are the result. 
    Pierre Friele is a professional geoscientist with 30-years experience in the forest sector, predominantly in the South Coast Forest Region, where he has worked  under contract for the Ministry of Forests out of its Squamish office. Friele suspected almost immediately that those killed on the road late last year died because a logging road high above them failed. 
    “I just had this gut feeling,” Friele said in an interview. “So I got this local avalanche guy who was doing a flight to take some pictures.” 
    When the avalanche expert returned with the photographs, Friele said his suspicion was confirmed. 
    The aerial evidence was not enough for Friele, however. Eight days after the deaths, he elected to walk into the remote area before further rain or snow altered evidence of what happened. “I’m the only person who has seen it up close,” he says. 
    Friele found that the road had been only partially deactivated. Deactivation can include many things such as breaking up the road surface to disperse water runoff during the winter season; or, where regular use is not required for several years, by removing culverts and installing cross ditches; or in the case when a road is no longer required for industrial use, by removing all culverts and bridges and pulling back fillslopes in steep terrain. Such work, if done promptly and properly, reduces the risks of future landslides. 
    While there was evidence that culverts had been pulled out and cross ditches had been cut through the road surface to restore more natural water flows, much of the massive amount of rock and soil pushed to the roadside during road construction, known as fill slope, remained unaddressed, Friele found. 
    And that was a problem, because over the years that untouched mass of earth and rock began to gradually fail in increments. Several small failures resulted in sections of ditch lining the old road becoming blocked. The blockages then caused water to flow onto the road surface in ways that weakened it causing the fillslope to eventually fail. 
    Because the road was abandoned, “these small slides and the associated water misalignment were never identified and corrected,” Friele concluded, adding that failure to deactivate the road properly before it was abandoned led ultimately to the fatal disaster.
    In a report he subsequently wrote on his findings in the field, Friele said  “failures on legacy forest service roads are common enough that those of us practising in the forest sector have been called to forensically investigate a number of them during our careers. Luckily, fatalities have been few, until this recent event, which has brought the issue to the fore.” 
    Foreseeable and preventable 
    Calvin VanBuskirk is a professional engineer and 30-plus year member of the Engineers and Geoscientists of BC. Like Friele, he too suspected that the Duffey Lake Road slide was not a natural event. 
    Shortly after the slide, he reviewed aerial images from the University of BC’s air photo library. The images showed the logging road had been built in the 1960s and abandoned in the 1990s. The photos also suggested that the road had altered natural drainage patterns, redirecting water onto marginally stable areas that were prone to failure. 
    In a letter he subsequently sent to Mike Farnworth, Forests Minister Katrine Conroy and Transportation and Infrastructure Minister Rob Fleming, VanBuskirk did not mince words. 
    “It is my professional opinion that the 15 November 2021, tragic, fatal landslide event northeast of Duffy Lake on Highway 99 was both foreseeable and preventable. 

    Engineer Calvin VanBuskirk at site of roadway that washed away in Saanich during November’s storms. People consistently fail to appreciate the power of water, he says. Photo: Ben Parfitt.
    “The landslide initiated on a resource (logging) road constructed in the late 1960s… It appears that the road was not deactivated and has not been inspected or maintained for decades… Had this area been subject to inspections/monitoring, the potential for this landslide could have been detected and appropriate measures… implemented to manage the landslide risk.” 
    Adding weight to VanBuskirk’s conclusions is a work record that includes years spent in the field doing landslide hazard and risk assessments on resource roads for numerous forest companies including Riverside, Canfor, Bell Pole, Tolko and Interfor, as well as work for the provincial Ministry of Forests and its timber-auctioning arm, BC Timber Sales. 
    We’ve been here before 
    In 2003, VanBuskirk co-authored a technical report for the Ministry of Forests that examined the underlying causes behind a spectacular occurrence of 66 landslides over a three-day period in June 1990. The devastation occurred in an extensively logged area east of Enderby in the north Okanagan, known as Fall Creek. An estimated $8 million in damage occurred due to debris hitting homes, vehicles, hydro transmission structures, battered water intakes and a section of highway. 
    Of note, the area studied was only equivalent to about seven Stanley Parks in size yet was crisscrossed by at least 100 kilometres of aging logging roads. 
    VanBuskirk, and fellow geoscientist Freeman Smith, concluded that the likely cause of most of the slides was “drainage diversions.” In other words, water that was forced to flow in unnatural ways because of the old, improperly decommissioned roads, many of which were overgrown with brush. Those unnatural flows led quite naturally to landslides. 
    Significantly, the duo concluded that the old Forest Practices Code, which was jettisoned in favor of today’s laissez-faire forest legislation, “would likely have prevented many of these slides”. 
    In addition to flagging the Fall Creek fiasco in his letter to the cabinet ministers, VanBuskirk noted that June 1990 also saw a couple and their daughter killed in the Kelowna area by a mudslide following heavy rainfall. 
    That same summer heavy rainfalls triggered a mudslide near Vavenby in the North Thompson region that killed one man, and four tree planters were killed when their vehicle plunged off a washed-out wooden bridge into the swollen waters of George Creek, southeast of Prince George. 
    At-risk highway corridors 
    Like VanBuskirk, Friele has investigated landslides. He has seen that a lot of old logging roads were not put to bed the way they should be and now the government has a big problem on its hands. 
    “We end up with this situation where the companies didn’t fully deactivate (roads) but the government didn’t really oversee the system properly. And they’ve now taken over the land,” Friele says. “Now it’s the government’s problem.” 
    Fortunately, for the province, many landslides triggered at old logging roads are far removed from human populations. But as the deaths at Duffey Lake underscore, logging roads can come very close to highways and vulnerable communities. 
    That’s why Friele advocates a targeted, proactive approach to reducing landslide risks. If he were making the call, he would prioritize highway corridors. 
    “Above Highway 1, in the Hope-Chilliwack area, there’s roads that are above the highway on the south side. The Trans-Canada Highway is constantly getting blocked. And a lot of those mudflows are related to old logging roads. And nobody’s been killed there. It’s quite amazing. There are mudslides almost every time it rains.”
    A tremendous disregard 
    The damage unleashed by last November’s heavy two-day downpour extended well beyond old logging roads to major highways used by tens of thousands of motorists every day as well as less frequently travelled city and suburban streets. 
    Like logging roads, more frequently travelled roads are highly vulnerable to damage by water, which is why the design, location, inspection and upgrading of critical drainage infrastructure like culverts are so important. 
    One of the less high-profile roads to fail last November was Chalet Road on the Saanich peninsula, not far from VanBuskirk’s home outside Victoria. A commuter travelling the road that morning drove through about eight inches of water flowing over the road at a creek crossing. By the time she got to work and phoned the municipality to alert them, the road section was gone. 
    Three months later, VanBuskirk travelled to the site to explain what had happened. Ducking below a line of yellow warning tape, he walked to the edge of the deep trench that severed the roadway. Typically, the creek below ran through a small 800-mm culvert underneath the road, he explained.  
    But as the rains fell last November, VanBuskirk said the creek level rose rapidly to four metres, or five times the height of the culvert. With the culvert overwhelmed, the only thing holding back the rising wall of water was the roadbed itself, which had effectively become a dam. But the road hadn’t been built to be a dam and it failed. 
    “When the road embankment gave way, it sent a wall of water down that channel that was estimated to be 30 feet wide and up to 10 feet deep. And it plucked chunks of rock off the bedrock surface—I measured one that was 18-inches thick, two-and-a-half-feet wide and just under five-feet long—and thrust it up into the trees. It was really impressive,” VanBuskirk said. 
    “What’s going on with logging roads, with culverts, with highways, with streets, with everything, is, unfortunately, a tremendous disregard for how powerful water is and for the speed at which things can be swept away.” 
    VanBuskirk, who has been hired to design the new creek crossing on Chalet Road, will be replacing that small culvert with a geotextile, reinforced soil arch that is more than four metres wide at its base (over five times that of the existing culvert) in anticipation of the heavy rains and high water flows that will inevitably come. 
    “An enormous amount of water can flow through a culvert. But when there’s more water than the culvert can handle, that’s when it becomes a problem. That’s when it washes out,” he says.
    “Let’s take a look.” 
    Friele, Jordens and VanBuskirk all say that one takeaway from last November is that government needs to arm itself with relevant information and then act. Where will more slides likely occur? What culverts and bridges may be most vulnerable? What repairs or reclamation needs to be done? 
    “Let’s take a look. Let’s fly these drainages and see where these landslides initiated,” Jordens says. “Let’s take a helicopter flight and go right to the source. Where did these landslides start? And if they started at old roads or in logged-over areas, how can we improve our practices?” 
    Helicopter flying is expensive, but sometimes necessary. Other technologies exist, however, that are relatively cheap and can provide valuable information quickly over large areas. 
    “We have tools in our toolbox that have come about in the last 10 to 20 years and they are very economical as well,” VanBuskirk says. “One of them is LIDAR, which is the airborne mapping system that you can use where you can pick up extremely detailed topographic information for basically a buck or so a hectare or less. The province of Alberta has done their entire province. BC, from what I can see, has very little of the province covered.” 
    VanBuskirk would also like to see the government use LIDAR data to help produce “detailed topographic and flow accumulation maps” that can be used to identify where the greatest landslide risks are. 
    “The cost of this work is likely much less than the costs of the resource-road-related damage caused by this single landslide event on Highway 99,” he adds. 
    Rehabilitating lands damaged by previous logging and road-building activities will be expensive. However, it is something the government has spent money on in the past and the results strongly suggest it was money well spent.  
    In the 1990s, under the direction of the now-defunct Crown corporation, Forest Renewal BC, hundreds of millions of dollars were spent on “watershed restoration” projects following logging. Significantly, it was the logging industry that ultimately paid for this work through higher timber-cutting or stumpage fees imposed on them by the government. 
    Between 1994 and 1999, a total of $302 million was spent on restoration work, much of it involving road deactivation—work that both improved water flows in damaged valleys, thus benefiting salmon and other species, and made things safer.
    “Both the government and companies were identifying old road systems and having them deactivated,” Friele says of those years. “There was a huge program of deactivation that went on for close to a decade. And then the Liberal government came in and just canned everything.” 
    Since then, successive governments have failed to restore such funding, meaning the costs of rehabilitating roads like those that killed the Hadzics last November are rising. 
    Government either bites the bullet now and recommences that work—or risks more preventable tragedies ahead.
    Ben Parfitt is a resource policy analyst with the Canadian Centre for Policy Alternatives, and a longtime investigative writer.

    Ben Parfitt
    More than the climate crisis was behind last November’s rising waters, death and destruction; experts urge province to make course correction.

    The catastrophic flooding in Merritt in November 2021 occurred after a rainfall similar to previous precipitation events that didn’t cause flooding. The difference? Professional hydrologists implicate logging, forest fires and snowpack in the nearby Coldwater River watershed. 
    WHEN PREMIER JOHN HORGAN declared a provincial state of emergency in the wake of last November’s horrific floods, landslides and deaths, he was quick to name the culprit. 
    The “never seen before” flooding in southern British Columbia was a direct result of “human-caused climate change,” he said, adding that such floods were “increasing in regularity” thanks to our unceasing use of fossil fuels. 
    But climate change alone didn’t account for the numerous highway washouts, the lethal landslide that killed five on the Duffey Lake Road, the thousands of people displaced from their damaged or destroyed  homes, the dikes and sewage treatment plants overwhelmed by the rising waters, and more. 
    Other important factors combined to turn last November’s deluge into the monster it became.  
    Heavy two-day rainfalls similar to those of late last year have occurred in the past without triggering the horrendous damage witnessed in November 2021. Not one, but many things conspired to cause such destruction.
    The essential public policy questions now are what lessons the government learns from last year’s events: 
    Are there things it can easily do now to more accurately anticipate what troubles lie ahead and therefore provide robust early warnings to vulnerable communities?
    Can it better regulate industries known to play a role in increased flood frequencies, such as the logging industry?
    And finally, what can it do to better incorporate knowledge about climate change-related events such as wildfires into flood forecasting models so that   more timely and effective warnings can be given to communities that may be in harm’s way?
    Deflecting accountability 
    One person who has pondered such questions since November’s events is Allan Chapman. A long-time professional hydrologist, Chapman once headed BC’s River Forecast Centre, the critical front-line agency tasked with warning the public and vulnerable communities about flood risks. 
    He says the premier’s invocation of climate change and climate change alone “deflects accountability for failures within government.” 
    The potential for last year’s rains to trigger extensive flooding, particularly to lands damaged by wildfires, was foreseeable, Chapman believes, and had only a partial connection to climate change. Other factors like extensive logging and logging roads in key river valleys, or the accumulated snow in mountains that rapidly melted in the face of the rain, were both known risk factors that had nothing to do with climate change at all.
    Given the prospects for increased flood severity due to wildfires and logging or the presence of snow in watersheds forecast to get a lot of rain, Chapman says flood forecasting and emergency planning staff in the provincial government had all the information they needed to issue early warnings to vulnerable communities about the potential for dangerous times ahead.
     Chapman first publicly voiced concern about the government’s response to last November’s heavy rains a couple of weeks after the event after analyzing the forecast centre’s actions in the lead-up to the floods. He said then that weather and streamflow data readily available to professional staff at the agency should have resulted in them making higher-level warnings far earlier than they did. 
    Since then, the provincial government has been named in a class action suit, in part for failing to adequately warn residents in the Sumas Prairie about the impending flooding, which resulted in thousands of farm animals being killed, some of the best farmland in the province being contaminated and farm buildings and machinery destroyed. 
    Chapman has since looked more closely at various data to try to make sense of what happened in mid-November. His review included rainfall data, water flow data in streams and rivers proximate to the flooding, snowpack data in key watersheds and significant land-use disturbances in the watersheds closest to where the flooding occurred. 
    He has detailed his findings in a 22-page report that he sent to provincial Ministry of Forests hydrologists. The River Forecast Centre is housed in the ministry that is responsible for ensuring the safety of dikes, for managing forest industry activities—including logging and road-building on public lands—and for dealing with wildfires. 
    Chapman also submitted a lengthy letter summarizing his findings to Forests Minister Katrine Conroy. 
    One of Chapman’s key findings is that the intense rains of last November were unquestionably large, but in keeping with other heavy rains of previous years. 
    What happened in November was, in many ways, a classic “pineapple express” or, as it is now more frequently called, an “atmospheric river.” 
    At some Environment Canada weather stations, including Abbotsford, Aggasiz and Hope, the rainfall recorded for a single day was a record. But the rainfall accumulations over the two days of the storm were not. 
    “Other major and similar storms appear in the record in October 2003, November 1990 and a few other years. The data lead to the conclusion that although the rainfall on  November 14 and 15 was certainly large, it was not unprecedented and should not have been unanticipated” Chapman reported. 
    Beyond extreme 
    It is what was layered on top of all of the rain that became the issue.
    A pineapple express delivers lots of rain simultaneously with warmer temperatures. If such events are preceded by snow accumulating in the mountains, that can be a big problem. During atmospheric river or pineapple express storms, temperatures warm and the freezing line rises as the storm front passes over. The warmth and rain turn much or all of the snow below the freezing line to water. 
    Chapman’s report looked at data from several “snow pillows” (sites where snow depths are measured) and weather stations operated by the BC government, and documented how the rapid melting of accumulated snow substantially augmented the rainfall water, increasing peak flows in key rivers. 
    He concluded that “the water contributed by snow melt” in the critical 48 hours beginning on November 13 and carrying through November 15 was half as much and possibly equal to all of the volume of rainfall at some measurement locations and was “a significant contributor to the severity of the river flooding,” particularly in the Merritt area. 
    This meant that on critical rivers such as the Tulameen, Nahatlatch and Sumas, peak water flows were in the range of what might be expected every 300 years. 
    But this was nothing compared to the peak flows on the Coldwater River. Based on water gauge readings on that river both at Brookmere and Merritt, Chapman found that the peak flows were “beyond extreme,” possibly reaching levels seen only once every 1,000 years. 
    Corresponding data for the Nicola River were not available in real time, Chapman noted. But by looking at readings from gauges in the nearby Coldwater, Chapman estimated that the Nicola’s peak flows were between 700 and 1,000 cubic metres per second—enough water to fill an Olympic-size swimming pool roughly every three seconds. That put the river’s peak flows at levels possibly 2.5 times higher than the previously highest recorded levels, based on 59 years of measurements. 
    “The rainfall was large, but not unexpectedly large based on the historical record,” Chapman says. “It was the rain on snow that proved to be so significant.” 
    And that, Chapman says, should not come as a surprise to anyone in the flood forecasting community. He explains that the historical data available show that “all the floods of record” in the Coldwater, Tulameen and Similkameen river valleys “result from October-January atmospheric river rain storms, and this combination of heavy rain and snowmelt. The November 13 to 15 storm, although extreme, should not be considered unusual in this regard. It is the standard flood-causing mechanism for these rivers.” 
    A burning issue 
    The “beyond extreme” water level on the Coldwater River was bad news for Merritt’s 7,000 residents. The town’s sewage treatment plant—like many such plants throughout BC—is on the floodplain. 
    In a cascade of events, the plant was overrun by floodwaters, its contaminated sewage then mixed with the floodwater which in turn contaminated groundwater wells used to supply local drinking water as well. 
    The evacuation of the town’s residents was inevitable under such circumstances. 
    Heavy rain on snow—a phenomenon well understood by hydrologists—elevated the severity of the floods. But it was not the only reason flooding was so severe. 
    Foresters and climate scientists know that temperatures are creeping up and more forests are becoming drier and susceptible to burning. 
    Mike Flannigan is an award-winning researcher and internationally recognized expert on wildfire behaviour who works at Thompson Rivers University where he is the new BC research chair in predictive services, emergency management and fire science.   
    He has long warned that wildfire seasons are starting earlier, extending later into the year and that BC along with Canada as a whole are witnessing “significant increases in the area experiencing high to extreme fire danger.” He would like to see the provincial and federal governments produce “risk maps” that clearly spell out where danger may be imminent due to wildfires and floods, especially for northern, more-remote rural communities, both Indigenous and non-Indigenous. 
    SparksGeo is a Prince George-based company whose geospatial analysts work with satellite data. In April, the company released a report suggesting a connection between the intense wildfires that burned in 2021 and subsequent flood-related destruction, particularly in the highway corridors where some of the most severe road damage occurred. 
    While it cautioned that “the causes of flood damage are complex and involve the interplay of many different environmental and engineering variables,” the company said the satellite imagery suggests a compelling correlation between the fires and the floods. 
    Given that apparent correlation, the company said it makes a lot of public policy sense to use satellite imagery and other knowledge of where wildfires have occurred as a tool to better protect the public in scenarios where there may be increased risks of flooding. 
    “It seems clear that accurate and timely mapping of wildfire damage is an important part of being able to assess the risk that severe flooding poses to our settlements and critical infrastructure,” the SparksGeo report concluded.
    Letting communities in harm’s way know of such risks well in advance would give them a chance to proactively invest in flood-protection infrastructure and reduce the likelihood of last-minute, frantic scrambling as was the case in Abbotsford last November when the Barrowtown pump station was only prevented from being overrun by rising floodwaters by the heroic, last-ditch efforts of a volunteer sandbagging crew.
    Merritt was never given that opportunity. But in 2007, the community of Terrace was.
    That year there was widespread fear that major rivers like the Skeena in the Terrace area and the Lower Fraser could overtop causing extensive damage. The culprit was a huge snow pack that Chapman and others predicted had the potential to cause extensive damage.
    Forewarned with that knowledge and the assistance of $200,000 in provincial and federal funds, Terrace armoured its sewage plants treatment lagoons with tons of additional rock as well as digging a deep 100-metre-long trench and filling it with rock to prevent the Skeena from encroaching on and destroying the multi-million dollar facility. The funds were part of $33 million made available by both governments to communities deemed to be in harm’s way that spring.
    Unprecedented behemoth 
    Three of the most-intense wildfires detailed in the SparksGeo report were the July Mountain, Lytton Creek and Tremont Creek blazes. Chapman considered all three in his report and found the significant areas of land burned in each amplified the flood risk. 
    His analysis is that the July Mountain fire burned 26 per cent of the Coldwater River watershed at Brookmere and 16 per cent of the Coldwater River watershed at Merritt. That fire, combined with those at Lytton Creek and Tremont Creek, burned a further 13 per cent of the Nicola River watershed at Spences Bridge. 

    Shortwave infrared satellite image of the July Mountain Fire (reddish brown area). The Coldwater River snakes along the fire’s lower edge on the left and then punches through the centre of the burn as it heads toward Merritt.

    SWIR image of the Lytton Creek Fire. The Fraser River is on the left. The Nicola River can be seen cutting through the eastern section of the burned area on the right as it heads for the Thompson River.

    SWIR image of the Tremont Creek Fire. Kamloops Lake can be seen in the upper right corner, the Thompson River on the left.
    One effect of such fires is to blanket once-absorbent forest soils with a wax-like coating—a result of chemical changes that occur during and immediately after fires. This can make them “hydrophobic” or water repellant. 
    In an interview, Flannigan said that wildfires can have profound consequences as far as water runoff is concerned. 
    “Some studies suggest as much as seven times more water flow between a forested watershed and a burned or harvested [logged] watershed,” Flannigan says. “Of course, it depends on many factors, but it is not unusual to see that kind of increase.” 
    He added that in the case of “hydrophobic ash,” it acts “almost like cement. The water just runs straight down based on gravity, no absorption.” 
    In his report, Chapman says the extensive area of land burned in key areas played a “compelling role” in the flooding that followed and that knowledge of where wildfires occur in future years and their proximity to vulnerable communities must become part of the flood forecasting and emergency planning regime. 
    “It is probable that these fires were major contributing factors, taking what would have been a large rain and snowmelt flood and creating an unprecedented behemoth catastrophic flood with a 1000 plus--year return period,” Chapman wrote. 
    Chapman notes that forest fire data are provided by the Northwest River Forecast Center in Portland Oregon as part of their flood forecast information for Washington and Oregon, but that similar information does not seem to be considered in BC. Flood forecasting and the models used to predict site-specific flood threats would be dramatically improved, in Chapman’s opinion, if two things happened: 
    The Ministry of Forests clearly recognized the vulnerability that certain communities face in the event of rain-on-snow events and built that knowledge into flood forecast models.
    The ministry ensured that information on areas burned by wildfires be built into such models as well and be considered as a key risk factor when deciding when and where to issue flood warnings. This would involve much more information-sharing between water and wildfire experts spread through a very large ministry.
    Such changes become even more crucial with climate change, something the provincial government was specifically warned about in 2010 by Jim Mattison, a long-time civil servant and formerly the provincial government’s top water official. 
    In a report  that he wrote as a consultant that year, Mattison noted climate change was starting to “affect the lives of citizens every day.” This demanded improved and more-effective forecasting, he said, which was one reason he advocated for more than doubling of BC’s Forecast Centre staff. Today, 12 years after his report was submitted, staffing levels stand at six, one more than they were when Mattison issued his report and six positions below the 12 he said were needed.  
    Mattison also warned that not enough data were being used by Forecast Centre staff to plug into their predictive flood models and therefore the models were “limited in their ability to provide accurate flow forecasts.”
    In its 2022 budget, the provincial government indicated the River Forecast Centre and provincial floodplain mapping programs will be expanded.
    The logging industry and flooding frequency 
    The word anthropogenic has been joined at the hip with climate change because unlike previous dramatic shifts in the earth’s climate going back hundreds of millions of years, today’s shifting climate is being driven by human activities. 
    But there are also more immediate human activities to be concerned about. One of the biggest in a mountainous, once extensively and naturally forested province is clearcut logging and related road-building activities. 
    In recent decades, logging rates have accelerated to unprecedented levels, particularly in BC’s vast interior region, where the provincial government actively encouraged the logging industry to dramatically increase logging rates starting more than 20 years ago.
    The pretext for what became known as “the uplift,” was that mountain pine beetle populations had exploded in number thanks to generally warmer winters and killed tens of millions of lodgepole pine trees - the most prevalent tree species in BC’s interior region. 
    “Salvaging” those dead trees before they lost their value became the goal, with the government giving industry the green light to log an additional 11 million cubic metres of trees per year. But turbo-charging logging rates had serious ecological and hydrological consequences as droves of healthy, living trees were cut down along with the beetle-attacked ones. By the time all this bonus logging was done, up to 63 million cubic metres of additional trees were logged, enough to fill a line of logging trucks bumper to bumper from Vancouver to Halifax five times over.
    Timelapse images of logging in the Coldwater River Watershed, including an area burned by the July Mountain Fire in 2021.
    Not surprisingly, by the government’s own admission logging rates are now poised to crash, much like the ecosystems that once supported healthy forests. 
    Younes Alila is a hydrological engineer and professor at the University of BC who specializes in forest hydrology and watershed management issues. Over years of study, he has concluded that “the flood regime in BC is super-sensitive to disturbances of any kind,” including logging activities, wildfires and climate change. Such disturbances are likely to result not just in the increasing severity of future floods but in their increased frequency. And their impacts, Alila warns, will be long-lasting. 
    “British Columbians are in for a hell of a ride for decades to come,” he predicts.
    In the 1990s, when he joined UBC’s Faculty of Forestry, Alila recalls there were limits on the amount of logging that could occur in any one watershed, the limits generally 25 per cent. But that subsequently went out the window in the logging free-for-all that followed. 
    “That threshold is not used anymore,” Alila said during an interview with CBC Radio a few weeks after last November’s floods. “Over the last 20 years, we have been  clearcut logging watersheds across all sizes by as much as 40 per cent, 50 per cent, 60 per cent and even more, which, of course, increases substantially the risk of flooding. My research shows that the flood regime is highly sensitive to clearcut logging in both small and large watersheds. As little as 20 per cent logging in large watersheds causes a 20-year, a 50-year and a 100-year flood event . . .  to become four to 10 times more frequent.” 
    A sensitive and fragile flood regime 
    “Entire ecosystems,” are being impacted by logging at such a scale, Alila warned, noting that if you could drop a hat out of an airplane flying over parts of the province today there is a 90 per cent chance it would fall in an area of forest that had been logged. 
    Alila says that restoring more natural water flows in logged BC Interior forests takes a very long time. In the first 20 years following logging and replanting, only 20 per cent of the “hydrological functionality” is restored. (Logging roads and the threats they pose to landslides and altered water flows are discussed in a second piece that focuses on the tragic deaths of five people on the Duffey Lake Road during last November’s heavy rains.) 
    “The way that we have been logging and increasing the cut rate and increasing cutblock size in my opinion does not reflect an industry or even a government that appreciates how sensitive and how fragile the flood regime in BC is to land use change and global warming,” Alila told CBC’s Chris Walker, adding that nothing less than a “complete paradigm shift” is needed to the way we manage forests. 
    In his analysis, Chapman also focuses on logging and related logging road densities in the Coldwater, Nicola and Tulameen river basins. His conclusion is that “there is a strong possibility for historic forestry activity to be associated with the extreme peak flows in those rivers and the flood-related damage to follow. 
    “Clear-cutting and forest fires encompass 35% of the basin of the Tulameen River at Princeton, and 41% of the basin of the Coldwater River at Merritt. Road densities are also very high at 1.85 km/km2, and 1.5km/ km2, respectively in the two basins, potentially augmenting the rapid movement of storm rainfall into stream channels, causing peak flows to be increased,” he wrote. 
    Alila subsequently outlined numerous things he feels must change in revised provincial forestry legislation. 
    An overhauled system should require a watershed assessment to be done prior to logging permits being issued. This includes projections of how logging may impact such things as floods, droughts, landslides and water yields, as well as considering the impacts of logging against the backdrop of a changing climate, Alila says. 
    He also recommends that thresholds be reinstated placing strict limits on the overall area of forest in a watershed that can be logged and that priority should be given to community watersheds, which are often critical to the provision of clean drinking water, watersheds with high fisheries values and large watersheds that drain into urban and semi urban areas, some of which may be on floodplains and therefore extremely vulnerable to flood-related damage. 
    “We cannot continue to log as if there is no connection between what we do to the landscape in the upland and downstream lowland values, especially when human lives and costly infrastructure are in harm’s way,” Alila says. 
    He would also like to see the important hydrological functions performed by forests embedded into the critically important allowable annual cut decisions made by the province’s chief forester. 
    Those decisions set the maximum logging threshold in various timber supply areas in the province and, in Alila’s view, have never properly accounted for the important hydrological role played by forests or how long it takes logged forests to recover once they have been logged. If such accounting happened, less forest would be logged.
    Cumulative impacts 
    Lastly, Alila says successive governments have failed to grapple with the outstanding issues of cumulative impacts of multiple industrial operations—logging, mining, natural gas—in watersheds over time.
    “For decades, no considerations have been given in BC to cumulative effects of land use,” Alila writes, noting that cumulative effects can apply to the forest industry itself, as is often the case because many logging companies may operate at the same time in the same watershed “with little or no coordination” from the government. 
    “In a nutshell, forest management in BC has never been conducted in ways that portray an appreciation of the value of forest cover in maintaining the overall health of the ecosystem,” he says. 
    In northeast BC, the overall health of the forests was understood by First Nations in the region because from one generation to the next they hunted wildlife, caught fish, trapped fur bearing animals, harvested berries and gathered medicinal plants. 
    When their leaders signed Treaty 8 in 1899, the agreement recognized the rights of First Nation members to continue to be able to hunt, fish and trap as before. 
    More than a century later, when members of the Blueberry River First Nation realized how multiple industrial developments—including clearcut logging, hydroelectric dams, natural gas drilling and fracking operations—had so fragmented their lands that they could no longer carry out their treaty-protected rights over much of their traditional territory, they went to court. 
    In a landmark decision last year, the BC Supreme Court ruled the provincial government had unjustifiably infringed on their rights through the cumulative effects of numerous government-approved industrial developments. The ruling effectively brought a great deal of industrial activity in the Nation’s traditional territory to a standstill, pending a court-ordered negotiation between the provincial government and the Nation. 
    The Supreme Court decision may only foreshadow what is to come. In addition to being named in the class action suit in Sumas Prairie, another class action naming the provincial government has been launched by citizens in the Grand Forks area who were flooded out of their homes a few years ago, and who blame the cumulative impacts of government-approved logging and logging road developments in the Granby and Kettle watersheds for the devastation that befell them. 
    Years of approving one industrial development after another and disregarding cumulative impacts are coming back to haunt the provincial government in a big way as residents, businesses and Indigenous and non-Indigenous communities alike across the province deal with the fallout. The bills for the destruction wreaked last November now approach $9 billion, and who knows what costs may be added into the mix as a result of the class action suits the government now faces. 
    Climate change is making a bad situation of the government’s own making even worse. Highlighting, again, the need for corrective action.
    Ben Parfitt is a resource policy analyst with the Canadian Centre for Policy Alternatives, and a longtime investigative writer.

