Herb Hammond

January 26, 2004 Hon Nathan Cullen Ministry of Water, Land and Resource Stewardship PO Box 9012 Stn Prov. Govt. Victoria, BC V8M 9L6 Via e-mail: biodiversity.ecosystemhealth@gov.bc.ca Dear Nathan Cullen, re: Draft BC Biodiversity and Ecosystem Health Framework This letter forms my response to the Draft Biodiversity and Ecosystem Health Framework, November 2023. My comments are provided in two categories: General Comments and Specific Comments. General Comments address major issues inherent in the Draft Biodiversity and Ecosystem Health Framework (the Framework). Dealing with these issues underpins the success or failure of the Framework. Specific Comments are directed to the text of the Framework. Addressing these comments will improve the Framework, but not necessarily ensure its success in the absence of addressing the issues described in General Comments. General Comments The British Columbia government as represented by the Ministry of Water, Land and Resource Stewardship is to be complemented for the forward-thinking Statement of Intent that begins the Framework: The British Columbia government commits to the conservation and management of ecosystem health and biodiversity as an overarching priority and will formalize this priority through legislation and other enabling tools that apply to, and can be accessed by, all sectors. The Framework is built on the foundation of upholding and enabling the articles set out in the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP) and the requirements of the Declaration on the Rights of Indigenous Peoples Act (Declaration Act). This foundation supports three pillars: Taking a whole-of-government approach that demonstrates vision, leadership, and integration: including setting ecosystem health and biodiversity objectives and standards that apply across sectors, and integrating and aligning provincial government decision- making, policies, processes, and legislation that affect ecosystems. Fostering and supporting a broader whole-of-society approach that facilitates actions and initiatives by individuals, organizations, private sector, governments, and communities to conserve and manage ecosystem health and biodiversity and to advance sustainable communities and economies. Adopting an open and transparent process through evaluation, reporting, continuous collective learning, and adaptive management. The core drivers of success are working together to maintain and enhance biodiversity, ecological integrity, and their overall resilience to ensure the coexistence of healthy ecosystems and human communities and economies in B.C. for current and future generations. This is the first time in BC history that objectives for protection of ecosystem health and biodiversity have been put ahead of objectives for resource exploitation and extraction. In that way, this is the first time in BC that a path to ecological and cultural sustainability has been adopted. This is an excellent start towards a responsible, reciprocal relationship with Nature — the foundation for ecological and cultural sustainability. However, implementation of this new relationship is a complex undertaking that reverses an approach to natural ecosystems designed to exploit their resources and redesign their character to suit short-term human desires. Throughout the history of British Columbia, legislation, education, and research, indeed the overall modus operandi for most of society, have and continue to support this short-term approach of exploitation and extraction of “natural resources” found in ecosystems. Thus, “taking a whole-of-government approach” and “fostering and supporting a broader whole-of- society approach” pose many challenges that could derail the implementation of the Framework. Most of these challenges are not described in the Framework, and I encourage the BC government to incorporate them in the Framework, and to give these challenges priority in both revising and implementing the Framework. Challenges and Solutions 1. Control of Ecosystems and Resources — Tenure Under current BC legislation, regulations, and policy the management and conservation of ecosystems, outside of parks and other protected areas, is controlled by private entities, primarily industrial resource extraction corporations. These corporations function under legislation that grants them virtually sole control over the resources furnished by the ecosystems within their tenure area. This control is strengthened by the policy of professional reliance whereby the way that corporations relate to biodiversity and ecosystem health is determined by “qualified professionals” in the employ of the corporation. While this arrangement is a clear conflict of interest, professional reliance suits both the aims of resource extraction corporations and the BC government. To effectively implement the Framework, tenure rights for industrial corporations need to be abolished. In their place, an accountable public agency needs to be established to implement precautionary, ecosystem-based standards for protection and conservation of biodiversity and ecosystem health. This public agency would be established and co- managed by representatives of Indigenous governments and the Provincial government. The “Office of Biodiversity and Ecosystem Health” proposed in the Framework would play the role of this accountable public agency. However, their work would only be effective if tenure held by industrial corporations and the policy of professional reliance are abolished. 2. Urgency to Protect Biodiversity and Ecosystem Health — Legislation Ahead of Revision of Framework Due to decades of extraction of natural resources from ecosystems across British Columbia, loss of biodiversity continues to grow, as ecosystem health declines. Thus, there is an urgency to implement the objectives and structures outlined in the draft Framework. The points raised in the Framework indicate that we know enough to change. Therefore, rather than revising the Framework before implementing legislation to protect biodiversity and ecosystem health, we need to enact appropriate legislation now. Development of legislation with the requirement for protection of biodiversity and ecosystem health across all government ministries and sectors of society needs to be the next step in development of the goals and objectives of the Framework. Important aspects of this legislation include: scientifically based, peer-reviewed definitions of biological diversity and ecosystem health. These definitions are readily available in scientific literature. precautionary definitions of biological diversity and ecosystem health. There is a need to incorporate a precautionary approach to err on the side of protection of the integrity of ecosystems, as opposed to exploitation. definition of ecosystem-based management. The legislation will specify ecosystem- based management as the primary tool to protect biodiversity and ecosystem health during human activities. Like the definitions above, the definition of ecosystem-based management will incorporate a precautionary approach. (see Addendum 1) protection for threatened and endangered species and their habitat, including old growth forests and other primary forests. establish the Office of Biodiversity and Ecosystem Health to administer the requirements of this legislation. This agency would be co-developed and co-managed by representatives of Indigenous governments and the BC government. I wish to emphasize the importance of establishing the legislation described above, as opposed to continuing to revise the Framework through ongoing public consultation. Such consultation will be much better served by the development of clear, comprehensive, precautionary legislation designed to protect biodiversity and ecosystem health. This is what a “whole of society” approach to implementing an “overarching priority for ecosystem health and biodiversity” looks like in action. Following this approach of legislation, rather than continued consultation on the Framework will also provide for important education of the civil service and the public in the requirements for protection of biodiversity and ecosystem health. 