Table of Contents
The TFL contains numerous small waterways and lakes, including Jamieson Creek, which runs in a general northwest to southeast direction through the licence area. Topographically, it is characterized by mid-elevation plateaus and gently rolling slopes. The eastern half of the land base lies primarily within the Montane Spruce biogeoclimatic zone, with small patches of Interior Cedar-Hemlock and Interior Douglas-fir in the northeast and southeast corners. The western half is predominantly in the Engelmann Spruce-Subalpine Fir biogeoclimatic zone. The principal tree species are lodgepole pine, Engelmann spruce, subalpine fir and Interior Douglas-fir.
In 1970, Kamloops Pulp and Paper, a partner of Weyerhaeuser Company of Tacoma, Washington, purchased B.C. Interior Sawmills Ltd. In 1971, Weyerhaeuser acquired all the shares of Kamloops Pulp and Paper and renamed its former partner Weyerhaeuser Canada Ltd. TFL 35 was then assigned to the new company.
The AAC fluctuated between 99 109 and 83 600 cubic metres until 1992, when it was raised to 125 600 cubic metres in recognition of specific management commitments by Weyerhaeuser Canada (hereafter referred to simply as "Weyerhaeuser"). That level remains in effect today and is applicable entirely to Schedule B Crown-owned licensee-operated lands. Weyerhaeuser elected not to accommodate harvesting under the Small Business Forest Enterprise Program; accordingly, 2653 hectares were removed from the land base in 1993 to reflect the end of the program in the TFL.
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 answer or solution to forest management problems such as AAC determinations. 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 35, I have considered known limitations of the technical information provided. I am satisfied that this 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.
In considering the various factors that Section 7 of the Forest Act requires me to take into account in determining AACs, I attempt to reflect as closely as possible operability and forest management factors that are a reasonable extrapolation from current practices. It is not appropriate to base my decision on unsupported speculation with respect either to factors that could work to increase the timber supply--such as optimistic assumptions about harvesting in unconventional areas or using unconventional technology that are not substantiated by demonstrated performance--or to factors that could work to reduce the timber supply--such as integrated resource management objectives beyond those articulated in current planning guidelines or the Forest Practices Code.
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, 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 35). 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.
In certain areas where land-use decisions have been made, government's 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 completely assess the impact of those portions of the land-use decision. However, the legislated requirement for five-year AAC reviews will ensure such decisions are addressed in the most timely manner possible. On the other hand, those elements of the plan that are clear--such as the designation of protected areas--must be fully accounted for and respected in any AAC determination.
TFL 35 falls within the purview of a land-use decision--the Kamloops LRMP--that has been made by government. Moreover, certain provisions of that LRMP have been declared a higher level plan under the Forest Practices Code of British Columbia Act. It is therefore required that this AAC determination consider and reflect that declaration.
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 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 far 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. Specific identified activities in traditional areas will be taken into account as far as possible under Section 7(3)(a) 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¦îr/î
Only one management option--the Status Quo option--was provided, the results of which indicate the current harvest level of 125 600 cubic metres per year could be maintained on a non-declining even-flow harvest projection for at least 225 years. No alternative harvest flow projections were provided though I am aware that the licensee has stated that a higher long-term harvest level is achievable. This steady-harvest-flow policy may project a more stable timber supply, but it also masks the maximum long-term potential and thus obscures the effects on long-term timber supply of changes in assumptions about forest management. While my determinations do focus on short- term timber supply, they give full regard to the maximum achievable long-term level and of the transition pattern in between. In my determination I have remained mindful of, and have made allowances for, this aspect of the licensee's harvest flow policy.
I am satisfied that the Status Quo option is an adequate reflection of short-term timber supply. Quite clearly, it avoids excessive changes from decade to decade and significant timber shortages in the future. On this basis, then, I accept it as the "base case" against which the effects of uncertainty on timber supply may be assessed.
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.
