Fred Marshall

I have viewed this video and have found the following: 1. The new planning process is stated to be ~ 8+ years long. It is a very complex, convoluted, confusing and lengthy process. How can it be reviewed every 5 years when the first one won't be completed for 8-10 years? 2. What geographic areas will a FLP cover relative to current TSA boundaries? 3. How will the new FLPs relate to the current LUPs across BC, especially as these plans need mega updating and revisions? 4. How will a FLP address or consider other developments proposed or happening on the landscape (I.e. in the Boundary TSA the doubling of Big White Mtn ski area which will include 3 golf courses and the different but associated Powder Renegade Lodge and associated ski operation)? 5. Ditto other developments i.e. pipelines, mines, dams across BC etc. 6. The new Protected Area program with the goal of formally protecting 30% of BC by 2030 and 50% by 3050 must be appropriately considered in any Landscape level plans BEFORE they are developed especially before the TSR process happens. 7. The TSR AAC process must be revised to remove it's deficiencies and defects so that it appropriately and correctly accommodates the amalgamation of TFLs and TSAs or whatever area the new LUPs will cover. If the area covered by the TSR process also includes areas designated or likely to be designated as formally Protected Areas, appropriate deductions must be made for these areas. They cannot be ignored in this process as they currently are. How will the new AAC for the Landscape area be distributed among the TFL holders and the volume-based holders? 8. While small Community Forests, Woodlots and Woodland Licences will be excluded from LUPs will they also have to comply with the other planning processes (FOM, FOPs, Site Plans etc.)? What is a "small" Community Forest? I fail to see how such a planning regime can and/or will result in improved management for all of BC's natural resources.

It appears that the auditing of forestry firms to ensure that their forestry operations are well and properly done, are sustainable across the landscape; respect indigenous values, respect all aspects of biodiversity; respect all water bodies, ensure all streams and riparian areas are well protected with all being in the best interests of the public who own them—is a complete sham. Like the forest companies, the auditing firms do their work to make money—and say and do whatever it takes to ensure they are very successful in doing this. The lesson we should all learn from this is that: No one should ever rely on any auditor who is paid by the entity they are auditing to produce a report that is fully honest. In the Boundary area we have definite proof of this folly involving SFI.

I am also concerned about the $10 million dollar subsidy to the forest industry for: " developing and implementing alternatives to clear-cutting practices, such as selective harvesting techniques, that better support forest resiliency, ecosystem health and climate adaptation, through a new $10-million silviculture innovation program;" On what, and how—exactly—will these millions of dollars be spent? Most all forest professionals in BC took Forestry 301 (or whatever course number Silviculture was) in college or university and learned what the various silviculture systems were—including selective and/or variable retention harvesting and how to apply them. So who will get these funds and why? Perhaps to develop a refresher course in selective harvesting? Or what? Many entities, like woodlot, Community forest licensees and private forest-land owners in and across BC, have consistently harvested the timber under their jurisdictions via some form of selective and/or variable-retention harvesting. Will any of the $10 million dollars accrue to these operators to recognize, encourage and perhaps even reward their good performance in this regard? Or will it be awarded and accrue to those entities that have have used clear-cutting or seed-tree with clear-cutting over most to all of their tenures? If so, then this is rewarding bad behaviour which would be very inappropriate. However, this has, unfortunately, been the modus operandi of the BC government for far too long. Surely it will not continue. I sincerely hope that these funds are allocated and spent in a manner that ensures that such expenditures and associated works are wisely, judiciously and fairly used and implemented.

I have read this treatise and give it very high marks. What was particularly significant to me was the statement below which indicated that, even though we are often dealing with landscapes that have been heavily modified—with the only objective then being to get the cut out as fast as possible and keep doing that—there is some hope to change this M.O. “Changing the character and condition of a single ecosystem within a landscape will not have as much overall influence as changing the broader character and condition of the landscape. However, working from the ecosystem, patch, or site toward the landscape may serve as an important catalyst for development of broad landscape visions and plans for protection and responsible use, and initiate important restoration activities. “Thus, starting with the restoration of a clearcut or road, a vision may be formulated for Earth-centred living that stimulates development and implementation of Nature-Directed Stewardship for a watershed or large landscape. “This approach offers a manageable, community-based way to initiate Nature-Directed Stewardship. In other words, start with the small, but manageable forest patch or site, and keep “walking up” the scale to expand site protection and restoration efforts to become watershed and landscape protection and restoration.” —Page 4

I have read this treatise and give it very high marks. What was particularly significant to me was the statement below which indicated that, even though we are often dealing with landscapes that have been heavily modified—with the only objective then being to get the cut out as fast as possible and keep doing that—there is some hope to change this M.O. “Changing the character and condition of a single ecosystem within a landscape will not have as much overall influence as changing the broader character and condition of the landscape. However, working from the ecosystem, patch, or site toward the landscape may serve as an important catalyst for development of broad landscape visions and plans for protection and responsible use, and initiate important restoration activities. “Thus, starting with the restoration of a clearcut or road, a vision may be formulated for Earth-centred living that stimulates development and implementation of Nature-Directed Stewardship for a watershed or large landscape. “This approach offers a manageable, community-based way to initiate Nature-Directed Stewardship. In other words, start with the small, but manageable forest patch or site, and keep “walking up” the scale to expand site protection and restoration efforts to become watershed and landscape protection and restoration.” —Page 4

