Issued to TimberWest Forest Limited
Table of Contents
The topography of the area is variable, ranging from flat, alluvial river valleys to steep, rugged and rocky slopes. Most of the drainages in the TFL flow westward toward the broken coastline. The smaller blocks located in the Cowichan Valley drain eastward through more gentle terrain than the coastal portion. A temperate, wet climate prevails over TFL 46 with an average annual precipitation of about 380 centimetres and average daily temperatures between -8 and 27 degrees Celsius. Snowfall is limited along the coastline but reaches as much as 100 centimetres in higher elevations.
TFL 46 is dominated by Douglas-fir and hemlock stands, with smaller amounts of cedar, balsam and alder largely making up the remainder of the forested area. Because of the relatively long logging history in this area, much of the TFL is covered by young, second growth stands which have regenerated following harvest.
|7.5 percent of Schedule B AAC|
|7.5 percent transfer to SBFEP|
|2.5 percent transfer to SBFEP|
Dec. 8, 1992
|Subdivision into TFLs 46 & 54|
However, the analytical techniques used to assess timber supply are simplifications of the real world. There is uncertainty about many of the factors used as inputs to timber supply analysis due in part to variation in physical, biological and social conditions--although ongoing science-based improvements in the understanding of ecological dynamics will help reduce some of this uncertainty.
Furthermore, technical analytical methods such as computer models cannot incorporate all of the social, cultural, and economic factors that are relevant when making forest management decisions. Therefore, technical information and analysis do not necessarily provide the complete solution to forest management problems such as AAC determination. The information does, however, provide valuable insight into potential impacts of different resource-use assumptions and actions, and thus forms an important component of the information I must consider in AAC determinations.
In making the AAC determination for TFL 46, I have considered known limitations of the technical information provided, and I am satisfied that the information provides a suitable basis for my determination.
(ii) redetermining AACs frequently, to ensure they incorporate up-to-date information and knowledgea principle that has been recognized in the legislated requirement to redetermine AACs every five years. The adoption of this principle is central to many of the guiding principles that follow.
The impact of the Forest Practices Code on timber supply is a matter of considerable public concern. In determinations made before the Code was brought into force, no final standards or regulations were available at the time the timber supply analyses were conducted. Accordingly, the analyses were unable to assess the impacts of any new constraints on timber production which might be imposed under the Code. In those determinations I did not consider any more stringent restrictions or additional impacts upon timber supply beyond those anticipated to occur due to the application of guidelines current at the time of determination. However, I assumed that the Code would at least entrench the standards exemplified by those guidelines as statutory requirements.
The Forest Practices Code of British Columbia Regulations were approved by the Lieutenant Governor in Council on April 12, 1995, and released to the public at that time. The Forest Practices Code of British Columbia Act was brought into force on June 15, 1995. Studies in selected TSAs (Forest Practices Code Timber Supply Analysis, BCFS, and BC Environment, February 1996) indicate that under the Code there will be some impacts on timber supply additional to those expected under previous guidelines. In AAC determinations made since the coming into force of the Code, I have viewed with some caution the timber supply projections in timber supply analyses that pre-date the Code, or that are based on information packages that largely pre-date the Code, as is the case in TFL 46. At the same time, I am mindful that the full force of the Code may not be felt during the transition phase of its implementation, and the impacts of specific factors on timber supply may not yet have been assessed on a local basis.
The impact on the timber supply of land-use decisions resulting from planning processes such as the Commission on Resources and Environment (C.O.R.E.) process or the Land and Resource Management Planning (LRMP) process is a matter often raised in discussions of AAC determinations. In determining AACs it would be inappropriate for me to attempt to speculate on the impacts on timber supply that will result from land-use decisions that have not yet been taken by government. Thus I do not consider the possible impacts of existing or anticipated recommendations made by such planning processes, nor do I attempt to anticipate any action the government could take in response to such recommendations.
Moreover, even where government has made land-use decisions such as the Vancouver Island Land Use Plan, it may not always be possible to analyze the full timber supply impact in AAC determinations. In most cases, government's land-use decision must be followed by detailed implementation decisions. For example, a land-use decision may require the establishment of resource management zones and resource management objectives and strategies for these zones. Until such implementation decisions are made, it is impossible to properly assess the overall impact of the land-use decision. Where specific protected areas have been designated by legislation or by order in council, these areas are no longer considered to contribute to timber supply. The legislated requirement for five-year AAC reviews will ensure that future determinations address ongoing plan implementation decisions.
The Forest Renewal Plan will fund a number of intensive silviculture activities that have the potential to affect timber supply, particularly in the long term. In general, it is too early for me to assess the consequences of these activities, but wherever feasible I will take their effects into account. The next AAC determination will be better positioned to determine how the Plan may affect timber supply.