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
TFL 35 is predominantly operable. The analysis netdown table indicated the long-term timber harvesting land base is 31 665 hectares, approximately 87 percent of the gross land base. This contrasts markedly with the surrounding Kamloops TSA, where the timber harvesting land base represents only 45 percent of the gross land base. The major netdowns in the TFL were for environmentally sensitive areas (1266 hectares), riparian areas (710 hectares) and existing roads (655 hectares). The vast majority of the timber harvesting land base is amenable to conventional ground-based harvesting systems, with only a few hundred hectares scheduled for non-conventional systems.
I am satisfied that the modelled land base is a realistic representation of what is economically and physically feasible to harvest. The possibility of an overestimate appears to pose little risk to the ability to achieve the short-term harvest level shown in the base case projection. A sensitivity analysis indicated the base case initial harvest level could still be maintained for two decades if the timber harvesting land base were reduced by 10 percent. Accordingly, I accept the modelled land base for use in this determination.
ESA inventories for all three categories were accepted by regional staff in 1993. I am satisfied that they reflect the best available information and are reliable for use in this determination.
District staff commented that there has been very little harvesting in these stand types. The licensee ascribed this lack of historic performance to the priority given by the company to harvesting stands that are overmature and/or susceptible to infestation and disease. Weyerhaeuser submitted that it has some operational experience in these stand types, both on and off the TFL, and will continue to operate in them where they fit into harvesting patterns. With regard to future plans, however, there was some inconsistency among the documents submitted. In the analysis, no substantive operations in these stands were modelled to occur for 30 to 40 years. The 20-Year Plan, in contrast, projected 12 percent of the total harvest volume to come from these stands.
A sensitivity analysis to test the impact of removing these stands from the timber harvesting land base indicated that the base case harvest level could still be maintained across the entire planning horizon. Normally the removal of area from the timber harvesting land base would be expected to lower the long-term harvest level. In this case, however, the licensee elected not to maximize the base case long-term harvest level. As a result, there may be additional timber supply inherent in the base case that could accommodate a land-base reduction without lowering the long-term harvest level.
In summary, I have some concerns about the lack of harvesting history and the uncertainty inherent in Weyerhaeuser's future plans for marginally merchantable stands. However, the base case projection for TFL 35--in contrast to many other units around the province--is sufficiently robust that it can withstand this uncertainty. For this determination I am satisfied that the assumption in the analysis (to make no reductions specifically for marginally merchantable stands) does not pose an unacceptable risk to timber supply. Over the period of Management Plan (MP) 8, however, I expect to see operations in reasonable balance across the inventory profile, with performance reports submitted as part of the licensee's annual reports to the district. This issue should be readdressed in preparation for the next determination.
District staff agree with Weyerhaeuser that, apart from the Bob Lake Plateau area, the TFL is nearly fully roaded. Nonetheless, the absence of any allowance for future roads is an unusual procedure, one that suggests the long-term timber harvesting land base has been overestimated to some extent in the timber supply analysis. And had the licensee modelled the maximum long-term harvest level, that, too, would likely have been optimistic. The failure to account for any losses, past or future, to cutblock trails represents further cause to believe timber supply has been overestimated, unless one accepts--and I do not--that all cutblock trails can and will be restored to full productivity.
The impact of these factors is difficult to quantify, particularly given the wide divergence in other units of estimated losses to roads and trails. However, in light of the sensitivity analysis indicating the base case could be maintained in the short term in the face of substantial changes in the land base, I am confident that whatever timber supply constraints materialize will be felt only in the medium and long terms. Over the five-year period of this determination, I am satisfied that these unknown losses will not pose an unacceptable risk to the base case harvest level. For the next determination, however, I expect that past and future losses to roads and trails will be fully incorporated into the timber supply analysis.
The estimated past losses and projected future losses for cutblock landings appear reasonable and have been approved by district staff. Accordingly, I accept them for use in this determination.
An inventory audit was undertaken by Resources Inventory Branch in the summer of 1995 and released in February this year. It found no statistically significant difference between the average mature volume per hectare indicated in the inventory and that found in the sample plots. On this basis, I am satisfied that the inventory is appropriate for use in this determination. As will be discussed below, under label assignment in analysis, however, some of the inventory labels were changed prior to incorporation into the analysis.