I have read this treatise and give it very high marks. What was particularly significant to me was the statement below which indicated that, even though we are often dealing with landscapes that have been heavily modified—with the only objective then being to get the cut out as fast as possible and keep doing that—there is some hope to change this M.O. “Changing the character and condition of a single ecosystem within a landscape will not have as much overall influence as changing the broader character and condition of the landscape. However, working from the ecosystem, patch, or site toward the landscape may serve as an important catalyst for development of broad landscape visions and plans for protection and responsible use, and initiate important restoration activities. “Thus, starting with the restoration of a clearcut or road, a vision may be formulated for Earth-centred living that stimulates development and implementation of Nature-Directed Stewardship for a watershed or large landscape. “This approach offers a manageable, community-based way to initiate Nature-Directed Stewardship. In other words, start with the small, but manageable forest patch or site, and keep “walking up” the scale to expand site protection and restoration efforts to become watershed and landscape protection and restoration.” —Page 4

In 2019, the Council of Forest Industries published a paper titled: “Smart Future: A Path Forward for BC’s Forest Products Industry” The gist of this paper is captured in the following quotes which exemplify the intent of its several proposals. My comments are in italics. COFI wants the government to: 1. Define the working forest land base. Like conservation areas, designate the area that will be available for harvesting and lock in the commitment. (Lock in the THLB.) 2. Implement a “no-net-loss policy” to provide certainty in the long term. Undertake a review every 5 years. (Keep it locked in with no reductions.) 3. Ensure policies and processes allow for timely and consistent access to the working forest land base. (Ditto. This mantra is repeated a third time to make sure everyone was clear on what the forest industry wanted and continues to want.) 4. Transition a portion of the existing forest licenses from volume-based to area-based to encourage further investment by companies in intensive forest management. (Give us more TFLs so we have more control over these areas and can then better manage (exploit) them.) 5. Convene an expert working group including government, industry, and academic experts to develop innovative and flexible approaches to climate-affected forests to ensure a more stable, fire-resilient and sustainable timber supply. (The Chief Forester’s Leadership Team was created to fulfill this role and has achieved remarkable success in doing so—except for the sustainable part!) A copy of this paper is attached as is a copy of my comments made shortly after it was released. Many people in BC had then, and still have, a much different vision of what actually constitutes a “Smart Future” for BC’s forests. COFI_-Smart-Future-A-Path-Forward-Sept-28-2019.pdf Excerpts-from-COFI-Plans-for-BC's-Future-with-comments-from-Fred-Marshall-Sept-30-2019.pdf

What is also painfully obvious is that conducting harvesting and road construction 5 times over the next 300 years creates 5 times as much Carbon as does doing this once! A fact that the forest industry and compatriots (i.e. some UBC faculty!) studiously avoid mentioning. These numbers need to be added to the graph. I have spent a lot of time travelling through Interfor's TFL 8 and associated operating areas in the Boundary TSA and, over their ownership period of the last 12-15 years of the Boundary forests, they have continually created extensive and very large clearcuts and built thousands of kilometers of roads and via their operations have significantly degraded these (OUR) forests. Over this time they have created many NSR areas and, as per a recent FREP report, degraded the south block---comprising ~ 1/2 of their TFL-8-- so that the majority of the riparian areas situated therein are NOT PROPERLY FUNCTIONING! The following summary statement from Section 5.1.1 Riparian/stream condition: not properly functioning of this report states that: "The Boundary Creek watershed was the largest in this study, with 21 sub-catchments sampled within the assessment polygon. Overall, the entire watershed was ranked as not properly functioning for the riparian/ stream assessment, mainly because of the very high levels of human-caused riparian disturbance across the watershed (Table 6). Forestry was identified as the main development activity upstream in all but one of the sub catchments, where agriculture was dominant, and there are more than 100 road crossings over streams in the watershed. The total proportion of the watershed affected by development was estimated by the assessors at 56% using aerial imagery and spatial layers." In Diane Nicholl's recent TSR AAC Determination for this TFL she made absolutely no allowances for: The degraded condition of these riparian areas as indicated by the FREP report. The increased areas of NSR Climate change and--- Cumulative Effects on the landscape --even though a comprehensive CE analysis report of the entire Boundary TSA was recently been completed. And, as usual, she included her pathetically impractical statement that it would be inappropriate for her to use either common sense or logic to apply the precautionary principle and reduce the AAC to a more sensible, safer and sustainable level. And this even though the Boundary area experienced a catastrophic flood in 2018 causing hundreds of millions of dollars worth of damage and leaving hundreds of very distraught homeowners whose homes have since been confiscated by the City of Grand Forks with some compensation for such taking. And yet the AAC was maintained at it's past level and hence Clearcutting continues unabated across the landscape thus ever increasing the risk of more watershed damage and devastating floods. In spite of all the dikes that are being built around the city of Grand Forks it may still incur future flood damage. Several years ago large sums of money were spent doing "Watershed Restoration Work" in the Boundary area to address riparian degradation caused mainly by logging and road building. Much of this money was used to create in-river and in-stream rock and log structures to deflect water away from eroding banks. Now--- many of these structures have fallen apart and are the cause of ever more bank erosion. See attached pictures of three log structure deteriorating in the Kettle River. The road located to the right of the pictures has since been washed away and is no longer accessible. Some entity has dumped several loads on the edge of the road in the hopes that---as the bank erodes--these rocks will fall into the river and ---hopefully stop the erosion. Fat to no chance of this happening. The next road in the path of river is the main highway between Kelowna and Rock creek--Hwy 33. We'll see what happens over the next few years. The picture of the degraded creek depicts a typical stream reach that is downstream of TFL-8! Unfortunately, the above scenarios are very sad examples of what is happening across BC---with such happenings aided and abetted and inherently supported by the Chief Forester of the day who continually approves AACs that are unsustainable and pose an ongoing threat to the future well-being of BC. We depend on our forested landscapes for virtually every facet of ecosystem services that these ---OUR---forests provide. Without our healthy, properly functioning forests we are doomed to experience ever more unnatural disasters occurring everywhere across BC.