    David Broadland
    In the last two years, the cost of hidden subsidization of BC’s logging industry has been greater than the industry’s contribution to BC’s GDP. And it's going to get worse.
    IN 2020 I WROTE A STORY titled “Forestry doesn’t pay the bills, folks.” It looked at the costs and revenues of the ministry of forests over a 10-year period and found that, over that time, the ministry spent about a million dollars a day more than it took in through stumpage revenue and the BC Logging Tax.
    While many people appreciated that analysis, others found it flawed. The skeptics noted that costs were based on entire ministry costs, not just forest-related costs. The Ministry of Forests, Lands, Natural Resource Operations and Rural Development, they believed, had many costs that were not related to forest management. Take those out and the picture would change, they hoped. Others noted that my analysis didn’t include export, corporate or municipal taxes paid by forestry companies or the income taxes paid by forestry workers, and so forth.
    Others observed that the analysis didn’t include costs such as the $24 million paid by the community of Peachland, which needed to install an expensive water treatment facility to take out the sediment that clearcut logging has introduced to its watershed; it didn’t include the estimated $100 million cost to the community of Grand Forks where flooding attributed to logging in the Kettle and Granby watersheds has cost people their homes and overturned their lives. Nor did it include the cost of fisheries lost as a result of increased sedimentation and rising water temperatures caused by clearcutting over 250,000 hectares of forest each year. And so on.
    In other words, there were two kinds of objections: 1. You didn’t credit the forest industry for all the revenue it provides for government, and 2. You didn’t include all the costs.
    This is an update of my first analysis, starting with the objections about not including all the revenue to government that the forest industry generates. I am interested in your objections to this report. I’ll include them when I update this story down the road. So let’s start with a brief reexamination of the numbers in my first report.
    The forest management subsidy
    Although the ministry publishes an Annual Service Report that provides generalized breakdowns of costs and revenues, it doesn’t specify which are forest-related expenses and revenues. So I filed FOIs with the Ministry of Forests, Lands, Natural Resource Operations and Rural Development aimed at clarifying what ministry revenue and expenses were forest-related. The documents released (attached at end of story) show the vast majority of its expenses are forest-related. The ministry’s account of its forest revenues increased the value of those revenues slightly over what I had estimated from their Annual Service Plans. In the graph below I show the net deficit for each year, 2010 to 2019. The cumulative operating deficit of the ministry over 10 years was $3.44 billion rather than the $3.65 billion identified in my earlier story. That works out to $942,466 a day.

    Taxes paid by workers and corporations don’t pay ministry bills, they pay for services used
    So what about the question of the personal income taxes paid by forestry workers and the municipal and corporate taxes paid by forest companies? Shouldn’t those be included, somehow, in determining whether “forestry pays the bills”?
    The ministry of forests, of course, doesn’t include corporate or municipal taxes paid by forestry companies or the income taxes paid by forestry workers in its reckoning of revenue, and for good reason. In each case, the taxes collected by some level of government, like municipal taxes collected from a sawmill operating within a municipality, or income taxes collected from a feller-buncher operator in Quesnel, go to pay for a host of services provided by that government that have nothing to do with the ministry of forests. These are services that are consumed, in part, by that sawmill or that feller-buncher operator.
    For example, the healthcare services provided to residents of a community with a mill operating in it are paid for by such revenue streams as corporate and income taxes. When the feller-buncher operator needs a hip replacement as a result of a work-related injury, the cost of that surgery is paid for by such government revenue streams. When the home of the head sawyer at the local sawmill is burglarized, the police that investigate are paid for by such revenue streams. The mill manager’s children are educated in a school that is partly funded by property taxes collected by the municipality, including from the mill. Forestry workers, and the companies they work for, aren’t just paying for government services through their taxes. Like the rest of us, they are also consumers of those services. Their taxes pay for their own use of myriad government services, just like every other kind of taxpayer.
    By the way, for various reasons, people who live in forestry-dependent communities have notoriously high health costs compared with urban populations.
    In general, all the arguments from the forest industry and its supporters about how much they contribute to the provincial economy are half true; they always fail to include in their analysis all the costs to government that are incurred to keep them housed, warm, fed, clothed, educated, employed, policed, healthy, mobile, governed and defended from enemies, both internal and external.
    The same principle applies to corporate income taxes. Those taxes go to pay for a host of government services those corporations consume, as well as the cost of the burdens their operations impose on the rest of the community.
    All workers and corporations in BC pay taxes, not just forest industry workers and corporations. In fact, in 2019, 98.2 percent of the workers in BC who paid taxes were not forest industry workers. Only a tiny fraction of BC companies that paid corporate income taxes were forestry companies.
    Another aspect of the ministry’s costs that people questioned was the “direct fire management” cost, the cost of fighting forest fires. To what extent is this cost actually attributable to the logging industry?
    All of BC’s largest fires in 2021 included large areas of clearcuts and plantations. Those clearcuts and plantations raise fire hazard to “high” for up to 30 years. They create fuel conditions in which fires are easier to ignite and harder to control, and so we are experiencing larger fires more frequently than would be the case had there been no logging. Moreover, much of the money spent fighting those fires is paid to logging companies and allied businesses. The logging industry needs to man-up and acknowledge its role in causing and benefitting from these fires. Forest fires destroy structures, damage community economies, harm human health and kill people. None of those costs have been included in the ministry’s accounting of “direct fire management costs,” and so attributing all of the ministry’s cost of fighting forest fires to the logging industry is likely a significant undercount of the true costs.
    Now let’s consider some of the costs I left out of my first analysis. Here, there’s plenty of room for improvement over my previous assessment.
    What constitutes a subsidy?
    First off, let’s define the term “subsidy.” The World Trade Organization does that in detail. Here, I paraphrase that organization’s definition of “subsidy.” A subsidy is deemed to exist when a government makes a direct transfer of funds; or government revenue that is due is foregone or not collected; or a government provides goods or services other than general infrastructure; or a government makes payments to a private body to carry out the type of functions that would normally be vested in government; and, as a result of any or all of these circumstances, a benefit is thereby conferred to an industry.
    The “forest management subsidy” illustrated in the graph above is an example of government revenue that is due but not collected. The BC government sets stumpage rates, yet those stumpage rates—even after all other sources of forest revenue are included—consistently do not cover the ministry’s operational costs for managing the industry’s operations on public land. As a result of the BC government’s failure to require the logging industry to pay for the cost of managing forest removal on public land, a benefit is conferred to the industry. That constitutes a public subsidy of the industry.
    Public subsidization of the forest industry’s consumption of electricity
    Now let’s consider other benefits conferred on the forest industry, starting with public subsidization of the electricity it consumes. Over the 10-year period for which we gathered data, the public subsidization of the cost of electricity used by forest companies amounted to $5.1 billion.
    You won’t find a record of this public subsidy anywhere in the forest industry’s or the ministry of forests’ public accounts of their operations. It occurs entirely as a result of BC Hydro’s inequitable rate structure. Here’s how we calculated it:
    Residential consumers of electricity in BC—who, as a class, are BC Hydro’s largest customer—pay a two-tiered rate for electricity. If a residential customer keeps their consumption to less than 675 kilowatt-hours per month, they pay 9.3 cents per kilowatt-hour. If they go over 675 kilowatt-hours, they pay 13.94 cents per kilowatt-hour.
    The principle applied to residential consumers is this: If you consume more than a set amount, you pay a higher rate. BC Hydro uses this strategy in order to encourage consumers to conserve electricity. Why? Because supplying additional capacity is very expensive. Consider the estimated $16 billion cost of Site C to understand just how expensive supplying additional capacity can be.
    But this principle of applying a higher rate for higher consumption is flipped on its head when it comes to forest industry consumers of electricity.
    BC Hydro’s current rate for “Large General Service” users—those customers whose average monthly consumption is at least 45,833 kilowatt-hours, and that would include all BC pulp and paper mills and virtually all sawmills and veneer/panel mills—is currently 5.96 cents per kilowatt-hour, no matter how much electricity is consumed. If a mill uses less than 45,833 kilowatt-hours, they pay a higher rate.
    Why wouldn’t the same principle of higher rates for higher levels of consumption be applied to the forest industry if the rationale for higher rates for consumers is to get them to conserve expensive capacity? Over the last 5 years, the forest industry has consumed an average of 6000 gigawatt-hours per year of BC Hydro’s output. Site C will generate 5100 gigawatt-hours of electricity per year. If the forest industry consumes the equivalent of Site C’s capacity, why aren’t there rates in place that would encourage industry consumers, like residential consumers, to conserve? And why should the industry pay less in any case? This preferential treatment amounts to a public subsidy.
    The magnitude of the subsidy can be determined from the difference in the rates for residential consumers and forest industry consumers.
    Since BC Hydro does not apply the same principle to forest product mills as it applies to residential consumers, the forest industry is being subsidized by BC Hydro residential consumers. That subsidy amounted to 4.81 cents per kilowatt-hour in 2010 and rose to 7.98 cents per kilowatt-hour by 2020.

    We obtained records through an FOI request for BC Hydro records that show the electrical energy consumption of BC forest industry companies for 5 years in that 10-year period (attached at the end of the story). Based on those numbers, and other data that allowed extrapolation for the years we didn’t have, we calculated that the public subsidization of the forest industry’s use of electricity amounted to $5.1 billion.
    Some of you will question whether the lower electricity rates given to the forest industry by publicly owned BC Hydro can actually be considered a public subsidy. You might point to WTO rulings in the Softwood Lumber Dispute regarding US claims that two BC forest companies were paid excessive rates for electrical energy they sold to BC Hydro. Those claims were rejected by the WTO, but not because differences in electricity rates can’t constitute a subsidy. The resolution of that issue by the WTO, in fact, confirms that electrical rates can constitute a subsidy. But the WTO’s mandate isn’t to consider the public interest. It’s only interest is in promoting international trade. For the average British Columbian, who has long been told by the industry and its promoters that “forestry pays the bills, folks,” the important issue is how much of the logging industry’s electricity bills are actually being paid by the excessively high rates of ordinary folks. Over the past ten years that has amounted to $5.1 billion.

    Public subsidization of the forest industry’s release of forest carbon emissions
    When an area of BC forest is clearcut, it is immediately transformed from being a carbon sink into a carbon source. While the forest industry and its supporters argue that the carbon in all forests will eventually return to the atmosphere anyway, the acceleration of this return caused by clearcutting creates an immense surge in carbon emissions that would never have occurred naturally, especially in the time frame in which this is occurring.
    Moreover, turning primary forests into plantations, where the intention is to log the plantation in 45 to 80 years, creates a large carbon debt that will never be repaid.
    Carbon that enters the atmosphere as a result of the forest industry’s activities has the same physical effect as carbon coming from a car’s tailpipe; they both cause global heating.
    In response to the climate emergency, the BC government introduced a carbon tax in 2008 which applied only to fossil fuels. The BC government acknowledged that carbon emissions needed to be reduced in order to avoid damage that could be expected as the result of climate change. They were thinking of such events as those that overwhelmed BC in mid November 2021, in which communities were flooded and transportation infrastructure was badly damaged. The fires in the summer of 2021 caused similar losses, with Lytton burned to the ground. These events will be very costly to BC taxpayers.
    By not applying the Carbon Tax to the forest industry’s forest-removal activities—which cause far greater carbon emissions than the burning of hydrocarbon fuels in BC—a financial benefit was conferred on the forest industry. That is, the public is subsidizing the forest industry’s carbon emissions. For the period 2010 to 2020, that subsidy is shown in the graph below:

    We calculated this subsidy based on the rate of the Carbon Tax for each year and the estimated biomass of forest removed in each of those years. We used the ministry of forests’ Harvest Billing System to determine the volume of logs removed from public land for each of the 10 years, and used the results of a scientific study conducted by Suzanne Simard and Jean Roach to estimate the original forest biomass those logs came from. The summary of how that biomass was estimated can be found here.
    We determined the value of annual forest carbon emissions by using the value of the BC Carbon Tax that was applicable in each of the 10 years. The total 10-year value of carbon emissions subsidization was $31.5 billion, or an average of $3.15 billion per year. In 2019, the BC Carbon Tax was $40 per metric tonne. Since the carbon tax is set to increase to $170 per tonne by 2030, this annual subsidy will rapidly increase in size.
    Public subsidization of the loss of carbon sequestration capacity caused by the forest industry
    Lastly, we calculated the subsidy related to the loss of carbon sequestration capacity caused by logging in the period 2010 to 2019. To calculate this subsidy we used the Province’s own account of net carbon sequestration capacity loss and the applicable level of the Carbon Tax for each of those years.
    Through the 1990s the province’s carbon sequestration capacity—the net amount of carbon BC forests could take out of the atmosphere each year—held relatively steady at about 90 million tonnes of CO2-equivalent. Beginning in 1999, as a result of logging and forest loss from other causes, the capacity of BC forests began to fall. The Province has estimated that capacity each year. Here’s what that decline looks like:

    To calculate the cumulative amount of this loss, we used the difference between the level in the 1990s and the level estimated by the Province for each year between 2010 and 2019.
    We then calculated a dollar value for the carbon sequestration that didn’t occur each year, using the value of the Carbon Tax that was applicable in each of those years. That totalled close to $22 billion over 10 years.

    How much of this should be attributable to logging and how much to the Mountain Pine Beetle and forest fires? We compared the volume of forest lost to each since 1999 and found that logging accounted for about 60 percent of the total forest loss. To be on the conservative side, we dropped this to 50 percent. So we attributed one-half of the cumulative monetary cost of carbon sequestration loss over the period 2010 to 2019 to logging—$11 billion.

    For those of you who don’t think this is a real cost, consider the efforts of Carbon Engineering, the Squamish-headquartered clean tech company that has created a machine that removes carbon dioxide from the atmosphere—like trees do—and turns that into a hydrocarbon fuel. The goal of the company is to build equipment that can do that at a cost of $100 per tonne. The company’s efforts have attracted investors and media attention from around the planet. The function of Carbon Engineering’s machine amounts to what trees do naturally—for free.
    In our calculation of the value of lost carbon sequestration capacity, we used Carbon Tax values ranging from $20 in 2010 to $40 in 2019. But at $100 per tonne—Carbon Engineering’s ultimate target—the cost to the forest industry for causing the loss of just this one forest function would be valued at $36 billion over a 10-year period. As noted above, the carbon tax is set to increase to $170 per tonne by 2030, so like the carbon emissions subsidy, the annual carbon sequestration subsidy will rapidly increase in size.
    If someone destroyed one of Carbon Engineerings’ privately-owned machines, there would be a huge bill to pay. But a logging company destroying a publicly-owned forest that provides exactly the same function? Well the public is paying the logging companies, through the various subsidies outlined here, to do just that.
    The total cost of all these subsidies is astounding. The graph below shows the total cost by year. The cumulative cost of just these four subsidies is $50.6 billion over those 10 years.

    The last thing to show you is how the total cost of these subsidies compares with the GDP of the forest industry, which is calculated by the provincial government. You can see in the graph below that in the last two years, the cost of the subsidies is actually greater than the industry’s contribution to BC’s GDP. This may now be a permanent condition since the largest of these subsidies are based on the value of carbon, which is rapidly rising. In 2019 it was $40 per tonne. By 2030 this will rise to $170 per tonne. At that point public subsidization of the forest industry will far exceed the industry’s contribution to GDP. Unless, of course, the provincial government’s approach to managing BC forests begins to recognize the role BC’s forests must play in mitigating climate change.

    The bottom line, though, is that forestry doesn’t pay the bills, folks. You pay the logging industry’s bills.
    In the next iteration of this story, we will consider the cash subsidies taxpayers provide the logging industry—like the Bridge to Retirement program and the BC Forest Enhancement Society—as well as offer an estimate of the cost of damage done to communities and public infrastructure by the floods and fires that have been, in part, caused by BC’s over-exploitation of its forests.
    David Broadland is happy to have finally launched the Evergreen Alliance. He hopes readers will register on the site so they can receive The Forest, the Alliance’s weekly newsletter, which will begin circulating through cyberspace after the new year.
    Forests ministry response to request for records of forest-related revenue and costs FNR-2020-07123 records.pdf
    Forests ministry response to FOI request FNR-2021-10554.pdf
    BC Hydro response to FOI request for energy consumption by forest industry 2021-232_Records.pdf

    Ben Parfitt
    As more old-growth trees topple and forest industry jobs plummet, an obscure government subsidy scheme fuels the collapse.  

    Thanks to generous BC government subsidies, wood pellet mill yards are overflowing with logs culled from the interior region’s primary or old-growth forests. Photo: Stand.earth.
    FOR MORE THAN 15 YEARS, the BC government has rewarded logging companies with millions of additional old-growth trees to chop down thanks to an obscure “credit” program that allows companies to log bonus trees that don’t count toward their licensed logging limits.
    The virtually unheard of program was noted briefly in a report released by the government in June following a press conference in which Premier John Horgan boasted of his government’s efforts to protect more old-growth forests even as protesters were being arrested in his own riding for blockading logging roads leading into ancient stands of trees.
    Despite being a fixture of government policy for a decade-and-a-half, the credits or subsidies, which one former senior-ranking civil servant in the provincial Ministry of Forests likens to a Ponzi scheme, have flown almost completely under the radar.
    Under the scheme, which applies across BC’s vast interior region, logging companies that truck lower value trees to wood pellet mills and pulp mills receive credits from the government that allow them to go back into the forest and log as many trees again.
    In addition to accelerating the loss of irreplaceable old-growth ecosystems, the bonus logging is certain to fuel even more job losses in BC’s battered forest industry, where 40,000 workers have lost their jobs in the past 20 years. But a new investigation by the Canadian Centre for Policy Alternatives finds even more to be concerned about including:
    • No record of how many millions of additional trees have been logged since the subsidies began in 2006, and government refusal to provide such information short of a formal Freedom-of-Information request, which could result in months if not years delay.
    • More than $37 million in taxpayer dollars given directly to wood pellet and pulp mills or their suppliers to help underwrite their costs of purchasing lower-quality wood fibre.
    • Rapidly rising demand for lower-quality logs from BC’s wood pellet mills, which further threatens old-growth forests, despite the industry’s claims to the contrary.
    The credits effectively amount to a government-sanctioned double-dip for the logging companies. But the biggest consequence may be that the bonus logging is off the books.
    In its June report, the government disclosed that the credit logging doesn’t count towards a company’s logging entitlement, known as its Allowable Annual Cut or AAC. That means that one of the only tools the government has to control logging rates—a cap—is badly compromised.
    Despite the government acknowledging that the subsidies will accelerate “declining mid-term timber supplies,”—a euphemism for running out of trees—it cannot or will not say how many millions more trees have been logged as a result of the credits.
    It’s certain, however, that the number is high. In the Prince George area alone, a 2017 report by the province’s chief forester, Diane Nicholls, found that in just one five-year period, logging companies cut down an additional 2.4 million cubic metres of trees under the credit scheme, with much of the downed trees going to the region’s wood pellet mills, a bottom-feeding industry that cares not a whit whether its wood comes from centuries-old or 20-year-old trees.
    In the same report, Nicholls, who occupies one of the highest positions in the provincial Ministry of Forests, noted that it is possible that the rate of credit logging will increase even further, resulting in a greater area of forest logged each year. However, she said, the additional logging was an “important tool” to keep lower quality logs flowing to the region’s wood pellet mills, and therefore she would not adjust future logging entitlement (AAC) downwards to reflect the additional number of trees being logged under the subsidy scheme.
    In an interview, Anthony Britneff, a former registered professional forester who held senior positions in the same ministry during his nearly 40 years of public service, called the credit scheme “a secretive, fraudulent Ponzi scheme in which the public’s timber is being allocated out of the legislated AAC process.”
    He said all British Columbians will be the victims, since the credit logging is happening in publicly-owned forests, “and that those responsible should be held accountable.”
    “A crime against the province”
    Arnold Bercov, a former president of the Public and Private Workers of Canada, said he is deeply unsettled by the subsidy program’s implications. He fears the credit logging will further deepen problems for already stressed forest ecosystems, community watersheds, rural First Nations, non-Indigenous rural communities, and forest industry workers alike.
    “It’s so bad what we’re doing. We’re liquidating what’s here. That’s what’s going on. And that’s just a crime against this province,” Bercov said.
    The union is one of three representing forest industry workers in BC and has been vocal about the need to protect more old-growth forests, and ensure that much higher value is added to whatever trees are logged in the province’s forests.
    While Bercov says the credit program poses risks to forests and forest workers alike, its biggest victims will be First Nations on whose ancestral lands all the bonus logging is taking place. “Ultimately, it won’t matter about First Nation land claims. In a few years, it won’t matter if they win or lose because there won’t be anything left to win,” Bercov says.
    “Here we are speeding down a climate emergency and we are putting holes in our only lifeboat,” says Suzanne Simard, a professor of forest ecology at the University of British Columbia and author of Finding the Mother Tree: Discovering the Wisdom of the Forest.
    Simard said she wonders now how many of the logs “trundling out of the woods daily” near her home community of Nelson in the West Kootenay region may be a result of the credit program, including trees from the interior rainforest, one of the rarest forest ecosystems on earth.
    Simard’s concerns are shared by Michelle Connolly, director of Conservation North, an organization devoted to trying to protect the interior region’s primary forests, those forests not disturbed by logging, mining or other industrial activities.
    “The BC government is targeting natural hemlock forests in our inland temperate rainforest for pellets even though this ecosystem is red-listed,” said Connolly. “Now we find out that the direct destruction of these rare forests is being subsidized with public money and packaged as a bioeconomy. I really want to know how decision-makers sleep at night endorsing this and calling it clean and green.”
    Connolly’s and Simard’s concerns appear to be borne out by data analyzed by the CCPA showing escalated the logging of old-growth cedar and hemlock trees, a clear sign of increased logging in wetter forests where such trees are found.

    Where the trees go, the jobs go
    Despite such concerns, the Ministry of Forests, Lands, Natural Resource Operations and Rural Development, says that it cannot say how many trees have fallen as a result of the credit program. In an emailed response to a written request from the Canadian Centre for Policy Alternatives or CCPA, the ministry said that information on credit applications and approvals is largely confined to paper documents and therefore not available. To arrive at a rolled up figure for the total number of credits granted would involve a “large and complex” search that the government won’t even consider doing until it receives a formal Freedom-of-Information request.
    “Although some of the information is available electronically, most is housed in other forms that will take time to research and compile,” Doug Kelly, the ministry’s acting executive director of safety, engineering and tenures said in an email.
    Short of waiting months if not a year or more to learn how the government would respond to an FOI request and what, if any, documents it would release, the CCPA has tried to gauge the potential scale of the credit program by analyzing publicly available logging data in BC’s interior region for each of the years from 2006, the year the credit began, through 2020.
    The vast interior region stretches east of the coast mountains to Alberta and everywhere between BC’s southern and northern borders. Some of the largest sawmills in the world are located in the region, along with pulp mills and a growing number of wood pellet mills.
    The combined horsepower of all those mills has escalated demand for trees from the region’s forests, which have been extensively logged for decades as well as being hammered by wildfires and massive beetle attacks that prompted even more logging.
    The CCPA analysis identified three notable trends including:
    A 50 per cent increase, on average, since 2006 in logs that could potentially trigger credits. These logs are identified in the database as Grade 4 logs. Steady logging of the highest value trees, which yield Grade 1 and Grade 2 logs. Under the credit scheme, a company receiving credits for delivering low-value logs can then use those credits to log higher-value trees. A decline in the logging of higher-quality pine trees, and increases in the logging of higher-quality spruce, fir, cedar, hemlock and balsam trees. The drop in logging of higher-quality pine trees suggests that logging companies have effectively run out of many forests where healthy pine once dominated, and are making up the shortfall by intensifying logging elsewhere, including the rare inland temperate rainforest, which scientists warn is on the verge of ecological collapse.
    Collapse, also neatly summarizes forest industry employment, which in 20 years has plummeted from 91,000 jobs to just 49,000 today.