Some have suggested that, given the large uncertainties present with respect to much of the data in AAC determinations, any adjustments in AAC should wait until better data are available. I agree that some data are not complete, but this will always be true where information is constantly evolving and management issues are changing. Moreover, in the past, waiting for improved data has created the extensive delays that have resulted in the current urgency to redetermine many outdated AACs. In any case, the data and models available today are superior to those available in the past, and will undoubtedly provide for more reliable determinations.
Others have suggested that, in view of data uncertainties, I should immediately reduce some AACs in the interests of caution. However, any AAC determination I make must be the result of applying my judgement to the available information, taking any uncertainties into account. Given the large impacts that AAC determinations can have on communities, no responsible AAC determination can be made solely on the basis of a response to uncertainty. Nevertheless, in making my determination, I may need to make allowances for risks that arise because of uncertainty.
With respect to First Nations issues, I am aware of the Crown's legal obligations resulting from the June 1993 Delgamuukw decision of the B.C. Court of Appeal regarding aboriginal rights. The AAC I determine should not in any way be construed as limiting the Crown's obligation under the Delgamuukw decision, and in this respect it should be noted that my determination does not prescribe a particular plan of harvesting activity within the TFL. It is also independent of any decision by the Minister of Forests with respect to subsequent allocation of the wood supply. Aboriginal rights will be taken into account as far as possible under Section 7(3) of the Forest Act and will be respected in the administration of the AAC determined.
Regarding future treaty decisions, as with other land-use decisions it would be inappropriate for me to attempt to speculate on the impacts on timber supply that will result from decisions that have not yet been taken by government.
Overall, in making AAC determinations, I am mindful of my obligation as steward of the forest land of British Columbia, of the mandate of the Ministry of Forests as set out in Section 4 of the Ministry of Forests Act, and of my responsibilities under the Forest Practices Code of British Columbia Act.
For each AAC determination a timber supply analysis is carried out, using a data package of information from three categories: land base inventory, timber growth and yield, and management practices. Using this set of data, and a computer simulation model, timber supply forecasts are produced. These include sensitivity analyses of changes in various assumptions around a baseline option, normally referred to as the "base case" forecast, which forms the basis for comparison when assessing the effects of uncertainty on timber supply.
The base case forecast represents only one of a number of theoretical forecasts, and may incorporate information about which there is some uncertainty. Its validity--as with all the other forecasts provideddepends on the validity of the data and assumptions incorporated into the computer simulation used to generate it. Therefore, much of what follows in the considerations outlined below is an examination of the degree to which all the assumptions made in generating the base case forecast are realistic and current, and the degree to which its predictions of timber supply must be adjusted, if necessary, to more properly reflect the current situation.
These adjustments are made on the basis of informed judgement, using current information available about forest management, whichparticularly during the period leading up to, and now during, the implementation of the Forest Practices Codemay well have changed since the original data package was assembled.
Thus it is important to remember, in reviewing the considerations which lead to the AAC determination, that while the timber supply analysis with which I am provided is integral to those considerations, the AAC determination itself is not a calculation but a synthesis of judgement and analysis in which numerous risks and uncertainties are weighed. Depending upon the outcome of these considerations, the AAC determined may or may not coincide with the base case forecast. But once an AAC has been determined that reflects appropriate assessment of all the factors required to be considered, no additional precision or validation may be gained by attempting a computer analysis of the combined considerations to confirm the exact AAC determinedit would be impossible for any such analysis to fully incorporate the subtleties of the judgement involved.
Section 7 (3)
In determining an allowable annual cut under this section the chief forester, despite anything to the contrary in an agreement listed in section 10, shall consider
These criteria and their application to TFL 46 were reviewed and accepted by district staff. I am also familiar with these criteria and understand them to be part of a larger strategy held by the licensee regarding harvest ages, stand management practices and expectations of future merchantable forest products.
I consider operability to be appropriately accounted for in the licensee's analysis for the purposes of this determination.
Reductions accounting for ESA requirements in the licensee's analysis were confirmed by BCFS staff as appropriate. Although the licensee has indicated that past performance shows higher levels of harvesting may have occurred in some of these types of areas, for the purposes of this determination, I agree with the BCFS assessment and consider the allowances made in the licensee's analysis to be a reasonable representation of current practice in TFL 46.
As discussed below, under - site productivity, the licensee has indicated that there is some uncertainty regarding the productivity estimates used in the analysis. For this determination, however, no conclusive evidence has been provided to demonstrate that the deduction of areas identified as low productivity sites in the licensee's analysis is not appropriate. Given this, and the fact that I consider the deductions reasonable and representative of current practice on TFL 46, I consider low productivity sites to be appropriately accounted for in the licensee's analysis.
I recognize that there is an increasing demand for, and marketability of, deciduous timber and consider it to be reasonable to include these types in the timber harvesting land base. I note that the licensee has demonstrated some performance in deciduous types and the licensee's performance in deciduous stands over the next 5 year period and the appropriateness of including deciduous sites in the timber harvesting land base will be reviewed at the next determination.. I expect that the licensee will continue to harvest in these stands as appropriate, in concert with their Management Plan commitments. Any deciduous harvest will be charged against the AAC.
