Evergreen Alliance Staff

Groups announce February 25 rally at Provincial Legislature, issue declaration calling on the Province to accelerate action for threatened forests. UNCEDED LEKWUNGEN TERRITORIES/VICTORIA—168 organizations across British Columbia have issued a declaration called United We Stand for Old-Growth Forests, calling on Premier David Eby and his government to fulfill their commitments on old-growth. Signatories of the declaration, including the Union of B.C. Indian Chiefs, the Climate Caucus network of municipal elected leaders, and B.C. General Employees Union (BCGEU), are urging Eby to follow through on his October 2022 promise to “accelerate” action to protect old-growth forests within 100 days, and implement a paradigm shift in forest stewardship to safeguard biodiversity. The organizers announced plans for a mass mobilization to hold the province accountable, with a march and rally scheduled for February 25, Eby’s 100th day. “The government’s continued negligence and stonewalling on truly protecting old-growth and elder trees is endemic in its approach to climate change and the stewardship of our environment,” said Grand Chief Stewart Phillip, President of the Union of B.C. Indian Chiefs. “This feigned ignorance of what is happening to our forests by government and industry will be our downfall, and the impacts of this inaction will prevent us from leaving our future generations with a rich legacy of vibrant, healthy and productive forest lands.” Phillip added. “We must do everything in our power to protect these ancient giants and we cannot stop putting pressure on our governments to do their jobs: to protect us and the environment, not act as timber barons whose only concern is this year’s financial statements.” Despite promising to implement all 14 recommendations from the Old Growth Strategic Review (OGSR) in 2020, the B.C. government has permitted the destruction of thousands of hectares of the most at-risk old-growth stands in the province. The 2020 recommendations were tied to a three-year framework with the goal to have all implemented in 2023 — to date, not a single recommendation has been fulfilled. Premier Eby pledged to accelerate action upon becoming leader of the B.C. NDP, and called on Water, Land and Resource Stewardship Minister Nathan Cullen to “begin implementation of recommendations of the Old Growth Strategic Review” in his mandate letter. However, the most at-risk old-growth forests are still being clearcut while B.C. stalls on enforcing logging deferrals. The deferrals are the bare minimum and most urgent recommendation of the 2020 OGSR. “We must continue to hold our governments accountable for their contributions to the climate crisis that we are suffering through, and this environmental negligence and corporate greed must be stopped,” said Kukpi7 Judy Wilson, Secretary-Treasurer of the Union of B.C. Indian Chiefs. “Our future generations are dependent on the actions we take today, and we are at a critical point in time for direct action to protect forest ecosystems. For too long we have allowed governments to tear down our ancient elders, who are our relatives, but no more. We are standing up to protect them.” Protecting the last stands of old-growth is as much an issue for human rights, labour, education, and healthcare as it is for environmental groups. Organizers say this is a movement for all people, which is reflected in the list of declaration signatories, and are inviting all individuals and groups to participate in the United for Old-Growth march and rally at the B.C. Legislature on February 25. The signatories are calling on the province to align all forest management with the principles of free, prior and informed consent for First Nations. The declaration draws on the Union of B.C. Indian Chiefs Resolution 2022-32, affirmed by Chiefs in June 2022, and calls for full financial support to enable logging deferrals, and fulsome funding for First Nations-led conservation initiatives. Organizers say the declaration is open to additional signatories and invite new groups to join and demonstrate the broad support for old-growth protection in the lead-up to February’s mass mobilization. “Whether it’s youth yearning for a liveable climate, working families seeking sustainable jobs in their communities, doctors and nurses speaking up for a healthy planet, Indigenous people defending what’s theirs, or faith, environmental and community groups standing up for irreplaceable ecosystems, protecting old-growth is a movement for everyone,” said Jackie Larkin, organizer with Elders for Ancient Trees, a founding signatory on the United We Stand declaration. “From elders to the youngest children, everyone belongs and all are welcome—we invite all organizations to join this declaration, and everyone who’s able to unite with us to make February 25th a day to remember.”

If anything is going wrong in our forests, it’s not the fault of the professional association of BC foresters, according to its CEO Christine Gelowitz. Foresters Herb Hammond and Fred Marshall disagree. WHEN FORESTER HERB HAMMOND RESIGNED IN DISGUST from the Association of BC Forest Professionals (ABCFP) in late November, his letter of resignation received a lot of attention. In response to Hammond’s letter, the ABCFP’s CEO Christine Gelowitz sent a letter to The Tyee explaining what Hammond got wrong, in her opinion. Below are Gelowitz’s letter, subsequent letters sent by forester Fred Marshall to Gelowitz and to the Office of the Superintendent of Professional Governance, and the latter’s response to Marshall. And, finally, Hammond’s response to Gelowitz. The matters discussed below are central to the role the ABCFP plays—or doesn’t play—in protecting the public interest from the ravages of BC’s logging industry. Nov 