    A beetle attack, logging frenzy and mounting wood waste
    The credit program has its origins in the epic mountain pine beetle infestation that gathered steam in the interior more than 20 years ago and that killed hundreds of millions of lodgepole pine trees.
    The scale, severity and duration of the infestation was made far worse by climate change, but infinitely worse by ill-advised, government-approved clear-cutting and tree-planting programs.
    Those programs saw vast swaths of forest logged and replanted primarily with tiny nursery-raised lodgepole pine seedlings, even though in many cases the forests that had been logged contained a mix of tree species.
    Forest scientists including Alex Woods, David Coates and Andreas Hamman were among those to warn early on that the overreliance on clear-cutting and pine-planting was a mistake, because the plantations would act as magnets not just for mountain pine beetles but tree-killing blights such as Dothistroma.
    As more and more of those vulnerable pine plantations began to fail, making a mockery of computer models that confidently predicted that they would maintain their health and vigor, the scientists warned that such plantations had become “a major restoration liability” and would remain so for years if not decades to come.
    In response to the epic infestation, the government decided to open the floodgates and allow logging companies to dramatically escalate clear-cut logging in the name of “salvaging” millions of the beetle-attacked trees before they became unusable as feedstock for two-by-fours and other lumber products. But data maintained by the BC government showed that it wasn’t just damaged pine trees that were logged, but millions of healthy spruce, fir, cedar, balsam and hemlock trees as well.
    The salvage logging was a bonanza to the interior forest industry and its two undisputed powerhouses, Canadian Forest Products or Canfor and West Fraser Timber, which own and operate some of the biggest lumber mills on the planet.
    But it also fueled a surge in wood waste, as millions more trees fell, only to be rejected for hauling to the nearest sawmills because they allegedly lacked the highest quality wood fibre. Making it easier for the companies to leave the rejected logs behind, provincial timber-pricing policies required them to pay just 25 cents—the bare minimum —for each cubic metre of lower quality logs left behind, even though many of those same logs could have been made into lumber.
    Waste Away
    The credit program emerged in response to the mountains of wood waste, but it also had roots in the growing demand for wood fibre from an aggressive new player in the forest industy.
    In 2006, the nascent wood pellet industry had eight mills in the province and was consuming roughly 2.5 million cubic metres worth of wood fibre a year. In the years to follow, it would grow to 13 mills and its appetite for wood would increase fourfold. And the industry isn’t done growing. Witness a proposal to build what would be the largest pellet mill in Canada in Fort Nelson, a mill that would require the logging of an additional 1.5 million trees per year.
    Traditionally, pulp and paper mills relied mostly, but not exclusively, on the mountains of wood chips and sawdust generated at sawmills, where, as a consequence of round logs being turned into rectangular products, only about half of each log ends up as lumber.
    But with surging wood pellet production putting the squeeze on a finite wood supply, it wasn’t long before both pellet mill and pulp mill owners were clamoring for huge numbers of whole logs. With droves of trees being cut down and left where they’d fallen, the challenge became how to convince Canfor, West Fraser and others to bring those logs into town.
    Enhancing business conditions
    The credit program effectively put fuel in logging truck tanks by rewarding logging companies with the promise of more trees to come.
    But there were even more tangible ways that the government subsidized or accelerated old-growth logging. It put money directly into the pockets of the major logging companies and sawmill operators, as well as the wood pellet and pulp companies.
    In 2016, a program unveiled by the provincial government created a new entity called the Forest Enhancement Society with an initial infusion of $85 million in taxpayer dollars, later topped up with a second installment of $150 million.
    The society is chaired by former provincial chief forester Jim Snetsinger, who is now a forestry consultant based out of Prince George.
    Over the years, the society has doled out money to reforestation and reclamation projects that rehabilitate lands damaged by wildfires and insect attacks. But it has also channeled significant funds into projects that it claims will substantially reduce carbon emissions by bringing lower quality logs and logging debris in from the bush, rather than seeing those logs burned.
    After reviewing the society’s lengthy list of funded projects, the CCPA estimates that at least $37 million in taxpayer dollars went directly to wood pellet mills and pulp mills or to companies working to bring lower quality logs and wood fibre into mill towns.
    Notable recipients of those public funds included:
    $4.37 million to BC’s biggest wood pellet company, Pinnacle Renewable Energy. Pinnacle is now owned by Drax, a UK company that burns 10 million tonnes of imported wood pellets per year to generate electricity. $2.18 million to Pacific Bioenergy, another large wood pellet producer based out of Prince George. $1.5 million to the Prince George Pulp and Paper mill. $1.25 million to the Domtar pulp mill in Kamloops. $3 million to Mercer’s Celgar pulp mill in Castlegar. In its 2020 “accomplishments” report, the Society states that “one of the biggest challenges” with lower quality logs left behind at logging operations “is that the value of the wood waste is lower than the cost to haul it to a facility like a pellet plant, co-generation electrical plant, or a pulp mill.”
    “Through grants that help cover transportation costs, we support organizations and companies who want to use that leftover wood fibre...instead of burning slash piles, the wood fibre is put to good use and supports our province’s bioeconomy and climate change goals.”
    Left completely unsaid is how saving wood from being burned at logging sites only to deliver it to pellet mills that make a product that is then burned equates to a climate benefit. Also left unsaid is the sweet deal that the combined Forest Enhancement Society and credit program subsidies bestowed on the companies involved.

    Old-growth cedar logs from one of the world’s most unique and imperilled forest ecosystems—BC’s interior rainforest—make their way into a wood pellet mill yard in Prince George. Photo: James Steidle.

    Take as one example, Canfor. Canfor is a partner in the Pacific Bioenergy pellet plant. It also owns the Prince George Pulp and Paper mill.
    Through grants received by the society, Pacific Bioenergy and Prince George Pulp and Paper got to underwrite their log purchase costs at taxpayer’s expense thereby increasing their profits.
    Then, after delivering such logs to those facilities, Canfor could apply for credits allowing it to log even more trees, including the higher-value trees that it covets for its sawmill operations.
    Credits equal further losses of remnant old-growth
    On BC’s coast, the earliest commercial logging dates back to the 1820s, when a sliver of the forest’s tallest and straightest old-growth fir trees were cut down to make ship’s masts. Since then, significant tracts of coastal forest have been logged two or more times. But in the interior, the commercial logging of “primary” or “old-growth” forests, which have never before been clear-cut, really only got seriously underway half a century ago.
    Because many interior trees are smaller than on the coast, the area of land cleared to yield a similar volume of wood to that on the coast is far greater.
    The interior region is also much more conducive to clear-cut logging on a vast scale due to its generally gentler terrain, which is not the case on the more mountainous coast. That reality, combined with the interior’s proximity to the United States’ lucrative housing market, made the region a magnet for lumber producers.
    When the first significant modern era pine beetle infestations began in the late 1980s on the vast Chilcotin plateau west of Williams Lake, the combination of big sawmills and highly automated logging equipment in the form of feller buncher machines resulted in a rapid increase in clear-cuts. The even more consequential beetle attacks that followed 20 years later only accelerated the deforestation because by then the sawmills were even bigger.
    The consequence? In just 50 years much of the interior’s once-bountiful primary or old-growth forests are gone, with horrendous consequences for endangered wildlife species such as woodland caribou, who need all that the forest contains and where a “low-quality” tree for lumber may be the highest-quality tree for lichen, without which caribou cannot survive. The additional forest losses associated with climate change and its role in fueling more prolonged and intense wildfires, tree-killing droughts, insect attacks and tree diseases, have further speeded the losses, leading to the deepening ecological and economic crisis.

    The BC government, which regulates the forest industry, says it cannot say how much government subsidies may be contributing to logs showing up at pellet mills, like this one in Burns Lake. Photo: Stand.earth
    Double trouble
    Earlier this year, the environmental organization Stand.earth released photographs and video footage showing pellet mill yards in Smithers, Burns Lake and Houston filled to overflowing with towering walls of logs.
    The images confirmed that contrary to the pellet industry’s assertions that “residual” wood chips from nearby sawmills were the primary feedstock for pellet mills, it was massive numbers of whole logs that kept such operations afloat.
    Provincial government subsidies have fuelled additional logging in the Houston area, where logs like this await conversion into wood pellets. Photo: Stand.earth
    Two of those pellet mills—in Burns Lake and Houston—are in the Nadina Natural Resource District, which is administered by the provincial forests ministry.
    In addition to the two large pellet operations in the Nadina district, Canfor operates a sawmill in Houston that was the largest mill in the world when it opened its doors in 2004 and remains one of the biggest lumber mills on the planet.
    The CCPA analyzed five years of logging data in the Nadina and found that on average the region’s logging companies extracted 14 per cent more trees from the region’s forests than they were entitled to cut under their Allowable Annual Cuts.
    Nearly one in every three trees logged during that timeframe were “lower quality” logs that could be used to generate credits. Although just how many actually resulted in credits being claimed is unknown because of the government’s refusal to release such information.
    Because we don’t know that number, we also cannot say to what extent Canfor and other companies operating in the Nadina may have used the credits as collateral or leverage to get what they really wanted, which was access to the highest-quality old-growth trees.
    But what can be said, because the data supports it, is that Canfor and others logged the region’s richest forests at a prodigious clip with two out of every three trees extracted producing Grade 1 and Grade 2 logs.
    What can also be said is that any lower quality logs claimed as credits by Canfor in the Nadina district provided a double economic benefit to BC’s largest forest company. As is the case in Prince George, where it is a partner in the Pacific Bioenergy pellet plant, Canfor has a stake in the Houston pellet mill, where it is a co-owner and operator along with Pinnacle Pellet and the Moricetown Indian Band.

    In Houston, Canadian Forest Products (Canfor) operates one of the world’s largest sawmills and is also a partner in the local wood pellet mill. Logs seen here will be chipped to make wood pellets at the Houston pellet mill. Photo: Stand.earth

    In the absence of a proper accounting from the government, it remains uncertain how much the credit program contributed to the Allowable Annual Cut being exceeded for five years running in the Nadina district. It is also uncertain how much the credit program has contributed to the increasing clip at which logging companies throughout the entire interior region have cut down the highest quality trees. In 2011, 39 per cent of all the trees cut down by Canfor and others yielded the highest quality logs. Every year thereafter that number increased to reach 59 per cent of the total at the end of last year.
    But what is certain is that logging more trees today means logging less trees tomorrow. A fall down in future logging rates is guaranteed for the simple reason that the industry is running out of the most desirable trees to cut down. And when the fall down comes, don’t expect any of the region’s major logging and sawmilling companies to stick around. Both of BC’s lumber giants, Canfor and West Fraser, have invested heavily in mills and forest assets in the US South, a hedge on the day when BC’s interior forests are thoroughly depleted.
    And we all fall down
    At more than 6.4 million hectares in size, the Mackenzie Timber Supply Area surrounding much of the massive Williston Reservoir is one of the largest forested administration zones in BC and larger in size than many European countries.
    But the once prosperous community of the same name is a shadow of its former self.
    As Mackenzie’s forest industry built up in the 1970s, jobs were so plentiful that workers were firmly in the driver’s seat. They could quit a job in one of the town’s mills in the morning and be working at another mill in the afternoon.
    Nearly 2,000 workers were once employed in one of Mackenzie’s five sawmills, two pulp mills, one paper mill, a value-added mill and a chip plant.
    Today, only one sawmill remains employing roughly 300 people (although the mill has been taking periodic shutdowns) along with the value-added mill, which employs a little more than 100 people in an operation that takes short trim ends from lumber mills and fits and glues them together in a process called “finger-jointing” to make longer finished boards.
    So decimated is Mackenzie’s once vibrant forest sector, that the value-added mill now imports trim ends from mills eight or more hours away.
    Peter Merkley is president of Local 18 of the Public and Private Workers of Canada, which recently lost 211 members who worked at Canfor’s last remaining sawmill in Mackenzie. The mill closed its doors for good on June 17, 2019.
    The union used to represent upwards of 800 mill workers in Mackenzie. Today, not a single union member is employed in the town.
    Adding to the angst of those who cling to the increasingly dim hope of a resurgence in local forest industry activity, Mackenzie’s remaining residents watch as logging trucks by the thousands truck logs past their doors to sawmills starved for logs in Prince George, Quesnel and elsewhere.
    Last year, according to data analyzed by the CCPA, Canfor pulled more than 425,000 cubic metres of logs out of the Mackenzie TSA, with a healthy 43 per cent of all those logs being the highest quality Grade 1 and Grade 2 logs.
    Merkley equates the activity to strip-mining. And he now fears no forest or community will be spared.
    “It’s going to happen everywhere, without a doubt, until there’s nothing left. And then, the companies are going to be out of here. It’s disgusting. And our government’s letting it happen, which is beyond me.”
    Ben Parfitt is a resource policy analyst with the Canadian Centre for Policy Alternatives, and a longtime investigative writer.

    David Broadland
    Our investigation found the ministry of forests with its collective head in the sand and the logging industry feeding on the huge public expenditure of money used to fight the fires.

    The Doctor Creek fire, the largest in the province in 2020. This BC Wildfire Service photo shows all three fuels BC’s forest fires are burning: Mature forest, plantations and clearcuts.
    WHY ARE THERE SO MANY LARGE, OUT-OF-CONTROL FIRES burning in BC’s Interior this summer? It’s partly the result of extreme hot weather made worse by climate change, but testimony provided to an Oregon court in 2019 revealed that clearcut logging, followed by replanting, creates fuel conditions that make fires easier to ignite and harder to control. These effects persist for decades. Since the area being logged each year in the Interior has more than doubled since the 1970s, southern BC has become a Molotov cocktail of clearcuts and young plantations ready to explode into flames with the first lightning strikes of summer.
    The Oregon testimony arose because a land conservation organization, Oregon Wild, sued the US Bureau of Land Management (BLM) for failing to disclose the extent to which logging on public land near an Oregon community would raise forest fire hazard. The Oregon case included written testimony from a BLM fuels specialist, provided under oath, that stated that logging and plantations increase forest fire hazard. Those two fuel conditions make a fire easier to ignite and harder to control.
    Here’s the relevant testimony by the BLM fuels specialist (we quote from the court judgment record): “The change from a ‘mature’ to an ‘early successional’ stand structural stage would change the associated stand-level hazard from low to moderate/high. The stands would go from a timber model to a slash fuel model with higher predicted flame length, fire duration, and intensity and decreased ability to control a fire, with the greatest risk of a fire start during the first 5 years following harvest. Over the next 10 to 40 years, stands would transition through stages associated with high stand-level fire hazard rating and go from a slash fuel to a brush fuel type, which are more volatile and susceptible to high fire-caused mortality rates. These potential fires would have high flame lengths, rates of spread, and intensity and would be difficult to initially attack and control. Overall fire hazard would increase for 5 to 20 years following planting, then drop from high to moderate after the next treatment.”

    Logging slash in an Interior clearcut (Photo by Sean O’Rourke/Conservation North)
    Fire hazard, as referred to in the testimony, isn’t quite what I thought it was, so I should outline the meaning of that term for you. A “fire hazard rating” is an assessment of the fuel comprised of living and dead vegetation in an area—a mature forest or a clearcut or a plantation, for example. The assessment estimates the ease with which a fire can be ignited, and, once ignited, the fire’s resistance to human control. If a fire ignites in a high hazard area, or encounters such an area, it can spread more easily than in mature forest.
    Fire hazard is independent of weather-related factors like moisture content, humidity, temperature or wind speed—all of which are influenced by climate change. Instead, hazard is all about fuels: the volume, type, condition, arrangement, and location that determines the degree of ease of ignition and the resistance to control. The distinction between climate effects and fuel effects is necessary to make for one important reason. Although the forests ministry can’t directly control climate change, it does have full control of how much of BC’s publicly owned forests are converted from a low fire hazard rating to a medium/high hazard rating each year. Since the early 1970s the ministry has ramped up the production of clearcuts and plantations—and, as a consequence, the fire hazard.
    The growing prevalence of clearcuts and plantations 
    The ministry of forests’ record of the extent of logging on publicly owned land shows there has been a large increase over the last 50 years. In the first five years of the 1970s, an average of 105,000 hectares of Crown land was being cut each year. In the 5-year period ending with 2018, that had risen to 240,000 hectares each year, a 230 percent increase.

    Data crunching by David Leversee, based on the ministry of forests’ RESULTS Openings and Consolidated Cutblocks.
    Over the past 40 years, about 8.5 million hectares of BC’s publicly owned forest have been logged. Based on the BLM fuel specialist’s testimony that the fire hazard associated with a plantation would be higher than the mature forest it replaced for up to 40 years, we can project that as much as 8.5 million hectares of BC now have an elevated level of fire hazard as a consequence of logging and replanting. That means 8.5 million hectares where fires will ignite more easily than mature forest, and 8.5 million hectares where fire will be harder to control. That number doesn’t include logging on private land.
    It’s that growing prevalence of clearcuts and plantations that’s worrisome. Lightning strikes in those areas will be more likely to ignite and the resultant fires will be more difficult to control than in mature forest. Lightning is the most common cause of forest fires in BC. Obviously, then, if there’s more land where fires are easier to ignite, more fires will occur. If fires are initially more difficult to control, they are more likely to grow. And once a fire grows large enough to start encountering multiple areas of higher-hazard fuels—like clearcuts and plantations—the fire becomes more and more difficult to control. If the area of the province that’s subject to this higher fire hazard is growing—and it is—then larger fires will become more numerous. That’s exactly what we are seeing this summer.
    One method of judging the prevalence of clearcuts and plantations is to view satellite imagery of Crown land. I highly recommend this to anyone skeptical about the extent to which publicly owned forests have been converted to higher fire hazard clearcuts and plantations across BC. Below is a satellite image of part of the area involved in the Flat Lake Fire:

    Satellite images show a lot of deceptively green areas. Unless you have been trained to interpret aerial imagery, it can be difficult to know what you are looking at. Many of the green areas in the image above are high-hazard plantations, many of which have now been burned.
    A better picture of the prevalence of clearcuts and plantations involved in the fires can be obtained by superimposing the ministry of forests’ fire perimeters onto the ministry’s record of logging in these areas. We’ve done that in the images below of four perimeters of 2021’s largest fires, shown as black lines. Past logging is indicated by the red-shaded areas. Each fire’s point of ignition is indicated by a bright red dot. The white areas are remaining primary forest or rangeland. Protected areas, like provincial parks, are shaded green. In each case you will notice that the area of past logging overwhelms the landscape. 

    The August 6 perimeter of the 60,000-hectare Flat Lake Fire (black line) superimposed on top of the BC ministry of forests’ RESULTS Openings record of logging (red-shaded area). The green-shaded area is Flat Lake Provincial Park.

    August 8 perimeter of the Sparks Lake Fire. On its west side, the fire burned to the edge of the massive 2017 Elephant Hill Fire, which burned through the logging indicated on the left side of the image above.

    August 8 perimeter of the Tremont Creek Fire southeast of Cache Creek.

    The August 8 perimeter of the White Rock Fire. The ministry of forests’ record of logging in the RESULTS Openings database misses some of the logging that has occurred. The area within the fire perimeter near Okanagan Lake (right side) has actually been heavily logged.
    The ministry’s records show that several of BC’s largest fires this summer were ignited in a clearcut or plantation and then quickly grew out of control. The White Rock Lake Fire ignited in an area of logging that was replanted in 2007. The Flat Lake Fire started when lighting struck a clearcut that was logged in 2015. The Sparks Lake Fire began beside a large area logged in the mid-1980s. The Octopus Creek Fire was ignited by lightning in an area logged in 2005 and planted in 2006. The Young Lake Fire was started by lightning in a clearcut logged in 2006 and replanted twice, in 2012 and 2015. And so on. Every one of the big fires in the southern Interior, no matter how they started, consumed thousands of hectares of clearcuts and plantations. The widespread conversion of BC forests from areas of low fire hazard to medium-high hazard by the logging industry is clearly playing a decisive role in the size of forest fires.
    Patrick Byrne, district manager of the 100-Mile-House Natural Resource District, declined to answer questions about the role clearcuts and plantations are playing in the Flat Lake Fire, but Byrne did note that “the fires burn quite nicely through plantations.”
    The aggressive behaviour of fires fuelled by clearcut logging slash and plantations puts firefighters in greater danger. BC Wildfire Service fire incident reports filed from the field often note extreme fire behaviour related to the fuel loading in clearcuts. A report from a fire in 2018 warned: “The slash blocks have more fuel loading than the standard slash fuel type, expect higher intensity. This higher intensity can cause fire whirls to develop, this would cause rapid fire growth and increased spotting potential.” Spotting refers to embers travelling downwind and starting new fires. Many incident reports from different fires make similar observations about the impact of the fuel in clearcuts on fire behaviour. 

    A fire whirl in a clearcut fire (Photo by BC Wildfire Service)
    The impact of clearcut logging on fires will last a very long time
    Fire hazard rating is, by definition, independent of the moisture content in fuel. Yet the dryness of a clearcut, plantation or area of mature forest has a large influence on the speed with which fire can spread. Clearcutting exposes the land to the full strength of the sun, evaporating ground moisture and lowering humidity, important factors driving increased fire size and severity.
    Clearcuts also allow drying winds and higher temperatures to more easily penetrate the edges of adjacent forest. BC forester Herb Hammond contends that “clearcuts are clear culprits for heating up and drying out not only the immediate area where they occur, but also the surrounding landscape. They change local and regional weather patterns, and turn former heterogeneous, ecologically resilient stands and landscapes into homogeneous, ecologically vulnerable stands and landscapes. Their vulnerability is well documented in both the rise of insect epidemics, which clearcuts are allegedly meant to suppress, along with wildfire risk.”

    BC Forester Herb Hammond
    The drier conditions caused by the widespread use of clearcut logging in BC will persist far longer than the BLM fuel specialist’s predicted “10 to 40 years” of higher fire hazard, as Hammond explains:
    “Forests, particularly as they grow older, conserve water in large part due to complex, multi-layer canopies, and overall composition and structure that are all geared to slowing the movement of water through the forest, while filtering and storing water at the same time. Clearcuts, on the other hand, expose the land to rapid water loss. After a clearcut in montane Interior forests, 150 to 200 years of natural stand development are necessary to get back to something close to the level of water conservation provided by intact, natural old forests. If one takes into account the development of decayed fallen trees that are needed to store and filter water, that could be doubled to 300 to 400 years. Most of these vital fallen tree structures get destroyed in high-production, mechanized clearcutting.”
    The dryness of clearcuts and young plantations is evident to anyone who has walked through one on a hot summer day and then stepped into the shade of adjacent mature forest. The difference in temperature and humidity is startling. That difference can even be measured by satellite imaging using microwaves. The top image below shows clearcuts near the Brenda Creek Fire in the Peachland area on July 16. The image below that shows the relative moisture content on the ground that same day. The dark blue areas contain the most moisture and the red areas are the driest. Yes, those red-yellow-orange areas are all clearcuts.

     (Graphics courtesy of David Leversee)
    There are several other aspects of how clearcut logging is practiced in BC that have had an impact on fire size. For example, in the Interior, the practice of “managed” forests has evolved to mean managed coniferous forests. Deciduous stands are eradicated, often using glyphosate sprayed from helicopters, so that more commercially valuable coniferous stands can be planted instead. This, too, has made Interior forests more vulnerable to large fires.
    James Steidle, forest activist, has campaigned against this practice in the Prince George forest district. Steidle observes: “The conifer-dominated forest type we are actively encouraging is highly flammable, while the broadleaf aspen forest type we are actively eliminating is incredibly fire resistant. With a few caveats, the conclusion is undeniable. According to a 2001 study by Steve Cummings et al, pine forests are 8.4 times more likely to burn compared to aspen forests, based on historical data.”
    With fewer stands of fire-resistant deciduous trees to slow down or stop fires, larger fires are inevitable.
    Another dubious ministry policy has been “salvage logging” of healthy non-pine forest stands alongside lodgepole pine killed by the Mountain Pine Beetle. Several of the largest fires in the Interior during the last six years have included thousands of hectares of salvage logging. The ministry of forests allowed companies that were awarded salvage logging licences to take not only dead pine, but healthy living trees as well. The ministry’s own records show that only 15 percent of the logging that occurred in BC since 2010 has been dead pine.

    Hammond is scathing about the salvage program and its consequences: “For a stand to be eligible for salvage stumpage rates, all that was needed was for the stand to have a lodgepole pine component of 3 percent or more. This led to a massive windfall for logging companies, which clearcut thousands of hectares of diverse, mixed species natural forests, many of them old growth, under the guise of ‘pine beetle salvage.’ These were the precise stands on which ecological recovery would have been centred through natural succession. Instead, the bulk of these areas have been converted to young lodgepole pine forests, as that species was the easiest to naturally regenerate and meet ‘reforestation’ requirements by the timber companies. So, the forest industrial complex have simply set up the forest landscape for both more frequent severe fire, and an even larger beetle outbreak—if the trees escape climate disruption.”
    Hammond predicts the relentless removal of primary forest in the Interior will eliminate essential ecological functions of old forest, and that will lead to more pine beetle epidemics, more “salvage logging,” more giant clearcuts and—inevitably—to more large fires: “Mixed species old-growth forests were once randomly scattered throughout the forest landscapes of much of the Interior. These forests were the home to carnivorous beetles who eat herbivorous beetles—like the Mountain Pine Beetle—and also the home for many cavity nesting birds that prey on herbivorous beetles. So, as long as these forests were found throughout the landscape, they served as important agents to keep bark beetle populations in balance. Along with all of the other benefits of old-growth forests and diverse natural landscapes, these benefits have been eradicated by timber-biased ‘forestry’ that increasingly has no place in BC or anywhere in the world.”
    Hammond believes the industry and their ministry partners have created a bleak future for BC forests: “The omnipresent danger of fire and ongoing drought, coupled with inhospitable soil and atmospheric moisture and temperature, call into question whether trees in clearcuts will ever grow to merchantable size in many clearcut areas. Indeed, we are already seeing plantation die off, including death by fire. Particularly in the Interior, we may soon begin to see ecosystem shifts, where former forests become degraded shrub ecosystems.”
    The growth in fire size is having broad impacts, including physical damage to communities and infrastructure, long periods of pervasive, health-damaging smoke, disruption to local economies, loss of large areas of wildlife habitat and loss of protected areas. The fires, partly a symptom of climate change, will worsen it: burned forests and plantations can’t continue to sequester carbon and the fires are releasing immense quantities of carbon to the atmosphere. Those emissions have doubled every 9 years since 1990, an exponential increase.