I observe some uncertainty regarding the regeneration of these stands. There is a possibility that these sites will become naturally dominated by coniferous species following harvest. While I recognize that any such variance could have implications for regenerated stand volume projections, it remains unclear at this time what the impacts on timber supply might be. In addition, any uncertainty applies to a small portion of the timber harvesting land base and does not impose a significant risk to the attainment of the AAC over the next 5 years or introduce further risk of unacceptable mid- or long-term outcomes.
Given my experience with respect to this factor and noting deductions made for similar areas in the province, I consider the licensee's analysis to be a reasonable representation of current practice with respect to the productivity impacts of constructing roads and landings in TFL 46. I have determined that no further adjustments to account for roads and landings are required.
I accept that the best information available at the time was used in completing the licensee's analysis. An inventory audit is expected to be completed for TFL 46 in 1997 which is expected to provide additional information regarding this factor for the next determination.
Due in part to historical planting efforts, approximately 48 percent of the timber harvesting land base is covered by Douglas-fir stands. Hemlock stands occupy a further 36 percent with lesser amounts of cedar, balsam and deciduous species making up the remainder of the timber harvesting land base.
A study conducted by the licensee indicates that the operational cruise volumes over a 5 year period were higher than the volumes indicated in the inventory. However, I do not consider the study to constitute a sufficiently large, representative sample of TFL 46 to convince me that the timber volumes used in the licensee's analysis in fact underestimate existing stand volumes by a particular magnitude. The operational cruise and planning information compared with the volumes used in the analysis is taken from a limited time frame and area. Because of this, the results could be influenced by other factors such as actual versus assumed utilization and differences in the sampled and overall average mix of species and sites.
While I remain mindful of the volume comparison differences, I am also aware that there are a number of reasons why these estimates can differ. As I discussed above, under - forest cover updates / reinventories, an inventory audit is expected to be completed in 1997 that should help reduce some of the uncertainties noted here for the next determination. For the purposes of this determination, given that the estimates used were approved by the BCFS for use in this analysis, and that there is no conclusive evidence to suggest their use is inappropriate, I have determined that no adjustments to the base case projection are necessary to account for volume estimates of existing stands, and I am satisfied with the existing stand volume estimates used in the licensee's analysis. This acceptance does not introduce unacceptable risk to the attainment of the base case harvest level.
Accurately estimating site productivity in both young and old stands is difficult. In young stands, growth often depends as much on recent weather, stocking density and competition from other vegetation, as it does on site quality. In older stands, which have not been subject to the management of stocking density, the trees used to measure site productivity may have grown under intense competition or may have been damaged, and therefore may not reflect the true growing potential of the site.
The licensee has indicated some uncertainty may exist regarding the site productivity estimates used in their analysis. Based upon studies completed in the province, I consider it possible that the productivity of some sites may be underestimated in the licensee's analysis. However, the magnitude of any underestimation is unclear at this time but I note that this uncertainty applies to up to 71 percent of the timber harvesting land base based on a review of the distribution of age classes and the age of the inventory.
While no conclusive evidence has been presented regarding any potential underestimation of site productivity in TFL 46 at this time, I recognize that trends and directions observed in recent studies support the likelihood of such an underestimation. For now, I observe that site indexes may be somewhat underestimated and consider this to add further stability to the base case harvest forecast as I discuss below under "Reasons for Decision". In the event that more refined estimates of site productivity are available, they will be considered in the next determination.
TIPSY generated yields were then reduced using Operational Adjustment Factors (OAFs). OAF #1 was applied to reflect reduced production due to unproductive areas such as swamps and rock outcrops that were too small to be reflected in the inventory and ranged from 12 to 20 percent depending on the stand. OAF #2 ranged from 8 to 20 percent to account for natural losses incurred by biotic forces, including disease, as stands mature.
I note that these reduction factors are higher than used in other units having similar characteristics. However, I note that the use of these factors for this determination were approved for use by the BCFS Research Branch. Therefore, for the purposes of this determination, I accept the use of these factors but expect a careful evaluation of their application by the licensee prior to the next determination. I will return to this point below under "Implementation of Decision".
Stands aged less than or equal to 40 years of age, about 55 percent of the current timber harvesting land base, and all future regenerated stands were modeled as managed stands in the licensee's analysis. Managed coniferous stands were assumed to regenerate at a density of 1200 or 1600 stems per hectare, depending upon species and site index. Regenerated stand yield tables were reviewed and accepted by the BCFS Research Branch for use in this determination. Stands dominated by deciduous species were assumed to regenerate naturally and thus existing stand VDYP yield tables were used in their projection.
