- general comments
The total area of TFL 45 is 243 000 hectares. The land base that is considered available for timber harvesting (the "timber harvesting land base") is limited by inoperability, environmental sensitivity, and unmerchantable forest types. Reasonable assumptions, and if necessary, projections, must be made about these factors and appropriate areas must be deducted from the productive forest area to determine the timber harvesting land base. The timber harvesting land base, as defined in the analysis, is 29 913 hectares.
The principal deduction from the productive forest land base was for inoperability. The operability classification for TFL 45, completed in 1994, identified areas that were harvestable using helicopter, cable and ground harvesting systems. Once these areas were identified, Interfor applied a minimum volume per hectare requirement for each operability class to identify all operable areas in the TFL.
I note that approximately 7 percent of the operable land base is expected to be harvested using helicopter harvesting systems, and 4 percent of the operable land base is occupied by 'marginal' standswhich are accessible, but have a low average volume per hectare and a high incidence of decay. There is a history of harvesting in these stands; accordingly, I do not believe that a partition is needed at this time to ensure performance in them. However, I emphasize that marginal and helicopter-logging stands occupy approximately 11 percent of the timber harvesting land base, and that harvesting must continue in these stands in order to support their continued contribution to the AAC.
District staff have expressed a concern about the areas within Dorothy Creek and the upper Hoodoo Creek drainage that were classified as harvestable using conventional harvesting systems. District staff believe that because these areas are characterized by steep terrain and access is difficult, it would be more appropriate to use helicopter systems for harvesting these areas. Regional staff have also indicated that the classification of some areas in Phillips Arm may be changed from conventional to non-conventional as some roads are permanently deactivated due to slope stability concerns. I acknowledge these concerns, and respond that harvesting practices in these areas, including choice of appropriate technology, will be conducted according to regulations in the Code. Given the licensee's experience with varied harvesting systems, I do not consider this matter to represent a significant risk to timber supply.
With the exception of the concerns noted above, BCFS staff have approved the operability classification and the minimum volume requirements applied in the timber supply analysis, and I accept the operability deduction as reasonable for use in this determination.
- roads, trails and landings
In the timber supply analysis, a deduction of 3.6 percent was applied to the portion of the productive forest land base covered by stands 60 years and younger, to account for existing roads. The projected impact from future roads, trails and landings was accounted for through a 4 percent deduction to the area in stands older than 60 years, applied after the first harvest. District staff believe that the road deductions applied in the analysis are low in comparison with silviculture prescriptions and site degradation assessment results on recently harvested areas. To assess the risks associated with larger road deductions, a sensitivity analysis was provided, with existing road deductions increased to 7 percent and future deductions increased to 5 percent, thereby decreasing the size of the long term timber harvesting land base by 4 percent. This analysis shows that the harvest levels projected in the base case can still be achieved for 5 decades, and that long-term timber supply is reduced slightly. Considering that an underestimation of the area in roads, trails and landings would impact long-term timber supply, I expect these estimates to be further refined for the next determination. I recognize that there is some uncertainty regarding the roads deduction; however, given that any risks are in the long term, I believe the deductions used in the analysis are suitable for this determination.
- reductions for environmentally sensitive areas
In the timber supply analysis, after other deductions for non-forested and non-productive areas, non-commercial cover and inoperability, 2910 hectares were considered unavailable for timber harvesting due to high environmental sensitivity, and 828 hectares were excluded from the timber harvesting land base due to moderate environmental sensitivity. Deductions applied to account for environmentally sensitive areas are discussed below under slope stability, recreation, wildlife, and avalanche.
- deciduous forest types
Stands dominated by deciduous tree species are not considered merchantable in the TFL. Accordingly, the area of the TFL occupied by deciduous stands was excluded from the timber harvesting land base in the analysis, either directly through deductions of the deciduous stands (798 hectares) or indirectly through other deductions, such as those for inoperable areas, environmentally sensitive areas and stream buffers (352 hectares). I am satisfied that the deciduous forest type deductions applied in the analysis appropriately reflect current management.
I note that there is some discussion about converting deciduous stands to coniferous stands. The licensee has indicated that it may be feasible to convert 200 hectares of alder stands to coniferous stands; however, the licensee has not committed to a strategy to convert these stands, the associated yield gains are unknown and other management issues must be examined. I am satisfied that no timber supply adjustments is required on this account at this time.