    Carbon emissions from forest fires are on track to double every 9 years since 1990. The current 9-year period runs until 2026, but 2021’s fires will likely be all that’s needed.
    The ministry has its head in the sand
    With the forest fire problem growing in size at an alarming rate, you would think the BC ministry of forests would have put significant resources and effort into understanding how the higher fire hazard of clearcuts and plantations is fuelling the growth in fire size. But the ministry appears to be avoiding the issue.
    FOCUS filed an FOI for any technical or scientific reports produced for the ministry between 2010 and 2020 that considered the relationship between logging and forest fire frequency, size, behaviour or intensity. Throughout that period, it was clear that the area being burned in BC during long, hot summers was growing rapidly. Had the ministry investigated? 
    Our FOI request produced a single study (see link at end of story) conducted by the ministry during that period that examined how fire behaviour was affected by man-made changes to forests. The records released show that in 2019, the ministry started the “Fuel Treatment Efficacy Project” to examine how different fuel-reduction treatments, like thinning or broadcast burning, had impacted subsequent forest fire behaviour and fire suppression tactics.
    The $50,000 internal study considered 17 forest fires, only one of which was in an area that had been “100 percent logged.” The researchers gave that fire “low priority” for further study. The main finding of study, as indicated in the 7-page report, was that there was “a paucity of examples” where forest fire had interacted with fuel treatments.
    Given the high stakes, it’s difficult to understand why the ministry of forests hasn’t examined the impact of logging and plantations on worsening fire behaviour in BC. Fighting those fires is increasingly costly, as I will describe below. Yet, judging by its response to our FOI, the ministry hasn’t lifted a twig to understand what’s happening.
    This failure is worrisome, and may stem from the transition of the ministry over the past 30 years from functioning as a regulator of the logging industry to being its primary enabler. It is perhaps unreasonable to expect that an organization that works every day to maximize logging would, at the same time, spend money and effort on digging up evidence that clearcuts and plantations are feeding large forest fires.
    Besides, the ministry knows that logging slash raises fire hazard. That’s why it requires logging companies to burn hundreds of thousands of slash piles every year in an attempt to lower the fire hazard that fuel poses.
    BC forester John Waters knows, too. In a 5000-word treatise advising his fellow Woodlot Licence tenure holders what they needed to do to reduce fire hazard after their logging, Waters summed it all up: “Decades of wildfire research and examination of large wildfires shows that wildfire spreads most rapidly in areas where there is an abundance of dry, fine fuel or old unburnt piled slash accumulations.”
    The ministry is very careful to never explicitly admit the obvious. If lack of fire hazard abatement results in injury, death or property loss, the Province and its industry partners could be held legally responsible for damages. The closest the ministry comes to acknowledging the higher fire hazard caused by logging is contained in its Guide to Fuel Hazard Assessment and Abatement in British Columbia, last updated in 2012.
    The Guide states: “In some timber harvesting circumstances, it will be impracticable to reduce fuel loads sufficiently so that potential fire behaviour is not increased relative to pre-harvest conditions.” Given the growing size of forest fires and the huge associated economic and environmental costs, we might ask why it would ever be “impracticable” to reduce fuel loads. Surely it should now be clear to the ministry that if reducing fire hazard would be “impracticable,” then logging should never occur in the first place.
    The Guide, of course, has nothing at all to say about reducing the fire hazard posed by plantations, which have, according to the BLM fuels specialist, the highest fire hazard. No worries. The ministry is already solving that problem. According to the ministry’s own records of the area logged and area replanted between 2000 and 2017, 1.2 million more hectares were logged than were planted. Just how bad this problem actually is depends on which ministry record of how much logging has occurred is used: the one made publicly available (below in black), or the one based on the ministry’s best data (red).
    Just to be clear, I am not advocating for leaving clearcuts unplanted. I am pointing out that our forests are not in good hands. They are being ransacked, and so is the public purse.

    The money whirl: Who benefits economically from forest fires?
    The ministry seems to have in place all of the policies needed to make fires worse and few that would mitigate the risk. One result is that fighting forest fires is costing BC taxpayers a lot more. In the 5 years starting with 2010, fire management cost BC $1.02 billion. In the following five years it more than doubled to $2.12 billion.
    Indeed, fighting forest fires has become a big business in BC, and much of the economic rewards from that business flow back to the logging industry itself. Of the $2.1 billion spent on fire management by the ministry of forests between 2015 and 2019, just under 70 percent was paid to private companies for services provided in the increasingly difficult battle to contain forest fires. Through an FOI request for records, FOCUS obtained details of payments totalling $1,471,832,630 (see link at end of story for complete list). Fires in 2017 and 2018 accounted for over 70 percent of that cost.
    Who benefitted? On the ground, fighting big forest fires requires constructing fire breaks and other measures that involve logging company personnel and equipment. So, paradoxically, a company that logged an area that was later involved in a fire could end up being contracted by the ministry to help fight the fire. Tolko Industries, which has created what are among BC’s largest clearcuts, was paid $4.6 million for work it did during the 2017 and 2018 fire seasons. During the five years covered by the records, there were 150 small companies with the word “Logging” in their company name that received, on average, $200,000 each for fire fighting operations during fire season. Seventy-two company names on the list included “Trucking” and 35 contained “Excavating.” Eighty-two companies provided helicopter services and the top 10 helicopter companies alone were paid $148 million.
    The private business at the very top of the money whirl was Conair, a BC-based company that provides fixed-wing air services for fighting forest fires. Over a five-year period Conair was paid $96,466,895.60.
    Next on the list were Perimeter Solutions Canada Ltd ($54,703,223.38) and Air Spray (1967) Ltd ($43,670,860.94). Perimeter and Air Spray supply fire retardant and retardant delivery to fires by aircraft. The $100 million spent on those services points to another level of damage that may be occurring as a result of the over-exploitation of BC’s forests. Fire retardants are known to be harmful to aquatic life, especially to stream-type chinook salmon smolts. Many chinook salmon populations in BC are now considered threatened. The growing use of fire retardants to fight BC’s forest fires is just one more threat to the species’ survival.
    Even transferring money to the over 8600 entities on the fire-fighting money list was expensive for BC taxpayers. For example, use of a Bank of Montreal Mastercard account cost hapless taxpayers $20,607,365.60.
    Since many of the companies that are receiving payments for fighting fires are the same companies that create the higher fire hazard of clearcuts and plantations in the first place, there is, to say the least, an appearance of a conflict of interest. 

    An air tanker drops a load of fire retardant on a clearcut fire in 2017 (Photo by BC Wildfire Service)
    Forget Brazil. BC's per capita rate of forest removal is worse than Bolivia's.
    The response to the growing size and cost of fires from those with an economic stake in continuing logging as usual in BC forests all have one thing in common: No one ever suggests reducing the ongoing production of clearcuts and plantations, the inevitable consequences of logging. Quite the opposite, in fact. Industry and government both know that as time goes on and less and less primary forest is available to be cut, to keep volumes up at mills will require even greater areas of clearcuts and plantations to be created. That’s the ministry’s plan, and that promises an even more catastrophic future for BC.
    If you’ve come this far in my story, you must be looking for a solution to the mess the mindustry has created. If so, ask yourself these questions: Could the rate at which primary forest is converted to clearcuts and plantations be reduced? Or is the current rate of forest exploitation needed just to meet BC’s own basic need for products derived from forests?
    Ministry of forests’ data shows that 80 percent of the value of BC forest products comes from exports, and most of those go to China, the USA and Japan. So BC is cutting far beyond meeting its own needs for wood products. The extreme nature of that over-cut becomes apparent when BC’s rate of forest-cover loss is compared with other states that are, like BC, heavily forested.
    Consider Bolivia. It’s the 8th most heavily forested country in the world. It has an area of 1.099 million square kilometres, just slightly larger than BC’s 944,735. When you do the arithmetic, Bolivia’s forest-cover loss from all causes between 2001 and 2019 amounted to .545 hectares per capita. BC lost 1.66 hectares per capita, more than three times Bolivia’s loss.

    Yet when we compare per capita income between BC and Bolivia, there’s no question about which country has the greater need to exploit its forests. In 2010, the mid-point of the 20-year period we’re considering, Bolivia’s per capita income was around $1900 per person. BC’s was $41,327. So Bolivia had a vastly greater economic need to exploit its forest resource than BC did. Yet BC’s per capita rate of forest loss was three times as high as Bolivia’s.
    Keep in mind, too, that BC’s high per capita GDP had little to do with the forest industry, which in 2010 accounted for only 2.5 percent of BC’s GDP, according to the BC government. By 2019, that had fallen to 1.8 percent.
    By the way, if you take the forest-cover loss attributable to the beetle epidemic and forest fires out of BC’s total and compare that to loss from all causes in other countries, BC still has the worst record, as shown below:

    Back in the late 1980s, we used to say “BC is the Brazil of the north,” to express our disapproval for what the government and logging industry were doing to BC forests. That’s no longer even remotely appropriate. Now the global forest destruction putdown ought to be, “Bolivia is the British Columbia of the south.” And Brazil? On a per capita basis, Brazilians are forest angels by comparison.
    It’s evident that the extreme rate of forest removal in BC that’s fuelling large forest fires has, in turn, been fuelled by the high level of exports. That has been supported by a forests ministry that long ago stopped regulating the industry and now whole-heartedly facilitates extreme logging. Successive BC governments have chosen to go along with this, thinking that somehow this must all be good for the economy, and if it’s good for the economy, that’s all that matters to most politicians. Now that choice is having severe consequences. Unless BC breaks away from converting low-hazard primary forests into higher-hazard clearcuts and plantations to service export markets, our province seems fated to burn increasingly out of control.
    This summer, when not monitoring the BC Wildfire Service’s dashboard and otherwise trying to keep cool, David has been watching the drying forest in his coastal backyard with growing alarm.
    FOI record: Fuel Treatment Efficacy Project Summary: Fuel Treatment Efficacy Project Summary FNR-2020-05652.pdf
    FOI record: Fire management costs external to ministry of forests: Fire management costs external to ministry of forests FNR-2021-10573.pdf

    David Broadland
    BC’s forest industry, with a little help from its dependents in mainstream media, has become expert at warping public perception of the industry.
    June 29, 2021

    Teal Cedar Products Ltd’s cedar shake and shingle mill beside the Fraser River in Surrey. About half of the cedar logs that go through the mill end up in the pile on the right.
    TEAL CEDAR PRODUCTS LTD, the company in the news over its logging of old-growth forests on southern Vancouver Island, knows something that it doesn’t want you to know: About one-half of the ancient forest Teal cuts in TFL 46, trucks to its log sort at Duke Point, and then booms across the Salish Sea and up the Fraser River to its mill in Surrey, spends time as a pile of sawdust and wood chips on its way to a pulp mill or a bag of garden mulch or some other low value product. About half.
    According to data published by the BC ministry of forests, approximately 52 percent of the logs removed from BC forests become wood chips or sawdust. Teal’s mill is no different. The image above shows its shake and shingle mill on the Fraser River. That big pile of sawdust on the right? That’s the destination of approximately half of the old-growth cedar logs it removed from TFL 46 near Port Renfrew.
    Like the wood waste from any other mill in BC, the sawdust and wood chips are then transported to a pulp mill and turned into short-lived products like newsprint, toilet paper, or garden mulch. But the extent to which the forest is wasted when it’s logged is actually much worse than this, whether it’s old growth or second growth.
    What can’t be seen in the mill image is the slash left behind in the clearcuts after logging: The stumps and roots, the non-merchantable tops, the branches, parts of the tree that were broken during felling, the rotten parts of the trees, smaller unmerchantable trees, standing dead snags, and woody debris on the forest floor. Oh, and the understory plants and the underground mycorrhizal network. Approximately one-half of the total biomass of a forest that is killed by logging stays in the clearcut until it burns or decomposes and then passes into the atmosphere. Yes, this would all happen over time, naturally. But logging unnaturally shrinks the time frame within which that occurs, and, in the developing climate emergency, accelerating the process of returning forest carbon to the atmosphere could be suicidal.

    Logging slash left after clearcut logging of old-growth forest in the Klanawa River Valley on southern Vancouver Island (Photo by TJ Watt)
    The wasted biomass left in the clearcut, along with the piles of sawdust and wood chips at the mill, account for 75 percent of the original biomass that was in an old-growth stand before it was logged. Seventy-five percent.
    In BC, of the remaining 25 percent that gets turned into lumber, plywood, veneer, panels, shakes, shingles and poles, about 80 percent of that is exported, mostly to the USA, China and Japan. That means that only about 5 percent of the total forest biomass that is killed in BC each year by logging is actually used here as a product that could store carbon for more than a couple of years. Five percent. The other 95 percent is the forest industry’s big, dirty secret.

    This matters because there is a climate emergency. Killing forests means killing the most effective way to remove carbon dioxide from the atmosphere and safely store it for hundreds of years. Over the past 20 years in BC, mainly as a result of logging, the province’s forests have lost over 90 percent of their annual capacity to sequester atmospheric carbon.

    It also matters because killing forests means killing the wildlife that lived in those forests. As a consequence of logging, BC is experiencing an unprecedented decline in wildlife populations. The greatest cause of biodiversity collapse is loss of habitat.
    And it also matters because British Columbians are subsidizing this colossal forest-wasting exercise: By paying for the forest management necessary for the gargantuan scale of logging involved to meet export market demand, by subsidizing the industry’s electrical energy usage, and by failing to tax the immense carbon emissions and loss of carbon sequestration capacity caused by the forest industry.
    As awareness of these facts grows, both the ministry of forests and industry are desperately trying to create counter arguments about the damage the industry is doing to climate stability and wildlife.
    On the government side, provincial and federal forest mandarins are scrambling to promote initiatives that make it appear they are on the verge of mitigating the harms to climate and biodiversity. “Innovations” like “collecting logging residue” to make “bioenergy” and “mass timber construction” to store carbon are being promoted as climate friendly reasons why forest conservation is unnecessary. These initiatives—eviscerated by serious scientists—only address the symptoms, not the disease itself, which is too much logging. Worse, these unproven initiatives likely will have no impact at actually reducing the harm, and instead provide only the appearance of “We’ve got this.”
    Individual forest product companies, too, are finding their own creative ways to maneuver their businesses through the climate and biodiversity minefields. This brings us back to Teal Cedar Products Ltd, and its claims about guitars.
    In BC Supreme Court, Teal emphasized its role in guitar making
    Recall that in its February 2021 application to the BC Supreme Court for an injunction against logging road blockades in TFL 46, Teal emphasized the impact the blockades had on its “Teal Tonewood Division.” The company’s injunction contains the term “shake and shingle mill” only once, with no description of the extent of that business at all. Yet for its “Tonewood Division,” Teal included this long description:
    “Teal Cedar will suffer particular damage to its Tonewood division, which supplies book-matched pairs of timber used to manufacture custom-made guitars.
    “Only the highest quality all-blonde, straight-grain Western Red Cedar meets Teal Cedar’s standards for this business. This wood is difficult to come by. A disproportionate volume of the Western Red Cedar logs that do meet this standard originate from the Southern Vancouver Island logging area where the Blockades have occurred.
    “From September to December 2020, Teal Cedar experienced a decline in production of approximately 25,000 Tonewood units, resulting in lost revenue exceeding $250,000. This was due primarily to a sharp shortage in Western Red Cedar logs available during this period for production. Teal Cedar’s customers have begun to seek out substitute suppliers and lower cost European and Sitka Spruce product alternatives. For these customers, the shift to lower cost, lower quality alternatives would likely be permanent.”
    Just based on the difference in the number of words used to describe its cedar products, you might think that most of the cedar Teal takes from TFL 46 is being used to make guitars. “Shake and shingle” got three words; guitars got 146.
    Teal’s use of the injunction application to emphasize the tonewood aspect of its business raises some questions about the veracity of the company’s claims.
    For one thing, Teal removed 2.5 times the volume of cedar from TFL 46 in 2020 than it did in 2019—when there were no blockades. That increase in volume doesn’t support Teal’s claim of a “sharp shortage.” Moreover, the log market value of the cedar Teal did remove from TFL 46 in 2020 was about $9.7 million, and this is a much lower value than that of the wood products made from those logs. Why would “lost revenue exceeding $250,000” need to be highlighted by Teal?
    Secondly, according to Teal-Jones’ videos about the company, its Tonewood Division is located in Lumby, BC. Teal has a shake and shingle mill in Revelstoke, 175 kilometres distant from Lumby by highway, that also uses old-growth cedar cut from that area. The Revelstoke area is known for being able to produce excellent guitar tonewood, both from red cedar and Sitka spruce. From Port Renfrew to Lumby is 600 kilometres by road and a log boom across the Salish Sea. Why wouldn’t Teal have simply made up the difference from its nearby Revelstoke operation instead of losing all those valuable tonewood clients?  
    But these are mere side issues relating to the believability of Teal’s claims. The main question that needs examination is this: Are guitar tonewoods actually a big part of Teal’s Vancouver Island logging and Surrey milling business, or is that just corporate greenwashing of the larger harms the company is doing? Several reporters covering the old-growth logging blockades emphasized the guitars.
    Mainstream media: Teal-Jones is “world's largest maker of acoustic guitar heads”
    On April 9, a week after Teal was granted an injunction, the company’s efforts to rebrand itself as a guitar maker hit mainstream media. Darren Kloster, a reporter for Victoria’s Times Colonist, interviewed Teal spokesperson Jack Gardner. Kloster wrote, “Gardner said ‘every stick harvested’ is processed at its mills in BC, including a facility in Lumby that cuts cedar blocks for guitars. Teal-Jones, he said, is the world’s largest maker of guitar tops and ships cut pieces to guitar makers in Canada and around the world.”
    Over the following weeks, as public support for the blockades grew and the RCMP began to arrest forest defenders, media coverage of the conflict ballooned and the “world’s largest maker of guitar tops” claim metastasized.
    Writing about the blockades in the May 27 Globe and Mail, Justine Hunter reported, “The Teal Jones Group is the largest privately owned timber harvesting and primary lumber-product manufacturing company in British Columbia. The family owned company is the world’s largest maker of acoustic guitar heads, and it also produces dimensional lumber for construction, log home timbers and cedar shingles.”
    On June 6, reporting for Reuters, Nia Williams wrote: “Teal Jones is a private company based in Surrey, near Vancouver. The company, the world’s largest maker of cedar guitar heads, says although the Fairy Creek watershed is almost 1,200 hectares, only about 200 hectares are available for harvest.”
    The role the guitar factor played in how reporters thought about what was important was clearly evident in stories written by former Vancouver Sun reporter Rob Shaw. Now a reporter for Victoria’s CHEK TV, Shaw produced at least two stories that included Teal’s guitar parts business. For the Daily Hive, he wrote: “The company’s Tonewood division is one of the world’s largest suppliers of acoustic guitar heads and plans to use some old growth trees—cedar and spruce have the best grain—to make guitar parts and other instruments.”
    On The Orca website, Shaw reported that “Teal-Jones, and its Tonewood Division, is the world’s largest maker of acoustic guitar heads.”
    Based on that “world’s largest maker” status, Shaw calculated that “There’s likely several protesters at Fairy Creek right now, as well as other environmental activists, holding acoustic guitars made from the very trees they demand not to be felled.”
    Shaw went on to observe, “It’s easy for the forestry community to paint them [the protesters] as hypocrites—though in reality, we are all guilty of hypocrisy when it comes to decrying the harm caused to the environment, and then consuming the very products that worsen those harms.”
    Shaw didn’t quote anyone from the forestry community who had accused guitar-playing old-growth protesters of being hypocrites; perhaps he sniffed out the hypocrisy all on his own. 
    From Shaw’s stories, it’s clear that Teal’s guitar claims had influenced how he viewed the company, the logging, the protests and the protesters.
    The four reporters didn’t all agree on which part of an acoustic guitar Teal was producing, but they all agreed that it was either the “largest maker,” or “one of the largest makers” of that part in the world.
    According to Teal’s Youtube video, it produces approximately 2-foot-long, quarter-inch thick, quarter-sawn planks of red cedar and Sitka spruce—known as tonewood—that can be used for the front panel of a guitar body, the surface that has the sound hole in it. Tonewood is still a rough sawmill product though, not what could properly be called a “valued-added” product, though Teal does. To make tonewood, Teal takes a cedar shake bolt and runs it through a bandsaw instead of a hydraulic splitter. If Teal turned the boards produced into guitars—they don’t—that would be “value-added.”
    FOCUS contacted Kloster, Hunter and Shaw and asked how they had confirmed Teal’s “world’s largest” claim. All responded, but none provided any evidence that supported the “largest maker” claim. It appears that Gardner’s claims to Kloster, along with information included in one of the company’s Youtube videos, was all that it took for the company’s logging of old-growth forest on Vancouver Island to be characterized by mainstream media reporters as an essential part of the global manufacture of acoustic guitars.
    There were significant gaps in their reporting: None mentioned that the manufacture of red cedar shakes requires felling the same iconic, ancient red cedar trees that Teal claims to use to make guitar parts. None of the reporters mentioned that Teal’s shake and shingle mill in Surrey is arguably the largest manufacturer of red cedar shakes and shingles in BC—and possibly the world.
    I can only say “arguably” because the privately-owned company has not provided a public account of its Surrey shake and shingle mill’s output for at least 10 years, if ever. The ministry of forests conducts a voluntary “Major Mill Survey” each year that publishes the estimated annual output of every kind of mill in BC. Almost every large mill participates, but not Teal-Jones’ shake and shingle mill in Surrey.
    What is the mill’s output? Its physical size is evidently much larger than that of the largest shake and shingle producer that does participate in the ministry’s mill survey. A video about Teal’s shake and shingle mill states there are 23 resaw machines—the company produces 24-inch tapersawn shakes—with matching packing and banding facilities below the resaw machines.

    Some of the 23 machines at Teal-Jones’ Surrey shake and shingle mill that produce tapersawn shakes (Photo via Youtube)
    Compare that with the company’s video description of its funky “Tonewood Division” facility, which it says is located in Lumby. The video shows a few glimpses of a rustic building containing cedar or spruce blocks, and a bandsaw leisurely cutting off a thin plank destined for a guitar. It’s clearly a small, niche operation.
    But given the prominence of the guitar business in its application for an injunction, it appears Teal doesn’t want the public to think of the company as a roofing producer. Instead, it would like to be seen as a manufacturer of acoustic guitar parts. Why?

    Teal-Jones’ Tonewood Division manufacturing facility, identified in a Youtube video as being in Lumby, BC
    Turning old-growth forests into roofing is like dynamiting the Sistine Chapel
    Ask yourself: would you feel better about Teal chainsawing down a majestic 1000-year-old Western red cedar if you were told it was felled to (1) make musical instruments, or (2) make roofing?
    If cedar shakes are installed properly on a steep roof that’s well maintained, the shakes will last for about 30 years. The roofing then needs replacing. This is the worst possible use of old-growth cedar. I should know. I’ve installed a number of shake roofs on houses I’ve built, and they have all been replaced in that time frame.
    Cedar shingles on a roof will have an even shorter lifetime. As decorative siding, shingles are likely to last a little longer, but not as long as the trees from which they came would have lived if they were left standing.
    Teal understands that it’s easier to sell old-growth forest destruction during a climate emergency and in the midst of biodiversity collapse if the public thinks it’s being done to make acoustic guitars than if it’s done to produce a roofing product or decorative shingles.
    FOCUS did a thorough internet search for Teal’s guitar-parts making business in Lumby—and throughout BC—but we couldn’t find it. We did an extensive search of satellite imagery for mills in the Lumby area. Mills of any size, from small to large, stick out like a sore thumb—there’s always a big pile of wood waste nearby. Yet the Lumby guitar-part-making mill could not be found. We searched through organizations of luthiers (guitar makers) around the world and could find no mention of Teal’s guitar parts business, even though it “is the world’s largest maker of acoustic guitar heads,” according to the reporters. On the other hand, Acoustic Woods, the Port Alberni based tonewood supplier, could easily be found in all of these searches.
    We requested information about “Teal Tonewood Division” from Teal—and the lawyer who had prepared its injunction application—several times—but they provided no response.
    Teal seems to have found a way to draw attention away from its core business and direct it toward a more palatable use of old-growth forests. Mainstream media seem more than willing to amplify that mischaracterization of the company’s activities.
    You can understand Teal’s dilemma: It has a large mill equipped to make a product that seemed like a good idea in the early 1900s. But it’s early in the twenty-first century, BC is down to its last few hundred thousand hectares of forests containing large, ancient trees, and there’s a climate emergency and a biodiversity collapse. Using those rare remaining stands for short-lived roofing products or decorative siding could easily be seen by the public as reprehensible, like dynamiting the Sistine Chapel. But using ancient forests for acoustic guitars that can then make beautiful music that feeds the human soul? How could you be against that?
    Why would mainstream media be so willing to pussy-foot around the demolition? Let’s go back to that big pile of sawdust beside Teal-Jones’ mill. That mound of ground-up fibre is an inevitable by-product of milling, and it is no different here than anywhere else on Earth. What that by-product has mainly been used for in the past was the production of newsprint, the cheap medium upon which Canada’s mainstream print media—like the Times Colonist, the Vancouver Sun, and the Globe and Mail—depend on for their continued business health. Deep down, newspapers don’t want to see those sawdust piles disappear. If they vanished, or became scarce, cheap paper—the oxygen of the newspaper business—would disappear. Given that fact, for newspaper reporters to say anything seriously critical about the forest industry would be, well, hypocritical.
    David Broadland is the former publisher of FOCUS, a print magazine whose financial stability depended heavily on paper prices hardly ever rising. He and Leslie Campbell were happy to begin the process of decarbonizing the publication in 2016 and have now completed that project.

    Ben Parfitt
    As UK’s Drax makes play for BC’s wood pellet mills, questions grow about wood-fired electricity.
    April 11, 2021
    WITH ITS SIX MASSIVE 660-megawatt power units, the Drax power station in North Yorkshire is the United Kingdom’s largest thermal electricity plant.
    When it opened in the mid 1970s, the giant facility burned coal. Today, however, Drax burns something else: wood, a raw material that grew so scarce during the Elizabethan era that it forced the country to convert to coal.
    So, when it comes to finding enough wood, Drax has an intractable problem. Only 13 per cent of England, Wales, Scotland and Ireland combined is forested, a number that would be smaller still were it not for major tree-planting efforts over the last century.
    Incapable of meeting its raw material needs from within the UK’s borders, Drax relies on imports, which now amount to 10 million tonnes of wood pellets annually. That is effectively double what all of the UK’s forests currently produce in new tree growth each year.
    The scale of Drax’s enterprise prompted the company to hire engineers to design new rail cars capable of holding 30 per cent more volume than coal cars. The new cars feature retrievable tops that open for loading and close during transport, thus preventing the wood pellets from getting wet. Meanwhile, the port facilities that those trains travel to can accommodate huge bulk carriers that arrive at dock with as much as 63,907 tonnes of wood pellets. Big as such shipments are, they are not even enough to keep Drax operating for two-and-a-half days.
    Only with big “fibre baskets” outside the UK, can Drax meet its needs. In early February it announced that it had reached an agreement with Pinnacle Renewable Energy Inc., British Columbia’s largest wood pellet producer, to purchase the company. Pinnacle is the world’s second biggest pellet producer and owns facilities in Alberta and Alabama as well.

