Fred Marshall

April 14, 2023

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.

February 20, 2023

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.

February 4, 2023

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

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