Regional and district staff have expressed doubts over the accuracy of the silviculture labels and the feasibility of achieving the conditions implied by them. To resolve these concerns, I direct the licensee to work with BCFS staff to develop an appropriate verification strategy. The substitution of silviculture labels is an unusual modelling procedure, and it is my understanding that it was undertaken without prior approval by or even notification of BCFS staff. This is of concern to me, regardless of how plausible and logical the substitution may be. Changes of such a significant nature to the inventory ought to be formally reviewed and discussed before implementation. The lack of consultation in this instance needs to be addressed before the next determination to ensure any future changes are mutually agreed upon beforehand. The implications for timber supply are discussed below, under Silviculture treatments.
| Lodgepole pine | ||
| Spruce | ||
| Interior Douglas-fir | ||
| Balsam |
Weyerhaeuser asserts that natural ingrowth will ensure balsam will continue to be represented on the timber harvesting land base as a secondary species. Elsewhere, (e.g., set-aside areas such as riparian areas) balsam-leading stands will be found either as part of the original stand structure or through natural succession.
Both the current and projected distributions reflect the use of silviculture labels, which is discussed above, under label assignment in analysis. Based on past and planned performance by the licensee, I accept these projections as reasonable for use in this determination. As noted in the earlier section, however, I expect the licensee to verify its assumptions in cooperation with BCFS staff over the next five-year period and to ensure that they are attainable and consistent with the LRMP.
Existing stands that were deemed managed, either because of their establishment date or on the basis of an assessment, were assigned to yield curves generated by the Table Interpolation Program for Stand Yields (TIPSY). The managed nature of these existing stands makes them suitable candidates for TIPSY, and the procedure was approved by Research Branch staff.
A sensitivity analysis indicated the base case harvest flow is largely insensitive to a reduction in existing mature volumes. Lowering existing volumes by 10 percent could lead to a brief compromise of forest cover objectives in approximately 100 years (if mid-term harvest levels were not decreased), but no short-term impact is projected. A sensitivity analysis tested the impact of a 10 percent increase in mature volumes and indicated the transition to harvesting younger stands would be postponed, assuming no change is made to the initial harvest level.
As noted earlier, under general comments, a recent inventory audit statistically validated, for the TFL as a whole, volumes estimated using VDYP and existing inventory information. With this in mind, I accept the licensee's modelling methodology and assumptions as suitable for this determination.
The most accurate measurements of site productivity come from stands between 30 and 150 years of age. Outside that range the estimates are believed to be less reliable due to a host of variables that affect growth: these include weather, stocking density, competition from other vegetation, and damage. It is now widely accepted that these old-growth-based site indexes underestimate the growth potential of regenerated, managed stands, which are generally less affected by over-stocking or competition with other vegetation.
This issue of uncertainty surrounding site index values for regenerating stands is a provincial concern. In an effort to obtain better information for use in estimating site productivity, the BCFS Site Productivity Working Group is overseeing a series of paired-plot studies in units throughout the six forest regions. Preliminary results indicate that for some species in some areas, current site indexes, determined using inventory information from existing unmanaged forests, underestimate the growth potential of some regenerated stands.
Despite the relative stability of the base case projection, the uncertainty regarding site productivity is of some consequence for TFL 35 as well. Current harvest projections indicate an abrupt transition in approximately 50 years from old growth to second-growth stands. According to a sensitivity analysis, forest cover objectives could be compromised in approximately 100 years if regenerated stand volumes were overestimated by 10 percent. Conversely, if regenerated volumes are underestimated, this would likely increase flexibility in achieving the base case harvest projection.
Site indexes for each forest polygon in TFL 35 were generated by the BCFS "Freddie" program. Area-weighted site index values for each growth type group and site class combination were then calculated from the polygon site index values. These new values were subsequently applied to all existing and regenerating stands, with the exception of good and medium site class regenerating lodgepole pine in the Montane Spruce dry mild 2 (MSdm2) and Engelmann Spruce-Subalpine Fir dry cold 2 (ESSFdc2) biogeoclimatic subzones. A special site index assignment of 21.1 metres for those classes was made based on growth intercept studies undertaken by Weyerhaeuser. BCFS staff approved the methodology used to assign both the area-weighted and special site indexes.