As was mentioned above in - site productivity, if site indexes are underestimated, then it stands to reason that managed stand yields could be higher. A sensitivity analysis indicated that if managed stand yields are increased by 25 percent, the base case harvest projection does remain the same for the first 5 year period of the projection but then increases about 7 percent per period for the next 15 years, stabilizing approximately 20 percent above the base case. This sensitivity, especially in the short-term, underlines the importance of further refined site productivity estimates as I discussed above and should new evidence become available it will be considered in the next determination.
The volume estimates for regenerated stands used in the licensee's analysis are based upon the best available information and I consider them reasonable for use in this determination.
Some concern has been expressed by BCFS staff that some of the MHAs used in the analysis seem low. While I agree that some of the MHAs used are lower than in other areas of the province, it is worth noting that some of the best growing sites in the province occur on this TFL and that the average age of harvested stands as projected in the licensee's analysis is about 80 years for regenerated stands which is not unreasonable. Further to this, the assumptions used are based upon evidence on operational experience, expected product size and market experience collected by the licensee.
I note that harvesting in this unit is in a transition phase from existing stands to second growth and depending upon market conditions, premium fibre value may often be found in younger stands. In addition, this transition will likely be influenced to some degree by landscape-level biodiversity objectives, especially with respect to old-seral stage distribution requirements, which are yet to be established as I discuss below under -landscape-level biodiversity. A sensitivity analysis indicates that short-term timber supplies are not sensitive to a 10 year change in the MHA and I have no evidence before me that indicates the harvest ages represented in the analysis are not appropriate. I am satisfied that the licensee's analysis is appropriate with respect to minimum harvestable ages on TFL 46 and make no adjustments to account for MHAs.
The representation of NSR in the licensee's analysis is representative of current practice on TFL 46 and consistent with provincial standards. Therefore, I have determined that no further adjustments to account for NSR are required at this time.
As discussed above under Not-satisfactorily-restocked areas, only 390 hectares of current NSR exist on this unit and there is no backlog NSR. The licensee's performance suggests that regeneration delay is in fact closer to 1.5 years rather than 2 years as assumed. This performance suggests that the licensee is meeting the regeneration delay assumption represented in their analysis and I therefore consider the licensee's analysis to be representative of current practice on TFL 46. Given this, I consider regeneration delay to be appropriately represented and make no further adjustments
None of these activities were incorporated into the licensee's analysis but could result in yield benefits in the mid- to long-term. It is not possible to quantify the impacts of these treatments at this time, however, they could influence many factors such as the green-up age, adjacency requirements, minimum harvestable age and managed stand volume estimates. For now, I consider these incremental treatments to represent an unquantified upward pressure on the base case analysis in the mid- to long-term as I discuss below under "Reasons for Decision".
In the licensee's analysis, stands older than 200 years are assigned a minimum diameter at breast height of 17.5 centimetres and a top diameter of 15 centimetres. For younger stands, the standards are a minimum diameter at breast height of 12.5 centimetres and a top diameter of 10 centimetres. All trees are assumed to be utilized to a maximum stump height of 30 centimetres. These utilization parameters represent current practice on TFL 46 and BCFS staff indicate that the licensee is meeting these utilization requirements in their operations.
I consider utilization standards and compliance to be appropriately represented in the licensee's analysis as it is consistent with current standards and practice.
A sensitivity analysis that examined the impact of increasing or decreasing forest cover requirements outside of the visual quality management areas indicates that the base case projection is not sensitive to adjacency requirements until a full 6-pass system is imposed which indicates some inherent management flexibility. In light of this, and the fact that no evidence has been presented to suggest the representation of adjacency requirements in the licensee's analysis are not appropriate, I have determined that there is no need to make adjustments to the base case projection for cutblock adjacency in this determination.
In the licensee's analysis, landscape-level biodiversity was assumed to be accounted for through land base reductions such as riparian areas, wildlife requirements, ESAs, and forest ecosystem networks in accordance with the 1991 "Guidelines to Maintain Biological Diversity in TFL 44 and TFL 46" which were considered to be appropriate at the time by the Ministry of Environment, Lands and Parks. The analysis indicates that 22 percent of the timber harvesting land base is currently considered old growth forest which was defined as stands older than 200 years. In addition, after other reductions such as wildlife reserve areas, ESAs, and operability, approximately 4700 hectares were removed from the timber harvesting land base specifically to account for forest ecosystem network linkages which connect the other reserve areas together. In total, 18 336 hectares, or approximately 92 percent, of the area currently identified as significant for forest ecosystem networks, were excluded from the timber harvesting land base.
The licensee's 20-year plan incorporates biodiversity guidelines current to 1995 and indicates that in approximately 5 years, the amount of forest older than 200 years remaining on the timber harvesting land base will be reduced to approximately 18 percent. The same plan indicates a further reduction of older forest is projected to about 14 percent in the second 5-year period. Concern has been expressed that constraints for older-seral stage distribution are not adequately accounted for in the licensee's analysis. However, I note that the licensee has indicated that biodiversity, including old growth, could be sufficiently maintained within the reserve and linkage areas in TFL 46, which represent about 17 percent of the productive forest area.