3. Interim Protection While new legislation is developed, and changes to existing legislation are put in place, there is a need to protect threatened and endangered species and their habitat, old growth forests, and other primary forests, as well as the ecological integrity of ecosystems across BC. In addition, interim protection needs to replace activities that severely degrade ecosystem health, like clear-cut logging and fracking for oil and gas, with activities that provide for protection of ecosystem health. Activities aimed at restoring ecosystem health may accompany activities that protect ecosystem health, particularly in areas where ecosystem health has been significantly degraded. Interim protection measures may be seen as a way to evaluate various aspects of protection of biodiversity and ecosystem health being developed for incorporation in overarching legislation. Specific Comments Specific Comments are referenced by page number in the Framework. These comments need to be incorporated into BC legislation and policy to achieve protection of biodiversity and ecosystem health. Climate change resiliency, indeed ecological resilience in general requires the maintenance of natural character, i.e. natural ecosystem composition, structure, and function. This needs to be clearly stated, as it forms the basis for protection of biodiversity and ecosystem health. (pg ii) “A holistic approach to stewarding BCs land and water resources, ensuring that they are healthy and resilient for the long term” requires application of an important hierarchal relationship between ecosystems, cultures, and economies. Stated simply, economies are part of human cultures and human cultures are part of ecosystems. Given this relationship, protection of the natural character of ecosystems provides for healthy, resilient human cultures that include diverse economies focused on people’s needs. This vital hierarchal relationship needs to be clearly stated in the Framework. (pg ii) “The Framework promotes an inclusive, partnership-based approach...through networks, governance structures...planning tables, forums, agreements and co-operation.” Under today’s legislation and policies that govern land management activities, structures like planning tables and cooperative planning initiatives ignore the reality that people involved in these types of collaboration have significantly different levels of political and legal power. For the framework to work the legal and political power of participants needs to be balanced. How does the BC government intend to provide for this balance? (pg iii) The Framework proposes to develop ways to protect biodiversity and ecosystem health “that is [are] adaptable to diverse ecosystems, cultures, and ways of approaching stewardship across the province.” While that is a laudable objective, it needs to be achieved in ways that do not compromise protection of biodiversity and ecosystem health in order to achieve the goals of local stewardship initiatives. (pg iii) The “whole-of-society approach” is the second pillar under the “foundation of upholding and enabling the articles set out in the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP) and the requirements of the Declaration on the Rights of Indigenous Peoples Act (Declaration Act)” for the Framework. The whole-of-society approach needs to recognize the hierarchy explained in 2 above, particularly as it relates to “sustainable communities and economies”. (pg 1) Under the heading, Ecosystem Health and Biodiversity in BC, the Framework states, “The health of an ecosystem can be evaluated by the degree to which it maintains biodiversity and other ecosystem benefits.” This statement would be more in line with scientific descriptions of biodiversity and ecosystem health if it stated, “The health of an ecosystem can be evaluated by the degree to which it maintains indigenous biodiversity and natural ecosystem composition, structure, and function.” (pg 2) Key terms are defined in the Framework. There are a few additions to these definitions which would improve their meaning for protection of biodiversity and ecosystem health. a) Ecological Integrity: add to the definition “natural ecosystem composition, structure, and function are the foundation for ecological integrity.” b) Ecological Resilience: specify “maintaining natural or inherent ecosystem composition, structures, functions, and processes.” c) Adaptive Management: need to specify that adaptive management may be either active or passive. The definition needs to briefly explain the difference between these two methods of adaptive management. (pg 3) The Famework states: “Ecosystem-based management (EBM) will be an important management approach to achieve this which looks to concurrently manage for ecological integrity and human well-being... there will continue to be areas of more intensive development to accommodate population growth and increasing demands for food, fiber, and energy.” This definition of EBM looks a lot like current management practices that are degrading biodiversity and ecosystem health. “Areas of more intensive development” end up being sacrifice zones for biodiversity and ecosystem health. These “sacrifice zones,” where biodiversity loss and degradation of ecosystem health are accepted ways of management, ignore that these areas are connected to, and interdependent with the landscapes around them. Sacrifice zones cause the landscapes around them to suffer loss of biodiversity and ecosystem health. If the Framework is to provide for protection of biodiversity and ecosystem health on a “whole landscape, whole ecosystem” basis sacrifice zones need to be excluded and a precautionary definition of EBM needs to be provided. Addendum 1 to this letter describes Nature-Directed Stewardship (NDS), which is an approach to our relationship with ecosystems that truly places protection of biodiversity and ecosystem health ahead of exploitation and extraction of “natural resources.” Sacrifice zones are not included in NDS. A key aspect of a principled, ecosystem-centric approach to our relationship with ecosystems includes the establishment of networks of ecological reserves at multiple spatial scales. Step 