    Logs await grinding into wood pellets at pellet plant in Houston, BC. Photo: © Stand.earth.       Virtuous energy or a false solution?
    Drax says that once its takeover of Pinnacle is complete it will be the world’s largest producer of “sustainable biomass” power. It also says that using wood to create energy is part of a “virtuous cycle” that ultimately benefits “the forestry sector, rural communities and the environment.” All of which allegedly helps the UK and its EU neighbors get off “dirty” coal as part of a broader suite of objectives aimed at lowering greenhouse gas emissions.
    Drax’s claims rest on the fact that mountains of wood waste are created all over the world as a result of industrial wood processing. When round logs are turned into rectangular lumber products, only about half of each processed log actually ends up as lumber. What’s left over is sawdust and wood chips, material that is a “perfect” source of fibre for wood pellets, Drax says. Turn such waste into a product that burns efficiently, then plant enough trees to suck up the equivalent of all the carbon that is released during that burning, and, presto—you have a “carbon-neutral” energy source.
    New research by the Canadian Centre for Policy Alternatives (CCPA), however, suggests that Drax’s claims are greenwashing. Whole trees, indeed whole tracts of forest, are being logged with the express purpose of turning trees into a product that is then burned. This results in immediate pulses of greenhouse gases sent into the world’s overheating atmosphere. Such pulses are as damaging to the Earth’s climate as burning coal—and can only be offset over decades—assuming that replanted trees actually live that long. This is a major reason why 500 scientists have warned that wood pellet burning is a “false solution” to climate change.
    An ancient relationship
    Logging forests to turn them into pellets has many British Columbians worried, including Quesnel mayor Bob Simpson.
    “There is no justification with what’s happening with climate change to allow tree harvesting for pellets,” Simpson says, noting that we cannot afford to be “going back to an ancient relationship with the forest [where] we cut them down to burn them.”

    Provincial data shows that logging trucks delivered massive numbers of logs to BC wood pellet companies between 2010 and 2020. Photo: © Stand.earth.
    The CCPA’s research shows that from 2010 through 2020, three wood pellet companies in BC— led by Pinnacle—took at least 1.3 million cubic metres of logs out of the province’s forests. At 645,211 cubic metres, Pinnacle alone was responsible for just under half those trees. Prince George-based pellet producer, Pacific Bioenergy, logged slightly less at 611,833 cubic metres while Princeton Standard Pellet was a distant third at a little more than 45,000 cubic metres.
    The CCPA crunched the numbers using a searchable database known as the Harvest Billing System, which is maintained by BC’s Ministry of Forests, Lands, Natural Resource Operations and Rural Development. The database provides details on logged trees by or on behalf of companies, where the trees were logged, the quality of the logs and what companies paid in stumpage fees to the Province for each tree they logged.
    In Pinnacle’s case, 95 per cent of all the trees ascribed to it in the database were in areas of forest auctioned by BC Timber Sales, an arm of the BC government. The data show that Pinnacle paid an average of $20.57 for each cubic metre of trees it logged during those years and that its total payments to the Province were more than $13.27 million.
    Most of its logs came from the Quesnel region, including trees from the extremely rare interior temperate rainforest to the east of Quesnel.
    The CCPA asked Josh McQuillan, Pinnacle’s superintendent of biomass, and Mike Thomas, a Pinnacle biomass purchaser, for details on the company’s log supplies. Neither replied. Instead, an email came from Karen Brandt of Pinnacle’s communications department:
    “The data you are seeking directly from Pinnacle is competitive in nature and therefore we are unable to disclose. However, I can say that we are 100% committed to ensuring that trees go to their highest and best use. Our pellets are either a direct by-product of the lumber industry, or the purposeful extraction of dead, diseased or damaged or low-quality trees.”

    Whole logs await conversion directly into wood pellets at a Peak Renewable Energy pellet mill in Burns Lake in March, 2021. Photo: © Stand.earth.
    In addition to its data analysis, the CCPA has obtained photographs and video showing large numbers of logs amassed at Pinnacle’s pellet mills in Smithers and in Burns Lake. The photographs show pellet mill yards filled with whole logs that are destined to be converted directly into pellets. Simpson says a similar situation exists at a Pinnacle mill to the north of Quesnel. Because of Pinnacle’s decision not to answer any questions about its wood fibre sources, it is unclear whether the photographs represent logs that are in addition to those analyzed by the CCPA.
    Logs at Pinnacle’s overflowing pellet mill yards could, for example, be delivered there by major logging companies under a new provincial program known as the “concurrent residual harvest system.” The new system, launched in the spring of 2019, encourages “business agreements” between logging companies and pellet mill operators, and is intended to ensure that “low quality” logs are delivered to pellet mills at deeply discounted stumpage rates. Identifying such logs would require knowing precisely who Pinnacle is doing business with. But that is something the company is apparently unable or unwilling to disclose.
    Whatever the ultimate source of Pinnacle’s logs, the data and photographs contradict the pellet industry’s assertions that it uses “residual” (i.e., waste) wood fibre to meet its needs. It also contradicts what BC’s chief forester, Diane Nicholls—one of the most powerful officials in the forests ministry—has said about the province’s pellet mills in a promotional video for the Wood Pellet Association of Canada.
    Pellets: the antithesis of value-added
    “When you look at pellet production in British Columbia, it’s part of building that circular economy in the forest sector. It uses residuals from sawmill production that may not be used otherwise,” Nicholls says in the video. “And that is a win, because it’s something that is an added value for the benefits of British Columbians. It provides jobs. It fulfills a niche in our sector that we didn’t have before.”
    But while making wood pellets adds value of a sort to trees that are logged, Nicholls did not address just how few jobs the wood pellet industry actually creates.
    Using job figures provided by two unions that represent workers at four of the province’s 14 pellet mills, along with published job figures from industry sources as reported in various media accounts, the CCPA estimates that BC’s 14 pellet mills directly employed just 303 workers in 2020. The United Steelworkers Union and the Public and Private Workers of Canada (PPWC) report that workers in the unionized pellet plants are paid about one-third less than their counterparts working in sawmills, and that pay in non-unionized pellet mills may be lower still.
    That same year, according to labour force statistics compiled by the provincial government, 45,000 people worked in BC’s forest industry. That figure includes all logging and log hauling jobs, all jobs in wood product mills, and all pulp and paper mill employees. This means that the wood pellet industry last year accounted for just over one-half of one per cent of the province’s forest sector jobs.
    Drax’s entry also comes at a pivotal moment for the wood pellet industry in BC.
    In a move without precedent in the province, another new entrant onto the wood pellet scene—Peak Renewables—is proposing to build the largest wood pellet mill in Canada and by far the largest in BC, in the remote Fort Nelson region.
    Because the Fort Nelson region has no active sawmills, the proposed pellet mill would feed on whole trees from the moment it opens. The company says the mill’s biomass would come almost exclusively from logging the region’s aspen trees and that about 1.2 million cubic metres of wood from such trees would be required annually (equivalent to approximately 1.5 million aspen trees).
    When the CCPA published details on the proposed pellet mill in February, concerns were voiced immediately from forest industry unions and conservation organizations.
    “A truly healthy and stable forest industry is built around the idea of circulating wood between mills, adding value at each step of the way,” Gary Fiege, national president of the PPWC, and Jerry Dias, national president of Unifor, wrote in a letter to Katrine Conroy, BC’s minister of Forests, Lands, Natural Resource Operations and Rural Development.
    “The proposed Peak mill is the antithesis of that idea. If built, it will be the first pellet mill in the province that is intentionally designed to churn through whole, living, perfectly healthy trees to make one of the lowest value (from a jobs perspective) forest products on Earth,” they continued.
    Conservation North, an organization that is fighting to protect primary, unlogged forests in the interior of the province, where all of BC’s wood pellet mills are located, also wrote to Minister Conroy voicing its opposition to the project. The Fort Nelson region has some of the largest tracts of primary or old-growth forests remaining in the Interior.
    Protect more forest & add more value
    “Wood pellets derived from primary forests are not a renewable source of energy,” Michelle Connolly, Conservation North’s director, wrote. “By definition, primary forests are forests that have never been disturbed by industrial or other human activity, and consequently are irreplaceable. They are ecologically important, they store more carbon and harbor more biodiversity than plantations or second-growth stands of the same forest type, and they mitigate flood risk.”
    Numerous letters of opposition to the project were received in the minister’s office. Notably, Minister Conroy was told in her ministerial mandate letter from Premier John Horgan to both conserve more old-growth or primary forests and to ensure that more value is added to the province’s forest products. The ministry must now decide whether or not to allow Canfor Corp, the largest forest company in BC, to transfer logging rights it holds in the Fort Nelson region to Peak, which would mark a critical milestone in Peak’s pellet mill plans.
    Opposition to the forest-harvesting project goes well beyond just conservation and union circles. Even the industry association representing Canada’s wood pellet manufacturers has voiced its objections.
    Major wood pellet purchasers, such as Drax, do not operate in a vacuum. The European Union has made it abundantly clear that sourcing wood pellets from primary forests, which store huge amounts of carbon in their old trees, is to be avoided because it is neither renewable or carbon neutral.
    The wood pellet industry portrays itself as using “residual” wood supplies, largely in the form of waste from sawmills or broken log bits left behind following clear-cuts logging.

    Junk wood? Apparently sound logs about to be turned into wood pellets at a mill in Houston, BC, where Pinnacle Renewable Energy is a partner. Pellet makers say “low-quality” logs have no value and should be turned into pellets and burned. Photo: © Stand.earth.
    Shortly after the CCPA released details on the Peak Renewables plan for the forests of Fort Nelson, Gordon Murray, executive director of the Wood Pellet Association of Canada (WPAC), published a commentary criticizing the company’s plan.
    “WPAC does not support wood pellet manufacturing proposals that are predicated on the large-scale harvesting of forests for the sole purpose of pellet production,” Murray wrote, adding that his organization was “inundated” with calls after details of Peak Renewable’s plan surfaced.
    “WPAC’s history is rooted in a fundamental principle: responsible sourcing,” Murray wrote in Canadian Biomass Magazine.
    “That means our pellets are produced entirely from a combination of the waste or residuals left from harvesting and sawmilling activities, the limited quantities of low-quality logs that need to be removed for forest enhancement or salvage projects and material that can’t be used for any other purpose. We are opposed to initiatives that risk the reputation we have built as a leading global supplier in sustainable wood pellet production.”
    A last resort
    But what does Murray mean when he says “can’t be used for any other purpose?” In Quesnel, Mayor Simpson says there may be an argument for burning wood at some point. But in his view, it should be at the absolute end of the production train. If a tree is logged, the log should go first to mills where everything from lumber to furniture is made because solid wood products hold onto the carbon in trees and those products may continue to store that carbon for decades and in some cases centuries. After the logs first pass through such mills, Mayor Simpson says, the leftover wood is best sent to a pulp mill (of which there are two in Quesnel).

    A pile of wood chips awaits conversion to wood pellets at Pinnacle mill in Burns Lake. Critics say far more value and far more jobs are generated when chips go to pulp mills instead. Photo: © Stand.earth.
    Traditionally, the mayor notes, pulp mills turned wood chips and sawdust into wood pulp that was then turned into various paper products. But these days, pulp mills can make everything from much-in-demand fibres used in surgical gowns, to bioplastics and biofuels. The pulp industry is only scratching the surface of what can be made from so-called “waste” wood, Mayor Simpson says, whereas the pellet industry is capable of making just one product and a product to immediately be burned at that.
    Wood pellets, says the mayor, should be “the last resort,” the caboose at the end of the train.
    What have we learned?
    In 2018, Pulitzer Prize-winning author, Richard Rhodes, wrote Energy: A Human History, a book that looks at how societies transitioned from one energy source to another. The first chapter, No Wood, No Kingdom, begins in 1598 in London, England, as a group of workers dismantle a theatre building as William Shakespeare looks on. The timbers of the ancient theatre are then carted away and resurrected on the other side of the River Thames to become the Globe Theatre, where some of the playwright’s most famous works were first performed.
    Scarcity is what drove the salvage and reassembly operation, as the forests around London—indeed across England—were steadily logged and people had to go farther and farther in search of trees to cut down.
    Rhodes’s journey through more than 400 years of history makes two things abundantly clear: energy transitions occur as energy supplies run short, and when the transitions occur, they do not happen overnight because of the immense engineering challenges involved.
    Fully transitioning from wood to coal did not happen in the blink of an eye. As coal-mining picked up, mines quickly became flooded with water and people then had to figure out how to dewater the mines, first with the power of horses and later, after horsepower’s limits became better understood, with steam.
    Contacted at his home in California, Rhodes said he was mystified that England appears to be reaching far back in time to harness the energy of wood, a raw material in very short supply in the UK today, and one that will ultimately not solve a planetary climate crisis as there is no guarantee that the greenhouse gases emitted when wood is burned today will be made up tomorrow when a tree is planted.
    “I really do wonder about this cycling of wood,” Rhodes said. “I really do wonder if there’s a CO2 advantage when they’re shipping these pellets. They’re putting them on diesel-fired freighters, I presume, and shipping them across the Atlantic.”

    Logs await conversion to wood pellets in Burns Lake. Will demand for renewable, “carbon-neutral” wood-fired energy in the UK, European Union and Japan be B.C.’s forests undoing? Photo: © Stand.earth.
    Despite this, the Wood Pellet Association of Canada believes that a surge in wood pellet demand lies ahead and that many more wood pellet mills will be built, including in BC.
    By 2027, the Association says that installed wood pellet production globally could reach 51 million tonnes annually. That would require a 40-per-cent growth in the industry in just six years.
    Where all the wood needed to make those pellets will come from is anyone’s guess.
    If the new pellet mill in Fort Nelson materializes and is built to the scale that Peak Renewables envisions, it would bring the number of pellet mills in BC to 15. Based on last year’s logging rate in BC of 52.3 million cubic metres of timber, the province’s pellet mill industry alone would account for the equivalent of just under 15 per cent of the entire provincial log harvest.
    The combined annual output of all of those mills would be a little more than 3.1 million tonnes of wood pellets, which is less than one third of what Drax’s power plant in North Yorkshire needs every year.
    Can the world’s forests supply enough biomass for another four such power plants while still protecting forest ecosystems and forest industry jobs?
    We may soon find out.
    Ben Parfitt is a resource policy analyst with the Canadian Centre for Policy Alternatives, and a longtime investigative writer. This story was originally published in Policy Note.

    Katherine Palmer Gordon
    Wildlife advocates say that unless urgent action is taken to protect their winter dens from the impacts of industrial logging, black bears may disappear from Vancouver Island within a generation.
    November 29, 2020

    A black bear pulls organic material into its den tree to create a soft floor (video still by Artemis Wildlife Consultants)
    DALLAS SMITH is President of Nanwakolas Council, a coalition of five First Nations on Northern Vancouver Island. Smith can’t understand why black bear dens are protected in the Great Bear Rainforest and on Haida Gwaii, but not on Vancouver Island. “It’s a huge question for the Nanwakolas Chiefs,” says Smith. “Just over the water—literally only a couple of kilometres away—black bear dens enjoy world class protection. Why not here?”
    Biologist Helen Davis, who has spent much of her career researching black bears, is equally bewildered. Despite the fact that privately-owned forest land and forestry tenures on Crown lands cover well over two-thirds of Vancouver Island, and the significant risks logging activity poses to bear habitat, the provincial government is doing nothing to protect dens on the Island. “There is no good explanation for it, says Davis. “None.”
    What’s the problem?
    A winter den may be used by multiple generations of black bears before the tree or stump disintegrates, but at that point, the bears must find other large trees or stumps to create new dens. The inventory of old-growth forest is rapidly shrinking, however, and second-growth trees are now typically harvested before they get large enough to accommodate new dens. 
    Logging technology has become more sophisticated as well. Many tree stumps used to be big enough for dens, but now even the largest trees can be cut to ground level. Helicopter logging and aerial survey technology have also replaced “boots on the ground” in many areas, says Davis, diminishing the ability to spot den trees before they are logged.
    No dens mean no bear cubs. It also means that homeless black bears are straying into the Island’s urban areas, where they are at high risk of being shot. Last January, it was revealed that BC conservation officers had killed 4,341 “nuisance” bears province-wide in just the previous 8 years. Add the impacts of climate change on forest health and declining salmon runs into the equation, and while black bears may not currently be considered a species at risk, it seems likely that will soon change. 
    Jake Smith fears that it will change much faster than we think. Smith is a Mamalilikulla First Nation hereditary chief and manager of the Nation’s environmental Guardian program. He and his fellow Guardians from other First Nations are constantly out on the ground in their territories, monitoring wildlife. Smith says they have been encountering fewer and fewer bears in the last decade. “At this rate,” says Smith sombrely, “we may see the last black bear on Vancouver Island within a generation.”

    Chief Jake Smith (right) with a tranquillized grizzly bear
    Taking it to the Forest Practices Board
     Davis has worked extensively with forestry companies on voluntary den protection guidelines, restored damaged dens, and created artificial ones where there aren’t enough large trees for bears to make new dens naturally. But she says these measures, while helpful, fall well short of what is required to ensure the continued survival of black bears on Vancouver Island. Nothing short of full legal protection of both dens and large trees is required, and urgently.
    In April 2019, Davis complained about the issue to the Forest Practices Board, which monitors and reports on compliance with the Forest & Range Practices Act (FRPA) on Crown lands. The Board responded in January 2020, acknowledging the lack of any governmental effort to afford black bear dens protection on Vancouver Island. While options exist in the FRPA to designate forested areas as having “regionally important wildlife status,” these have never been used for bears.

    Biologist Helen Davis beside a black bear den that was created from a stump and a piece of plywood.
    The Board also noted that the Ministry of Forests, Lands, Natural Resource Operations and Rural Development (FLNRORD) couldn’t say whether current forestry management is effective or not to adequately protect bear dens, or even accurately estimate the current bear population on the Island. The Board has no enforcement powers, however, and refrained from calling for formal den protection. Instead it simply urged the provincial government to “work with First Nations and stakeholders” on den “management.” 
    It was unequivocal in its final conclusion, however: “If second-growth forests are harvested before they develop old-growth features, and old-growth harvest continues, the supply of suitable denning habitat on Vancouver Island will decline.”
    The provincial government’s stance
    A few days before BC Premier John Horgan called a snap election on September 21, the provincial government released an independent report on BC’s old-growth forest management. The report, A New Future For Old Forests, noted that the retention of “forests of old trees” is key for maintaining biological diversity, and concluded bluntly: “The overall system of forest management has not supported the effective achievement of legislated objectives for old-growth forests.” 
    The report recommended prioritizing conservation of BC’s forest biodiversity and, at least until a new strategy is implemented, deferring development in old forests where ecosystems are at “very high and near-term risk” of irreversible biodiversity loss. In its wake, FLNRORD Minister Doug Donaldson agreed to defer any logging on up to 353,000 hectares until August 2022, but the areas being deferred contain little old-growth forest. 
    Shortly before the election on October 24, the provincial NDP party began proclaiming it would protect all old-growth forest, but didn’t provide any details. Pleading election restrictions on provincial government media communications, no one would be interviewed or disclose any more information (as of late November). 
    Green Party MLA Adam Olsen, an advocate for bear den protection, is sceptical that much will change: “My experience of working with the BC NDP on forestry is they have to be dragged kicking and screaming to do anything. Their approach is basically 1950s redux. It’s all about the economic opportunities in logging, and decisions about wildlife are made by the forestry ministry. Everything has been set up to fail these animals.”
    The forestry sector’s stance
    Government agency BC Timber Sales (BCTS) manages 20 percent of the provincial allowable annual cut. BCTS encourages protecting dens on Crown lands, but also emphasizes that BCTS must “be mindful of the licensee’s harvesting rights and their autonomy to direct their own operations.” In other words, logging rights trump den protection.
    The two biggest forestry companies operating on Vancouver Island (in terms of geographic spread) are Mosaic Forest Management Ltd, which handles approximately 6,000 square kilometres of private forest lands and forestry tenures on behalf of Island Timberlands and TimberWest, and Western Forest Products Ltd (WFP).
    Mosaic declined the opportunity to be interviewed, instead emailing a statement from its director of sustainability, biologist Molly Hudson, saying that Mosaic’s forestry decisions are guided by its “Bear Den Policy.” The policy, which Mosaic refused to disclose, requires protection of dens “wherever possible.” When asked for examples of when it has not been possible, Mosaic did not respond. 
    WFP was also not available for an interview. Communications director Babita Khunkhun emailed to say that WFP “actively conserves habitat, including black bear dens, as part of our ongoing commitment to our role as stewards of forestlands.” In addition, wrote Khunkhun, WFP has “rigorous measures in place to identify and retain bear dens on the lands under our care, full-time biologists on staff, and uses independent consultants to design operating plans with the aim of conserving wildlife. Our measures include training field staff and contractors to identify and conserve bear dens and minimize disturbances to hibernating bears. We leave a reserve around dens and between October 21 and April 30, we adapt our road building and harvesting operations in proximity of dens.” 
    Of course, WFP isn’t simply being a good environmental citizen; it’s required to meet provincial objectives for wildlife and biodiversity under BC’s Forest Planning Practices Regulation, including the objective to retain wildlife trees. Those objectives are however subject to the qualification that meeting them will not “unduly reduce the supply of timber from British Columbia’s forests.” WFP’s Vancouver Island forest stewardship plans, a requirement of the FRPA, specify only the minimum areas required to be set aside as wildlife tree retention areas in its cut blocks. The plans contain no specific reference to black bears.
    The Teal-Jones Group, which operates on southern Vancouver Island, is currently the subject of a blockade of intended old-growth logging at Fairy Creek near Port Renfrew. Teal-Jones also declined to be interviewed or provide any information about its guidelines—if it has any—for den protection.
    What happens on private forest lands?
    The FRPA does not apply to private forest land, even if classified as “managed” forest land under the managed forest program, where owners voluntarily commit to managing their properties to meet legislated environmental objectives. 
    According to the Managed Forest Council (MFC), Southern Vancouver Island is home to the largest area of private forest land in the province. The MFC regulates the roughly 18 percent of private forest land that is in the managed forest program (about 800,000 hectares), but was unable to say how much of that is on Vancouver Island. The MFC’s Field Practices Guidelines contain an objective for critical wildlife habitat protection on “agreed terms” with the government, but do not mention bears. 
    On its website, the Private Forest Landowners Association states that its members: “Recognize, and through agreement with the provincial government, protect critical wildlife habitat where it cannot be protected on Crown lands alone.” The PFLA was contacted for more information, but did not respond.
    An unacceptable state of affairs
    Helen Davis says: “Some of the forestry companies are doing better in the last three years, but it’s hard for me to celebrate when we’ve known about the problem for more than 25 years and it’s taken them this long to act.” 
    Davis also points out that even when a den is protected by a logging outfit, it isn’t necessarily done the right way. She has seen lone trees standing on ridge lines, prone to being blown over in a strong wind, and at the sides of busy roads with nothing screening them from traffic. “Bears will probably abandon those dens, because they no longer afford adequate protection.”

    A black bear den tree in the middle of a cut block
    Jake Smith is scathing about the lack of meaningful engagement by both forestry companies and government. “I bring deep knowledge into my role as a Guardian,” Smith says. “I have been on these lands all my life. First Nations understand we need to protect bear habitat now, but everything we say to provincial officials falls on deaf ears.” 
    As to promises to protect old-growth trees, Smith isn’t holding his breath. “Everything is dollar-driven. If the government and forestry companies were really interested in protecting bear habitat or big trees, they would already be working with First Nations to do it.” 
    Indeed, A New Future For Old Forests recommends full engagement of Indigenous leaders and organizations on the development and implementation of policy and strategy to conserve large trees and biodiversity. Dallas Smith, President of Nanwakolas Council, agrees with that: “What’s urgently needed is a collaborative approach between First Nations, forestry companies and government that puts large trees and wildlife first, before dollar signs. It’s frustrating,” he continues. “There’s no leadership by government to take this on, and to bring the forestry industry along with them. Forestry companies tell us they want to partner with us, but they don’t want to do things differently. They want everyone to guarantee their economic future but won’t accept they have to do their part to protect the bears’ future.”
    First Nations are no longer going to accept the status quo, adds Smith. “Those days are over.” Guardians like Jake Smith are out on the land, identifying den trees, both existing and potential, and ensuring the logging companies know about them. Dallas Smith points out that all tenure applications also have to go past the First Nations for review: “They are taking a long, hard look at each one. If it doesn’t meet their standards for protection, they aren’t going to give it a green light.”

