David Broadland

January 29

8 hours ago, Yudel said:

“At 58,000 hectares, the promised new Incomappleux Conservancy is relatively large,” says Pettitt. “VWS is pleased that it takes in the entirety of the Incomappleux unit of our park proposal. The Conservancy is close to twice as large as the Incomappleux unit of VWS’s park proposal; but the extra is mostly clearcuts, inoperable terrain, rock and ice."

So a little under half of the conservancy is "clearcuts, inoperable terrain, rock and ice." That's very different from 94% being "rock and ice" [(58,000-3,600)/58,000 ha].

I don't follow the arithmetic that leads you to believe "a little under half of the conservancy" is clearcuts, inoperable terrain, rock and ice. The half of the new conservancy that was in the original Valhalla proposal also included rock and ice.

Again, look at a high res satellite image. Better to believe your eyes.

But you are missing the main point which is that the current government has shown that it will include a large fraction of unthreatened ecosystems in its program to conserve biodiversity. This will allow it to make its 30 percent quota without actually conserving much highly productive old forest and the high levels of threatened biodiversity found therein.

This conservancy has several mining claims in it. In BC a "conservancy is defined by the Park Act as:

(3.1)Conservancies are set aside

(a)for the protection and maintenance of their biological diversity and natural environments,

(b)for the preservation and maintenance of social, ceremonial and cultural uses of first nations,

(c)for protection and maintenance of their recreational values, and

(d)to ensure that development or use of their natural resources occurs in a sustainable manner consistent with the purposes of paragraphs (a), (b) and (c).

Any government can interpret "(d)" to mean whatever they want it to mean, unfortunately.

January 29

Hi Yudel,

These are 144 dpi screenshots of the PDF pages Fred sent to me. You can drag them off the website page onto your desktop.

January 29

6 hours ago, Yudel said:

"The vast majority of the area of the new conservancy consists of biodiversity-scarce ice and rock... The areal extent of the Incomappleaux Valley that’s now in the conservancy that was considered suitable for logging—see Interfor’s map of its timber harvesting land base in blue in the image below—was only 3600 hectares... much of which had already been logged once—little of that area still contains high levels of biodiversity: a mere 273 hectares."

I think this is misleading. You equate everything outside the timber harvesting land base (THLB) with "rock and ice". But the THLB is simply the forest that is currently economical to harvest. This can be based on proximity to mills and/or current log prices (higher log prices leads to more area being economical to log). Areas outside the THLB might not only be forested, they might also be biodiverse. The fact that old growth forests were mapped outside the THLB supports this (even taking into consideration possible VRI inaccuracies, forested area and THLB are not synonymous since the THLB area itself was constructed using VRI). These old forests outside the THLB may not be as productive or have trees as big as those inside the THLB, but there's no reason to assume they have little biodiversity value, and they certainly shouldn't be called "ice and rock"!

Your overall point, that the size of a protected area does not tell us how much old growth was protected inside that protected area, is still true. But you likely underestimated the importance of this conservancy for old growth protection.

Thanks for your comments Yudel.

You are correct that there is some high elevation alpine forest on the sides of some of the valleys in the conservancy. These are relatively low biodiversity areas compared to the small remaining area of old forest at the bottom of the valleys. As you know, biodiversity declines both with lower temperatures and increasing elevation.

There are still a lot of relatively untouched high-elevation ecosystems in BC that contain trees because they are not commercially attractive. I highly doubt they ever will be, but you are right, we don't know for sure. Still, right now, they are not under imminent threat of being logged.

We need to conserve those remaining high productivity forests in valley bottoms, which are now rare. Those ecosystems are the most threatened. They should have the highest priority for protection/conservation.

If you look at a high-res satellite image of the Incomappleaux conservancy you will see that the vast majority of it is higher elevation ice and rock.

June 26, 2023

David Shipway shared the response he received from Jillian Tougas:

SCNRD_David_Shipway_Response.pdf

April 21, 2023

Thanks for that Martin!

April 13, 2023

The Forest Practices Board responded to this complaint—sent by email on April 4—on April 13 with the letter below, sent to the logging companies named in the complaint and copied to me. I will update this page as the Forest Practices Board proceeds.

From the Forest Practices Board:

File: 97250-20 / 23021 April 13, 2023 VIA EMAIL

Aaron Racher, General Manager Operations TimberWest Forest Corp.

David Younger, Younger Brothers Holdings Woodlot 2032

Chantal Blumel, Okisollo Resources Ltd.

Leslie Fettes, District Manager Campbell River Natural Resource District

Re: Notification of Complaint – Logging of old forest on Quadra Island

Dear Participants:

On April 5, 2023, the Forest Practices Board (the Board) received a complaint from David Broadland on behalf of the Discovery Islands Forest Conservation Project (the complainant). TimberWest (Tree Farm License 47), Okisollo Resources Ltd. (Woodlot 2031), and Younger Brothers Holdings (Woodlot 2032) are named in the complaint.

On Quadra Island, the complainant has identified approximately 655 hectares of old forest which it estimates to be 4 percent of the Crown forested land base. The complainant believes that the failure to complete landscape-level planning and to spatially designate old growth management areas, combined with government’s decision to establish or expand 11 woodlots in Special Management Zone 19, has put the remaining old forest at risk of being logged or degraded. The complainant believes that the three licensees named above continue to log old forest on the island.

A summary of the complaint relevant to each licensee appears below. The complete complaint is attached for reference.

TimberWest

• TimberWest is degrading small patches of old forest in TFL 47.

• TimberWest has no effective strategy to meet the old seral stage targets implied by the Vancouver Island Land Use Plan Higher Level Plan Order.

• TimberWest is not abiding by the strategies recommended by the Vancouver Island Summary Land Use Plan for managing concentrations of veteran trees.

• TimberWest’s strategy for sustaining forest ecosystem structure and function within cutblocks is ineffective because it doesn’t retain forest within cutblocks.

Okisollo Resources Ltd.

• Okisollo Resources Ltd. is logging old forest despite stating in its woodlot licence plan (WLP) that it would retain existing old forest, even “scattered small patches of old forest.”

Younger Brothers Holdings

• Younger Brothers Holdings is logging old forest for roads and degrading old forest by removing trees 250 years old and younger.

• Younger Brothers Holdings made substantive changes to its woodlot licence plan in 2019 concerning old forest reserves without any written communication with the ministry about a major amendment to the plan.

The complainant believes that urgent action is required to conserve all remaining old forest to protect biodiversity and other values. For relief, the complainant requests that the Forest Practices Board determine the most effective approach to conserving the remaining old forest on Quadra Island.

The Board must deal with public complaints about a party’s compliance with Parts 2-5 and 11 of the Forest and Range Practices Act. The Board does not represent the complainant, rather it acts as an independent third party. It is possible that after initial investigation, certain aspects of this complaint fall outside the jurisdiction of the Board. More information on the Board’s complaint investigation process is available here.

I would like to emphasize that the Board is interested in resolving complaints wherever possible, and I would appreciate any suggestions you might have to that end.

I will be contacting you soon to begin investigating this complaint. If you have any immediate questions or concerns please contact me at (contact information removed).

Yours sincerely,

Tracy Andrews, RPF Manager of Audits and Investigations

CC: David Broadland,

Discovery Islands Forest Conservation Project Attachment

November 25, 2022

Amanda Follett Hosgood at The Tyee reports on Herb's resignation from the ABCFP here.

March 24, 2022

Yves, that is such a comprehensive submission. It must have taken a great deal of time to write, but also a large commitment in time and energy just to comprehend the issues involved. That commitment is very admirable; thanks for making it.

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