iv) MS:Regional and district-specific variation in Code interpretation and implementation ($0.29/m³)

In some regions and districts, local interpretation and implementation of Code requirements have reportedly resulted in the development of local standards that exceed the normal regulatory requirements of the Code. Where this has occurred it has placed upward pressure on costs within a number of logging cost categories.

Regional and district-specific variations in Code interpretation and implementation was only identified as a major cost driver in the Northern Interior.

Cost categories which have been significantly impacted by local interpretation and implementation of the Code include:

• Tree to truck:tree to truck cost increases related to the inexperience of some MoF staff and differences in interpretations regarding Code requirements. These were contributing factors to administrative delays in approvals and served to further reduce operational flexibility.
• Road expenses:Several examples were noted with regard to increased road costs, some of which included district manager requirements for geotechnical assessments on all roads, district staff requiring larger culverts than required under the Code, uniform district permanent access (roads and landings) soil disturbance limits (often 7%) for all cutblocks regardless of size and disagreements between MoF and MELP staff with respect to Code requirements.
• Forest management and engineering:Some issues identified as having contributed to increased costs included the approval of only 1 year of blocks on a forest development plan as a way to reduce potential conflicts with forthcoming LRMP and Landscape Unit requirements, and withholding the approval of operational plans unless licensees agree to incorporate the requirements of draft versions of guidebooks.

b) Forest practices ($7.70/m³)

Forest practices cost drivers accounted for a total of $7.70/m³ in logging costs for the 1992 to 1996 period, which is equal to approximately 37% of the total increase of $20.62. Regionally, cost increases attributable to the forest practices cost drivers account for a slightly greater proportion of the cost increase in the Northern Interior (39%) than in the other two regions (36% in the Southern Interior and 37% on the Coast).

i) VQO:Visual quality objectives ($0.22/m³)

Visual quality objectives were only identified as a major cost driver in the Southern Interior of the province.

It is apparent from participants' comments that many operators in other areas, and particularly on the Coast, have chosen to avoid the additional cost of operating in visually sensitive areas while there are other operating areas still available. However, as operations become increasingly constrained by other requirements, harvesting will have to shift into visually sensitive areas in order for licensees to meet their cut control requirements. Meeting visual quality objectives in these areas will require smaller, more dispersed cutblocks and an increased emphasis on non-clearcut systems. As a result, it is expected that the cost of meeting visual quality objectives will increase over time.

The only cost category significantly impacted to date by visual quality objectives is the tree to truck phase. The cost increases associated with this driver are related to the additional costs of selective harvesting carried out to meet visual quality objectives in portions of the Southern Interior.

ii) GU:Green-up and adjacency requirements ($0.55/m³)

Green-up was only identified as a major cost driver on the Coast.

Forest harvesting has been carried out on the Coast for a much longer period relative to other areas of the province. In a number of areas in the Interior, operators have yet to complete their first pass, and green-up of adjacent cutblocks is therefore not yet a significant issue. On the Coast, however, where there is a long history of forest harvesting, green-up requirements are significantly more constraining.

In addition, the impact of green-up requirements has reportedly had a disproportionate impact on the Coast depending on the way that operating areas have been developed. Areas which have been harvested using alternating cutblocks and leave strips may be more constrained by green-up requirements than those that were logged by progressive clearcutting, since any remaining operable timber in areas clearcut progressively may now be accessed without waiting for adjacent areas to green-up (provided that rate of cut restrictions do not further constrain harvesting). As a result, green-up requirements may serve to penalize those operators who have incorporated leavestrips in the development of their operating areas.

The cost categories which have been significantly impacted by the green-up requirements of the Code include:

• Tree to truck:increases in tree to truck costs were related to the greater dispersal of operations required as a result of green-up requirements, longer travel times for logging crews and longer and more frequent equipment moves between blocks.
• Hauling:hauling cost increases related to green-up requirements were the result of more scattered operations and the associated longer haul distances.
• Forest regeneration:forest regeneration cost increases were the result of more dispersed operations, an increased proportion of planted blocks and the use of larger, more expensive planting stock as a means to achieve green-up faster and reduce the impact of green-up requirements on other cost categories.
• Road expenses:road costs increased due to the dispersal of operations and the accompanying requirement to construct, maintain and deactivate more road in order to access the required timber volume.

iii) SC:Soil conservation requirements ($1.70/m³)

Soil conservation requirements were found to be a major cost driver in all areas of the province, although the impact on costs was far greater on the Coast and in the Southern Interior than in the north of the province.

The cost categories which have been significantly impacted by soil conservation requirements include:

• Tree to truck:On the Coast, soil conservation requirements forced some operators to change to more expensive harvesting methods (helicopter, longline and other full suspension methods) to address soil disturbance limits for roads, landings and dispersed disturbances. In a number of instances, the combined effect of reductions in cutblock size and restrictions on the percentage of cutblock area that may be occupied by roads and landings made it impossible to meet soil disturbance limits using conventional methods. In the Interior, there was a move towards increased use of low ground pressure and cable methods on summer ground to limit the risk of exceeding dispersed soil disturbance limits.

