In reaching my AAC decision for the Lillooet TSA, I have considered all of the factors presented above and have reasoned as follows.
For the Lillooet TSA, the corrected base case projection in the BCFS timber supply analysis indicated that harvests could be maintained at 650 000 cubic metres for three decades, but then must decline by about 8 percent per decade before reaching the long-term harvest level of 362 600 cubic metres per year, 90 years from now. The
8-percent-per-decade decline in timber supply projected in the base case is a relatively low rate of decline in comparison with projections in some other TSAs, which indicates some ability to buffer downward influences on timber supply. Sensitivity analysis indicates a relatively high degree of stability in the existing timber supply. For example, a 10-percent reduction in the timber harvesting land base does not necessitate an immediate reduction in the initial harvest level, but does shorten its duration from 30 to 20 years.
My considerations have identified a number of factors, that were not accounted for in the base case due to changes in practice or in information since the completion of the analysis, that limit or increase the timber supply relative to the base case projection.
The main factors identified as limiting the short-term timber supply relative to the base case projection include:
land base: a reduction in the timber harvesting land base by about five percent due primarily to the removal of the Stein Valley as a provincial park; the park decision reduces available mature timber volumes by about seven percent;
age of inventory: the inventory is about 7-8 years out of date for harvesting and natural disturbance and therefore the TSA is already well into the first decade of the harvest forecast;
riparian habitats: an approximately one-percent reduction to the timber harvesting land base is required to account for riparian reserves and management areas;
stand-level biodiversity: an approximately 5000 m³ reduction annually in timber supply is required to account for stand-level biodiversity;
unquantified potential reductions are indicated in the future to account for:- management for wildlife habitat such as deer winter range;
an unquantified, but most likely very small, reduction is indicated to account for special management requirements in newly designated community watersheds.
With respect to these latter two points, there is a great deal of uncertainty about their likely implications for timber supply, as plans have not yet been approved for the management of these values and there is a great deal of unproven speculation about potential outcomes. Until more definitive information is available to me on these factors, in view of the stability in the timber supply in this TSA, I am considering that they can be adequately accommodated within the determination as discussed below. I expect these matters will be given further direction through the LRMP process, such that a quantifiable accounting may be incorporated in future determinations. In the meantime, based on the flexibility of the timber supply analysis, in my judgement any emerging risk associated with these factors will be manageable within the five-year period before the next determination without jeopardizing environmental objectives or the integrity of the subsequently projected timber supply.
As noted under Stein Valley and Harvest flow alternatives, the case of the Stein Valley park is somewhat different from other newly created parks I have considered in other recent AAC determinations. In most cases to date, the PAS has been integrated into a land-use planning process, and in these determinations I did not consider it appropriate to attempt to account for the timber supply impact of the newly created park in isolation from the rest of a land use plan where the plan included ongoing implementation of elements intended to augment the timber supply, such as zones for intensive timber production. In contrast, the creation of the Stein Valley park was not part of a CORE or LRMP process; an LRMP process has only recently been initiated in the Lillooet TSA. Therefore, in considering the effect of the designation of the Stein in the absence of any countervailing elements of a land use plan, I have considered it appropriate in this AAC determination to account for the full impact on timber supply of the designation of the park.
The main factors suggesting that the short-term timber supply may be greater than projected in the BCFS analysis base are:
volume estimates for existing mature stands: an inventory audit indicates that the total mature timber inventory volume for the TSA was significantly underestimated in the BCFS analysis;
minimum harvestable ages: a slight increase in supply may be possible from the harvesting of trees in the TSA at ages below assumed minimum harvestable ages.
The results of the inventory audit identify the likelihood that a new timber supply analysis, based on a complete re-inventory but given the same management regime and land base as used in the BCFS base case analysis, would show a significant increase in available mature timber volumes on the timber harvesting land base. However, without further analysis it is difficult to predict with accuracy what the magnitude of such an increase in timber supply would be. Nonetheless, it is evident that the additional volumes will contribute substantially to the stability of the projected timber supply.