24, 2022: Response to Herb Hammond’s resignation letter from Christine Gelowitz, RPF, CEO of the Association of BC Forest Professionals The letter written by Herb Hammond, a retired professional forester, and published on the Evergreen Alliance website and in Focus on Victoria, unfortunately demonstrates a misunderstanding of the mandate of the Association of BC Forest Professionals (ABCFP) and misconstrues it with the role and authority of the Provincial Government. Christine Gelowitz, RPF, CEO of ABCFP By provincial law, the ABCFP’s duty is to regulate the people who practise professional forestry. The work of the ABCFP as a professional regulator entails setting education standards for professionals to enter the profession; setting professional service practice standards, competency standards, and a code of conduct; and holding its registrants to account for following professional standards via a public complaint and discipline process. Neither the ABCFP, nor its registrants, have been assigned the duty or authority to set forest management objectives, rates of forest harvest, or other forest management policy concerns raised in Mr. Hammond’s letter. That accountability is held by the Province of BC or the landowner. In this regard, the ABCFP functions in the same manner as other professional regulators. For example, the College of Physicians and Surgeons does not make health care policy or health spending decisions; Engineers Geoscientists BC does not set mining policy or building codes. In all respect, policy decisions in these areas are the role of government and elected officials, just as it is in forestry. Misinformation is a problem for the public’s understanding forest management in BC. This in part is why the ABCFP has standards of competence and knowledge for practising forest professionals and requirements for them to maintain their competence and knowledge via ongoing professional development. These same requirements do not apply to retired forest professionals. Retired forest professionals are free to share their opinions but they are not allowed to provide advice or services that constitute the practice of forestry. Again, this is common among all regulated professions. A retired physician cannot provide medical treatment and would be unlikely to share advice, given that their knowledge is no longer current and they may not be protected from liability as a result. We recognize that Mr. Hammond and others may want different forest policy choices made and different objectives set for forests and forest management in BC. One of the strengths of the ABCFP is the diversity of views within our population of registered forest professionals. ABCFP registrants are free to express their opinions about forest and land stewardship, as individuals or in groups that share a common message. As a professional regulator however, the ABCFP does not pick sides or lobby for particular forest policies or outcomes as this would put the organization at odds with the regulatory model chosen by the people of BC. The reality remains that in BC, policies and decisions on how our forest land base is used are made by the landowner, in this case the Province of BC, via the provincial legislature and the government composed of those elected by the voters of British Columbia. Christine Gelowitz November 30, 2022: Response to Christine Gelowitz from retired professional forester Fred Marshall As the senior employee for the ABCFP, you are inherently bound to speak out on its behalf and uphold its principles to the best of your ability. However, it appears that you believe that the ABCFP and its members are above reproach and NOT responsible for the state of BC’s forests. Rather, you state that this is the sole responsibility of government. I disagree. Forester Fred Marshall For example, in your letter to Herb you stated that: “Neither the ABCFP, nor its registrants, have been assigned the duty or authority to set forest management objectives, rates of forest harvest, or other forest management policy concerns raised in Mr. Hammond’s letter. That accountability is held by the Province of BC or the landowner.” This statement is not only misleading but also incorrect. While it is the responsibility of the Province of BC—the landowner—to develop, pass and enforce both policy and legislation governing how BC’s resources are managed, they do this after considering the advice of all resource professionals in BC, including—and very largely so, when related to forests—the members (registrants) of the ABCFP. A specific example relates to determining the “rates of forest harvest” for BC. The timber supply review processes and subsequent AAC determinations set the stage for the entire focus and purpose of managing BC’s forest. This inherently includes all of nature, which is relegated to “resources” living in and/or related to the forests—fish, wildlife, water, aesthetics and the ecosystem services upon which all life depends. Contrary to your statement that no ABCFP members have the duty or authority to set or determine these “rates of harvest,” this responsibility has been assigned to and placed with the Chief Forester pf BC, whose decisions cannot by fettered by the government. All Chief Foresters have been members (Registrants) of the ABCFP, as is the current one. In your closing statement you note: “The reality remains that in BC, policies and decisions on how our forest land base is used are made by the landowner, in this case the Province of BC, via the provincial legislature and the government composed of those elected by the voters of British Columbia.” This statement also conveys the message that the state of BC’s forests is solely the responsibility of the government and NOT, in any respect, that of the ABCFP or it’s members. I again disagree. All