A further reassignment that was not approved was the conversion of good site spruce and fir within the MSdm2 and ESSFdc2 subzones to good site pine following harvest. This is a plausible extrapolation, but I am concerned that it lacks scientific support and that the procedure was not approved by BCFS Research Branch. For this determination it is not a significant issue, as it affects timber supply only in the medium and long term; prior to its incorporation in future analyses, however, field measurements supporting this assumption should be documented and submitted to Research Branch for approval.
The analysis also assumed a 5 percent increase in volume at all ages for lodgepole pine stands planted after 1999. This incremental yield is based on the use of genetically improved seedlings from Weyerhaeuser's Grandview Nursery near Vernon. Again, this was approved by Research Branch.
As noted earlier, under site productivity estimates, a sensitivity analysis indicated a 10 percent decline in regenerated stand volumes could precipitate a temporary breach of forest cover constraints in about 100 years. No short-term impact was evident, though.
For this determination I accept the regenerated volume estimates used in the analysis. Should they prove to be optimistic I am satisfied there is no undue risk to timber supply in the short term and that there is ample time to implement any harvest-level adjustments necessary to accommodate the revised estimates.
The target rotation ages chosen closely approximate culmination ages. Regional staff have expressed some concern that the target ages are lower than the minimum harvestable ages used in the surrounding Kamloops TSA. It was also felt that for some analysis units, particularly those with pine-leading stands, the target ages are low.
I note that the projected average harvest age throughout the simulation is higher than the average target rotation age. Due to the licensee's focus on older stands the average harvest age now is more than 64 years above the average target rotation age. In 50 years this gap will drop to about five years--coinciding with the shift of operations to younger, regenerated stands--but will then increase thereafter.
In summary, the licensee's assumptions and procedures create a reasonable outcome in terms of projected age of actual harvest, notwithstanding differing professional estimates of minimum harvestable ages. The volumes projected for harvest at the target ages are realistic--only 90 hectares yield less than 150 cubic metres per hectare throughout the entire simulation--and, as noted above, actual volume/area ratios are likely to be higher, given that harvest ages in the field will almost always be higher than the target ages. For this determination, I accept the modelled harvest ages.
BCFS staff concur that the modelled time periods more closely reflect actual performance in the field. Regardless, for this determination the discrepancy is inconsequential. A sensitivity analysis indicated that changing the regeneration delay periods to three years for plantations and seven years for naturally regenerated stands would not affect the base case: the non-declining harvest flow projection could still be maintained across the simulation period.
In summary, I am satisfied that the modelled regeneration delay periods are appropriate and pose no risk to projected timber supply.
I find the NSR estimates reasonable and note that the backlog NSR is scheduled to be restocked in a timely manner. In summary, the base case has incorporated this factor suitably.
(iii)-- silvicultural treatments to be applied to the area;
MP 8 referred to a strategy to increase mixed-species plantations, but indicated that a lack of good volume information for mixed-species stands precluded modelling of this strategy in the analysis. The current analysis therefore assumed a widespread emphasis on management for pine. (See earlier discussion, under species profile.) Weyerhaeuser has committed to implementing the LRMP directives and stated that the next analysis will be better able to incorporate the company's shift to mixed-species plantations. Regional staff thus expect the reforestation operations during the term of MP 8 will involve somewhat more mixed planting than modelled, although pine will continue to be the principal species.
I note that the commitment in MP 8 to mixed-species planting is consistent with recent trends in forest management, as prescribed in the Forest Practices Code and the Kamloops LRMP. The implementation details of that commitment remain to be finalized, however, and there will undoubtedly be a transition period as the licensee works with BCFS staff to bring MP 8 into accord with the provisions of the LRMP.
For this determination I accept the modelled assumptions and the general commitment in MP 8 to the LRMP. By the time of the next analysis I expect the transition will be complete and sufficient information will be available to allow Weyerhaeuser to quantify and model its mixed-species reforestation strategy more precisely. Any impacts on timber supply will be assessed at that time.
