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.
Allowable annual cut level reduced for Tree Farm Licence 8
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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.