A landscape unit planning process which is intended to determine biodiversity emphasis options in view of Code requirements for the area commenced in 1996 and is expected to be finalized prior to the next determination. While I recognize that uncertainty exists regarding future directions concerning the retention of old growth forests in the area and that old growth contributions from the timber harvesting land base may be required until some second growth stands now in reserve have matured and can provide old growth attributes, I do not consider this to impose unacceptable levels of risk to timber supplies over the course of the next 5 years. Given the land base exclusions used in the licensee's analysis and that the 20-year plan indicates that about 18 percent of the timber harvesting land base will be over the age of 200 years following this 5 year period, I find it reasonable to wait for the outcome of landscape level planning processes which are expected to provide direction and help to reduce this uncertainty by the next determination. While this clearly underlines the importance of establishing these landscape level objectives, the Code will provide guidance regarding operational activities over the next 5 years. In addition, I note that the licensee's timber supply analysis and 20-year plan indicate a focus on harvesting younger stands. Thus, while higher level plans are being formulated for older stands of timber, the opportunity to harvest younger stands in the interim reduces the risk of excessive development in older stands that could compromise the setting of reasonable objectives for maintaining older forests on the landscape
In reviewing requirements for landscape-level biodiversity it is not entirely clear that further timber supply adjustments are necessary at this time. In addition, the landscape level biodiversity requirements may be met to some extent through the application of requirements for existing areas reserved for riparian, ESAs and forest ecosystem networks. I expect any further impacts on timber supply arising from the landscape-level biodiversity provisions of the Code should be more apparent by the time of the next determination and I will return to this point below under "Implementation of Decision". Nonetheless, I have remained mindful of the risks regarding landscape-level biodiversity as I discuss below under "Reasons for Decision".
Although the licensee has been operationally managing for stand-level biodiversity for the last two years, the retention of wildlife tree patches was not explicitly represented in their analysis. Over the next five year period, plans indicate that 91 percent of clearcuts will have reserves. Studies by the Vancouver Forest Region and estimates by the licensee indicate that reserve areas, retained exclusively for stand-level biodiversity requirements, have averaged about 3 percent of the total area.
Province-wide, provisions for biodiversity requirements under the Code, including the retention of wildlife tree patches, are expected to reduce harvest levels in the short term by a range of 2 to 4 percent. The findings of the Vancouver Forest Region and the licensee support an impact in this order of magnitude from stand-level biodiversity measures. However, Ministry of Environment, Lands and Parks staff have suggested that stand level requirements for this area may be higher than this. I do note though that contributions from areas deducted to account for other requirements such as riparian areas and ESAs will likely contribute to the attainment of stand level objectives.
In view of the evidence presented and applying judgement based upon my experience, I consider a 3 percent inventory reduction to be reasonable at this time and have accounted for the impact this will have on timber supply below under "Reasons for Decision". I recognize the potential for refinements to estimates for stand-level biodiversity as the impacts of Code requirements become more clear in the future. Any such refinements will be considered in future determinations as they become available.
The TFL contains portions of two major community watershedsShawnigan Lake and Sooke Lake watershedswhich total approximately 1400 hectares. In the analysis, these areas were represented as requiring a 3-metre green-up, except in the visually sensitive areas, where a 5-metre green-up was modeled. Given that there are specific provisions for community watersheds under the Code, I anticipate that an accounting for the management practices required will be available for consideration at the next determination. For the purposes of this determination, I am comfortable with the licensee's analysis with respect to these areas given that no specific conditions beyond those represented have been defined for these areas and that they represent a very small proportion of the overall timber harvesting land base.
It is unclear at this time exactly how much additional habitat will be required for species at risk. However, given that there are new Code requirements for these species that are incremental to those already accounted for in the licensee's analysis, I accept that there likely are additional areas that will be constrained beyond those represented in the analysis. Nonetheless, I am also aware that current analysis of the draft "Managing Identified Wildlife Guidebook" does not project a large impact on timber supply on a provincial basis, although in local areas the impact may be larger. For this determination, I have accounted for the risk that this introduces to timber supply as discussed below, under "Reasons for Decision".
I find that the licensee's estimate of additional land base deductions for riparian habitat has been derived from a rigorous, map-based assessment which is considered reasonable at this time by Ministry of Environment, Lands and Parks staff. Therefore, in my judgement, it is reasonable to conclude that a further riparian deduction of approximately 3 percent of the timber harvesting land base is required in the TFL to account for riparian provisions of the Code, and I have taken this into account in my determination, as discussed below, under "Reasons for Decision".