professional resource managers—especially the members of the ABCFP—share fully in this responsibility. These resource professionals have been given, via legislation, this responsibility—exclusively. It is these registrants who must learn, interpret, understand and apply various forest practices that reflect the relevant policies and legislation upon the landscape. Unfortunately, what we see upon the landscape is not a pretty picture. A picture that, in many respects, reflects the signature of the ABCFP and its registrants upon the landscape. Two renowned resource managers portray this axiom very well: Thad Box, a retired professor of range management in the US commented about the “Worth of Our Work”. He described the resource professional’s stature and the reflection or “signature” of their work on the landscape as per the following: “A prosperous tomorrow depends on good land health. It is essential for us to keep options open for future generations. Finding a way to help land stewards live the good life while maintaining sustainability is a job that fits the principle of Granddad’s recipe for curing ham. It reminds us that quality is seldom determined by a single act. It is the outcome of a process. The worth of our work is in the effect of people who husband the land we serve.” Aldo Leopold, in Sand County Almanac, stated this paradigm in a somewhat different way. He said: “I have read many definitions of what is a conservationist, and written not a few myself, but I suspect that the best one is written not with a pen, but with an axe. It is a matter of what a man thinks about while chopping, or while deciding what to chop. A conservationist is one who is humbly aware that with each stroke he is writing his signature upon the face of his land. Signatures of course differ, whether written with axe or pen, and this is as it should be.” The ABCFP is made up of thousands of individuals who, collectively, represent the Association in both word and deed with the latter being their “signature” upon the face of the land. The signature on the land of forest professionals is often one of destruction and degradation. Thus, the essential ingredient of a conservation ethic is starkly lacking in the work of the ABCFP and many of its members. This harsh signature is reflected in the deplorable condition of BC’s forest landscape, and certainly does not comprise excellent resource management; although it certainly should. Instead, we view degraded landscapes covered with extensive roads and clearcuts, many of which disrupt and/or destroy biodiversity and render the people and communities located down-slope of them at unduly high risks of flood damage. We recently witnessed such damage—across the landscape—in Grand Forks, Merritt, Princeton, the Fraser valley and in other areas of BC. I have read several Forest Stewardship plans and several TFL Management Plans prepared by forest professionals. The statements contained in these documents are often so vague and/or inconsistent that one cannot tell what kind of “signature” is intended to be portrayed on the “face of the land” that is entrusted to the licensees to manage. The Chief Forester—a high-profile member of the ABCFP and hence a reflection of its stature and integrity—has repeatedly refused to acknowledge climate change, cumulative effects on the landscape and/or to apply the precautionary principle when engaging in the TSR /AAC determination process across BC. Such dogmatic denial of factors that have huge negative impacts on the AAC is not in the public interest; yet the Association ignores such behavior. Such denial results in the determination of unsustainable levels of AAC, yet such is supported by the ABCFP. Incredible, but true. Also extremely disappointing. How could the ABCFP ignore such blatant disregard for the public interest which all members of all resource-related professions in BC are bound through their codes of ethical practice to hold paramount in their personal and professional lives? Yet they, and many ABCFP members, do this and beat their chests and pat themselves on the back by making statements such as you just did regarding Herb Hammond’s resignation. One only has to evaluate the deteriorating health of BC’s forested landscapes and the reduced level of biodiversity represented by the steep decline in the number and diversity of wildlife species present to realize that these indicators reflect a very low and unacceptable level of management that has been applied to them by members of the ABCFP. A level of management that these people, individually and collectively, supported by the ABCFP, have and are writing their signatures upon the face of the land. Unfortunately, the signatures on the land often fail to protect that land and the public interest. Fred Marshall December 2, 2022: Fred Marshall’s letter to Office of the Superintendent of Professional Governance I believe that the ABCFP has breached the intent of the Professional Governance Act by acting in a manner and by making false statements that support both it’s activities and those of its members. These activities do not conform to the Professional Governance Act and do not serve the public interest as they are bound to do as per the following Professional Governance Act requirement: It is the general duty of a regulatory body at all times to serve and protect the public interest with respect to the exercise of a profession, professional governance and the conduct of registrants; The ABCFP Code of Ethics, as do all of those of other professions involved with the management of natural resources, require that the public interest be held paramount over and above the demands of employment. And the Professional Governance Act also requires that all of the professional associations are responsible to