    Dallas Smith, President of Nanwakolas Council
    What good looks like
    Jeff Mosher manages Taan Forestry, owned by Xaaydaa GwaayGalang (the Haida Nation). Mosher says black bears play a critical role in Haida Gwaii’s ecosystem: “They’re a top predator in the food chain, for example. Sitka black-tailed deer have been a huge problem here, but the bears are helping keep the population down.” Bears are ecologically important in other ways: “They leave salmon carcasses and salmon-rich bear scat in the forest, containing important nutrients for the trees’ growth.”
    Black bears are culturally significant to the Haida (Taan is a Xaayda word meaning “black bear”) and the company therefore goes “well beyond” minimum protection requirements, says Mosher. “We’re lucky on Haida Gwaii because, thanks to the efforts of the Haida Nation, we have plenty of old-growth trees left that we can set aside. We’re planning for where new dens could go, planting cedar and allowing other trees to reach a sufficient size to be suitable for new dens.” Taan also proactively rehabilitates old dens, and field staff undertake physical ground searches for large trees and bear dens when flagging their cut blocks. Any den found is given a 60-metre reserve (the minimum requirement is 20 metres) in which no logging-related activity is allowed to take place. In prime denning season—November 15 to May 15—the restricted area is increased to 200 metres. 
    These measures aren’t necessarily typical, says Mosher. “Other forestry companies have left Haida Gwaii because it wasn’t worth it to stay. But Taan’s shareholder is the Haida Nation. Protecting bears is a priority, even if it means a lower dividend.”
    Taan is a good model, says Davis, who is in the process of drafting “ideal guidelines” that forestry companies should be required to follow, including requirements to physically survey cut blocks for bear dens. FLNRORD should be mandating not only protection of the inventory of existing bear dens, she says, but planning to provide sufficient habitat in the form of large trees to meet future needs. The recommendations in A New Future For Old Forests should be implemented in full, as soon as possible. The Wildlife Act could be used to protect dens on all forested lands, public or private. 
    A review of the effectiveness of the objectives of private managed forest lands, including protection of key public environmental values, has been underway by FLNRORD for nearly two years. Public feedback summarized on FLNRORD’s website strongly calls for more robust environmental regulation. Given the extent of private forest lands on Vancouver Island, exempting them from regulation would hugely devalue any measures applied on Crown lands only.
    Why it matters
    Black bear wildlife viewing brings substantial tourism revenue into provincial coffers, says Davis, as do hunting licences. Their role in maintaining biodiversity is critical. Not least of all, as Jake Smith points out, the cultural and spiritual interconnection between black bears, the forest ecosystem and First Nations is not only special, it’s fundamental: “That’s why it’s my job to help protect these animals. It’s so important.” 
    If British Columbians and tourists want to continue to enjoy the visceral thrill of seeing the wild black bears of Vancouver Island, and if we want the bears to continue playing their part in the Island’s ecosystem, then something needs to be done, and fast. Otherwise Jake Smith’s grave prediction that we may see the last black bear on Vancouver Island within a generation is all too likely to come true. “We can’t let that happen,” says Smith. “We won’t.”
    Katherine Palmer Gordon is an award-winning non-fiction author and a contributor to numerous anthologies and magazines. She is currently working on her eighth book, showcasing Indigenous leadership in environmental stewardship and community wellbeing in the Great Bear Rainforest and Haida Gwaii.
    Learn more:

    David Broadland
    August 2020
    Buried in 71 ministry timber supply reviews is a huge gap in harvest sustainability that makes Forest Stewardship Council certification of BC wood products an international scam.
    The hidden, but official, harvest sustainability gap
    IS BC’s FOREST INDUSTRY SUSTAINABLE? The BC Council of Forest Industries claims that “BC leads the world in sustainable forestry.” What would be required for COFI’s claim to be true?
    There’s a lot that could be said here. COFI’s claim could be true if its current members and their predecessors, for example, hadn’t logged 97 percent of biologically-productive old forest in BC. It could be true if there weren’t 1800-plus species of plants and animals facing extinction in BC. It could be true if clearcut logging didn’t have a detrimental impact on the temperature, flow and sediment load of salmon bearing streams and rivers. It could be true if clearcut logging didn’t cause an increase in the frequency, duration and magnitude of peak flows of rivers causing major flooding. It could be true if clearcutting an average of nearly 170,000 hectares per year for the last 20 years hadn’t created the conditions that have led to annual carbon emissions from forest management in BC that are nearly three times higher than all the Canadian oil sands projects combined. And so on. But let’s put that record of undeniable environmental harm to one side. Let’s focus on the one measure of sustainability that both the industry and government point to as evidence that logging BC forests at the current rate is “sustainable”: The Forest Stewardship Council’s stamp of approval. FSC certification is dependent on the condition that, to quote its standards for BC, “the rate of harvest of forest products shall not exceed levels which can be permanently sustained.”
    An analysis of BC government data—information that COFI and its members are aware of—reveals this is not the case.
    Consider the logging conducted on 28 Timber Supply Areas (TSAs) in BC’s Interior. The combined allowable annual cut (AAC) in those TSAs is currently 44 million cubic metres. That represents nearly 70 percent of BC’s total allowable annual cut of 63.9 million cubic metres.  If the cut on the Interior TSAs cannot be “permanently sustained,” then BC forest products should not have FSC certification.
    The Forest Act requires that, every 10 years, BC’s Chief Forester conducts a “Timber Supply Review” for each TSA. That review determines what level of harvest could be sustained in the mid-term for that TSA. The “mid-term” is the period between 10 and 50 years out from the date a timber supply review is finalized.
    If the current allowable annual cut is significantly higher than the projected mid-term harvest level determined in  a timber supply review, then the current AAC in that TSA is unsustainable. This also applies to the aggregate of all 28 BC Interior TSAs. If the total AAC for the TSAs is higher than the sum of their mid-term harvest levels, then the current provincial AAC is unsustainable.
    That’s exactly what we find when we add together the individual gaps for all of the 28 timber supply reviews for BC’s Interior. The current allowable annual cut in these TSAs is 44 million cubic metres per year. The timber supply reviews say the mid-term level that’s sustainable is 32 million cubic metres per year. Therefore the current allowable cut in Interior TSAs is 12 million cubic metres on the wrong side of being sustainable.

    In those TSAs where the current AAC is higher than the mid-term harvest level, the timber supply review generally plots a 10-year pathway to the mid-term level. Reductions in the harvest appear to be underway in a number of Interior TSAs, although only time will tell for sure. The downturn in lumber prices in 2019 may account for the drop in actual harvest that we now see. Results for 2020 are incomplete.
    How much forest is being logged to produce that 12-million-cubic-metre overcut? Between 2014 and 2018, one hectare of forest yielded an average of 348 cubic metres of logs in BC. At that rate, the 12 million cubic metre overcut would require that 34,482 hectares—345 square kilometres—of forest be logged.
    As mentioned above, timber supply areas account for about 70 percent of BC’s AAC. The other 30 percent is cut in areas under tree farm licences (TFLs). Province wide, the current allowable annual cut on 34 TFLs is 1.75 million cubic metres higher than the mid-term supply projected by the forests ministry.
    The ministry’s own records, then, show that nearly 14 million cubic metres per year more than can be “permanently sustained” are being cut across the province. That overcut alone results in the loss of 40,000 hectares (400 square kilometres) of forest each year.
    The current total provincial AAC of 63.9 million cubic metres would need to be reduced to about 50 million cubic metres just to meet the Forest Stewardship Council’s rudimentary measure of sustainability.
    For many years BC’s rate of harvest has exceeded the level that the ministry of forests believed could be permanently sustained. The FSC certification has been, to put it as politely as possible, an international scam.
    BC’s forest managers have been quiet about the magnitude of this sustainability gap. That could be out of a concern that if it were known BC wood products don’t meet FSC’s fundamental test, some buyers of BC wood products—like Home Depot—would stop buying. About 80 percent of BC’s manufactured wood products are exported, with 50 percent of that going to the USA. Home Depot’s wood purchasing policy is to give preference to FSC-certified sources. But BC wood doesn’t actually meet FSC’s most basic requirement for certification.
    Origins of the harvest sustainability gap
    How did the sustainability gap develop? If we were to confine our exploration of this question to recent history, the official gap is the result of the loss of Lodgepole Pine stands during the Mountain Pine Beetle infestation. That began in 1999 and peaked in 2005—15 years ago. Since the AAC reductions will play out over the next 10 or so years, we can see that it will have taken 25 years for BC’s government to fully implement cut controls it knew in 2005 it would have to implement.
    Why wasn’t a cut in AAC imposed in 2005?
    Directions to BC’s chief forester by consecutive forests ministers, Rich Coleman and Pat Bell, guided AAC determinations throughout the pine beetle infestation and subsequent salvage logging. Coleman, a close ally of the forest industry, directed the chief forester to maintain or enhance (increase) AAC. Pat Bell, who represented the Prince George district as an MLA, an area hard hit by the beetle, directed the chief forester to show “leniency” in AAC determinations for areas affected by the beetle. These written directions have been guiding AAC determinations even into the era of the current NDP government. In other words, the decision not to lower the AAC was a strictly political decision, not based on science, in spite of warnings from forest and climate scientists at the time.
    By 2006, BC government forest scientists were predicting a loss of up to 80 percent of the “merchantable pine volume” in the province as a result of the beetle infestation. That would have amounted to 1.1 billion cubic metres, equivalent to 22 years of logging in the Interior at the region’s pre-beetle AAC of 50 million cubic metres per year. This estimate has lately been reduced to a 55 percent loss of merchantable pine; at the time, though, decision-makers were told it could be up to 80 percent. Faced with that momentous loss, did forest managers in 2006 question the assumptions under which they had been operating?
    Recall that, by 2006, forest scientists had attributed the immense impact of the Mountain Pine Beetle infestation to higher temperatures in winter and summer, a consequence of global heating and climate change. Warmer winters meant that fewer beetles were killed by cold weather, while hotter summers allowed higher rates of beetle reproduction. Hotter, drier summers also meant greater water stress for pine trees, weakening their natural defences against insect attack.
    Also known to forest scientists at the time was that logging forests initiates an immense premature release of carbon to the atmosphere, and that carbon emissions are the main cause of global heating and climate change. Government scientists were aware, then, that logging forests played a significant role in amplifying natural disturbances like the Mountain Pine Beetle infestation.
    Faced with evidence that logging had helped to create the conditions that led to the beetle infestation, and aware of the tremendous long-term loss to the allowable annual cut, what questions did government decision-makers ask?
    Coleman and Bell, it would appear, ignored the science and made short-term political calculations completely detached from the question of whether industrial forestry was sustainable.
    Their government—and industry—responded with short-term economic thinking. They focussed on cutting as many of the dead and dying trees as quickly as possible—including non-pine trees that just happened to live in the same forests. In taking that approach, they also ensured that forestry-dependent communities would become even more dependent on forestry, even though the forests they depended on were rapidly declining in health and extent.
    The main element of this economic plan was increasing the allowable annual cut in the Interior from 50 million to 68 million cubic metres to facilitate salvage of dead and dying pine trees. Indeed, the harvest of pine—mainly dead—doubled compared to before the outbreak. But forests ministry records show that at the peak of the beetle outbreak in 2005, forest companies had only reduced their cut of non-pine species in the Interior by about 15 percent over the level they were cutting before the outbreak started. Let that sink in. Government and industry were told that BC was about to lose up to 40 percent of the total merchantable volume available in the Interior. Industry and government could have responded by backing off completely from cutting non-pine species. Instead they backed off 15 percent.
    Vancouver Sun journalist Larry Pynn wrote about what happened next in a 2012 investigative report,“In the Wake of a Plague.” He documented the environmental damage resulting from salvage logging southwest of Prince George. Clearcuts had previously been limited to 60 hectares in the Interior, but the forests ministry removed any limit on cutblock size to facilitate salvage logging. Pynn noted that a lack of planning and coordination for the “frenzy of logging” that was occurring led to large clearcuts merging into vast clearcuts. He described a 2009 report by the Forest Practices Board that found “more than half of the harvest since 1978 is now in patches larger than 250 hectares and more than one-third in patches larger than 1,000 hectares... Incredibly, at least seven harvested patches, amalgams exceeding 10,000 hectares—25 times the size of Stanley Park—have emerged...”
    Pynn noted that then BC Chief Forester Jim Snetsinger had expressed “‘significant uncertainty’ about the environmental effects of the 80-percent increase in harvesting in the Lakes, Prince George and Quesnel timber supply areas, particularly in regard to biological diversity and hydrologic function.”
    The result of that “frenzy” is now evident in age class distribution data included in timber supply reviews for the TSAs most heavily impacted by the beetle and subsequent salvage logging. For example, in the Lakes TSA, centred on the forestry-dependent community of Burns Lake, 40 percent of the net Timber Harvesting Land Base (THLB) now has trees between zero and 20 years old, with over half of that between zero and ten years. In the 100-Mile House TSA, 33 percent of the net THLB has forest cover between zero and 20 years of age. By “zero” we mean a bare, unplanted clearcut or burned over plantation. The Quesnel, Kamloops and Prince George TSAs each have 26 percent of their net working forest lying as bare clearcuts or young, fire-vulnerable plantations up to 20 years of age.

    Above: Age class distribution for Crown land in the Lakes TSA. “THLB” is the Timber Harvesting Land Base. Note that 40 percent of the forest cover in the THLB is 20 years of age or younger. Source: FLNRORD.
    A common perception that the “frenzy” of logging was largely a result of the response to the pine beetle is, according to the forests ministry’s record of harvesting in the beetle-affected areas, not accurate. Although the AAC in the affected areas was increased, the harvest records show that there were only two years—2005 and 2006—in which the actual harvest was more than 10 percent higher than the pre-beetle AAC. What the beetle did change was the mid-term supply of harvestable forest and the size of the clearcuts that were allowed, seven of which, as Larry Pynn observed, had grown into 10,000-hectare monsters.
    The cumulative impacts of unsustainable logging
    Starting in 2000, following close behind the increasing area of deforestation, a new phenomenon began to emerge in the Interior: forest fires began to get larger. Much larger. Carbon emissions released by forest fires are estimated by the BC government as part of its emissions reporting obligations. Those estimates show emissions from forest fires have doubled every nine years since 2000. Is the inexorable growth in the size of forest fires related to the growing extent of clearcuts in the Interior?
    Hanceville-Riske Creek Fire 2017.mov
    This 1-minute panoramic video shows a 240-square-kilometre (6 kilometres by 40 kilometres) section of the 2017 241,160-hectare Hanceville-Riske Creek Fire. Note the logging roads and burned over plantations and clearcuts. The lake at the bottom left corner is Tzazati Lake; movement is from south to north.
    A group of Australian forest scientists believe that country’s historically large fires in late 2019 were made worse by logging. In a comment piece in the science journal Nature Ecology and Evolution, they wrote, “…there is compelling evidence that Australia’s historical and contemporary logging regimes have made many Australian forests more fire prone and contributed to increased fire severity and flammability. This occurs because logging leaves debris at ground level that increases the fuel load in logged forests. It also changes forest composition and leaves these areas of forest both hotter and drier…”
    In BC, the vast majority of forest fires are started by lightning. In 2009, forest research scientists Meg Krawchuk and Steve Cumming published the results of an 8-year study of lightning ignition in 60,000 square kilometers of boreal forest in Alberta. They found that wildfires started by lightning ignition “increased in landscapes with more area harvested.” Because of the physical nature of the fuel in a “harvested area”—its dryness, smaller size, etc—it is more readily ignited by lightning than the fuel in an undisturbed stand of trees.
    Krawchuk and Cumming also noted: “In addition to the fine fuels and slash remaining after forest harvest, post-disturbance regeneration might also contribute to flammability.”
    Several science-based studies have shown—in other jurisdictions—that land that has been clearcut burns more severely than intact forest. The relative abundance of fine-grained fuel at ground level in clearcuts, along with higher temperatures, lower humidity and open exposure to winds, all factor into their higher flammability compared with intact forest. As well, clearcuts adjacent to intact forest stands cause those stands to be drier and more flammable, too.
    Clearcut logging changes the hydrologic and thermal functioning of adjacent forests, and on the scale at which clearcut logging has taken place in BC, the practice has changed fire behaviour. Remarkably, no BC forest scientist has undertaken to study the connection between clearcut logging and changes in fire behaviour and size. Or, if they have, their work hasn’t been made public.
    By the way, those Australian scientists came forward because, they said, “much of the conversation in the aftermath of the spring and summer bushfires had rightly focused on climate change, but the impact of land management and forestry on fire risk was often neglected in these discussions.”
    The scientists highlighted this as a concern because land management policy was “well within the control of Australians” and the fires had been used by some sectors of the forest industry in Australia “to call for increased logging in some areas.”
    The “call for increased logging” is already occurring in BC and is coming from the same  line of economically-motivated reasoning employed by industry and government that gave BC the “uplift” in AAC in response to the Mountain Pine Beetle outbreak. Like claims of “sustainable forestry,” expression of such views appears to be part of the human-powered feedback loop that has amplified the catastrophic impact of forest removal on global heating and climate change in BC and elsewhere.
    Coastal clearcuts are growing in size, too
    In the description of the sustainability gap above, I focussed on forests ministry data from 28 TSAs in the Interior. The Mountain Pine Beetle did not directly impact coastal BC, but 150 years of relentless logging has left just as big an impact on coastal forests. However, it’s harder to quantify the impact using ministry records. Data for the nine TSAs in coastal BC is in a state of flux as the ministry completes timber supply reviews following the physical rearrangement of TSA boundaries that arose from the Great Bear Rainforest Agreement.
    The sustainability gap on the coast is most clearly indicated by ministry data on forest cover age class distribution. For example, the 2014 Timber Supply Review for the now-defunct Strathcona Timber Supply Area is revealing. This TSA included a large area of Vancouver Island in the vicinity of Courtenay, Campbell River, Gold River, Tahsis and Zeballos, as well as the adjacent mainland coast and the Discovery Islands.
    The ministry’s 2014 data shows an astounding 64 percent of the area on which logging could occur had trees younger than 60 years old. Thirty-six percent of Strathcona TSA’s area had trees 20 years of age or younger—similar to the Interior TSAs devastated by the beetle. Only 24 percent of the TSA was covered with stands between 70 and 230 years of age—old enough to be logged, and not so old as to cause great controversy. Remaining old-growth forest—240 years and older—occupied only 12 percent of the TSA’s area available for logging, according to the ministry’s data. This was in 2014, and extensive logging since then could only have pushed the average age of trees lower.

    Above: Age class distribution for Crown land in the Strathcona TSA (2014). “THLB” is the Timber Harvesting Land Base. Note that 64 percent of the forest cover in the THLB is 60 years of age or younger. Source: FLNRORD.
    In the Strathcona TSA, most of those trees younger than 60 years are plantation Douglas fir, which has a culmination age of about 80 years. Logging before that age would be an extraordinary waste of a publicly-owned asset, even by the standards of BC’s forest industry. Logging the remaining old growth is increasingly controversial in the midst of a climate emergency and a collapse in biodiversity. That leaves just 23 percent of the area that’s available for logging with trees old enough to log but not so old as to invite blockades of logging roads.
    A review of recent satellite imagery of land that was in the Strathcona TSA in 2014 shows that clearcuts are becoming larger as younger trees become a higher percentage of what’s cut. This trend is in play all across the province.
    Ministry data that covers all of BC show that in the five years between 2002 and 2006, inclusive, an average of 448.6 cubic metres per hectare were harvested. For the five years between 2014 and 2018, inclusive, the harvest per hectare had dropped to an average of 348 cubic metres. The implications of this direction are clear. As time goes on and all old-growth forests in the Timber Harvesting Land Base are liquidated—which has been the implicit policy of the ministry—the area needed to be logged each year in order to achieve the mid-term harvest level will grow even larger. The actual extent of clearcut logging in the province can best be understood by viewing the most recent satellite imagery. Please take a moment to click through the slides at the top of this page that show the vast transformation from primary forests to plantations that’s almost complete.
    The regularly expanding area that gets logged each year means the area of fuel-laden clearcuts and fire-vulnerable plantations younger than 20 years of age will cover an increasingly higher percentage of BC’s land base. As average global temperature increases and the frequency, duration and severity of drought and periods of extreme summer heat increases, it’s difficult to imagine that having a higher percentage of highly-flammable land in BC is going to work out well. Forest fire management in 2017 and 2018 cost BC taxpayers $1.28 billion.
    Other cumulative effects on non-timber values such as the integrity of watersheds and the level of biodiversity will also become increasingly serious as the average age of forests falls and the area of logging grows. The forest-industrial complex is leading BC into an inherently unsustainable future.
    An uncertain future
    The numbers I used above to quantify the gap between the current AAC and the mid-term harvest level all come from timber supply reviews. Those reviews are conducted by BC’s chief forester or deputy chief forester. The estimates developed by the reviews rely heavily on computer modelling of future tree growth and stand yield. Processes that depend on such modelling are only as good as the data that goes into the models—we all know the expression “garbage in, garbage out”—and in BC, that data is known to be, well, uncertain.
    In 2018, Anthony Britneff and Martin Watts, both registered professional foresters, made a 134-page joint submission to a panel of forest scientists and professionals assembled to investigate concerns Britneff had expressed in writing to forests minister Doug Donaldson (there’s a link to the report at the end of this story).
    Britneff and Watts recently summarized their concerns in a 20-page report prepared for Focus, outlining numerous problems associated with the data used to inform the timber supply reviews we analysed for this story (link to report at end of story).
    Watts and Britneff challenge a claim made by various chief foresters in many of the timber supply reviews, that the “best available information” is used in coming to a determination of allowable annual cut. Britneff and Watts provided us with evidence in the case of the Bulkley Valley TSA review, for example, that shows the “best available information” included data that an independent consultant had determined did not meet “Ministry Standards” on several counts.
    They also note that a major source of uncertainty in computer modelling is “ineffective data management,” and recount how, throughout the 1990s and 2000s, the Forest Analysis and Inventory Branch (FAIB) struggled to effectively manage forest growth-and-yield data, which, as a consequence, had become “corrupted.” The result, say Watts and Britneff, is that “any studies or models using FAIB sample plot data prior to 2017 are suspect.” That would impact most existing Timber Supply Reviews and the corresponding AAC determination.
    Watts and Britneff believe the growth and yield models themselves are problematic and cite numerous ways in which the models provide inaccurate and unreliable estimates. For example, consecutive versions of the models produce different results from the same data, and the difference is significantly greater than the timber supply review process reflects in its consideration of uncertainty. As well, an FOI request showed FAIB had no record of the actual data used to calibrate one of the computer models central to estimating timber volume in natural stands. Watts and Britneff also point out that the growth and yield models lack the sophistication needed to reflect actual forest complexity.
    They point out similar modelling problems in determining managed (plantation) stand yields, managed stand site productivity and expected gains from using select seed to produce planting stock.
    All of those factors create a level of uncertainty about the growth and yield estimates used in ACC determinations that, Watts and Britneff say, create serious doubts about projected mid-term harvest levels.
    Astonishingly, the models cannot account for climate change. On this point, Britneff says, “scientists within the forests ministry have reported and published that our Interior managed forests will most likely experience increased tree mortality, reduced growth and reduced utilization as a result of an increase in forest health issues due to climate change.”
    Yet, because the models cannot accommodate climate change, none of the climate-related effects that are expected to reduce growth and yield are included in the timber supply reviews that determine AAC.
    Watts and Britneff note that while current Chief Forester Diane Nicholls has been directed by Minister Donaldson to include “the best information on climate change and cumulative effects of multiple activities on the land base” in the timber supply review process, Nicholls has effectively demurred.
    In a 2019 timber supply review for the Lakes TSA, she deferred consideration of cumulative effects to the land use planning process and stated “the potential rate and specific characteristics of climate change in different parts of the province are uncertain. This uncertainty means that it is not possible to confidently predict the specific, quantitative impacts on timber supply.”
    The chief forester went on to state that “no responsible AAC determination can be made solely on the basis of a precautionary response to uncertainty with respect to a single value,” but provided no justification for this statement.
    Britneff and Watts observe that Nicholls’ response “is in stark contrast to the federal government’s guidelines on taking a precautionary approach in the absence of full scientific certainty.”
    They point out that the chief forester “uses the concept of uncertainty to exclude factors that would lower the AAC, such as climate change, while at the same time ignoring the uncertainty associated with factors that enable an increase—or simply increase the AAC—such as natural and managed stand growth estimates, genetic gain estimates for select seed, and the increased productivity assigned to managed stands.”
    The end result, they say, is an “AAC determination process that clearly favours timber harvesting over integrated decision making, leading to an AAC that is too high and unsustainable, particularly in the mid-term.”
    Above, we noted that the mid-term harvest level determined by Chief Forester Nicholls and her predecessors is some 14 million cubic metres lower than the current AAC. Yet Britneff and Watts make a strong argument that the process and technology used to come to that determination are actually overestimating that mid-term harvest level.
    It should be clear to everyone that what’s happening to BC’s forests is not sustainable. Coupled with the widespread acceptance by governments and people around the globe that planet Earth faces a climate emergency and a collapse in biodiversity, BC’s government needs to act. The only meaningful action that can be taken is to conserve what remains of natural habitat in biologically productive forests and to reduce emissions, particularly large-scale sources of carbon like BC’s forest industry. For BC’s government to continue to hide the extent of the damage being done by what is now a minor contributor to the provincial economy is unconscionable.
    David Broadland’s grandfather, a Russian immigrant who came to Canada in 1911, was the chief cook in a 200-man logging camp near Campbell River on Vancouver Island. The logging show was operated by Bloedel Stewart & Welch. At that time, the forest industry was a major factor in BC’s economic health. Times have changed.
    Submission by Anthony Britneff and Martin Watts to the Forest Inventory Review Panel (2018)Britneff and Watts 2018 submission to the Forest Inventory Review Panel.pdf
    Summary of above submission provided to Focus: Summary of Britneff and Watts 2018 submission to the Forest Inventory Review Panel.pdf
    You may also be interested in David Broadland’s “Forestry doesn’t pay the bills, folks”

    David Broadland
    March 2020
    Wildfires in BC are getting bigger. Much bigger. The forest-industrial complex blames fire suppression. The evidence suggests large areas of fuel-laden clearcuts are changing fire behaviour.
    A RECORD COMPILED BY BC GOVERNMENT SCIENTISTS since 1990 captures in cold, hard numbers the scale of the ecological apocalypse underway in BC’s Interior forests. The record shows that since 1990, the amount of carbon released into the atmosphere by wildfires in BC has doubled every nine years.
    For the nine years from 1990 to 1998, scientists estimated 52.3 million tonnes (megatonnes) of greenhouse gas emissions were released to the atmosphere by forest fires. From 1999 to 2007, that more than doubled to 120.9 megatonnes. Over the next 9-year period, ending with 2016, the total released doubled again, to 249.8 megatonnes.
    In 2017, 1,353 fires burned 1.22 million hectares, including some very large fires, all in BC’s Interior: the 191,865-hectare Elephant Hill Fire, the 545,151-hectare Chilcotin Plateau Fire—which was actually the merging of 20 separate fires—and the 241,160-hectare Hanceville Fire, another merging of smaller fires into a mega-fire.
    BC scientists estimated 176.6 megatonnes of greenhouse gases were released into the atmosphere by those 2017 fires.
    The next year was even worse: 2,117 fires burned 1.36-million hectares. Scientists haven’t yet made public their estimate of greenhouse gases released into the atmosphere for that year, but it will likely be close to 200 megatonnes.