To meet these objectives, constraints must be placed on timber harvesting, road building and other forest practices in the sensitive areas. These constraints are based on research and experience, and on public preferences and acceptance of degrees of alteration of visual landscape. The constraints are expressed in terms of "forest cover" requirements that relate to the maximum allowable percentage of a visually sensitive landscape that can have visual disturbance at any one time, and through "visually effective green-up", i.e., the stage at which regeneration is perceived by the public to represent a newly established forest.
The licensee's analysis accounted for visual quality management by incorporating specific visual quality objective (VQOs) zones. Approximately 15 455 hectares, or about 23 percent, of the timber harvesting land base are identified as visually sensitive. The modification and partial retention VQO's compose approximately 62 and 37 percent of this area respectively. Depending on the VQO assigned, varying amounts of area within the zone are permitted to have stands less than 5 metres in height at any time.
Standard BCFS procedures were followed in the identification of these zones and the definition of their associated forest cover requirements. BCFS staff have confirmed that the visual quality objectives incorporated in the licensee's analysis are reflective of requirements for these zones and current practice on TFL 46. In view of this and the fact that I have no evidence to suggest visual quality requirements are not appropriately represented in the licensee's analysis, I am satisfied for the purposes of this determination, that no further accounting is required.
Currently, the VILUP is being implemented through the Vancouver Island Resource Targets process. An "Interim Technical Report: Discussion Paper" was released in April 1996 which outlines proposed resource management goals, delineation of Enhanced and General Management Zones, and refinement of objectives for the existing Low Intensity Areas. Through the Resource Targets process, and with the support of Forest Renewal BC, it is possible that management in the Enhanced and General Management zones could offset impacts as a result of the establishment of Low Intensity Areas.
In keeping with my guiding principles for AAC determinations, until such implementation decisions are made, it is not possible to properly assess the overall impact of the resource targets portion of the land-use decision. Future AAC determinations will be better positioned to incorporate timber supply implications of the plan as implementation is completed and strategies are assigned.
However, where specific protected areas have been designated by legislation or by order in council, these areas no longer contribute to the timber supply. As was discussed above under -protected areas, through the VILUP, two new protected areas have been designated by legislation within TFL 46; the Carmanah Walbran and Hitchie Creek Provincial Parks, and I have fully accounted for the exclusion of these areas in this decision.
For this determination, no further accounting is required as a result of the VILUP.
(b) the short and long term implications to the Province of alternative
rates of timber harvesting from the area;
An alternative harvest rate was examined which started at the current harvest level of 558 860 cubic metres per year. This level could be maintained for 10 years before declining down to the long-term harvest level of 535 000 cubic metres. However, the level could then only be maintained for 40 years before falling below the long-term harvest level for 10 years.
The licensee submits that elevated harvest levels are not supported by either the forest development plan or the 20-year plan. Although the timber supply analysis shows some flexibility, in order to avoid future disruptions, the initial harvest level projected was established at the steady long-term level.
For this determination, I accept the base case forecast as a suitable reference on which to base my considerations.
I am aware of the potential implications of a change in harvest level on the communities surrounding TFL 46 which are largely dependent on forest-based income. This is of particular importance to Youbou, which relies on the timber harvested from TFL 46 for employment and economic activity.
(c) the nature, production capabilities and timber requirements of
established and proposed timber processing facilities;
The Cowichan Sawmill includes a large log sawmill, a small log sawmill, a planer mill and dry kilns. The Elk Falls Sawmill includes a small log sawmill and integrated whole log chipping facility, a planer mill and dry kilns. Both mills have been re-tooled to handle smaller diameter timber from second-growth stands. These renovations have helped to resolve past economic difficulties experienced in harvesting and utilizing timber from younger stands. The new milling configuration creates an opportunity for the successful utilization of small diameter, second-growth timber which is forecast for harvest in TFL 46.
Fletcher Challenge Canada, which owns 51 percent of TimberWest Forest Ltd., owns and operates two pulp and paper mills: the Croppkn and the Duncan Bay mills. The Croppkn Pulp and Paper Mill has an annual fibre requirement of 3 323 700 cubic metres and produces 686 000 metric tons of pulp and 437 000 metric tons of paper. The Duncan Bay Pulp and Paper Mill has an annual fibre requirement of 2 736 750 cubic metres and produces 819 000 metric tons of pulp and 593 000 metric tons of paper.
Approximately 53 percent of the wood supply from TFL 46 goes to the Cowichan Sawmill, approximately 10 percent goes to the Croppkn Pulp and Paper Mill, and the remaining 37 percent is sold or traded.
The estimated annual fibre requirements of all the facilities is approximately 6.9 million cubic metres. TimberWest Forest Ltd. obtains fibre supply from a number sources including a number of forest licences in the Vancouver Forest Region and two tree farm licences (TFL 46 and TFL 47). Fibre for the two pulp and paper mills is obtained from various chip agreements as well as from internal production.
