Size of the timber harvesting land base
One submission indicates the size of the productive forest land base used in the Forest Service analysis is realistic.
Another respondent suggests the Forest Service analysis estimates of area reductions for unclassified roads, trails and landings is too low. Furthermore, experience in the Lillooet River drainage indicates an additional loss of 3,300 hectares of timber harvesting land base might be possible. A submission by a forest company indicates the reduction for roads in the Forest Service analysis was too high as trees can be reestablished on a portion of the growing space along roads. This comment was accompanied by a computer simulation conducted by the Ministry of Forests' Research Branch which shows the long-term impact is about one half of the road width impact.
An industry submission suggests the economic situation has changed since the timber harvesting land base was mapped in 1991. This respondent reviewed the mapping and found it was conservative, although it was not possible to do a detailed check on all mapsheets. Operability on some mapsheets was considered optimistic. A list of mapsheets with comments regarding operability was also submitted to the Squamish Forest District. The submission concludes that the timber harvesting land base might be underestimated by about 10 per cent due to potential increases in the amount of helicopter logging, some increases in conventional logging and because some second growth forests may now be considered operable.
Another industry submission makes a similar point, stating strong timber prices and innovative harvesting techniques allow economical harvesting of lower quality and less accessible timber, effectively increasing the size of the timber harvesting land base. They suggest an allowance be considered for additional harvesting areas not currently included in the timber harvesting land base.
Several other industry submissions favour the land base used in the technical critique. One submission notes that some areas in current logging plans were not included in the Forest Service analysis timber harvesting land base due to tree height criteria, and suggest these older hemlock and balsam forests are easily reforested and contain enough merchantable timber to make them economic for logging. They also point out that some previously logged areas were not included in the Forest Service analysis.
Another submission suggests replacing economic criteria with a silvicultural criterion (such as site productivity) to determine whether high elevation and low productivity sites are included in the timber harvesting land base. This approach addresses concerns about regeneration and rate of forest growth.
Others suggest community watersheds be excluded from the timber harvesting land base, unless their inclusion is requested by the community of water users.
One industry submission states that upcoming biodiversity and riparian management guidelines will further erode the operable timber supply. It is suggested the government assess the impact of these policies and be prepared to make adjustments where the benefits do not justify adverse social and economic impacts.
Forest volume estimates
Industry submissions reaffirm the uncertainty of future forest volumes and the potential impact of this uncertainty on timber supply analysis.
One respondent is optimistic about the long-term potential of the Soo Timber Supply Area to support a higher timber supply level than shown in the Forest Service analysis.
Concern was expressed regarding possible impacts on timber supply if volumes harvested from remaining mature forests are actually lower than estimated due to a higher than average incidence of decay.
Another submission points out that the trend of declining harvested volume per hectare is not recognized in the Soo Timber Supply Area plan and this will compound the effects of a shrinking land base on the allowable annual cut.
One submission questioned the validity of the management regimes for second growth fir used in the Forest Service analysis, especially the multiple applications of fertilizer on some sites. The respondent states this adds uncertainty to forest volume predictions.
·Forest cover requirements
One respondent questions the analytical techniques used to model cutblock adjacency requirements and suggests they do not constrain timber supply enough. Furthermore, adjacency is the largest constraining factor in determining the allowable annual cut and will have an impact on both the short- and long-term harvest levels. These comments were based on an interpretation of Dr. John Nelson's (University of British Columbia) work on modeling adjacency constraints.
It is suggested that due to past practices of concentrating cut in small areas, cutblock adjacency requirements are inadequate and need revision.
Another submission suggests cut block adjacency requirements will have a much larger impact on the harvest level than indicated in the Forest Service analysis.
The industry submission calls for a re-examination of visual quality objectives and other constraints to ensure they accomplish the desired objectives and that their use is justified despite the cost of lost timber production.
Minimum harvestable ages
Two industry submissions suggest minimum harvest ages based on timber product objectives as modelled in the Forest Service analysis should be reconsidered. They question the extent to which todays harvest should be constrained by unpredictable future needs. Alternatively, it was suggested that minimum harvest ages could be selected to complement timber production by eliminating age class gaps or by determining the culmination of mean annual increment. Increased research to develop more realistic culmination projections is recommended.