ensure that they and all of their members ensure that this principle is both honored and upheld. However, the ABCFP, as per Christine Gelowitz’s letter and its other related actions continue to fail to best serve the public interest. For example: The process of timber supply reviews and allowable annual cut determinations by the Chief Forester have inordinate impacts not only on BC’s forests but all associated natural resources. This is therefore an extremely important process, likely the most important one related to the health and well-being of all natural resources in BC. While the Chief Foresters have unfettered freedom to carry out this process, the various forest ministers, nonetheless, have sent them guidance letters containing various aspects that they would like the Chief Foresters to consider as they carry out this process. However, the ABCFP has never sent such a letter to the Chief Forester, asking them to consider aspects, especially regarding upholding the public interest, in this process. By failing or even refusing to do this they have, inherently, given their full support to the Chief Foresters to do whatever they feel appropriate and endorsing same. Additionally, they recently formally recognized former Chief Forester Diane Nicholl’s work in these endeavors by bestowing upon her the highest ABCFP award available—the Distinguished Forester Award. I believe that Diane Nicholls, acting as the Chief Forester of BC, has failed to uphold the public interest in these processes. And, the ABCFP, by giving her this award, has indirectly condoned her actions which tend to keep the AAC as high as possible for as long as possible. In most instances this has not been in the best public interest. The state of BC’s forests is far from being good, let alone excellent, and it is deteriorating daily, exacerbated by the over-harvesting of BC’s forests. Our forests no longer have the inherent capacity to absorb and tolerate the climatic and man-made changes they are experiencing today. Rather, they are rapidly declining—at an ever increasing rate. I therefore request that your office investigate this matter to determine whether the ABCFP has properly executed its duties as required under the PGA. Fred Marshall December 6, 2022: Office of the Superintendent of Professional Governance responds to Fred Marshall Under the professional reliance model, government sets the natural resource management objectives or results to be achieved; professionals hired by proponents decide how those objectives or results will be met; and government checks to ensure objectives have been achieved through compliance and enforcement. While government, professional foresters, and ABCFP all operate directly or indirectly within the natural environment, they nonetheless have distinct responsibilities that are important to be aware of. The response from the Office of the Superintendent of Professional Governance was unsigned Regulatory bodies such as ABCFP are tasked with regulating professional foresters within a defined scope of practice, and in the best interests of the public. While neither ABCFP nor the forest professionals create forest policy, they must nonetheless operate within this legislative scope. Government ministries such as the Ministry of Forests create policies, which must be adhered to by professionals who work within the scope of practice related to those policies. While some government statutory decision makers hold a professional designation, such as Registered Professional Forester (RPF), these statutory decision makers undertake their work and make decisions as government employees, and not as registrants of a regulatory body. It is important to note that while the Office of the Superintendent of Professional Governance (OSPG) currently oversees the governance of regulatory bodies such as ABCFP, individual ministries are still responsible for determining where and how professional reliance is appropriate according to the needs of individual business areas. While the OSPG is keen to learn of concerns related to regulatory bodies that may suggest a systemic issue, these concerns and systemic issues must nonetheless be related to the scope of responsibility of the regulatory body and not issues pertaining to legislative issues. If you have concerns regarding forest policy, I urge you to connect with the Ministry of Forests directly. I also encourage you to browse the OSPG website to learn more about the role of the OSPG. I would like to thank you again for bringing these matters to our attention. Office of the Superintendent of Professional Governance December 7, 2022: Fred Marshall responds to OSPG Thank you for your response. However, if your office does NOT believe that government employees who are “registrants” have to act as professional registrants because they are government employees, then we certainly don’t need your office for anything. Ditto the ABCFP and other professional associations. It appears that the OSPG is solely focused on and only interested in the administrative aspects of ensuring all professional associations have the following in place and that all meet the specifications of the Professional Governance Act: 1. Adequate qualification requirements for its members/registrants (education and training) 2. Require that all members/registrants complete their PD records as per the stated format and on time. 3. Abide by the applicable Code of Ethics. 