(d) the economic and social objectives of the Crown, as expressed by the
minister, for the area, for the general region and for the Province; and
The Minister stated in his letter that "any decreases in allowable cut at this time should be no larger than are necessary to avoid compromising long-run sustainability." He placed particular emphasis on the importance of long-term community stability and the continued availability of good forest jobs. To this end he asked that the Chief Forester consider the potential impacts on timber supply of commercial thinning and harvesting in previously uneconomical areas. The latter would likely require the use of alternative harvesting systems, and to encourage this the Minister suggested consideration of partitioned AACs.
To date, the use of alternative harvesting systems and commercial thinning have not been significant in this TFL. However, in areas that are subject to visual quality objectives, the use of these systems may be appropriate. The Minister's memorandum addressed the effects of visual resource management on timber supply. It asked that pre-Code constraints applied to timber supply in order to meet VQOs be re-examined when determining AACs in order to ensure they do not unreasonably restrict timber supply. As noted earlier, under visually sensitive areas, the existing visual quality management objectives for this area were assigned according to current standards and I accept them as appropriately represented in the licensee's analysis.
I have thoroughly considered the social and economic objectives of the Crown as stated by the Minister of Forests and have accounted for them in my determination wherever appropriate.
(e) abnormal infestations in and devastations of, and major salvage
programs planned for, timber on the area.
I have carefully reviewed this information and accept that the best information available to assess this factor was used in the licensee's analysis. As such, I do not find it necessary to make further adjustments to the base case analysis in order to account for non-recoverable losses.
The licensee's base case indicates an initial harvest level of 535 000 cubic metres per year, about 4.3 percent below the current AAC of 558 860 cubic metres, can be maintained for the first 170 years.
My considerations have identified forest management requirements and changes in practice or information since the completion of the timber supply analysis that either increase or decrease the timber supply relative to that projected in the base case harvest forecast.
Factors that place some quantified downward pressure on the base case timber supply projection are Forest Practices Code requirements for:
Studies in TFL 46 and the Vancouver Forest Region indicate that reserve areas, exclusively for stand-level biodiversity could in effect reduce the inventory volume by about 3 percent in the short term. In view of this and applying judgement based upon my experience, I consider a downward pressure on the base case harvest projection of 3 percent to be reasonable at this time in order to account for stand-level biodiversity requirements associated with the Code. I remain mindful however, of the potential for refinements to estimates for stand-level biodiversity as the impact of Code requirements becomes more clear in the future and any such refinements will be considered in future determinations as they become available.
A rigorous, map-based assessment of additional land base reductions to account for riparian habitat has been completed by the licensee and is considered reasonable by Ministry of Environment, Lands and Parks staff. I agree that the estimate is reasonable for use in this determination and therefore consider riparian areas to represent a quantified downward pressure on the base case harvest projection of about 3 percent.
Factors that introduce an upward influence to the base case harvest projection but which are unquantified at this time are:
I consider it possible that the productivity of some sites may be underestimated in the licensee's analysis. While the magnitude and impact of any such underestimation remains unclear at this time, the likelihood of this occurring adds stability to the base case harvest forecast in all periods.
Stand tending activities considered incremental to the basic silviculture requirements for TFL 46 have been undertaken by the licensee including pre-commercial thinning, fertilization and when available, the use of genetically improved planting stock to regenerate sites following harvest. Although pre-commercial thinning is not scheduled to continue, significant areas have already been treated. In addition, the licensee intends to continue fertilizing portions of the private lands within the TFL and continue to use genetically improved stock where feasible. The impacts of these activities were not accounted for in the licensee's analysis, but could influence many factors such as the green-up age, adjacency requirements, minimum harvestable age and managed stand volume estimates resulting in yield benefits in the mid- to long-term. Since it is not possible to quantify the impacts of these treatments at this time, I consider these incremental treatments to represent an unquantified upward pressure on the base case analysis.
Factors that work to offset the unquantified upward uncertainties on the base case timber supply projection are:
As was discussed above under - landscape-level biodiversity, the licensee did account for their approved 1991 biodiversity plan for the TFL. However, given the subsequent implementation of the Forest Practices Code, there is now some uncertainty regarding biodiversity objectives for this unit. A landscape unit planning process which is intended to determine biodiversity emphasis options in view of Code requirements for TFL 46 commenced in 1996 and is expected to be completed prior to the next determination. I note that many areas are excluded from the timber harvesting land base in order to account for other requirements that will also contribute to the maintenance of biodiversity. In addition, the licensee intends to focus on the harvest of younger stands while higher level plans are being formulated for older stands. Given this, and the inherent stability of the base case harvest projection in the short-term, I do not consider uncertainty regarding this factor over the next 5 years to introduce unacceptable levels of risk to the timber supply or the maintenance of biodiversity values. Nonetheless, this uncertainty does exist and I anticipate that any impacts on timber supply arising from the landscape-level biodiversity provisions of the Code will be more apparent at the next determination.