3 in the description of Nature-Directed Stewardship (Addendum 1) identifies establishment of ecological reserves at multiple spatial scales as an important part of NDS. To be effective in the protection of biodiversity and ecosystem health EBM needs to be defined in the Framework, legislation, and policy using the philosophy, principles, and process for Nature- Directed Stewardship provided in Addendum 1. (pg 4) The Framework calls for a shift from “managing commodities” to “enhanced production potential for ecosystem goods and services.” Ecosystems function to maintain the integrity and resilience of the whole ecosystem, and do not focus on the production of any one aspect of ecosystem benefits, i.e. “goods and services.” Therefore, the idea of “enhancing” ecosystem “production” is a false concept. Attempting to “enhance” ecosystems often leads to loss of biodiversity and ecosystem health. Methods used in enhancement of ecosystems remove essential composition, structure, and/or function that are necessary to maintain resilient ecosystems. Therefore, the concept of “enhancing ecosystems” needs to be removed from the Framework. (pg 5) Under the section entitled Desired Outcomes the Framework suggests that “Advances [to] reconciliation” includes the “right to harvest.” The concept of right to harvest needs to be defined so that it does not include status quo timber management, like that practised in many joint ventures between First Nations, timber companies, and the Province. (pg 5) “Resilient communities and economies” are a desired outcome by applying the Framework. “Diverse and ecologically sustainable local, regional, and provincial economies” are the desired outcome. There is a need for the Framework to define what an ecologically sustainable economy means. Such an economy is based on the protection and maintenance, and where necessary, the restoration of natural ecosystem composition, structure, and function. Applying this definition of an ecologically sustainable economy will provide for the development of economies that protect biodiversity and ecosystem health. (pg 6) As specified in the Framework, Pillar 2: Fostering and supporting a broader whole-of-society approach includes “supporting sustainable and stable natural resource sectors that continue to be a source of good jobs and economic security for communities” as a way to provide for “economic security for communities.” Currently, this objective of Pillar 2 does not exist, and will not occur under the current forest tenure system. The tenure system needs to be abolished to achieve this objective. (see General Comment 1, above) (pg 9) To achieve the goals of the Framework through an Open and Transparent Process (Pillar 3), there is a need to establish a “State of Ecosystems” inventory that documents the current condition of ecosystems across BC. The inventory needs to be field-based, and accurately represent the current condition of biological diversity and ecosystem health across the Province. The inventory will provide a baseline measurement from which future conditions of biological diversity and ecosystem health may be compared to the current situation. If protection of biological diversity and ecosystem health is to fulfil the goal of a new paradigm for relating to ecosystems in BC, regular inventories will need to be required as part of legislation and policy to enable evaluation of how well biological diversity and ecosystem health is being protected. These inventories will form the basis for public reporting “on the state of ecosystem health and biodiversity and progress in implementing the Framework.” (pg10) Thank you for the opportunity to comment on the “Draft BC Biodiversity and Ecosystem Health Framework.” I look forward to hearing how my comments will be incorporated in future legislation and policy, and/or iterations of the Framework. As a show of good faith, I encourage you to move directly to development of legislation and policy for the protection of biodiversity and ecosystem health, rather than continuing to revise the Framework. Following this path will ensure the public that the BC government will implement the Framework, as opposed to the Framework becoming a “talking point,” while biodiversity and ecosystem health continue to decline. Sincerely, Herb Hammond General Description Nature-Directed Stewardship Plans Herb Hammond October 28, 2022 Foundation of Nature-Directed Stewardship: Nature-Directed Stewardship (“NDS”) is a system of ecosystem protection, maintenance, restoration, and human use. Through networks of ecological reserves, ecosystem integrity and biodiversity are protected at multiple spatial scales, while providing for kincentric, Earth-centred human use of ecosystems. The priority in NDS is to maintain (or restore) natural ecological integrity — including biological diversity — across the full range of spatial (from very large to very small areas) and temporal (from short to long periods of time) scales. The second priority is to provide for balanced human and non-human uses across spatial and temporal scales. Within human culture, NDS facilitates the development of ecologically based, diverse, steady state community economies. Nature-Directed Stewardship (NDS) envisions people living as a respectful part of the ecosystems that sustain us and practicing reciprocity with those ecosystems. NDS plans and actions are inclusive of the needs of all beings, all our relations. In this vision, ecosystems are seen as identities to be respected, not objects to be dominated—wisdom passed down by Indigenous elders and knowledge holders across Canada and elsewhere in the world. What people acquire from a kincentric relationship are clean air, pure water, climate moderation, healthy food and shelter, meaningful work, and respectful relationships with each other and Earth. NDS provides for well-being, while asking little from the ecosystems that provide for well-being. Ecosystems are selfless—an important lesson for our species. General Process for Nature-Directed Stewardship Plans This description of the process proceeds in the order of the steps below. However, as the process develops there are iterative relationships between the steps to improve understanding and interpretations. Step 1 Describe Character of Ecosystem: how the natural system works by describing the composition, structure, and function. Character includes modifications to ecosystems by Indigenous management systems but does not include development activities by industrial societies. Describe Condition of Ecosystems: how the activities of industrial societies have impacted the natural character of ecosystems. This step highlights areas for protection and identifies areas for ecological restoration. Step 2 Define Ecosystem Patterns and Processes: identifies ecological limits and identifies the boundaries and constraints for ecologically sustainable human activities. Step 3 Design What to Leave: networks of ecological reserves and networks of ecological restoration at multiple spatial scales. Ecological reserves include progressively finer networks of protected ecosystems. Protected Areas and linkages are the broadest scale network of