    Greenhouse gas emissions from wildfires in BC have doubled every nine years since 1990. The last 3 years suggest that rate of increase will continue.
    Last year—2019—saw a cooler, wetter summer and a relief for wildfire fighters. Yet the first three years of the current 9-year interval have already released 75 percent of the 500 megatonnes needed to maintain the doubling of the carbon released every nine years.
    All of the biggest fires, in both 2017 and 2018, occurred in areas where the impact of Mountain Pine Beetle infestation over the past 20 years has been most intense. The beetles have affected 16 million hectares of BC forests—an area more than five times that of Vancouver Island.
    Large areas of the 2017 fires overlapped salvage clearcuts of beetle-killed trees. In a report on the impact of the 2017 fires, the Ministry of Forests noted that about 80 percent of the fires’ area occurred in forests “significantly impacted” by Mountain Pine Beetle. The four largest fires of 2018 also burned in areas damaged by beetle infestation.
    The magnitude of the release makes provincial and municipal plans for reducing carbon emissions in BC appear functionally pointless—like trying to drain the Fraser River with a garden hose.
    Can anything be done to slow or reverse the trend toward bigger wildfires? That would depend on what’s causing wildfires to be bigger and whether or not humans can reverse the cause.
    Recently, the Vancouver Sun reported that two BC forestry scientists, Werner Kurz and Lori Daniels, are representing Canada in “a $1-million partnership between Canadian researchers and the US Department of Agriculture Forest Service to ‘de-escalate the devastating forest wildfires that are increasingly occurring due to climate change.’”
    The Sun reporter, Randy Shore, interviewed Daniels, a professor of forestry at UBC, who told him: “We are paying a huge cost in carbon today because we were so good at putting out fires in the past.”
    Daniels believes wildfires are getting bigger because of the build-up of fuel in forests, which Shore described as “fallen needles and dead branches.” If fire hadn’t been suppressed, those needles and dead branches would have been burned off by natural fire.
    Daniels offered a solution: “What happens if we thin out the forest and reduce the stress on those trees competing for a limiting resource like soil moisture?...Will the trees left behind grow faster and sequester more carbon? There is lots of evidence that under some circumstances, that is the case.”
    For such thinning to be effective at reducing fuel in the forest it would have to be removed. Daniels suggested the possible development of a new biomass economy: “If it is going to be burned, we should do that at high efficiency and displace fossil fuel with a form of sustainable energy. Lots of small communities are still reliant on fossil fuels, so these are linkages that we can make.”
    The idea sounds eminently reasonable, doesn’t it? But what if it’s wrong? What if “fire suppression” is not at the heart of escalating wildfires? Do forest scientists ever get things wrong?
    The forest-industrial complex—the forest-interested government agencies, industry, universities and media—that has led BC into the black-box carbon trap of exponentially-increasing emissions outlined above, is unable to hold itself accountable for the environmentally disastrous forestry practices it devised that have contributed disproportionately to a warmer climate. Its miscalculation of what was sustainable created giant clearcuts that shrivelled the forests’ ability to sequester carbon. That played a significant role in making winters too warm to kill the Mountain Pine Beetle, and that change was followed by widespread pine mortality, immense areas of salvage clearcuts, and now giant wildfires roaring through those same clearcuts.
    Now, it appears, the forest-industrial complex is diverting our attention away from what’s actually happening on the ground. The accumulation of giant clearcuts has altered microclimates and left hundreds of millions of tonnes of fuel on the ground. And now it’s burning, easily ignited by lightning, and affecting fire behaviour.

    A BC Wildfire Service air tanker tackles an aggressive wildfire in a clearcut
    An August 2018 “incident update” by the BC Wildfire Service describes the “behaviour prediction” for a fire near the Baezaeko River west of Quesnel: “Fire activity will have the potential to challenge control lines; don’t let your guard down. Be aware of gusty winds and the effect on fire behaviour, if only for a short time. The slash blocks have more fuel loading than the standard slash fuel type, expect higher intensity. This higher intensity can cause fire whirls to develop; this would cause rapid fire growth and increased spotting potential.”
    “Fire whirls” are like small tornados, formed by the rapid uplift of air in an intense fire. “Spotting” is the ability of fires to send out embers far ahead of a fire and start new fires. Wildfire Service incident updates commonly note the impact of logging slash in clearcuts that makes fires burn more intensely and dangerously.
    Yet nowhere to be seen in the forest-industrial complex’s description of what needs to happen now is an examination of the ways in which a landscape increasingly dominated by very large clearcuts has changed the behaviour of fire in BC’s forests. Nowhere to be seen is the option of reducing the volume of timber cut in BC to allow the provincial forests’ carbon sequestration capacity to recover.
    Unless you are delusionally optimistic, there’s no reason to believe that feeding tree parts to industrial burners will reduce the acceleration in the thermal destruction of BC’s forests. Once jobs are created to feed the burners, those bio-jobs will become the thing that must be protected at all costs. That way of thinking is what gave BC the beetle infestation in the first place.
    The stated belief that the acceleration in wildfire emissions is due to past fire suppression appears destined to become one of the great, all-time dead-end ideas in BC’s short but dramatic history of ecosystem disruption.
    Unless there is some real change in the fundamental factor driving this acceleration—the loss of BC forests’ carbon sequestration capacity—then between 2026 and 2034, the fifth nine-year interval in this exponential increase, BC forest fires will produce a total of 1,000 megatonnes of CO2-equivalent emissions, or an average of 110 megatonnes per year. The Mountain Pine Beetle infestation affected 16 million hectares of BC forests. Only a small fraction of these have burned, so there’s a high risk of more and bigger fires in the coming years.
    An aside to those folks who might think the scientists are purposely overestimating emissions from wildfires in order to justify amping up industrialization of forests: the estimate for 2017 works out to about 50 tonnes of forest carbon per hectare, which is less than what would be left on the ground after an Interior clearcut.
    Let’s put the magnitude of the wildfire emissions problem in perspective. BC’s carbon emissions—from all sources except forest-related emissions—totalled 64 megatonnes in 2017. CleanBC, the provincial government’s emissions reduction plan, has so far been able to identify, on paper, just 19 megatonnes of annual reductions it hopes will happen by 2030. LNG Canada at Kitimat will trigger 9 megatonnes. Teck Resources’ Frontier oil sands project was going to produce 4 megatonnes. The City of Victoria is targetting about 0.390 megatonnes through its climate action plan.
    Compare those drops in the bucket to the 110 megatonnes of annual emissions from forest fires alone that now seem certain to be in our near future. Other net emissions—the loss of forest carbon sequestration capacity and the premature decay of forest carbon initiated by harvesting—caused by BC’s forest industry and tallied in Defusing BC’s big, bad carbon bomb in our last edition—are upwards of 190 megatonnes each year.
    It’s the Province’s official position that it can’t do anything about any of these forest-industry-caused emissions. Although the exponential growth in emissions from wildfires outlined above appears in the British Columbia Provincial Greenhouse Gas Inventory, as do other emissions related to BC’s forest industry, they are not counted in BC like your car’s tailpipe emissions. Is that because they don’t impact climate stability? No, it’s because the Province claims nothing can be done about these net emissions.
    In the Province’s Methodology Book for the British Columbia Provincial Greenhouse Gas Inventory, the authors state that emissions from forest fires “are more volatile and subject to natural factors outside of direct human control and so are not reported as part of BC GHG emissions totals…”
    Yet it has become an article of faith of the forest-industrial complex that historical fire suppression by humans is the primary cause of big fires, and big fires mean higher emissions. This official confusion is disconcerting and demands a ground-truthing expedition.
    FOLLOWING THE FIRES OF 2017, which included the 191,865-hectare Elephant Hill Fire, the Ministry of Forests’ Pat Byrne, district manager of the 100-Mile House Natural Resource District, told the 100-Mile Free Press in July 2018: “Much of the area that was burned by both the Gustafsen and Elephant Hill fires, they burned over fire-dependent ecosystems…These ecosystems rely on fires as much as the soil and the air and the water they get. It’s how they evolve…The forest relies on a 10 to 15 year fire cycle to thin out the vegetation and create a more open forest…Removing fire from the landscape resulted in a dense forest and created conditions where fire could burn hotter and more aggressively than a natural setting would have ever allowed.”
    Byrne told the Free Press: “You’ve got a fire-dependent ecosystem and you exclude fire from it. What do you expect is going to happen?”
    The usual refutation of the “fire suppression causes big fires” belief is that “The Big Burn” of 1910 in Idaho, Montana, Washington and BC, occurred before the era of fire suppression had begun. The Big Burn, also known as “The Great Fire,” “The Devil’s Broom,” and “The Big Blow-up,” burned through 1.2 million hectares, which just happens to be about what was burned in BC in 2017.
    The Ministry of Forests’ own records show that four of the ten largest fires (in area) in BC’s recorded history occurred before the era of fire suppression began.
    If big, aggressive fires occurred before aircraft were able to bomb fires with water and fire retardant, how valid is the forest-industrial complex’s claim that “fire suppression” is the main cause for today’s big fires?
    There’s even more-convincing evidence that the fire-suppression-causes-big-fires narrative may be a big smoke screen blown into the talkosphere so the forest industry can cut more trees.
    One of the tools that’s available today that allows us to ground-truth the claims of the forest-industrial complex—to actually see what wildfires are burning—is satellite photography. We can compare aerial images taken before a fire with images taken afterward to see what was burned, and how completely it burned.
    Satellite photography of the area burned by the Elephant Hill Fire north of Arrowrock Provincial Park shows that much of the area had been severely modified in the last 20 years (below). At the time of the fire, it was mostly regrowth in clearcuts and unplanted clearcuts. In this area there was little “dense forest” left to burn. On Ministry of Forests maps of the Mountain Pine Beetle infestation, this area is shown as having a 71 to 100 percent rate of “kill” of lodgepole pine, hence the widespread clearcuts left by salvage logging.

    (Click image to enlarge) This part of the Elephant Hill Fire, according to Ministry of Forests’ mapping of the Mountain Pine Beetle infestation, had been heavily impacted by beetle kill. Earlier satellite images, taken after the salvage logging but before the fire, show some areas with regrowth and other areas with none. Only the oldest regrowth survived the 2017 fire. Many thousands of square kilometers of former lodgepole pine forest, killed by beetles and salvaged, were burned in 2017 and 2018. The beetle infestation has affected 16,000,000 hectares of BC forest, only a small fraction of which has been burned by 2020.
    The area shown above is typical of the juxtaposition of giant fires and massive clearcuts that are transforming BC’s interior forests into a wasteland. The density of mature forest has been reduced to thin ribbons of dark green separating seemingly endless burned-over clearcuts. Only the roads and wetlands are fireproof.
    Satellite imagery allows us to see, close-up, the fate of specific features engulfed by the fires. The images below show one such area burned by the Elephant Hill Fire. The first image below was taken about 2010. It shows clearcuts that have been partially replanted. Note the light green regrowth, the unplanted areas and the extent of more mature trees (dark green). Note the large piles of slash piled close to the roads. After this image was taken, more logging took place before the Elephant Hill Fire burned this area in 2017.

     Click image to enlarge
    Compare that image with the photo below. This satellite image was made in 2019, about two years after the Elephant Hill Fire. Note that most of the regrowth in the clearcut has been killed or damaged. Much of the unplanted area of the clearcut has burned (light gray areas). Some of the mature trees that were left around the clearcuts have survived while others were killed by the fire. The slash piles are now ash piles. These features are typical of BC’s biggest wildfires in the Interior.

    Click image to enlarge
    The satellite photography also shows that areas where extensive mechanical thinning had taken place survived the fire in some places but were incinerated in others. Corridor thinning mimics, to some extent, natural fire’s ability to open up a forest stand, but it’s an interim stage that will lead to a clearcut in the not-too-distant future. An extensive east-west belt of such thinning running across the entire pathway of the Elephant Hill Fire north of Loon Lake did not prevent the fire from moving northwards.
    The same mixed fire-survival performance of extensive thinning efforts can be found in satellite photography of the Hanceville Fire.
    (The most current satellite photography can be found at inaturalist.org.)
    The satellite photography shows that slash, left in logged-over areas, was an important factor in the eventual size of the Elephant Hill Fire. Equally evident from the satellite photography is that any plantation regrowth younger than about 20 years has been largely wiped out.
    Satellite photography of the huge areas burned by the Hanceville and Plateau fires of 2017 shows the same general outcomes: vast areas of clearcuts burned clean with the small patches of adjacent, mature forest that had been left between clearcuts moderately to severely damaged.
    The 16 million hectares of BC forest that have been impacted by the beetle infestation, combined with decades of extensive clearcutting of live conifer forests, has created an apocalyptic landscape in BC’s interior forests. Ministry of Forests’ reports on the 2017 and 2018 fires show large areas of the Interior—entire forest districts—where the “cumulative percentage of merchantable forest volume killed since 1999” is “greater than 45 percent.” This description, of course, doesn’t include the loss before 1999.
    The “killing” is the result of the logging of live trees, beetle infestation and wildfires. The result is a vast open area in the Interior that is littered with hundreds of millions of tonnes of tree parts in various stages of decay, all of it potential fuel for wildfires, just waiting for ignition. Although much of this area hasn’t been replanted, that which has been is also, under the right conditions, potent fuel requiring only ignition.

    Flames fuelled by clearcut slash flare outward from the Chutanli Lake Fire, July 30, 2018
    IN BC, THE CAUSE OF IGNITION for every wildfire is determined and recorded by the BC Wildfire Service, and so is each fire’s physical size. These records end up in the National Forestry Database. They show us that between 1990 and 1998, 59 percent of the area burned by wildfires in BC was attributed to fires ignited by lightning. Over the next nine-year period that rose to 81 percent. In the nine-year period ending with 2016, it rose to 85 percent. So lightning has become the overwhelming source of ignition of large wildfires in BC.
    The records also show that while the total area burned as a result of lightning ignition has risen, the actual number of forest fires started by lightning has fallen. Between 1990 and 1998, there were 12,158 fires ignited by lightning. During the next 9-year interval, that fell to 8,837 fires. That was followed by 9,339 fires ignited by lightning in the 9-year interval ending with 2016.
    The growth in the area burned by wildfires ignited by lightning isn’t the result of more lightning strikes hitting the forest—a factor that would be beyond human control.
    Now here’s the most critically important point in this story: Scientific research shows lightning is more likely to start a fire if it hits a harvested area than if it hits a forested area.
    Back in 2009, forest research scientists Meg Krawchuk and Steve Cumming published the results of an 8-year study of lightning ignition in 60,000 square kilometers of boreal forest in Alberta. They found that wildfires started by lightning ignition “increased in landscapes with more area harvested.” Because of the physical nature of the fuel in a “harvested area”—its dryness, smaller size, etc—it is more readily ignited by lightning than the fuel in an undisturbed stand of trees.
    Krawchuk and Cumming also noted: “In addition to the fine fuels and slash remaining after forest harvest, post-disturbance regeneration might also contribute to flammability.”
    The forest-industrial complex has, it would seem, created an immense area in the Interior of BC that is a crude incendiary device—like a Molotov cocktail—that only needs the right conditions of temperature, humidity and a bolt of lightning to burst into flames.
    The satellite imagery of BC’s recent big fires certainly confirms Krawchuk’s and Cumming’s speculation about the flammability of regrowth in clearcuts. In BC’s dry Interior forests, those plantations act like kindling and, in areas where fires burned in 2017, there’s now little remaining of 20 to 25 years of a build-up of kindling—or, as the forest-industrial complex calls it: “The Forests for Tomorrow.”
    Let me summarize.
    First, we know from National Forestry Database records that lightning strikes are igniting fewer fires, but the fires ignited by lightning are becoming larger.
    Second, we know from Ministry of Forests records and satellite photography that the cumulative area of harvested forest in BC’s Interior has grown very significantly in the last 20 years, and in many areas exceeds the amount of forested land.
    Third, we know that the big fires in BC’s Interior in 2017 all involved heavily harvested areas where either beetle-killed or live trees had been removed.
    Last, scientists have found that the more a landscape is harvested, the more lighting ignition occurs, and that’s because harvested areas have fuel on the ground that is more ignitable than standing forest.
    These facts strongly suggest that it’s the growing expanse of fuel-laden clearcuts that are producing larger fires.
    Climate change is no doubt making the fuel drier and more ignitable, and perhaps adding a little strength to winds that fan the fires. But it’s also possible that vast areas of clearcuts are creating those same effects all by themselves. Removal of the tree canopy allows the sun to heat the forest floor more readily, which reduces humidity and raises temperature. Removal of trees allows wind speed at forest-floor level to be higher in clearcuts than would be the case in an expanse of mature forest. Leaving 40 to 60 percent of the biomass of the forest in a clearcut creates a huge fuel load that is apparently readily ignitable by lightning and easily fanned by wind.
    Focus has obtained numerous photographs taken from fire-spotter aircraft, including those used in this story, that depict fires that apparently started in clearcuts, or clearcuts engulfed in flames. So there’s good evidence on the ground that this is happening. But this version of what’s happening is definitely not the narrative that is coming from the scientists whose role it is to keep timber flowing from the forests to the mills.
    The forest-industrial complex is pointing its collective finger at drier conditions created by climate change, and too dense fuel in the forest as a result of fire suppression. Its favoured solution appears to be to go into the forest and remove more trees.
    It’s possible that the forest-industrial complex is suffering from the cognitive bias known as the law of the instrument: Give a man a hammer, and he will find that everything he encounters needs pounding.
    CONSIDER THE MAGNITUDE OF THE PROBLEM: In 1997, BC’s 60 million hectares of forests were able to sequester the equivalent of 103 megatonnes of carbon dioxide each year. Wildfires were emitting an average of 6 megatonnes each year.
    Twenty-three years latter, BC still has 60 million hectares of potential forestland, but has lost those 103 megatonnes of sequestration capacity. Wildfires are now emitting, on average, 58 megatonnes per year.
    Those two changes amount to a net increase of 155 megatonnes per year in emissions related to our provincial forests. That doesn’t include the 88 megatonnes of emissions that we must attribute to the premature decay of wood that will result from harvesting trees for wood products each year.
    The prognosis is bad. Going in the same direction, a further increase in the industrial use of forests by mining them for bio-energy will, if the past is any predictor of the future, just make things worse.
    As I pointed out last edition, the lowest-hanging fruit for BC in mitigating the damage being done to climate stability by its forestry practices is to end the export of raw logs, most of which are cut from coastal forests. If the Province banned raw log exports and reduced the annual allowable cut by 6.5 million cubic metres, 11 megatonnes of annual carbon emissions would be eliminated.
    We previously estimated that would impact 1,650 jobs. In a future low-carbon economy (assuming that’s where we are going), there would be no possible justification for allowing 1,650 jobs to produce 11 megatonnes of net emissions. Instead, the forest-industrial complex needs to start redirecting resources to jobs that don’t destroy forests. It needs to reinvent itself into an agency that can bring the forest back to its former health and capabilities.
    As it ponders its future, perhaps the forest-industrial complex ought to take to heart the words of Aldo Leopold, the American author, philosopher, scientist, ecologist, forester, conservationist, and environmentalist: “We abuse land because we regard it as a commodity belonging to us. When we see land as a community to which we belong, we may begin to use it with love and respect.”
    David Broadland is the publisher of Focus. He is working with a group of scientists, journalists and citizens to explore the potential for conserving selected BC forests for carbon sequestration, biodiversity conservation and short-distance tourism potential. He welcomes your feedback.

    David Broadland
    January 2020
    Over the past 20 years, BC forests were so heavily logged that net carbon emissions caused by the industry are now twice as large as Alberta’s oil sands.
    AT THE HEIGHT OF LAST SUMMER'S ECONOMIC MELTDOWN in the BC interior’s forest industry, Marty Gibbons, president of United Steelworkers Local 1-417, based in Kamloops, told the Canadian Press: “Something needs to change immediately or these small communities that don’t have other employers are going to wither and die.” Gibbons concluded that “the largest driving factor is the Province’s complex stumpage system that results in high fees.”
    The average stumpage rate in BC—the price the Province charges forestry companies for harvesting a cubic metre of tree on Crown land—was around $23 for both the interior and the coast in 2019 (1). But the average stumpage paid for timber harvested from Crown land by major raw log exporters like TimberWest and Western Forest Products in the Campbell River Natural Resource District was much lower, ranging between $8 and $11 per cubic metre. Smaller companies paid even less—as little as $5 per cubic metre. Yet raw logs for export were selling at an average price of $128 per cubic metre through 2019 (2).
    Raw logs worth $4.146 billion were exported from BC to other countries for processing over the past five years (3). This huge overcut—unnecessary to meet domestic and international demand for BC’s finished wood products—has averaged 6.5 million cubic metres per year over those five years, equal to 41 percent of the total cut on Crown and private land on the coast (4). So claims that high stumpage rates in BC are the problem that needs to be solved seem out of touch with reality.
    But Gibbons is still right: something “needs to change immediately.” The required change, however, might be more than what he’s thinking. The interior’s forest industry has been destabilized by two climate-change-related phenomena—devastating wildfire and explosive mountain pine beetle infestation—that have been amplified by the immense extent of BC’s clearcut logging. Gibbons wants to knock a few bucks off the forest companies’ costs so they can run more shifts at the mills. What’s really needed, though, is a much deeper kind of change, one that would quickly transform BC’s forest industry. To start, we need to end the export of raw logs and shift that same volume to a new class of forest: protected forest-carbon reserves.
    There’s an urgent need to remove carbon from the atmosphere and reduce emissions at the same time. The only way to remove carbon on a large scale and then store it safely for a long time is to not harvest healthy, mature forests of long-lived species.
    The next 10 years need to be full of bold ideas as we look for and find solutions to the climate crisis. Initiatives like the Carbon Tax in Canada are necessary to disincentivize the use of fossil fuels, but planet Earth isn’t going to give us time to tax our emissions into submission. We need some quick shifts that will cut 10 megatonnes with a few strokes of the Premier’s pen. In BC, protecting the forest instead of destroying it is our only realistic option. If we don’t do this, we’ll run the risk that the rest of the world will start counting the emissions we are releasing from our forests and begin to think of us—and our manufactured wood products industry—as the Brazil of the North.
    Perhaps what’s required most at this critical moment is recognition by the BC government that an international market for sequestered forest-carbon is coming soon, and that forest companies need to start switching from destroying publicly-owned forests to protecting them. Not just old-growth forests, but mature second-growth stands of long-lived species, too.

    Forest loss (yellow) on Vancouver Island and the south coast mainland between 2000 and 2018 Source: Hansen/UMD/Google/USGS/NASA
    Our government leaders don’t seem to be thinking straight yet. Instead, deforestation on the BC coast is accelerating. Over the past six years, the area of coastal Crown land that was clearcut increased 16 percent over the previous six-year period. Our provincial forest’s capacity to serve as a carbon sink has vanished. Its catastrophic collapse is recorded in a 20-year segment of the Province’s annual inventory of provincial greenhouse gas emissions. In 1997, BC forests could sequester the equivalent of 103 megatonnes of CO2 annually. By 2017 that had fallen to 19.6 megatonnes (5). From 2020 on, our forests will be a net source of emissions—even without including those from wildfires. The image above shows—in yellow—the physical area of Vancouver Island, and the adjacent mainland coast, that was clearcut between 2000 and 2018. Vancouver Island has become an ecological war zone. But a different economic role for the forest is emerging, one that doesn’t destroy it.
    That new purpose is highlighted by a gaping hole in Canada’s plan to meet its emissions reduction commitment under the 2015 Paris Agreement. Canada’s 2018 progress report to the UNadmits there’s a nearly 100-megatonne gap in the plan to 2030 (and this assumes the rest of the plan will actually work). How will Canada live up to its promise over the next 10 years? The progress report puts it this way: “Potential increases in stored carbon (carbon sequestration) in forests, soils and wetlands will also contribute to reductions which, for a country such as Canada, could also play an important role in achieving the 2030 target.”
    The report offers no other possibility for filling that gap.
    Canada, then, will likely depend on using the carbon sequestration capacity of its forests to meet its Paris Agreement commitments.
    Article 5 of the Paris Agreement, through its reference to a commitment in Article 4 of the United Nations Framework on Climate Change, encourages all countries to “…promote and cooperate in the conservation and enhancement, as appropriate, of sinks and reservoirs of all greenhouse gases not controlled by the Montreal Protocol, including biomass, forests and oceans as well as other terrestrial, coastal and marine ecosystems.”
    Depending on how Article 6 of the Paris Agreement is eventually detailed (its development was stymied at the Madrid COP), it’s possible that an international market mechanism for forest carbon is coming, and it can’t come soon enough.
    The over-exploitation of BC’s forests has added to an explosion in net carbon emissions, delivered to the atmosphere each year by the forest industry’s endless road building and progressive clearcuts. Below, I’ll show why this now amounts to over 190 megatonnes every year (and possibly much more), a far more powerful carbon bomb than is being dropped by Canada’s oil sands industry (6). It’s long past time for us to understand the inner workings of the bomb and to defuse it.
    There are two separate parts to BC’s bomb, and I will take you through each of these in some detail below.
    First, when a mature or old forest stand is logged, assuming it’s healthy, the living biomass that’s killed and cut up into small pieces begins a premature process of decay, often hundreds of years before that decay would occur naturally.
    Secondly, when that mature or old, healthy stand is clearcut, its potential to sequester carbon in the future is lost and it could then take anywhere from 60 years to several hundred years before a new replacement forest could sequester as much carbon as was being stored in the previous stand.
    Let me take you through the inner workings of each of these parts of BC’s carbon bomb. First, let’s consider the magnitude of the carbon emissions released when wood prematurely decays.

    Biomass left behind after clearcut logging on Crown land on Quadra Island (Photo by David Broadland)
    WHEN AN AREA OF FOREST IS CLEARCUT, three decay processes are initiated that result in emissions of carbon to the atmosphere.
    First, the removal of the trees allows the sun to warm the forest soil to a higher temperature than was possible when it was shaded by trees. That additional warmth speeds up decay processes and the release of greenhouse gases, a process somewhat akin to the melting of permafrost in the Arctic. Soil scientists tell us that forest soil contains even more carbon than all the trees and other biomass that grow in it. Recent studies have reported that as much as 20 percent of the carbon in the layer of soil at the forest floor is released to the atmosphere after an area of forest has been clearcut. This release is a wild card in our emerging understanding of the impact of clearcut logging on carbon emissions. For now it remains unquantified, but it’s definitely not zero.
    The second decay process begins after an area of forest is clearcut and the unused parts of trees left on the forest floor begin to decay. In his 2019 report Forestry and Carbon in BC (document at end of story), BC forest ecologist Jim Pojar estimated that 40 to 60 percent of the biomass of a forest is left in a clearcut. That includes the branches, stumps, roots, pieces of the stems that shattered when felled, the unutilizable tops of the trees, and unmerchantable trees that are killed in the mayhem of clearcut logging.
    For our purpose, we will use the mid-point of Pojar’s 40 to 60 percent estimate: half of the biomass is removed, and half remains on the forest floor. The Ministry of Forests’ log scaling system tells us what volume of wood is removed from the forest as merchantable logs. We then assume that an equal volume of wood is left in the clearcut.
    In 2018, the total volume of wood removed from BC’s forests, as reported in the ministry’s Harvest Billing System, was 54.1 million cubic metres. As per above, we are using the same number for the volume of wood that was left in clearcuts all over the province. So the total volume of wood in play is 108.2 million cubic metres. Both pools of wood—the wood left behind and the wood trucked away—begin to decay after a relatively short period of time following harvest. Each cubic metre of wood will eventually produce about 0.82 tonnes of CO2-equivalent emissions (7). So the wood left behind will produce 44 megatonnes and the wood trucked away will also produce 44 megatonnes of CO2-equivalent emissions—eventually.
    The average 6.5-million-cubic-metre cut for raw log exports accounts for 11 megatonnes of that 88-megatonne carbon bomb.
    You might have heard that the carbon in the logs that are harvested and turned into finished wood products will be safely stored in those products indefinitely. But the Ministry of Forests’ own research shows that after 28 years, half of the carbon in the wood products is no longer being safely stored; at 100 years, only 33 percent of the wood is still in safe storage (graph below). The rest will have returned to the atmosphere or is headed in that direction.