4. And, as stated by Christine Gelowitz: “By provincial law, the ABCFP’s duty is to regulate the people who practice professional forestry. The work of the ABCFP as a professional regulator entails setting education standards for professionals to enter the profession; setting professional service practice standards, competency standards, and a code of conduct; and holding its registrants to account for following professional standards via a public complaint and discipline process.” However, according to Christine Gelowitz’s and your supporting rationale, they (professional registrants) can do whatever their employer tells them to do—especially government employees—even though, as illustrated by my examples, the work they do is not in the best public interest. How could you possibly arrive at this conclusion? Christine Gelowitz also stated: “As a professional regulator however, the ABCFP does not pick sides or lobby for particular forest policies or outcomes as this would put the organization at odds with the regulatory model chosen by the people of BC.” How then can the ABCFP publicly honour (by awarding them as a Distinguished Forester) one of their registrants, i.e. the Chief Forester, when that person has made timber supply review allowable annual cut determinations that are not in the public interest. This is “picking sides and lobbying for particular forest outcomes”, i.e. cut levels that are unsustainable. Again, how could you possibly view this behaviour as NOT promoting and rewarding the work of the Chief Forester—even though she was, at the time, a government employee. Your position appears to state that any registrant can do whatever their employer tells them to do—especially government employees—and they cannot and will not be held personally or professionally responsible for their actions. Christine Gelowitz also stated: “The reality remains that in BC, policies and decisions on how our forest land base is used are made by the landowner, in this case the Province of BC, via the provincial legislature and the government composed of those elected by the voters of British Columbia.” NOT true. Most all operating policies and decisions made in BC regarding how BC’s forest land base and many private forest holdings are managed, by law, and made by appropriately qualified resource professionals—i.e. registrants. Registrants who, collectively, make up the various professional associations. And, even though Christine attempts to distance and absolve the ABCFP for any decisions made on the landscape and the results of such decisions and actions taken by its members, the ABCFP is ultimately responsible for the actions and performance of its members. Yet you seem to agree with Christine’s claim that this is not true. How so? What will it take to get the Office of the Superintendent of Professional Governance to take some meaningful action in guiding (yea, even disciplining) the ABCFP and any other professional associations that operate under the OSPG when they are—either directly or indirectly—supporting actions that are not in the public interest? Needless to say, my hopes and expectations that the PGA would ensure that the resources of BC were being well managed via their oversight over the professional associations charged with doing this have been dashed. Hence, the poor management of BC’s natural resources continues, not only unabated but inherently supported by the PGA. Fred Marshall December 7, 2022: Herb Hammond to Fred Marshall The reply from the OSPG is beyond disgusting. They could have simply replied: “If you don’t like the current state of forests and forestry, then elect a different government.” If that is the case then, as you point out, we do not need the OSPG or professional associations for anything. They are just window dressing to give the illusion that well-educated, ethical “professionals” are taking good care of the forest, while in reality the forests are controlled and managed by corporate timber companies. Professionals just do what they are told by their employer. Herb Hammond The disconnect that the OSPG and the ABCFP display between the exclusive rights of their members to practice forestry, and the responsibility of their members and licensing bodies to evaluate whether that practice protects the public interest is striking. I am glad to no longer be associated with this gong show that is clearly constructed to obfuscate who really controls forests and what the actual condition of public forests is. Thanks for your persistence in following up on the clear failures of the OSPG and ABCFP to do their jobs. Herb Hammond December 16, 2022: Herb Hammond’s response to Christine Gelowitz et al This letter responds to Christine Gelowitz’s response to my November 24, 2022 letter of resignation from the Association of BC Forest Professionals (ABCFP). Ms. Gelowitz asserts that my letter “demonstrates a misunderstanding of the mandate of the Association of BC Forest Professionals (ABCFP) and misconstrues it with the role and authority of the Provincial Government.” To the contrary, I have a clear understanding of the ABCFP’s mandate. The source of our differences lies in the breadth through which the mandate is interpreted. 1) Disconnecting “Regulation of Profession” from Policy and Practice; and Protection of the Public Interest Ms. Gelowitz explains that the work of the ABCFP “entails setting education standards for professionals to enter the profession; setting professional service practice standards, competency standards, and a code of conduct; and holding its registrants to account for following professional standards via a public complaint and discipline process.” However, she seems to assert that these duties have nothing to do with policies, processes, and standards affecting the practice of forestry, including setting forest management standards, rates of forest harvest, and other forest management policy concerns. Instead, Ms. Gelowitz asserts that those responsibilities rest entirely with the provincial government. This position lacks logic and contradicts both the ABCFP’s Code of Ethical and Professional Conduct (code of ethics) and the way that forestry