reserves, followed by Protected Landscape Networks at the medium and small watershed scale, while the finest scale of reserves is Protected Ecosystem Networks at the site or patch scale. Step 4 Determine What to Use and How to Use It: Amongst the networks of ecological reserves and networks of ecological restoration, Human Use Areas are designated that respect the reserve networks and activities are designed within ecological limits. Restoration Areas constitute a type of human use area. Together, human use areas and restoration areas provide the foundation for diverse, community-based economies that function within the natural limits of Nature. Interpretive maps are developed for each step based upon Indigenous knowledge and appropriate Western science. Interpretive maps provide a practical, user-friendly way to reach the goals of each step. The interpretive maps developed for the four steps above provide a Nature-Directed Stewardship Plan map set, which is the core of a Nature-Directed Stewardship Plan. Interpretive maps are unique to each community and ecological landscape where plans are developed.

Introduction to Nature-Directed Stewardship “Looking at life from a different perspective makes you realize that it’s not the deer that is crossing the road, rather it’s the road that is crossing the forest.” —Author Unknown Nature-Directed Stewardship (NDS) is a system of ecosystem protection, maintenance, restoration, and human use. It was developed by the Silva Forest Foundation to protect ecosystem integrity and biodiversity at multiple spatial scales, while providing for Earth-centred human use of ecosystems (Silva Forest Foundation 1997). The first priority in NDS is maintaining (or restoring) natural ecological integrity—including biological diversity—across the full range of spatial (from very large to very small areas) and temporal (from short to long periods of time) scales. NDS (otherwise known as “ecosystem-based planning”, “ecosystem-based conservation planning”, or “Nature-Directed Stewardshipping”) is widely accepted by scientists and practitioners as the state-of-the-art approach to forest planning and use (Kaufmann et al. 1994). Indeed, NDS has also been successfully applied in many different types of terrestrial, aquatic, and marine ecosystems (Price, Roburn, & Mackinnon 2008). Nature-Directed Stewardship envisions people living as a respectful part of the ecosystems that sustain us. Our plans and actions are inclusive of the needs of all beings, all our relations. In this vision, ecosystems are seen as identities to be respected, not objects to be dominated, wisdom passed down by Indigenous elders and knowledge holders across Canada and elsewhere in the world. What people acquire from this relationship are clean air, pure water, climate moderation, healthy food and shelter, and respectful relationships with each other and Earth. People acquire well-being, while asking little from the ecosystems around them. Ecosystems are selfless—an important lesson for our species. The vision of living as a respectful part of the ecosystems that sustain us is the starting point and constant touchstone for making ecosystem-based decisions or Nature directed decisions. Being a respectful part means recognizing that we are only one small, often ecologically insignificant part of the mosaic of natural ecosystems and learning from and protecting those ecosystems we inhabit. Being a respectful part means being Nature directed in our thoughts, plans, and activities. Natural ecosystems function fully and flawlessly without industrialized human societies, but the converse is not true. Yet, from rural to urban landscapes, forest to grassland landscapes, and fresh water to marine landscapes, human beings have degraded and destroyed the very fabric of ecosystems. Our ill-conceived actions have fuelled climate change, water degradation, loss of biological diversity, and created many obstacles for human health and well-being. These results are not respectful of ecosystems and demonstrate the lack of a holistic, thoughtful, precautionary, and inclusive vision. NDS is rooted in a vision that avoids recreating these problems, while providing a system to restore natural ecosystem integrity and resilience. NDS asks that we use the vision of people living as humble, respectful parts of ecosystems to reach for an inclusive future that provides for the well-being of all—human and non-human. The NDS vision is achieved through a practical, tested system of planning and ecologically responsible human use of ecosystems i.e., home systems—our home. At the same time, it provides for ecologically and culturally sustainable communities and their economies. In other words, Nature-Directed Stewardship provides a picture of the ecological framework that is necessary to protect, and the ecological limits that constrain human uses in order for them to be sustainable. Ecologically and culturally sustainable management of ecosystems recognizes a hierarchical relationship between ecosystems, cultures, and economies. Economies are part of human cultures, and human cultures are part of ecosystems. Therefore, protecting ecosystem functioning provides for healthy human cultures, and the economies that are part of these cultures. This understanding is the foundation for and guides the planning and implementation of Nature-Directed Stewardship/Nature-Directed Stewardshipping/ecosystem-based conservation planning. NDS offers a way to plan and implement ecosystem-based use of forests, and ecological restoration of previously degraded forests and associated ecosystems. Given the extensive nature and long history of human-centred forest-based activities, applying NDS in these landscapes often focuses on ecological restoration. In our rush to exploit “resources” found in forests, we have forgotten that we are part of ecosystems supported by a bigger ecosystem—the landscape. By forcing our will on forests, we have degraded those ecosystems and the watersheds and landscapes that support them. We know enough to do better. We have workable methods for protection of Nature, and for assistance for Nature to restore (where necessary) fully-functioning ecosystems. This change begins with an Earth-centred approach rather than a human-centred approach: we are part of ecosystems, and what we do to ecosystems we do to ourselves. We must focus on needs, not on wants. Consumption must be replaced by conservation embedded in a steady state economy. We must act on the understanding that Earth sustains us, we do not sustain Earth. Herb Hammond was a Registered Professional Forester and now is a forest ecologist with 30 years of experience in research, industry, teaching and consulting. Together with his wife Susan, he founded the Silva Forest Foundation, a charitable society dedicated to research and education in ecosystem-based conservation planning. Herb has worked cooperatively with Indigenous Nations and rural communities to develop more than 20 ecosystem-based plans across Canada, and in Russia, the United States, and Indonesia. The 170-page Nature-Directed Stewardship Plans for Glade and Laird Watersheds appears immediately following the comments section, below.