Closely linked to the biodiversity emphasis options noted above will be the determination of wildlife habitat requirements in the area. Although it remains unclear at this time exactly how much additional habitat will be required for species at risk, I am aware that new Code requirements for these species are expected to be incremental to those already accounted for in the licensee's analysis, but at present, the impacts are not expected to be large. Overall, I accept that there likely are additional requirements that will further constrain the base case harvest projection.
While none of these unquantified factors can be measured with complete certainty, my personal knowledge and experience provides guidance with respect to the orders of magnitude associated with each of these risks. For the purpose of this decision, and in the absence of any definitive guidance on these factors, it is my judgement that, the unquantified factors that work to increase or stabilize the timber supplies in the base case projection are offset by the unquantified factors that exert a downward influence on the base case in the short-term. I expect these matters to be more carefully assessed at the time of the next analysis. In the meantime, I am satisfied that this approach does not introduce unacceptable risk into this decision and this approach fully recognizes the social and economic objectives of the Crown.
The licensee's 20-year plan has identified some spatial concerns in the second 5 year period of the projection but changes in harvest scheduling, alternative assumptions regarding biodiversity requirements and different cutblock configurations could alleviate this short-term deficit. As I discussed above, the use of alternative or incremental silviculture practices could influence many factors, including spatial assumptions used in the 20-year plan in a manner that improves operational flexibility in the short-term.
Apart from the unquantified influences, there are two quantified influences on the base case which combine to represent a downward pressure of approximately 6 percent. However, sensitivity analysis indicates that if more than half of the existing stand volume estimates are reduced by 10 percent, the base case harvest projection can still be maintained for the next 20 years. Further, the base case projection can still be maintained for 5 years if volume estimates for regenerated stands are reduced by as much as 25 percent. I therefore consider that the base case harvest projection is attainable in the first 5 years of the projection, even after accounting for these factors.
In summary, I conclude that adjusting the AAC to the proposed harvest level, which is a reduction of about 4.3 percent below the current AAC, is reasonable and will not impose unacceptable levels of risk to future timber supplies on TFL 46. It is worth noting that this reduction also accounts for the removal of the Carmanah Walbran and Hitchie Creek Provincial Parks. At the time of the next determination, I expect that information regarding biodiversity objectives, the Vancouver Island Land Use Plan and any timber supply impacts resulting from the implementation of the Code will be much clearer than they are now. This adjustment is also consistent with the social and economic objectives of the Crown to avoid unnecessary adverse impacts on current or future generations by setting the AAC not so high as to cause later disruptive shortfalls in supply, nor so low as to cause undue social and economic impacts today.
November 28, 1996
Allowable annual cut
7. (1) The chief forester must determine an allowable annual cut before December 31, 1996, and after that determination at least once every 5 years after the date of the last determination, for
then, with respect to that timber supply area or tree farm licence area, as the case may be, the chief forester is not required to make the determination under subsection (1) of this section before December 31, 1995, or within 5 years after the last determination, but is required to make the determination
February 26, 1996
To: Larry Pedersen
From: The Honourable Andrew Petter
Minister of Forests
Re: The Crown's Economic And Social Objectives Regarding Visual Resources
Further to my letter of July 29, 1994, to your predecessor, wherein I expressed the economic and social objectives of the Crown in accordance with Section 7 of the Forest Act, I would like to elaborate upon these objectives as they relate to visual resources.
British Columbia's scenic landscapes are a part of its heritage and a resource base underlying much of its tourism industry. They also provide timber supplies that are of significant economic and social importance to forest industry dependent communities.
Accordingly, one of the Crown's objectives is to ensure an appropriate balance within timber supply areas and tree farm licence areas between protecting visual resources and minimizing the impact of such protection measures on timber supplies.
As you know, I have directed that the policy on management of scenic landscapes should be modified in light of the beneficial effects of the Forest Practices Code. In general, the new policy should ensure that establishment and administration of visual quality objectives is less restrictive on timber harvesting. The change is possible because alternative harvesting approaches as well as overall improvement in forest practices will result in reduced detrimental impacts on visually sensitive areas. Also, I anticipate that the Forest Practices Code will lead to a greater public awareness that forest harvesting is being conducted in a responsible, environmentally sound manner, and therefore to a decreased public reaction to its visible effects on the landscape. In relation to the Allowable Annual Cuts determinations that you make, please consider the effects that the new policy will have in each Timber Supply Area and Tree Farm Licence.
In keeping with my earlier letter, I would re-emphasize the Crown's objectives to ensure community stability and minimize costs as the forest sector moves to more value-based management. I believe that the appropriate balance between timber and visual resources will be achieved if decisions are made consistent with the ministry's February 1996 report The Forest Practices Code: Timber Supply Analysis.
Finally, in my previous letter I had asked that local economic and social objectives be considered. Please ensure that local views on the balance between timber and visual resources are taken into account within the context of government's broader objectives.
Minister of Forests