In assessing the factors identified above which work to increase or decrease the timber supply from that projected in the base case, I note the following. The corrected BCFS base case projection shows that although the timber supply is forecast to decline in the mid term, there is considerable stability in the short term, with an initial harvest level projected to be maintained for three decades. As noted, sensitivity analysis shows that the removal of ten percent of the timber harvesting land base shortens by one decade the duration for which this initial level can be maintained, but does not necessitate an immediate harvest level reduction. Thus the designation of the Stein Valley provincial park¾which removes a smaller fraction, about five percent of the timber harvesting land base or seven percent of the existing mature volume¾does not of itself necessitate an immediate AAC reduction; considered alone, the Stein designation would still allow the projected initial harvest level to be maintained for more than two decades.
Several other factors discussed above further limit the projected timber supply. Of these, the major influence is that of the age of the inventory, which effectively reduces the projected duration of the initial harvest level by more than half a decade. Management of riparian habitats and requirements for stand-level biodiversity, together with the other factors identified, will also limit the short-term supply to a lesser extent as indicated. From the sensitivity analyses provided, in my judgement, the total identified constraints on timber supply additional to those considered in the corrected base case analysis will reduce the achievable duration of the projected initial harvest level by a maximum of two decades. Therefore, particularly in view of the strong probability of a substantial underestimation in the inventory volumes incorporated in the BCFS analysis, as identified by the inventory audit, and the associated likelihood of additional timber supplies, as well as the potential for some flexibility in minimum harvestable ages, I am satisfied that the initial harvest level projected in the corrected BCFS base case analysis can be maintained for a period of at least one decade from today.
I am aware that there is uncertainty in a number of the factors considered, and that land use and management regimes may change. While I therefore recognize that there will be harvest level reductions in future determinations, the timing of these reductions is subject to some uncertainty, both from the future downward pressures discussed above, and from the additional volumes identified by the inventory audit. However, I am satisfied that in this determination no immediate AAC reduction is required for biophysical reasons, and that to make such a reduction at this time would be inconsistent with the socio-economic objectives of the Crown as expressed by the Minister of Forests in his letter of July 28, 1994, (see Appendix 4).
In this regard, before making my determination, I considered the possibility of an immediate proportional reduction to the AAC to account for the designation of the Stein Valley park, to explore the premise that, when land-use decisions affect timber supply in the medium and long term, maintaining the harvest on the reduced TSA area raises questions about intergenerational equity. Immediately reducing the AAC now to account for the Stein decision would reduce the timber supply impacts projected for the medium term. Reducing the AAC at this time, however, would immediately affect existing forest-dependent employment and provincial revenues, which can also affect our ability to sustain a healthy environment and economy for the next generation. These important considerations are implicit in the Minister's letter expressing the social and economic objectives of the Crown.
Since in this case the evidence before me shows that the timber supply impacts of the park designation can be fully taken into account without an immediate AAC reduction and without placing future timber supply at risk or unnecessarily compromising non-timber values, then, particularly in view of the Minister's expressed social and economic objectives, I have reasoned that maintaining the AAC at this time is the preferred alternative.
It must be noted that in the case of other park designations in areas in which the timber supply is not as stable in the short term as is currently the case in the Lillooet TSA, it may not be possible to account fully for the impacts on timber supply of the associated withdrawal from the timber harvesting land base without an immediate reduction in the AAC.
The Stein land-use decision has resulted in greater clarity regarding deferrals, by creating the park in conjunction with reducing the area in deferrals related to the protected areas strategy. Nevertheless, a large portion of the timber harvesting land base (about 13 percent) is still under various deferrals and delays in the TSA. In keeping with my guiding principles, I have not taken this into account in this determination as I will not speculate on the outcome of future land use decisions. I also recognize in my determination that there is uncertainty about appropriate management practices in the TSA that account for biodiversity, wildlife habitat and visually sensitive areas in relation to their impacts on timber supply, employment and local communities. The Lillooet LRMP process should tackle these important issues, which can then help guide the timber supply analysis that supports the next determination.
In the meantime, if issues remain unresolved and at some point the district manager becomes concerned that the allowable harvest level cannot be met on the remaining available land base while continuing to meet integrated resource management objectives, the district manager may wish to take steps towards an application to Cabinet for the specification of designated areas that would allow for a temporary AAC reduction under Part 15 of the Forest Act.