No impediments to regeneration have been identified in the inventory of environmentally sensitive areas for the TFL. However, Interfor has indicated that regional standards for the density of trees in regenerating stands ("stocking standards") will not be adhered to on colluvial sites, sites with a high water table, sites with shallow organic soils over rock, and sites where lower stand densities are used to meet wildlife management objectives. Lower stocking standards were not modeled in the analysis. While I do not expect lowered stocking standards to have a significant effect on the amount of timber produced by these stands (except stands with extremely low densities), some of them may more appropriately be classified as environmentally sensitive regeneration sites, which do not fully contribute to the timber harvesting land base. Since this adds some uncertainty to medium- and long-term timber supply, I encourage the licensee to investigate this matter further so that it can be taken into account in future determinations. The total area involved and the projected management regime should be clarified at that time.
In addition, District staff indicate that there are several potential impediments to regeneration, including Sitka spruce weevil, rodent damage, brush competition, root rot, and excessively hot and dry microclimate conditions which were not identified in environmentally sensitive area mapping for potential regeneration problems. Interfor has outlined measures to control brush and deciduous species competition in MP No. 3; however, the management plan does not address other impediments to regeneration. Interfor has stated that difficulties in meeting obligations for establishing stands are not anticipated, although I note that the licensee has been conducting research in some areas which have been difficult to regenerate in the past.
I note the concerns of District staff; however, no substantial impediments to regeneration have been conclusively identified. Nevertheless, I believe the concerns of the district should be investigated. I expect district staff to work with Interfor to validate their concerns. If any problems are identified, they should be addressed in future management plans and timber supply analyses. For this determination, I accept the regeneration assumptions used in the analysis.
(iii) silvicultural treatments to be applied to the area;