Dear President Mierau and Council Members, Association of BC Forest Professionals (ABCFP): By way of this letter, I resign my membership in the ABCFP. I no longer wish to be part of an organization that alleges to “care for BC’s forest and forest lands,” while remaining silent about the degradation and frequent destruction of natural forest integrity and resilience perpetrated by the vast majority of forestry activities. I will provide examples of these endemic problems below. The ABCFP spends more time worrying about what title people involved in forest management do or do not use than providing standards and oversight of activities to protect forest integrity and resilience. The constant reminder, under threat of fines and potential incarceration, to retired forest professionals that they are not permitted to practice forestry, even to provide advice, is a specific example of this problem. In many aspects of societies retired people are viewed as sources of wisdom to be consulted and listened to as a way of reaching sound conclusions that protect the public interest and the ecosystems that sustain them. In the absence of definition and oversight of forest management in BC by the ABCFP, the organization has contributed significantly to the many endemic problems that plague the profession. Here are a few examples: (1) A plethora of scientific articles urge the protection of primary forests and remaining intact forests to mitigate climate change and reduce loss of biodiversity. Incorporation of this knowledge into new ways of forest protection and use that maintain forests as carbon sinks, and sources of high levels of biodiversity are professional obligations to protect the public interest. Instead, the ABCFP promotes, often by their silence, “business as usual” forest management that exacerbates climate change and biodiversity loss, and shifts forests from carbon sinks to carbon sources. (2) The determination of the allowable annual cut (AAC), along with where and how the AAC is extracted have major impacts on the integrity of forests and the well-being of forest-based human communities. However, the AAC is based on questionable (or no) science. Together with a strong lobby from the timber industry to keep the cut as high as possible for as long as possible, the structure used to calculate timber available results in non-sustainable AACs. This problem has become increasingly obvious as industrial forest tenure holders are unable to find trees to cut to meet their AACs and/or resort to logging of younger and younger trees to reach their AAC. The ABCFP has an obligation to provide scientifically sound and precautionary models, inventory standards, and forestry methods that protect the broad public interest. This obligation has been shirked to the point that the ABCFP may be viewed as more of an industry lobby group than a professional association that stands up for the well being of the public. The actions and inaction of the ABCFP may be interpreted as being in support of keeping the level of cut as high as possible for as long as possible. (3) Pure water is a vital ecological benefit produced by forests at no cost, as long as the natural integrity of forests are maintained. However, with the exception of some small non-industrial forestry operations, industrial forestry degrades water quality, quantity, and timing of flow. The degradation of water starts as soon as roads and the first logging occur in a watershed. As more roads and logging occur in a watershed the degradation of water grows. The type of logging and its location within a watershed influence how large and long lasting the negative impacts of forestry on water are. The work of Younes Alila, UBC forest hydrologist, and his graduate students has been seminal in urging big changes to forest management to protect water. The public has also been very vocal (and right) about the many negative impacts of forestry to water. Science supports that old growth forests provide the best water with the most reliable flows. Climate scientists reminds us that with the loss of intact, natural forest cover, water problems will increase as climate change progresses, leading to more floods, droughts, and water shortages. However, the ABCFP has been silent about the wide ranging impacts of forestry on water, including floods and drought. This silence certainly looks like the ABCFP is captured by the timber industry and not acting in the public interest. (4) Professional reliance, which was put in place by a provincial government that desired to privatize public forests has been entrenched in forestry practices as the modus operandi. This approach permits no disclosure of information to the public by timber companies about the standards and specific forest data on which timber management operations are based. Thus, we have private entities preparing plans and carrying out timber extraction on public lands with no effective accountability to the public. The ABCFP support for professional reliance is a direct conflict with their stated intention to protect the public interest. If that intention was real, the ABCFP would support the abolition of professional reliance and support the development and enforcement of clear, precautionary standards for forest management. The public interest is not protected by turning forests over to the discretion of the timber industry. The public interest is protected by ensuring that all forest activities maintain the natural ecological integrity and biodiversity that provide the ecological benefits that the public depends upon. (5) Clearcutting has been thoroughly discredited for its wide ranging negative impacts on carbon sequestration and storage; biodiversity; water quality, quantity, and timing of flow; and non-timber forest uses. Climate scientists have been vocal in their opposition to clearcutting, because it exacerbates climate change and fuels biodiversity loss. Yet, despite a mountain of evidence to the contrary, clearcutting remains the system of choice for most timber management in BC. This is another place where the ABCFP silence is in direct opposition to the public interest. Even if short-term employment is the only aspect of the public interest considered, clearcuts still fail to deliver as much employment as ecologically responsible partial cuts. (6) In the world’s rush to commit to less carbon intensive forms of energy, BC forests have now become a target for the wood pellet industry that supplies wood pellets to burn for the production of electricity in the United Kingdom, Japan, and elsewhere. Burning wood pellets to produce electricity emits significantly more greenhouse gas emissions per unit of electricity produced than