Silviculture treatments affect the rate at which regenerated stands become established and the quality and quantity of timber produced therein. For the near future, the success or failure of the silviculture program places timber supply at no undue risk. A sensitivity analysis indicated no impact in the short term from even a 10 percent reduction in regenerated volumes. By the next determination, however, the extent to which the silviculture program will facilitate the growth targets ought to be more evident, and the results should be incorporated into the analysis with greater clarity.
The same strategy was adopted for regenerated stands modelled with TIPSY, except that decay factors were included in the reductions applied by the model. As discussed earlier, under volume estimates for regenerated stands, the normal OAF 2 factor was not applied. These procedures were approved by BCFS Research Branch, and I accept their suitability for this analysis.
Data collection and the completion of the information package on which the analysis was based took place before the introduction of the Forest Practices Code and prior to the completion of the Kamloops LRMP. As a result, the management practices assumed in the analysis do not meet the new requirements in several instances.
Since the analysis, a landscape inventory for the entire licence area has been submitted that accords relatively closely with the LRMP. Very few additional areas have been assigned VQOs, however. Weyerhaeuser has affirmed that its visual management strategy during the term of MP 8 will take into account the new inventory information and the directives of the LRMP.
This more recent information does not significantly affect the assumptions underlying the base case. For the next determination, I expect the new landscape inventory to be incorporated into the analysis but am satisfied that its omission now poses no unacceptable risk to timber supply in the short term.
Two small areas with high wildlife value were excluded totally from the productive forest in the analysis. A separate wildlife management area, covering 785 hectares adjacent to swamp complexes, was modelled with a requirement that 25 percent of the area be retained in late seral stage. The same seral-stage and harvest-age definitions were used as for the deer winter range.
The LRMP did not address the issue of moderate-value mule deer habitat, but did identify 765 hectares within the TFL, predominantly in the Interior Douglas- fir biogeoclimatic zone, as critical deer winter range. Within this range, at least 25 percent of the forested area must provide thermal cover at all times. Ministry of Environment, Lands and Parks staff estimate thermal cover is provided once a stand reaches 10 metres.
The area estimate of 765 hectares and the associated cover requirements are actually less constraining on timber supply than the licensee's current management strategy for deer winter habitat. It should be noted, however, that the LRMP's figure is a product of a strategic overview process for a much larger land base. As subsequent, more detailed, mapping is carried out over the next few years I fully expect further refinement and reconciliation of the plan to ensure it meets or exceeds current management strategies for deer habitat.
The aspect of the LRMP relevant to deer habitat management that may impose a downward pressure on timber supply at some point is its emphasis on management for mixed species. This issue has been discussed in more detail above, under Silvicultural systems and reforestation, where I concluded that the inevitability of a transition phase means the timber supply repercussions of the shift to mixed-species planting will not be fully identified until at least the next timber supply analysis.
A larger part of the licence area falls within the LRMP's critical moose winter range. In contrast with the identified deer winter range, however, the plan did not specify forest cover criteria or other management practices whose impact on timber supply can be quantified at this time. As a result, it is not clear whether the base case harvest projection can be achieved while accommodating the management procedures necessary to meet the general LRMP objectives for moose winter range. BCFS staff do not anticipate any impact on timber supply for at least the near future.
In summary, the LRMP's emphasis on mixed-species management for mule deer winter range may affect timber supply in the medium and/or long terms. I am assured by the relatively small area in question and by the need for a transition phase that there should be no impact for at least the term of this determination. The prescriptions for moose winter range appear less restrictive than for deer, although it is possible they may also affect timber supply in the future. Succeeding AAC determinations will be better positioned to assess the long-term effects of moose management.
and Reserves | Applied in Analysis | |
< 1 hectare | ||
> 1 hectare | 20-metre buffer | 50% |
A land-base reduction of 50 percent was modelled in the analysis to approximate the harvest constraints within the buffer areas. No harvesting is permitted within the reserve areas; consequently they were completely netted out of the productive forest. In total, and following allowances for overlap, 1212 hectares of riparian management areas were identified. This resulted in a net reduction of 710 hectares, or 2 percent, from the productive forest land base. In addition, forest cover requirements associated with some wildlife management zones adjacent to swamp complexes (see above, under wildlife) were considered to be a surrogate for riparian area reductions.