is practiced in the forest across BC. Disconnecting education standards, practice standards, and competency standards from how forestry is practiced, including plans and operations, is illogical. All these roles of the ABCFP have demonstrative effects on how forestry is practiced. For example, government sets policies and regulates forestry practice based to a significant degree on the advice of forest professionals in the employ of the government. Major universities in the province with forestry programs and/or forest-related research employ forest professionals that influence government legislation and policy. Prominent lobby groups, like the Council of Forest Industries and the Truck Loggers Association also employ forest professionals that influence how government sets policy and regulates forestry. Thus, the ABCFP, through their duties to regulate their membership, has a widespread and strong influence on how forestry is practiced in BC, including government legislation, regulations, and policy; and planning processes like allowable annual cut determinations and land use plans. Ms. Gelowitz asserts that “in BC, policies and decisions on how our forest land base is used are made by the landowner, in this case the Province of BC, via the provincial legislature and the government composed of those elected by the voters of British Columbia.” In other words, the government of BC defines and protects the public interest in forests through the provincial legislature. Given this situation, the ABCFP cannot continue to state that they protect the public interest in forests and forest management across BC. According to the ABCFP, that is the government’s job. However, this approach contradicts the ABCFP code of ethics, which specifies that registered professionals are charged with the responsibility of protection of the public interest. The code of ethics states, in part: “Independence...Registrants must uphold the public interest and professional principles above the demands of employment or personal gain; Forest Stewardship...Registrants work to improve practices and policies affecting forest stewardship. Registrants must uphold forest stewardship and practice the responsible use of forest resources based on the application of an ecological understanding at the stand, forest, and landscape levels, which maintains and protects ecosystem function, integrity, and resilience.” There are other aspects of the code of ethics that support that registered professionals are charged with protection of the public interest. However, protection of the public interest is not possible without having influence on legislation, regulations, and policies that affect how forestry is planned and practiced. Yet Ms. Gelowitz asserts that the “landlord” is responsible for “policies and decisions on how our forest land base is used,” thereby protecting the public interest. Thus, when it comes to the public interest, the ABCFP cannot have their cake and eat it too. If the ABCFP and registered members are not involved in policies and decisions on how our forest land base is used, then they need to remove all aspects of this responsibility from their code of ethics. The two statements above are examples of wording that should be removed from the code of ethics, since—according to Ms. Gelowitz—those are responsibilities of the provincial government. As articulated by Ms. Gelowitz, the duties of the ABCFP could largely be replaced by well-informed clerks, who license professionals to follow the dictates of government. And, since governments are largely directed by corporate lobbies, that means that the use of forests and related ecosystems of BC will be largely oriented to the needs of extractive, exploitive industrial objectives. In this situation, licensed professionals will reassure us that tree farms provide most, if not all the benefits of intact natural forests. Thus, with the limited role of the ABCFP as put forth by the Association, there is little need to have a staff of registered professionals. 2) Precautionary Decisions and the Practice of Forestry If Earth, including humans, is to survive the growing crises of climate change and biodiversity loss, management of public forests must increasingly focus on protection and restoration, not extraction and tree farms. Forests are our largest terrestrial carbon sink, sources of irreplaceable biodiversity, and provide the most effective water storage and filtration system in nature. Forests need to be protected, restored, planned, and managed in open and transparent ways based on a combination of Indigenous knowledge and sound Western science. Decisions need to be precautionary, erring on protection and maintenance of ecosystem integrity and social well-being. However, it is naïve to think that such responsibilities may be vested in ephemeral governments, where objectives for forests change with the goals of the party in power. Similarly, such responsibilities are inappropriate for organizations whose primary responsibility is short-term monetary profits, justified by professionals working for those organizations, or in self-regulating professional bodies that lack definitive standards for planning and management, and a rigorous process of oversight by independent experts. In professions other than forestry, there is a very strong emphasis on precautionary decisions and actions to protect the public interest: • Doctors work to prevent serious illness and death. • Engineers design buildings and bridges that don’t fall down, and airplanes that stay in the sky. • Lawyers defend people’s rights to avoid unjustifiable incrimination. • Architects design buildings that don’t fall down. Such precautionary decisions do not characterize forestry, calling into question its status as a true profession. Foresters routinely work to minimize logging and road costs, and high-grade remaining timber supplies, while presenting their actions as “in the public interest,” when in fact their main focus is to protect their employer’s interest. With the lack of a precautionary ethic as part of the code that foresters adhere to by their membership in the ABCFP, industrial forestry is more like mining than the professions of medicine, engineering, law, and architecture. 