    This BC Ministry of Forests graph shows how the carbon stored in wood products declines over time. After 28 years, half of the carbon stored has been lost to the atmosphere. At 100 years, 33 percent remains.
    BC’s Greenhouse Gas Inventory quantifies the magnitude of the currently acknowledged deterioration of wood products. For 2017 it noted that “Emissions from Decomposition of Harvested Wood Products” contributed 42 megatonnes annually to the provincial greenhouse gas inventory, which is close to our estimate of 44 megatonnes for 2018 (8).
    For ethical reasons, we ought to attribute all of those future emissions to the year in which the wood was harvested.
    Note that the period of safe storage of carbon in wood products is much shorter than the expected life of most of the tree species that grow in coastal BC. A Sitka spruce is capable of attaining 700 years of age. Douglas fir commonly reach 600 to 800 years of age, and have been known to survive to 1000 years. Red cedar can reach even greater longevity. The Cheewat Lake Cedar near Clo-oose has been estimated to be as old as 2,500 years.
    The coastal forest’s longevity—compared with BC’s interior forests—arises, in part, because the coast’s wetter climate lowers the incidence of drought and wildfires that could kill the forest. As well, there are no mountain pine beetles in coastal BC.
    By eliminating the export of raw logs and instead protecting an equivalent volume of long-lived coastal stands each year, 11 megatonnes of CO2-equivalent emissions could be avoided. That would be a much more substantial reduction in provincial emissions than, for example, the BC Carbon Tax has produced after 10 years.

    The author measures the circumference (27 feet) of an apparently healthy 700-800-year-old Douglas fir on Quadra Island. Douglas fir are known to live for as long as 1000 years.
    THE SECOND PART OF THE BOMB—the loss of sequestration capacity—is a measure of the net growth, per year, of the carbon stored by our forests. Provincial data shows that sequestration capacity held steady at about 103 megatonnes of CO2-equivalent emissions per year between 1990 and 1999, and then began to decline through to 2017, the last year for which data is available. But the rate of decline suggests that our forests are now a net source of emissions, even without including the emissions released as a result of natural disturbances such as wildfires.
    The impact on climate stability of BC’s forests losing the ability to absorb 103 megatonnes of CO2-equivalent emissions per year is no different than the impact of releasing 103 megatonnes of CO2-equivalent emissions every year. Let me give you just a glimpse of how unbridled logging has reduced sequestration capacity. Consider the impact of logging roads.
    Logging in BC has required the construction of a vast and very expensive network of industrial-duty roads that have gouged out an equally vast area of previously productive forest and covered it over with blasted rock and gravel. The public has paid for these roads through reduced stumpage payments. They’re poor, if not impossible places for trees to grow.
    In BC, logging roads and landings are allowed to occupy up to seven percent of the area of a cutblock. As well, to avoid slash burning, the unmarketable wood left in a clearcut is increasingly consolidated in semi-permanent piles that, like the roads and landings, reduce the space available for a new forest to grow.
    A recent report at The Narwhal by Sarah Cox described a study in Ontario that examined the extent of such forest loss in that province. Cox reported that researchers there found “logging scars created by roads and landings…occupied an average of 14.2 percent of the area logged.” So our province’s seven percent restriction could well be an underestimation of the forest base that’s being lost. But let’s use seven percent and calculate how much forest has been lost.
    Sierra BC’s recent report, Clearcut Carbon (document at end of story), put the total area logged in BC between 2005 and 2017 at 3,597,291 hectares, which included private land on Vancouver Island.
    If seven percent of that area was covered with roads and landings, the area of forest lost over that 13-year period would be 251,810 hectares. That’s larger than Vancouver Island’s largest protected area, Strathcona Park.

    In this randomly selected, typical aerial view of Crown forest on Quadra Island, the permanent, ballasted logging roads occupy 8.2 percent of the area of the recent clearcuts.
    Sierra BC chose a 13-year period for its report because it takes at least 13 years after a clearcut has been replanted for the area to shift from being a source of carbon emissions to a carbon sink. The report grimly observed: “For at least 13 years, these areas are ‘sequestration dead zones’: clearcut lands that emit more carbon than they absorb.”
    In the case of roads, though, the forest land they now occupy has become a permanent just-plain-dead zone, and another one the size of Strathcona Park is being created every 13 years.
    While the blame for BC’s forests becoming a net source of carbon emissions has been directed at non-human causes like the mountain pine beetle and wildfires, the forest industry’s production of 251, 810 hectares of just-plain-dead zones and 3.6 million hectares of sequestration dead zones every 13 years is pushing ecological stability to the brink.
    Once upon a time, management of BC’s forests was based on the concept of “sustained yield.” It was a commonly held belief of residents of this province that this meant the annual allowable cut was restricted to no more than the amount of new forest growth each year. Many of us, including myself, have mistakenly believed that approach to managing the public forests was how the Forest Service still operated. This is clearly not the case.
    The Forest Service has turned the resource into an annual carbon bomb that has become one of the largest carbon emitters/carbon-sink killers in Canada. At more than 190 megatonnes a year (88 from premature decay emissions and 103 from loss of the forest-carbon sink), it’s well over twice the size of emissions from Canadian oil sands operations and three times the rest of BC’s emissions. Yet we cut far more than we need for our own use. That’s just plain nuts.
    The most obvious starting point for repairing BC’s broken forest-carbon sink would be to ban the export of raw logs. That would make it possible to put the 6.5 million cubic metres of trees that weren’t harvested into a protected carbon reserve each year until the provincial forest-carbon sink has been rebuilt to at least 1997’s level: 103 megatonnes per year.
    YOU MIGHT THINK THAT THE GREATEST CHALLENGE to eliminating raw log exports and putting that uncut volume into protected carbon reserves would be the huge loss in employment that would result. You’d be wrong.
    There were 17,800 people employed in “forestry and logging with support activities” in all of BC in 2018, according to BC Stats (9). This figure doesn’t include BC’s wood products manufacturing jobs, but eliminating log exports wouldn’t affect those jobs since raw log exports create zero manufacturing jobs in BC.
    2018 was a very good year for employment in the forest industry. The total volume cut in BC forests, including on both public and private land, was 54.1 million cubic metres. Of that, 30 percent was cut on the coast and 70 percent in the interior. Based on that split, about 30 percent of the employment in “forestry and logging with support activities” was on the coast, or about 5340 jobs. In 2018, raw log exports were at a five-year low of 5.03 million cubic metres, equivalent to 31 percent of the coastal cut. So eliminating log exports that year would have eliminated about 31 percent of those 5340 coastal logging jobs, or 1650 jobs. It would have also eliminated, or at least greatly delayed, 8.3 megatonnes of emissions.
    To put those 1650 jobs in perspective, they represented less than one-tenth of one percent of BC’s total workforce in 2018. They are amongst the most carbon-emission-intensive jobs on Earth. In the approaching low-carbon economy, employment will need to shift from carbon-emission-intensive to carbon-absorption-intensive. Any job that is part of a low-cost process for removing carbon from the atmosphere is going to be in demand. Allowing trees to grow is currently the lowest-cost process for absorbing carbon from the atmosphere. This is unlikely to change.
    When BC starts to put thousands of hectares of forest land into carbon sequestration reserves each year, optimizing the amount of carbon stored will require scientists, surveyors, mappers, planners, foresters, tree planters, thinners, pruners, salvagers and fire suppressors. It’s likely to include some selection logging. If anything, optimizing the forests’ capacity for sequestration is likely to require more workers than are provided by road building and the mechanized form of clearcutting widely practiced on the coast. Where would the money for all this employment come from?
    The Carbon Tax is slated to rise to $50 per tonne in 2021. If the 5-year-average export cut was ended and the trees left standing, a net reduction in emissions of 11 megatonnes would have an annual value of $550 million. That’s a lot more than necessary to keep 1650-2000 jobs in a transformative BC Forest-Carbon Service. Do the arithmetic yourself.
    David Broadland is the publisher of Focus. He is working with a group of scientists, journalists and citizens to explore the potential for conserving selected BC forests for carbon sequestration, biodiversity conservation and short-distance tourism potential. He welcomes your feedback.
    Forestry and Carbon In BC by Dr. Jim Pojar: Forestry and Carbon in BC Dr. Jim Pojar.pdf3.51 MB · 75 downloads 
    Clearcut Carbon by Sierra BC: 2019-Clearcut-Carbon-report.pdf2.14 MB · 71 downloads

    David Broadland
    November 2019
    If history repeats itself, local plans to reduce GHG emissions will come up far short of targets. Shouldn’t there be a Plan B?
    IS THE APPROACH TAKEN BY Victoria and Saanich to reduce GHG emissions within their jurisdictions flawed in some fundamental way that guarantees little or no reduction?
    This is a vital question to consider. Almost all local governments in the CRD have recently declared a “Climate Emergency,” yet the best local example of a well-considered climate action plan—put in place ten years ago by Saanich—has produced only a small reduction in emissions. If the action plans local governments are creating are just more of the same approach Saanich has already tried—and they are—why would the result be any different?
    In 2008, during a previous peak in public interest and concern about global climate change, the BC government introduced North America’s first broad-based carbon tax. At the same time, the municipality of Saanich began drafting a plan to reduce territorial sector-based GHG emissions. By 2010, Saanich had launched its forward-thinking “Climate Action Plan.” One of the plan’s primary goals was an “at least 33 percent” reduction in territorial emissions from 2007 levels by 2020. Ten years later, how did that go?
    Back in 2010, Saanich’s Climate Action Plan put the municipality’s 2007 sector-based territorial GHG emissions at 521,000 tonnes per year. What are they now? In 2019, after declaring a Climate Emergency, the municipality quickly developed the outline (see document 1 at end of this story) of a new climate action plan that plotted a pathway to reduce sector-based territorial emissions by 50 percent by 2030 and reach carbon neutrality by 2050. Saanich’s new starting point, according to that outline, would be 512,900 tonnes. So nearly 10 years after launching its 2010 action plan, Saanich’s sector-based territorial emissions are only 8,100 tonnes below 2007 levels. That works out to a 1.6 percent reduction, well within the uncertainty associated with the accuracy of the 2007 estimate of emissions. Why does Saanich now expect a different result on its second try using the same approach? Victoria is using the same methodology in its Climate Leadership Plan (see document 2).

    "Pathways to 2050 GHG Reduction Targets" from the City of Victoria's Climate Leadership Plan. Plotting points on a graph has been tried before.
    According to the climate action plans for both communities, all that residents need to do is summed up in three initiatives: First, property owners need to get rid of their oil and natural gas heating and hot water systems and buy electric heat pumps. Second, car drivers need to switch to a bicycle, an electric bus, or an electric car. Third, Victoria and Saanich foresee the availability of “renewable natural gas,” although it’s uncertain where that will come from and how much such facilities would cost, both in dollars and embodied emissions. But residents should get ready to pay for it.
    All of these provisions require new consumption: of electric cars and bicycles, new heating systems, new infrastructure to create biogas, and probably new offices to house a growing contingent of Climate Emergency managers. We just need to buy our way to lower emissions.
    While the experience of Saanich’s 10-year-long unsuccessful attempt at lowering emissions should provide local governments with ample warning that it’s far easier to plot reductions on paper than to achieve them in the real world, there are other reasons to doubt substantial reductions will ever materialize.
    One example: neither community has any intention of constraining population growth or the gentrification of existing neighbourhoods. Thus, we will continue to see, as long as the Canadian economy is growing, new buildings and infrastructure created to service a growing population, and neighbourhoods becoming increasingly affluent and filled with bigger, more luxurious homes. Such growth comes with immense embodied emissions, and some of what’s being created right now is surprisingly energy-inefficient.
    In the City of Victoria, much of the growth is in the form of concrete and glass condominium highrises in the Downtown core. While emissions reduction planners might think that such modern buildings will be energy efficient, BC Hydro doesn’t. In High-Powered Highrise, a report released earlier this year, Hydro noted: “Despite the suites in newer high-rise buildings often being marketed as energy-efficient and including things like LED lighting and Energy Star® appliances, the combined electricity usage of the overall building is approximately two times more than high-rises built in the 1980s, and almost four times more than low-rise buildings built that same decade.”
    Why? According to BC Hydro, “This increase can largely be attributed to these newer, high-rise condo buildings (those with five stories or more) being equipped with high consuming luxury amenities, including pools, hot tubs, party rooms and fitness centres.”
    The strong desire for a luxurious home is also evident in many new low-rise multi-unit buildings in Victoria and Saanich. The market for luxury, it turns out, is a far more powerful determinant of what gets built than concerns about energy efficiency or carbon emissions, even in the midst of a Climate Emergency.
    The relentless demolition of perfectly useable smaller, older homes, which are then replaced with high-end single-family homes two or three times the size, doesn’t support the Climate Emergency managers’ expectation, which underpins their emission-reduction targets, that consumers of housing are seriously concerned about either energy or material conservation.
    The absence of any measures in their climate action plans to constrain population increase and physical growth in Victoria and Saanich isn’t the only reason to doubt real reductions in carbon emissions will be achieved.
    The most serious problem with both action plans is that they only address a small fraction of the emissions that Victoria and Saanich create, or cause to be released somewhere else.
    Civic governments count their emissions using what is known as “sector-based territorial emissions accounting.” In developing their climate action plans, both Saanich and Victoria have identified emissions created by the burning of fossil fuels, or the release of methane, within their boundaries using four sector-based GHG inventories: transportation (automobiles and buses), stationary energy (which includes, for example, all energy related to buildings), industrial products and processes (for example the City’s asphalt plant) and waste (solid waste, sewage, composting). Both Saanich and Victoria are acting in accordance with what is known as the Global Protocol for Community-Scale Greenhouse Gas Emission Inventories (GPC) and their methodology aligns with the guidelines of the Intergovernmental Panel on Climate Change (IPCC). Using this protocol, Victoria identified 387,694 tonnes of territorial carbon emissions; as mentioned above, Saanich estimated 512,900 tonnes. The two communities’ analyses of territorial emissions yield similar per capita levels: 4.52 tonnes per person in Victoria and 4.8 tonnes per person in Saanich.
    Both these numbers, though, are far lower than the known per capita emissions of Canadians, which were 19.6 tonnes per person in 2017.
    Saanich and Victoria, then, have set their sights on addressing less than 25 percent of our known per capita emissions. Where do the other 75 percent of Canada’s per capita emissions come from?
    About 26 percent of emissions come from the oil and gas industries, releases that occur before their end-products reach consumers. Another 10 percent comes from heavy industry (fertilizers, iron and steel, cement, aluminum, and pulp and paper). The vast majority of the remaining 64 percent of emissions are created by the production and use of housing, transportation, and goods and services consumed by Canadians in their daily lives. Because 85 percent of Canadians live in cities, most of this consumption occurs in urban centres like Victoria. So cities, and how their governments approach emissions reduction, will have a large impact on whether Canada’s response to the Climate Emergency is effective or not.
    It’s only been in the last couple of years that comprehensive attempts have been made to quantify all the carbon emissions that human activity in cities creates directly or causes to be released elsewhere. Research done by the international organization C40 Cities provides some valuable insight. C40 Cities describes itself as “a network of the world’s megacities committed to addressing climate change.” Its board includes such climate luminaries as former New York City Mayor Michael Bloomberg and current Paris Mayor Anne Hidalgo. Vancouver is participating in the initiative.
    C40 Cities has developed an alternative emissions accounting approach that focuses on the consumption of goods and services by residents of a city. In this approach, GHG emissions are reported by consumption category rather than GHG emission source category.
    The 12 categories of consumption C40 Cities uses (and the percentage each category adds to emissions in a North American city) are: capital (15.3 percent); utilities and housing (26 percent); food, beverage and tobacco (7 percent); public transport (10.2 percent); private transport (7.3 percent); government (9.5 percent); clothing, furnishing and household equipment (8.8 percent); restaurants, hotels, recreation and culture (7.2 percent); communications (2.7 percent); education and health (3 percent); miscellaneous goods and services (1 percent); and “other” (2 percent).
    A C40 Cities study (see document 3), released in March 2018, noted that “consumption-based GHG emissions of C40 cities are significant, and significantly larger than sector-based GHG emissions established using the GPC.”
    How much larger? The C40 study found that “16 cities, mostly in Europe and North America, have consumption-based GHG emissions at least three times the size of their sector-based GHG emissions.”
    Although Victoria and Saanich weren’t part of this study, it’s not unreasonable to surmise that consumption-based emissions here are also “at least three times the size” of the sector-based emissions used by Victoria and Saanich in their climate action plans. It should be noted that Saanich commissioned a study of its 2015 consumption-based emissions. That report was released in 2018. It concluded that consumption-based emissions were two times higher than emissions based on sector-based accounting. The study did not include several of the categories C40 Cities uses, including “government services.”
    Let me give you just a few examples of emissions not counted by Victoria or Saanich in their sector-based territorial accounting that would be counted in consumption-based accounting.
    Emissions associated with the cement used in concrete for constructing buildings, foundations, sidewalks, retaining walls, overpasses, etc, are not counted because the cement is manufactured elsewhere. So, too, is the steel rebar used to reinforce this concrete. Saanich has an aggregate mine that provides the sand and gravel used in concrete, but Victoria doesn’t. Thus no emissions related to producing and transporting the ingredients of the concrete in Victoria’s downtown highrise boom are included in its territorial accounting of emissions.
    Another example is “government services.” While both Victoria and Saanich do count GHG emissions caused directly by the burning of fuels resulting from their own operations, they don’t include the carbon emissions embodied in the more than $500 million in funding the two governments collect each year from residential, institutional and business taxpayers.
    There are no lumber or plywood mills in Victoria or Saanich, so none of the emissions or loss of forest carbon sinks associated with the forest industry and its products are included in municipal accounts of emissions, even though these products are essential for the physical growth and maintenance of our homes, hospitals, schools, and places of business.
    Nor do Saanich or Victoria count the emissions created when their residents fly, for business or pleasure, to Vancouver, Paris—or wherever.
    Although a small amount of the food we consume is grown here, most is grown elsewhere and transported to the island. Virtually none of the emissions embodied in our food is counted by Victoria or Saanich. Missing from their tallies, too, are the emissions embodied in the cellphones, computers, flat-screen TVs and other electronic devices manufactured elsewhere but consumed widely by Victoria businesses, institutions and households.
    I won’t go on. You get the idea. In Saanich and Victoria, Climate Emergency managers are counting only a small fraction of the GHG emissions that households, businesses, institutions and governments here are actually causing, directly or indirectly, to be released into the atmosphere. Using C40 Cities’ “at least three times” multiplier, a more realistic estimate of the City of Victoria’s emissions would be 1.2 megatonnes per year. Let’s put Saanich down for 1.5 megatonnes.
    Obviously, local climate action plans will have no success at reducing emissions that they’re not even acknowledging or targetting.

    FOCUS editor Leslie Campbell admires a carbon sequestration facility on Quadra Island (Photo by David Broadland)
    IS THERE A DIFFERENT COURSE OF ACTION that municipal governments could take to mitigate their emissions? Yes, there is. In a written response (document 1) to Saanich council’s declaration of a Climate Emergency, Manager of Sustainability Ting Pan noted there were two ways to achieve carbon neutrality. The first was to eliminate carbon emissions completely. The second was to “balance carbon emissions with carbon removal.”
    By “carbon removal,” Pan meant the sequestration of carbon by trees. The simplest form of this approach to mitigate emissions, known as “offsets,” is available to a person making a trip by airplane. Payment of an additional small fee—which, the offsetting company promises, will go towards planting a seedling somewhere on the planet—helps to expunge feelings of guilt and shame that some people experience when boarding an airplane. But this form of offsetting has been widely criticized, and rightly so. Forest scientists tell us (document 4), for example, that it takes about 17 years after a coastal BC clearcut has been replanted (which is often delayed several years after harvesting) to switch from being a source of carbon emissions to being a carbon sink. So offsetters that promise to plant a tree to mitigate emissions from, say, your flight to Stuttgart or Calgary, have no immediate effect on reducing atmospheric carbon. Moreover, if trees planted for offsets are cut down in 30 or 40 years, and that low-quality juvenile wood is then used for some short-lived product like shipping pallets or pulp for paper or biofuel, most of the carbon that tree stored is quickly released to the atmosphere. But there’s another possibility for using carbon removal, and this would be similar to that developed for the Great Bear Rainforest, which protects mainly old-growth forest.
    If second-growth trees on the south coast of British Columbia that are slated to be logged (and all Crown land currently under forestry tenures is slated to be logged, eventually) were left to grow, they would sequester more and more carbon each year for a few hundred years. If they were left until they get very old—a Douglas-fir tree, for example, can reach 1000 years of age or more—they would sequester large amounts of carbon over long periods of time.
    Saanich’s Ting Pan put the current cost of offsets at $25 per tonne. At that rate, to offset Saanich’s estimated 1.5 megatonnes of consumption-based emissions for a year would cost about $38 million, and Victoria’s 1.2 megatonnes would cost $30 million a year.
    Ting Pan noted that, while “carbon removal” was “theoretically possible,” there is “no known precedence of any Canadian municipalities taking this approach to become a carbon neutral community.” She added that such offsets “will have to be generated outside of Saanich’s municipal boundary…and would likely contribute to global emissions reduction. However, purchasing offsets have limited direct benefits to local residents, businesses or the local environments.”
    That last statement is ironic, and I’ll explain the irony later. But the only alternative to a “carbon removal” approach is to repeat the actions Saanich took starting in 2010—an approach that hasn’t proven effective and addresses only a third or less of the actual emissions it should. It seems doomed to fail. In a Climate Emergency, shouldn’t our governments be trying out different options to see what works best?
    THE RISK THAT CIVIC CLIMATE ACTION PLANS WILL FAIL to deliver significant reductions in community-based emissions demands a Plan B for insurance.
    Certain species of trees, like Douglas fir, Western red cedar and Sitka spruce, can store atmospheric carbon for several hundred, even thousands of years. Forest scientists tell us that coastal old-growth forests store from 750 to 1130 tonnes of carbon per hectare, all absorbed from the atmosphere over the centuries. Our coastal rainforests can contain twice as much carbon per hectare as tropical rainforests like those in the Amazon jungle.
    While old-growth forests around the Salish Sea are becoming increasingly rare, second-growth forests that have a high percentage of Douglas fir, with trees up to 80 years old, are, by comparison, widespread. Select areas of the coast that measure high for biodiversity, tourism and recreation potential, and have the capacity for growing large Douglas fir, cedar or Sitka spruce, could be set aside and managed for optimal carbon sequestration. This wouldn’t mean an end to forestry jobs in these selected areas, but clear-cut logging would end. This approach is already being employed with old growth in the Great Bear Rainforest by the First-Nations-operated Great Bear Carbon Credit Corporation.

    Second-growth forests on Crown land like those on Sonora Island (left) and Maurelle Island (right) are slated for clear-cutting. Municipal governments could conserve these areas’ biodiversity, tourism potential, and carbon sequestration capacity by paying fees to offset their own communities’ GHG emissions. (Photograph by David Broadland) 
    The Crown-owned second-growth forests around the Salish Sea could absorb many millions of tonnes of carbon from the atmosphere and store that carbon for several hundred years. But they are being clear-cut at an unsustainably high rate, and their potential for storing carbon is rapidly being lost. Tragically, these second-growth forests are being harvested at an age when they are just beginning to absorb carbon at the highest rate per year, a pace that would continue for another 100 to 200 years if left to grow. Through a combination of government shortsightedness and mechanized-forestry corporate greed, BC is losing one of the most effective tools available on the planet for removing carbon from the atmosphere. Some of the loss is justifiable to the extent that lumber is necessary for building housing in BC. A substantial portion of that loss, however, is being exported as raw logs, which provides minimal economic benefit for coastal residents.
    Ironically, most of the rapid liquidation of both old-growth and second-growth forests on Vancouver Island and the northern Gulf Islands is being carried out by TimberWest and Island Timberlands, both of which are owned, to a large extent, by public service pension funds that provide many former government (federal, provincial and municipal) employees with good pensions. Many of these former civil servants have retired to the Victoria area. The community benefits greatly by their presence here, but some of that economic benefit has come at the cost of widespread environmental damage caused by logging of both old-growth and second-growth forests. The south coast is not just losing the potential for carbon sequestration; logging-road construction and clearcutting are blasting, filling and shredding wildlife habitat, diminishing biodiversity and the land’s ability to store water.
    Can municipal governments step forward and preserve carbon sinks as an insurance policy against the potential failure of their climate action plans to perform as needed?
    Saanich’s Ting Pan, as noted above, wrote that, “purchasing offsets have limited direct benefits to local residents, businesses or the local environments.” The irony in that assessment is that local residents and businesses have already benefitted—through money that has flowed into this community from those public service pension plans and increased government revenues—from the destruction of forest-based carbon sinks that is occurring all around the Salish Sea.
    HOW MIGHT THE COST of protecting the remaining old growth and selected areas of second growth be charged against consumption-based emissions in communities like Victoria and Saanich? Households would pay a fee, based on household income, to municipal governments. Municipalities would transfer that money to the Province. The Province would then allocate funds to those affected resource communities selected for carbon sequestration projects to transition them away from timber extraction on Crown land and towards carbon sequestration, biodiversity conservation, and development of tourism/recreation/research infrastructure.
    Why should Saanich and Victoria collect carbon sequestration fees based on household income? A new scientific study (see document 5) on consumption-based household GHG emissions provides evidence for what most people already know: The greater the household income, the higher its consumption-based emissions. This peer-reviewed research quantifies the substantial difference in emissions between low-income and high-income households in the US. Canadians and Americans have very similar per capita GHG emissions, so the data from this new study is useful in Canada. The numbers suggest that Canadian households with incomes of $150,000 have consumption-based annual emissions of about 56 tonnes; a household income of $100,000 produces 50 tonnes; $60,000 in household income produces 33 tonnes; and $30,000 in income produces 22 tonnes. At Tang’s estimate of $25 per tonne to offset emissions, a household with $60,000 in income would pay an annual emissions offset fee of $825. A household with $150,000 in income would pay $1400.
    If Victoria’s or Saanich’s Climate Emergency managers could prove that their action plans had reduced community emissions by, say, five percent, then their residents’ fees could be reduced by five percent, or whatever reduction had been achieved. If emissions go up, the fees go up, and more forest land is converted to carbon reserve.
    As Saanich’s Ting Pan noted, “there is no known precedence of any Canadian municipalities taking this approach to become a carbon neutral community.” There’s also no known example in Canada of a municipal climate action plan producing significant emission reductions. Such plans are often branded to include the word “leadership.” Victoria has called its plan the “Climate Leadership Plan.” But can following a path that’s known to badly underestimate actual emissions, and which uses an approach that has already proven itself to be ineffective, be regarded as “leadership”?
    David Broadland is the publisher of Focus. He is working with a group of scientists, journalists and citizens to explore the potential for conserving selected BC forests for carbon sequestration, biodiversity conservation and short-distance tourism potential.
    Documents referred to:
    1. Saanich Manager of Sustainability's response to Climate Emergency Declaration.pdf
    2. City of Victoria Climate Leadership Plan.pdf
    3. C40 cities consumption-based-emissions.pdf
    4. PICS Carbon Sequestration in British Columbia's Forests.pdf
    5. Scale, distribution and variations of global greenhouse gas emissions driven by U.S. households.pdf

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