Although consistent with the guidelines of the day, these management measures have been superseded by the more constraining requirements of the Forest Practices Code. The Forest Practices Code Timber Supply Analysis projected a 3 percent land-base reduction attributable to riparian requirements in the nearby Okanagan TSA. No specific analysis has been performed for this unit or the surrounding Kamloops TSA but, given my knowledge of the terrain in this unit, I regard it as likely that an overall reduction of a comparable magnitude will be necessary here to account for riparian management measures under the Code. This suggests that, relative to the timber supply analysis, approximately 1 percent more land base will need to be removed. A sensitivity analysis indicates the base case initial harvest level could be maintained for at least two decades in the event of a 10 percent land-base reduction. Accordingly, I am satisfied that the timber supply impact of riparian management measures will be restricted to the medium and long terms. Riparian management implications should become clearer with further implementation of the Code.
In summary, I am satisfied that the analysis has taken recreation concerns into account appropriately and have no reason to believe they will affect timber supply, relative to the base case, in the short term. The information gathered from the new recreation inventory will be utilized in the timber supply analysis supporting the next AAC determination.
First Nations in the LRMP area are also actively compiling traditional and economic land-use data for their own use. Should that information become available to BCFS staff, any related impact on timber supply will be assessed in future determinations.
At the time of completion of the analysis, no landscape units had been designated by the District Manager. The LRMP identified 29 macro, or large-scale, units--which the District Manager will further refine--and recommended preliminary biodiversity emphases in each. The Jamieson/Skull unit, which contains nearly all of TFL 35, was assigned a low biodiversity emphasis.
At the stand level, the timber supply analysis assumed a deduction of 323 hectaresapproximately 1 percent of the current timber harvesting land baseto account for future wildlife trees required under the Forest Practices Code. Although a reasonable estimate at the time, it now seems insufficient to meet stand-level biodiversity requirements under the Code.
As noted earlier, under Silvicultural systems and reforestation, the licensee expressed its intent in MP 8 to manage mixed-species plantations, but inadequate data constrained it to model the reforestation of most harvested areas to lodgepole pine. The management assumptions in the base case, therefore, are contrary to the intent of the LRMP and the Biodiversity Guidebook, both of which prescribe maintenance of the natural species distribution. As discussed in the earlier section, the impact on timber supply is unclear but can likely be accommodated during the transition period contemplated by the plan and the Forest Practices Code.
In summary, the biodiversity measures assumed in the analysis have been superseded by the Code and the LRMP. However, given the resiliency of the base case and the demonstrated insensitivity in the short term to even a 10 percent land-base reduction, I am satisfied that implementation of biodiversity requirements under the Code poses minimal risk to timber supply during the period of this determination. Over the ensuing decades it is probable that timber supply will be less than estimated in the current analysis. This issue will be further discussed in "Reasons for Decision" below.
I find these assumptions reasonable, and do not expect the Forest Practices Code to impose more stringent requirements that would constrain timber supply further than modelled.
I accept the profile modelled as reflective of the best available information and appropriate for this determination.
While I would have preferred to have seen alternative harvest flows, I accept the base case projection as a suitable point of reference for my determination. In the next timber supply analysis, however, I expect to see alternative harvest flows modelled.
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.
The principal benefit of commercial thinning is the flexibility it lends to harvest planning. In management units where timber supply shortfalls are predicted, commercial thinning can be used to maintain fibre flow during those "gaps." The non-declining harvest-flow projection for TFL 35 means there is little need for such a management tool, and, as noted above, under Commercial thinning, no thinning is planned. Nor is there evidence of a need or opportunity for a partition. (See earlier discussion under Partitioned component of the harvest.
The Minister's memorandum addressed the effects of visual resource management on timber supply. It asked that constraints applied to timber supply in order to meet VQOs be re-examined in light of the beneficial effects of the Forest Practices Code when determining AACs in order to ensure they do not unreasonably restrict timber supply. As noted earlier, under visually sensitive areas, there are relatively few VQOs designated in this unit. Although future analyses will include a more comprehensive landscape inventory, I am satisfied that the base case is sufficiently robust that there is no reason at this time to expect timber supply to be constrained in the near future by additional visual resource management measures.
