Rapid changes in social values and in our understanding and management of complex forest ecosystems mean that there is always some uncertainty in the information used in AAC determinations. One important way to deal with uncertainty is to redetermine AACs frequently, to ensure they incorporate up-to-date information and knowledge. This principle has been recognized in the legislated requirement to redetermine AACs every five years.
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 AAC—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 AAC—such as integrated resource management (IRM) objectives beyond those articulated in current planning guidelines.
The impact of the Forest Practices Code on timber supply is a matter of considerable public concern. Even without the Code, I consider it reasonable to expect that, based upon recent trends, the constraints upon timber supply from the application of current guidelines would become increasingly significant over the next five years. In determinations made prior to implementation of the Code I have not had the benefit of formally established regulations or standards which might assist me in assessing the impact of new constraints on timber production which might be imposed under the Code; these will be included in the next timber supply analysis. However, while I have not considered any more stringent restrictions or additional impacts upon timber supply beyond those anticipated to occur due to the application of current guidelines, I have assumed that the Code will at the very least entrench the standards exemplified by current guidelines as statutory requirements.
The impact on the timber supply of land-use decisions resulting from regional planning processes such as the Commission on Resources and Environment (C.O.R.E.) process or from sub-regional processes such as the Land and Resource Management Planning (LRMP) process is a matter often raised in discussions of AAC determinations. In this respect, 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 which 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, due to the complexity and time requirements of the timber supply analysis process, it may not always be possible in the current round of analysis to address some land use decisions which have already been made. The ongoing five-year AAC review will ensure such decisions will be addressed in the near future. While this was not an issue in the Fraser TSA, a related issue—informal log-around strategies implemented because of uncertainties surrounding future land-use decisions—was of particular concern. I have addressed this issue in detail in my consideration of section 7(3)(a)(vi) "Planning delays" and under the heading "Reasons for decision".
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 appropriate I will take their effects into account. The next timber supply review will be better positioned to determine how the Plan may affect the short- and long-term timber supply.
Some have suggested that, given the large uncertainties present in some cases with respect to some 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 may make must be the result of applying my judgement to the best available information, taking any uncertainties into account. 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.
Overall, in making AAC determinations, I am mindful of my obligation as steward of the forest land of British Columbia and of the mandate of the Ministry of Forests as set out in Section 4 of the Ministry of Forests Act.
