Size of the timber harvesting land base
A forest industry submission maintains further information is needed to provide confidence that double-counting did not occur in the various reductions from the timber harvesting land base. For example, an area may have been removed twice because it has steep slopes and low growing potential.
Another submission questions why it was assumed that 10.5 per cent of the timber harvesting land base would be lost to roads, trails and landings when the Soil Conservation Guidelines limit allowable losses to seven per cent.
A third submission notes that the estimates of the land base are incomplete because they do not account for other ongoing processes, such as the regional land-use plan or the Forest Practices Code, or for changes in harvesting and processing methods.
The removal of areas considered to have stands that are not environmentally or economically feasible to harvest is questioned by another submission. While these stands may not be useful for sawlogs, other products such as posts are feasible, according to this individual. Following the harvest, such sites can then be returned to full productive capacity.
Minimum harvestable age
One respondent suggests minimum harvestable ages could be reduced by 10 years if intensive silviculture were practised.
Productivity estimates
One respondent states that the productivity estimates for second-growth forests are suspect and very liberal, but offers no evidence except to point to failures in Europe where more favourable climates prevail.
Forest management practices in visually sensitive areas
One submission suggests these should be relaxed since the tourism industry produces low-paying jobs, compared to the forest industry. This individual states that ski hills and golf courses are as visually disturbing as clearcuts; the latter, at least, are reforested and don’t cost money to enter.
Another respondent contends that, in selecting management objectives, visual quality should be secondary to environmental values such as wildlife winter range, biodiversity, etc. If a choice must be made to reduce timber supply constraints, environmental quality must take precedence over viewscapes for tourists.
Wildlife and fish habitat requirements
According to one submission, forest cover requirements for deer winter range should be relaxed by at least five per cent. This individual maintains that deer do not feed in mature forests, but often follow harvesting crews to eat the mosses and lichens growing on felled trees. The need for cover can be met by leaving groups of trees on sunny slopes and by partial cutting. This individual also asks why cattle are allowed to graze in these areas if concerns for deer are so high.
One submission questions the boundaries of the area of core caribou habitat; in particular, it asks whether the upper Spillimacheen River was included. The harvest level guidelines developed for the core areas are satisfactory, according to this individual, but because caribou are wide-ranging, detailed planning is required over a broad area to ensure the range of habitats used in each season is available and connected.
The submission from Kootenay National Park staff contains the following comments regarding fish and wildlife values:
• it offers strong support for ecosystem networks but expresses concern that they may not be wide enough to function effectively as wildlife corridors
• further wildlife habitat measures are needed, such as maintenance of deciduous trees, large rotten wildlife trees, and openings with understory forage; these are not found in dense, even-aged, managed forests
• green-up and forest cover requirements do not appear to be sufficient to protect the functioning of watersheds that contain high-value fish resources
The Park staff submission also states intensive silvicultural practices in managed stands may exacerbate Armillaria root disease problems, leading to poor growth or tree mortality. Such fungal diseases are a critical agent of biodiversity and an essential factor in the creation of suitable wildlife trees.
An individual respondent expresses support for more forest ecosystem networks.
Biodiversity
One submission agrees with the requirement to maintain at least 10 per cent of each management zone as older forests, but speculates whether partial cutting and simulation of older-forest characteristics could help minimize this reduction.
Another respondent predicts the amount of older forests remaining in 50 years will be minuscule compared to historical amounts, putting at risk wildlife that depend on this type of forest. This individual also states that inoperable areas may not provide the characteristics needed for species that depend on older forests, and emphasizes the need to protect representative forests. The Kootenay National Park submission and another individual submission echo these concerns, adding that 140-year-old forests do not provide adequate habitat for some old-growth-dependent species.
The Kootenay National Park submission also stresses the importance of maintaining a mix of forests of all ages, including some older than 250 years, in order to protect biodiversity values and to provide long-term sources of high-quality wood.
Estimates of unsalvageable timber losses
A forest industry submission questions whether the estimate used in the Forest Service analysis reflects the higher levels of utilization currently being practised.