burning coal. At best, burning wood pellets is a misguided attempt to lower greenhouse gas emissions. At worst, it is blatant greenwashing. As another place to market timber, the timber industry in BC has eagerly joined the chorus promoting the development of the wood pellet industry in BC. Allegedly, the wood for these pellets comes from waste from logging and sawmilling operations. This situation has been rationalized by the declaration by forest professionals that portions of trees that are not merchantable logs are “waste” that is burned after logging is finished. In reality, no tree parts are waste. The “waste” that is now burned needs to be left on the ground, because it is an important part of forest composition that functions to replenish soil nutrients, conserve water, and provide habitat for a variety of organisms essential to forest functioning. To add to the problems created by wood pellets, there is abundant, credible evidence that intact BC forests, including old-growth forests, are being logged to produce and export wood pellets. Protection of these intact forests, particularly old-growth and other primary forests, is extremely important to mitigate climate change and slow biodiversity loss The ABCFP is silent about the problems created by the wood pellet industry, despite the fact that creation of wood pellets is not in the best interest of the public, particularly since it increases greenhouse gas production. Apparently, the ABCFP maintains that what is good for the timber industry is good for the public interest. Another aspect of this issue is that the former chief forester of BC, Diane Nicholls, is now the Drax vice president of sustainability. Drax, located in the UK, is the world’s largest user of wood pellets to generate electricity. The switch from senior government official to senior industry manager was made after Nicholls facilitated the development of the wood pellet industry in BC. Nicholls is a prominent member of the ABCFP. Despite her unethical actions around facilitation of the expansion of the wood pellet industry and then leaving government to join Drax, the ABCFP has not initiated a review of Nicholls behaviour vis a vis the Code of Ethics. The likely reason to be cited by the ABCFP is that disciplinary proceedings need to be initiated by an individual, either a member of the ABCFP or the general public. This raises another example of the ABCFP practicing a culture of silence on prominent issues they need to speak out about in order to protect the public interest and the overall credibility of forest professionals. (7) In her role as Chief Forester, Diane Nicholls established the “Chief Foresters Leadership Team,” to provide her with advice about how to manage the forests of BC. The Leadership Team consists of the chief foresters of all the major timber companies throughout BC. Such a “team” skews the advice to recommendations that support timber extraction and away from advice that supports protection of forest integrity and the broad public interest. This is yet another example of the silence of the ABCFP in issues critical to the conservation and sustainable management of the public forests of BC. The ABCFP has the opportunity to support development of a Chief Forester’s Leadership Team that is inclusive of experts on the diverse issues affected by forest management, from climate change and biodiversity loss to non-timber enterprises and Indigenous reconciliation. Such a leadership team would also include representatives of the general public, who are familiar with the current practices of forest management. The failure of the ABCFP to suggest a more appropriate leadership team than that appointed by the chief forester appears to be another example of the systemic timber bias of the organization. FROM THE STANDPOINT OF THE FOREST and all life that depends on healthy, intact forests, the success (or failure) of a forest professional is measured by their footprints in the forest. Good forest management leaves few footprints and fully functioning forests. Unfortunately, most of the forestry done in BC leaves many large footprints and degraded forests. The ABCFP’s role in the large footprints of forestry is a measure of their hypocrisy when one compares their code of ethics and other public documents with what actually happens in the forest. All one needs to do is fly across the province to see the dire state of forest management. From there it requires little analysis to understand the large negative impacts that forestry has on all aspects of ecological integrity and biological diversity. The ecological benefits from pure water to carbon storage have been seriously degraded by industrial forestry. This has resulted in forestry being the largest source of greenhouse gas emissions in BC. Industrial forestry exacerbates climate change and biodiversity loss, thereby contributing globally to the climate and biodiversity crises. Industrial forestry is part of the problem, not part of the solution. The forests are in trouble. Earth’s climate is collapsing. The ABCFP and many of its members are complicit in this trouble. Transformational change in how we define and practice forestry is needed. However, the ABCFP seems to have chosen to ignore increasingly loud and dire warnings from climate and ecological scientists that intact natural forests need protection to mitigate climate disruption and reduce biodiversity loss. Instead of supporting needed change to forestry/forest management, the ABCFP and most of its members have chosen to support continued logging of intact natural forests across BC. That approach leads to a dead end that will not only harm forests, but also human society. I no longer wish to be part of an organization that is unable to see the forest for the timber. Yours truly, Herb Hammond