Weyerhaeuser solicited public input for MP 8 during February and March of this year, and also held two open houses in Kamloops and Barriere. No written comments were received from the public. Ministry of Environment, Lands and Parks staff exchanged letters with the licensee on wildlife, biodiversity, landscape and riparian management issues. Those concerns have been discussed in the appropriate sections of this document.
The timber supply analysis indicates the current AAC of 125 600 cubic metres could be maintained throughout the 225-year planning horizon. Although this forecast relies upon a number of assumptions that may be optimistice.g., site index reclassification, use of silviculture labels to project growth, extensive stand-tendingonly four factors can be positively identified that cast doubt on the feasibility of the base case.
A similar situation exists with regard to the biodiversity requirements of the Forest Practices Code. Although the land-base assumptions and reductions adopted in the timber supply analysis were reasonable at the time the analysis was initiated, they are likely inadequate to meet current requirements, particularly at the stand level. Both the Biodiversity Guidebook and the Kamloops LRMP also emphasize maintenance of the natural species distribution, in contrast to the management assumption in the base case that large areas of TFL 35 will be converted to lodgepole pine plantations following harvest. As there is likely to be some overlap between riparian and biodiversity requirements, I am unwilling to speculate on the precise impact biodiversity management will have on timber supply. Given the stability of the base case, however, I am convinced that the necessary restrictions can be accommodated in the short term without affecting timber supply.
The absence of any allowance in the current analysis for future losses to roads and past and future losses to cutblock trails has undoubtedly led to an overestimation of the size of the long-term timber harvesting land base. It is difficult to estimate the area in question, as there is uncertainty throughout the province regarding the magnitude of these losses. As with the riparian and biodiversity concerns, however, the effect on timber supply should be restricted to the medium and long terms.
The timber supply implications of the LRMP requirements for tree species diversity are similarly difficult to estimate. In the short term, as Weyerhaeuser brings its reforestation strategy into line with the LRMP, there will clearly be no impact. It is possible the maintenance of other species in place of the lodgepole pine modelled in the timber supply analysis may result in longer green-up periods and higher minimum harvestable ages, but those effects will not be quantifiable for some time yet. And, in any event, they will change timber supply, if at all, only in the medium and long terms.
In summary, none of these factors is likely to affect timber supply during the period of this determination. The cumulative land-base impact of the four factors is unlikely to exceed 10 percent, a level that a sensitivity analysis indicated could be sustained without affecting the short-term harvest level. In the event of maximum probable downward pressures, the most likely outcome would be a mild future decline, as opposed to the flat line forecast in the base case. Both the Forest Practices Code and the LRMP allow for a transition period, at the end of which the true timber supply picture will be more evident.
No factors were identified that would suggest timber supply has been underestimated, at least in the short term. The licensee referred to a potential long-term harvest level of 137 000 cubic metres but did not model any harvest-flow projections to depict such a forecast.
In summary, I am satisfied that the base case is sufficiently resilient to withstand the downward pressures for at least the term of this determination.
Chief Forester
October 1, 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
(a) the Crown land in each timber supply area, excluding tree farm licence areas and woodlot licence areas, and
(b) each tree farm licence area.
(1.1) If, after the coming into force of this subsection, the minister
(a) makes an order under section 6 (b) respecting a timber supply area, or
(b) amends or enters into a tree farm licence to accomplish the result set out under section 33.1 (1) (a) to (d),
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
(c) within 5 years after the order under paragraph (a) or the amendment or entering into under paragraph (b), and
(d) after the determination under paragraph (c), at least once every 5 years after the date of the last determination.
(1.12) If the allowable annual cut for the tree farm licence area is reduced under section 7.1 (3), the chief forester is not required to make the determination under subsection (1) or (1.1) of this section at the times set out in subsection (1) or (1.1) (c) or (d), but must make that determination within one year after the chief forester determines that the holder is in compliance with section 7.1 (2).
(1.2) When the chief forester determines an allowable annual cut for a tree farm licence area, any management plan that specifies an allowable annual cut for that area is conclusively deemed to be amended so that the allowable annual cut specified in the management plan is the same as the most recent one determined by the chief forester.