  Operators carried out informal surveys and inspections on active blocks to assess soil disturbance levels and were sometimes required to shut down operations when soil conditions might lead to unacceptable levels of disturbance. In addition, several participants indicated that the inflexible application of soil disturbance limits for roads and landings in some districts (often 7%) forced operators to build inefficient on-block road systems (overly-narrow roads, small landings and a lack of turn-outs) which reduced the efficiency of operations while increasing the risk of injury to workers.

• Forest regeneration:soil conservation requirements led some operators to change to more expensive mechanical site preparation methods and equipment, particularly in the Northern Interior.
• Road expenses:increases in road costs were due to construction inefficiencies related to narrower roads and fewer turn-outs and spur road rehabilitation costs on some blocks necessitated by soil disturbance limits for roads and landings.
• Forest management and engineering:forest management and engineering cost increases were related to carrying out soil disturbance surveys, increased supervision of logging operations and ribboning of sensitive sites and split-lines between summer and winter ground.

iv) R&L:Road and landing requirements ($1.91/m³)

The road and landing requirements of the Code were found to be a major cost driver in all areas of the province, although their impact on costs was far more pronounced on the Coast. Some of the reasons given for the larger magnitude of the Coastal cost increase include:

• The steep, often gullied nature of Coastal terrain.
• Higher Coastal rainfalls and a relatively greater abundance of streams.
• More difficult road construction and a higher likelihood of terrain instability.

The cost categories which have been significantly impacted by the road and landing requirements of the Code include:

• Tree to truck:increases in tree to truck costs were primarily restricted to the Southern Interior, and were a result of the combined effect of small landings, narrow roads and limited turn-outs on skidding and loading efficiency.
• Forest regeneration:increases in forest regeneration costs were most pronounced in the Northern Interior, and were the result of reduced silviculture access arising as a result of increased levels of road deactivation.
• Road expenses:increases in road costs were greatest on the Coast, and were the result of higher standards for road construction, maintenance and deactivation.
• Forest management and engineering:forest management and engineering cost increases were related to increased road engineering requirements, geotechnical inspections of road locations and increased supervision of road and bridge projects.

v) RMA:Riparian management area requirements ($0.80/m³)

Riparian management area (RMA) requirements were found to be a major cost driver in all areas of the province, with the greatest impact occurring on the Coast.

The cost categories which have been significantly impacted by riparian management area requirements include:

• Tree to truck:increases in tree to truck costs were related to the additional costs of falling, yarding and skidding around RMAs. Where cable systems were used, additional costs were incurred in feathering riparian management zones, more frequent equipment moves and reduced yarding efficiency where the location and orientation of RMAs reduced yarding distances below optimum. Where skidding was employed, additional costs were incurred in skidding to designated crossings, often coupled with a second machine entry or handfalling in riparian management zones.
• Road expenses:increases in road costs were related to restrictions in road practices within RMAs, locating roads outside RMAs where possible, single machine crossings of streams during road construction, etc.
• Forest management and engineering:forest management and engineering cost increases were the result of increased planning and layout requirements to properly locate and classify streams and delineate riparian reserve zone and riparian management zone boundaries.

vi) CBS:Cutblock size requirements ($1.93/m³)

Cutblock size requirements were found to be a major cost driver in all areas of the province, with the greatest impact occurring on the Coast.

The cost categories which have been significantly impacted by the cutblock size requirements include:

• Tree to truck:increases in tree to truck costs are related to less efficient harvesting (inefficient yarding and skidding distances, inefficient machine complements), more equipment moves due to smaller cutblocks and increased travel costs for logging crews.
• Hauling:hauling cost increases attributable to this driver were primarily the result of dispersed cutblocks and the accompanying increase in haul distance.
• Road expenses:increases in road costs were related to fragmentation of operations, increased road construction, maintenance and road deactivation required to access smaller blocks, more frequent equipment moves and an increase in spur road rehabilitation costs attributable to the combined effect of smaller blocks and inflexible soil disturbance limits for roads and landings.
• Forest management and engineering:forest management and engineering cost increases were related to the additional timber cruising, layout, operational planning and cutting permit application requirements necessary to address the increased number of cutblocks required to harvest a given volume.

vii) OC:Other Code-related cost drivers ($0.22/m³)

Other Code-related cost drivers were major cost drivers in both the Northern Interior and Coastal portions of the province.

The only cost category which was significantly impacted by this cost driver is forest regeneration. The cost increases in this category were primarily the result of silvicultural accruals to address the anticipated cost of pre-free growing spacing requirements for stands harvested during the current year. However, as not all companies reported their silviculture costs on an accrual basis, the impact of this cost driver is expected to increase over time as a greater number of stands reach sufficient density to trigger this requirement.