Photo by TJ Watt THE FOREST IS IN TROUBLE, which means that we are all in trouble. The problems in the forest have little or nothing to do with natural disturbances or other natural forest processes. We are the trouble with forests. We are the forest’s pest. From climate disruption, floods, and droughts to insect outbreaks, degradation of water and soil, and loss of biodiversity, human manipulation of forests is the root cause. Our activities have been carried out under the guise of “sustainable forestry.” However there is little about our management that protects forests, and a lot about our management that protects the financial well-being of a few privileged individuals and companies engaged in timber exploitation. Management means to “control things or people.” Forestry in BC, indeed across Canada, has been firmly entrenched in a colonial paradigm, a way of thinking that started about 150 years ago in this country. That way of thinking by colonial settlers conveniently defined all the land and water as “terra nullis,” or “legally unoccupied or uninhabited.” This gave way to the subjugation and genocide, both overt and covert, of the Indigenous people, the rightful owners and inhabitants of all of Canada. The colonial paradigm quickly lead to an extractive, exploitive view of nature. Indigenous people maintained a responsible, gratitude-filled, and reciprocal relationship with nature. However, settlers ignored this wisdom and adopted an irresponsible, one-way relationship where nature was renamed to be “natural resources” that had no value until extracted and made into human stuff. From what Robin Wall Kimmerer beautifully describes as a living “basket of benefits” that furnishes the full spectrum of the needs for all life, colonial settlers and governments relegated nature to inanimate “things” that only had value if they served human wants and greed. Our current relationship with forests, as defined by forestry or forest management, follows the colonial paradigm. We have ignored our hearts and common sense as we reduced complex forests—nature to timber, allowable annual cuts, rotation ages, dimensional lumber, tree planting, excessive corporate profit taking, and far fewer jobs in forest communities than warranted by the high levels of logging. To add insult to injury, our assault on forests has, and continues to be massively subsidized by government. We need to give voice to this story of our past to understand why and how, as just one small part of nature, we have arrived at this ominous now. Our short-sighted unfeeling treatment of Earth, often propped up by misdirected, dogmatic science leaves us on the brink of runaway climate disturbances, biodiversity collapse, and social and economic inequities that threaten the future of settler and Indigenous societies, alike. In his poignant book, Change the Story, Change the Future: A Living Economy for a Living Earth, economist David Korten reminds us that the current framing story, i.e. dominant ethic for society, is the sacred money and markets story. Under this story, our efforts for meaningful change are constrained. Colonial attitudes toward nature, and more recently the omnipresent corporate control of land and governments, keep this story alive. Based on his decades of experience working with communities around the world, Korten urges us to shift to a sacred life, living Earth story. He defines “sacred” as “what is most important, most essential to the well-being of the community and its members, and therefore most worthy of special respect and care.” To solve the problems that beset our forests, from old-growth, biodiversity, and water protection to equitable sharing of benefits and meaningful employment, we need a new story to guide our relationship with forests. That story, that new relationship with forests is grounded in protection of natural ecological integrity and resilience and made manifest through nature-based planning. The priority for protection of nature is publicly established through an overriding law that requires compliance from all other laws, regulations, and policies that affect forests—that affect all of nature. A hierarchical relationship underpins nature-based plans and facilitates ecologically and culturally sustainable protection and use of forests—of ecosystems in total. Economies are part of human cultures, and human cultures are part of ecosystems. Therefore, first protecting ecosystem parts and processes provides for healthy human cultures and the economies that are part of these cultures. This understanding is the foundation for what Indigenous people refer to as a kincentric relationship with nature where human beings see themselves as related to all beings and as dependent upon the ongoing integrity of all aspects of ecosystems, i.e. home systems. Moving to nature-based planning and living may be achieved through a short transition period where human activities shift from exploitation to restoration and regeneration. Transition provides redistribution of wealth to fund restorative and regenerative activities. Transition shifts perverse subsidies that facilitate ecosystem exploitation, to ecologically and socially responsible subsidies that promote protection, restoration and regeneration. The cornerstone of an effective transition period and beyond is the development of diverse, inclusive community-based economies founded upon nature-based plans. From the knowledge learned from many Indigenous mentors and Western science, I have developed more than 25 nature-based plans (NBPs) across Canada, and have facilitated NBPs in other parts of the world. Without fail these plans inspire and empower communities to embrace a new relationship with nature—a relationship that has always been in their hearts. Where communities have access to forests and choose forestry as one way of relating to forests, application of nature-based approaches produces 3-5 times the number of jobs per tree cut compared to most industrial forestry. If this approach was followed across BC, we could reduce the volume of timber cut by 60 to 80 percent. If politicians denounce this new relationship as “not politically achievable,” we need to remind them that the electorate defines what is politically achievable. If we are told a new relationship is not realistic, we need to explain that there is more than one reality and the reality we advocate is inclusive for a very wide range of people and all forest beings. We know enough to change. Indigenous, observation-based knowledge, particularly that gained through extensive times living as part of ecosystems—not apart from them—needs to be embraced as a holistic basis for decisions. And, linear, reductionist western scientific methods may be used in appropriate places to complement observation-based knowledge. The time is way past due for Indigenous, observation-based, and precautionary knowledge to shape our relationship with forests—with nature. The use of “a lack of science,” “a lack of understanding” to justify aggressive relationships with forest, often through assumptions of convenience, needs to stop. Herb Hammond is a Registered Professional Forester and forest ecologist with 30 years of experience in research, industry, teaching and consulting. Together with his wife Susan, he founded the Silva Forest Foundation, a charitable society dedicated to research and education in ecosystem-based conservation planning. Herb has worked cooperatively with Indigenous Nations and rural communities to develop more than 20 ecosystem-based plans across Canada, and in Russia, the United States, and Indonesia.