Yes, for sure, several people should make a formal ethics complaint against Diane Nicholls and her senior staff for not appropriately doing work that upholds the Public Interest as paramount. Instead the Roundup/Aspen work was done to benefit the forest industry as paramount and as such was completely unethical. Unfortunately, while all professional organizations and their members (Registrants) are bound by the PGA act and their respective Codes of Ethics to uphold the public interest as paramount in all aspects of their work, I have found the ABCFP to be inordinately aligned with the forest industry instead of the people of BC. What a shame.

Yes, for sure, several people should make a formal ethics complaint against Diane Nicholls and her senior staff for not appropriately doing work that upholds the Public Interest as paramount. Instead the Roundup/Aspen work was done to benefit the forest industry as paramount and as such was completely unethical. Unfortunately, while all professional organizations and their members (Registrants) are bound by the PGA act and their respective Codes of Ethics to uphold the public interest as paramount in all aspects of their work, I have found the ABCFP to be inordinately aligned with the forest industry instead of the people of BC. What a shame.

Herb, your comments are right on. This report contains lots of biased flaws and expectations. However Chief Forester Diane Nicholls somehow believes that her “expectations” will be honoured and met by Interfor without any valid reasons to support such beliefs. Interfor has NOT met the expectations she listed in her previous TSR paper. Why should they do so now? She has no valid reason to base any part of her AAC determination on the chance that they will be honoured and fulfilled when they very likely won’t. I have completed a quick review of the TFL-8 AAC determination paper and will do a more in-depth analysis shortly and report on same. While there are several aspects that indicate an inappropriate bias towards keeping the AAC as high as possible for as long as possible—three aspects are especially relevant. These are: 1. Re making allowances for climate change—the chief forester’s statement in this regard is: “I have not accounted for them in this AAC determination”. 2. A formal cumulative effects report for the entire Boundary area was completed in 2019. The chief forester’s statement in this regard is: “No analysis of cumulative effects was conducted as part of this timber supply analysis.” These positions completely ignore the minister’s direction statements which said that the chief forester should ensure the “TSR process incorporates the best available information on climate change and the cumulative effects of multiple activities on the land base and explores management options that align with established climate change strategies, adaptation and mitigation practices”. Clearly these requests made by the minister of forests represent the public interest in these areas, yet the chief forester ignored them. How can she ethically do this? 3. Provincial log specs vs. Interfor’s log specs: Concerns were stated that Interfor’s log specs varied significantly from the provincial ones and hence were illegal and these differences should be fully considered in the AAC determination. In response to these concerns Interfor stated that: “....operationally, top size utilization is market driven and set by the licensee.” And, even though this statement actually meant that “top size utilization is an economic decision and hence profit driven and set by the licensee,” the chief forester accepted it! It should also be noted that Interfor's Code of Ethics states that: We conduct ourselves with honesty and integrity. We act in a manner that reflects our company’s high ethical standards. We comply with the law and conduct business that protects and enhances our company’s reputation. Hmmm? Obviously some anomalies exist. Lots of other comments/examples to follow; however these three provide an indication of the entire thrust of this document which supports Interfor’s over-riding objective relative to their TFL—i.e. to keep the AAC as high as possible for as long as possible regardless of the risks involved. And to do so notwithstanding what they say in their Code of Ethics. And the chief forester’s AAC determination obviously supports the attainment of Interfor’s objectives. Obviously, the TSR AAC determination process needs mega changes. Yet formal requests to appoint an independent 3-person panel to formally review this process and recommend changes have been ignored.