3) Standards: Incorporation of Indigenous Knowledge and Leading Science to Address Issues in the Practice of Forestry The ABCFP code of ethics begins with the following statements: “Registrants are responsible to hold paramount the safety, health, and welfare of the public and the protection of the environment. “The practice of professional forestry is undertaken in a manner that protects the public interest by ensuring the multiple values society has assigned to BC’s forests are balanced and considered.” The code of ethics concludes with a section titled, “REPORTING”, which requires registered professionals to report instances where “the continued practice of professional forestry by another registrant, or by another person, including a firm or employer, might pose a risk of significant harm to the environment or to the health or safety of the public or a group of people.” To fulfill the expectations created by these parts of the code of ethics, registered professionals need to be directed by, and adhere to precautionary standards that are based on Indigenous knowledge and leading scientific understandings. These standards need to address the issues that confront forestry. To suggest as Ms Gelowitz does in her letter that “The reality remains that in BC, policies and decisions on how our forest land base is used are made by the landowner, in this case the Province of BC...” ignores the extensive technical information that needs to be assimilated and applied to practice forestry that protects the public interest. This position also ignores the responsibility of the ABCFP and its registrants to protect the environment, as well as the health and safety of the public. Problems with the ABCFP’s lack of involvement in the many critical issues that surround forestry are becoming increasingly more evident. Due to the onslaught of industrial clearcut/tree plantation forestry, the last vestiges of primary forests are disappearing from the forest land base designated for forestry. With the disappearance of primary forests, including old-growth forests, the ecological integrity and resilience of remaining forests also declines. Non-sustainable rates of cut and the dominant use of clearcuts to log forests are two of the primary causes for forest degradation being on the increase across BC. Such forest degradation, which is considered deforestation by many knowledgeable scientists and practitioners, has resulted in forestry being the single largest source of greenhouse gases in BC, the leading cause of biodiversity loss, the largest source of water degradation, a major cause of floods and droughts, and a major contributor to disasters, like the flooding, landslides and road washouts that occurred in the November 2021 “atmospheric river” event. I would be happy to provide citations from the scientific literature that explain these problems with forestry, as well as problems referred to in other parts of this letter. The ABCFP’s silence on these issues casts a large shadow on its effectiveness as a regulator of the profession of forestry. To suggest that the government is the body that sets standards for the practice of forestry ignores the extensive technical information and understandings that underlie development of standards that sustain ecosystems and protect the public interest. Furthermore, forest professionals and the ABCFP have a professional responsibility to act when the practice of forestry is creating problems for forests and society. In contrast, the decisions of government are political decisions and reflect the bias of a particular political party. Problems with the practice of forestry are seen through the lens of a political ideology and are not often science-based. Thus, these “standards” are not “professional”, but political. If the ABCFP and their members blindly accept such standards, they are stepping away from the due diligence and protection of the broad public interest that is asserted by registered professionals. One cannot imagine a doctor blindly accepting a procedure set by government that puts a patient at risk. That is why medical practitioners develop precautionary standards that are focused on protection of a patient’s health. However, the ABCFP and its members, by defaulting to “standards” set by government, constantly put the complex functions and processes of forests in harm’s way. In this regard, it calls into question whether forestry is conducted in a professional manner. If the ABCFP and their members continue to put forth the idea that the management of forests is directed by the government of the day, the practice of forestry defaults to the methods and rationale of the timber industry. That approach has led us from healthy, intact forests to timber farms that have changed forests from carbon sinks to carbon sources, exacerbated climate change, steadily decreased biological diversity, and provided fewer and fewer benefits to forest workers and forest communities. The time is past for the ABCFP and its members to acknowledge that protection of the public good requires that they take active responsibility for the restoration and protection of forests across the landscape of BC. The future of BC depends in no small way on the health of forests. What that future looks like is being shaped by the way forestry is practiced across the province. Herb Hammond