Professional forester calls for an end to clearcutting in BC and a reduction of the allowable annual cut to less than half its current level. A clearcut in the Prince George area (Photo by Sean O’Rourke, Conservation North) AS A REGISTERED PROFESSIONAL FORESTER, I have received many email invitations from the Association of BC Forest Professionals (ABCFP) promoting a “Free E-course” which purportedly will explain my profession’s Code of Ethical and Professional Conduct. Ethical behaviour and professionalism are not taught. They are inherent values of honest, compassionate, and thoughtful individuals. The ABCFP would do better to address the endemic problems of forestry that are exacerbating both the climate emergency and biodiversity crisis than to give the illusion of ethical professionalism. The Code of Ethical & Professional Conduct states, in part under Section 2, Independence: “Registrants exhibit objectivity and are professionally independent in fact and appearance, and must: a. uphold the public interest and professional principles above the demands of employment or personal gain…” Nothing could be more important and essential to upholding the public interest than acting to reduce greenhouse gas emissions into the atmosphere and to slow loss of biodiversity. Yet, standard industrial forestry practices of clearcuts and short-rotation tree plantations do the exact opposite. Industrial forestry degrades water and watersheds through the destruction of old, intact primary forests that produce the highest quality water in moderate flows, and the destruction or removal of fallen trees that store and filter water. These same old, primary forests are necessary to conserve water, particularly under the stresses of heat and moisture loss that get progressively worse with global heating. The fallen trees build future moisture- and nutrient-sufficient soils. Old-growth forests are critical storehouses of carbon, sequester the most carbon compared to other forest phases, produce the highest quality water, and harbour the highest levels of biological diversity, including specialist species found nowhere else. Not to mention the vital cultural importance of these forests to Indigenous people, and to a growing number of non-Indigenous people. Yet, driven by its commitment to a short-term, timber-extraction bias, the forestry profession consistently discounts the importance of old-growth forests for other than required timber supplies. This bias for timber extraction at the expense of all other forest values has been supported by spokespeople for the ABCFP and even by forestry academics who proclaim, in the face of scientific studies showing the opposite, that there is plenty of old-growth already protected in parks and other protected areas. These false claims expose a willful ignorance of the difference between old-growth forests that grow on deep, moist soils, compared to old-growth forests that develop in bogs, on shallow moisture-deficient soils, and at high elevations. The Fairy Creek rainforest is but one example of the endemic problems with professional forestry. Who are the forest professionals that designed clearcuts in old-growth forests that contain the blue-listed specklebelly lichen? In another example, what about the ongoing decline of woodland caribou that depend upon old-growth forest habitat? This dependence of woodland caribou has been known for decades. Yet, during that time forest professionals have continued to authorize logging plans that destroy caribou habitat. We will never know how many threatened and endangered species have been wiped out by “professional” forestry, because no one bothered to ask if they existed before exploiting the forest for timber in the first place. If you don’t ask the question, you don’t need to worry about the answer. Does that approach uphold the public interest? Is that approach an example of ethical professionalism? Forestry is a significant player in the shift of British Columbia’s, and Canada’s forests from carbon sinks to carbon sources. While wildfires may make up the largest part of that shift, logging, slash burning, and the production of short-lived wood products are significant contributors to forests being the single largest source of greenhouse gas emissions of any economic sector in BC. Also, important to note is that clearcuts and tree plantations are highly flammable, increase wildfire risk and cause large, intense wildfires. When it comes to the public interest, foresters have a professional obligation to recognize that, among “the multiple values that society has assigned to BC’s forests,” protection of a livable climate and the biodiversity that sustains all life on Earth are paramount values, without which the other values will cease to exist. As a first measure towards climate correction, the provincial government needs to stop clearcutting all forests, particularly old primary forests on Crown land and reduce the provincial allowable annual cut by more than half. Herb Hammond is a Registered Professional Forester and forest ecologist with over 40 years of experience in research, industry, teaching and consulting. Currently his work is carried out through Silva Ecosystem Consultants and the Silva Forest Foundation.