(1.3) In determining an allowable annual cut under this section the chief forester may specify portions of the allowable annual cut attributable to
(a) different types of timber and terrain in different parts of Crown land within a timber supply area or tree farm licence area,
(b) different types of timber and terrain in different parts of private land within a tree farm licence area, and
(c) gains in timber production on Crown land that are attributable to silviculture treatments funded by the Province, the federal government, or both.
(2) The regional manager or district manager shall determine a volume of timber to be harvested under a woodlot licence during each year or other period of its term, according to the licence.
(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
(a) the rate of timber production that may be sustained on the area, taking into account
(i) the composition of the forest and its expected rate of growth on the area;
(ii) the expected time that it will take the forest to become re-established on the area following denudation;
(iii) silvicultural treatments to be applied to the area;
(iv) the standard of timber utilization and the allowance for decay, waste and breakage expected to be applied with respect to timber harvesting on the area;
(v) the constraints on the amount of timber produced from the area that reasonably can be expected by use of the area for purposes other than timber production; and
(vi) any other information that, in his opinion, relates to the capability of the area to produce timber;
(b) the short and long term implications to the Province of alternative rates of timber harvesting from the area;
(c) the nature, production capabilities and timber requirements of established and proposed timber processing facilities;
(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
(e) abnormal infestations in and devastations of, and major salvage programs planned for, timber on the area.
Section 4 of the Ministry of Forests Act (1978) reads as follows:
Purposes and functions of ministry
4. The purposes and functions of the ministry are, under the direction of the minister, to
(a) encourage maximum productivity of the forest and range resources in the Province;
(b) manage, protect and conserve the forest and range resources of the Crown, having regard to the immediate and long term economic and social benefits they may confer on the Province;
(c) plan the use of the forest and range resources of the Crown, so that the production of timber and forage, the harvesting of timber, the grazing of livestock and the realization of fisheries, wildlife, water, outdoor recreation and other natural resource values are coordinated and integrated, in consultation and cooperation with other ministries and agencies of the Crown and with the private sector;
(d) encourage a vigorous, efficient and world competitive timber processing industry in the Province; and
(e) assert the financial interest of the Crown in its forest and range resources in a systematic and equitable manner.
Appendix 3: Minister's July 28, 1994 Letter to the Chief Forester.
File: 10100-01
Jul 28 1994
John Cuthbert
Chief Forester
Ministry of Forests
595 Pandora Avenue
Victoria, British Columbia
V8W 3E7
Dear John Cuthbert:
Re: Economic and Social Objectives of the Crown
The Forest Act gives you the clear responsibility for determining Allowable Annual Cuts, decisions with far-reaching implications for the province's economy. The Forest Act provides that you consider the social and economic objectives of the Crown, as expressed by me, in making these determinations. The purpose of this letter is to provide this information to you.
The social and economic objectives expressed below should be considered in conjunction with environmental considerations as reflected in the Forest Practices Code, which requires recognition and better protection of non-timber values such as biodiversity, wildlife and water quality.
The government's general social and economic objectives for the forest sector are made clear in the goals of the Forest Renewal Program. In relation to the Allowable Annual Cut determinations you must make, I would emphasize the particular importance the government attaches to the continued availability of good forest jobs and to the long-term stability of communities that rely on forests.
Through the Forest Renewal Plan, the government is taking the steps necessary to facilitate the transition to more value-based management in the forest and the forest sector. We feel that adjustment costs should be minimized wherever possible, and to this end, any decreases in allowable cut at this time should be no larger than necessary to avoid compromising long-run sustainability.
In addition to the provincial perspective, you should also consider important local social and economic objectives that may be derived from the public input on the Timber Supply Review discussion papers where these are consistent with the government's broader objectives.
Finally, I would note that improving economic conditions may make it possible to harvest timber which has typically not been used in the past. For example, use of wood from commercial thinnings and previously uneconomic areas may assist in maintaining harvests without violating forest practices constraints. I urge you to consider all available vehicles, such as partitioned cuts, which could provide the forest industry with the opportunity and incentive to demonstrate their ability to utilize such timber resources.
Yours truly,
Signed by
Andrew Petter
Minister