Several issues raised in the Discussion Paper prompted input.
Landscape management
Three respondents comment on the practice of visual landscape management. The major licensees claim that the newly defined criteria for landscape management set out in the Land and Resource Management Plan are more reasonable than the previous guidelines that were incorporated into the base case of the Forest Service analysis.
One respondent stresses the importance of managing visually sensitive areas with care in order to maintain tourism values. In contrast, another respondent declares that the concept of landscape management seems "inherently dishonest."
Biodiversity
Four respondents mention the importance of protecting biodiversity. Two respondents state the conservation of biodiversity should be an overriding objective of forest management. One author maintains that healthy forests contain historic levels of all species. Another submission suggests that alternative silviculture techniques such as single-tree selection, shelterwood and seed tree should be used more often in the Kamloops Timber Supply Area in order to maintain biodiversity. Further, at least 10 per cent of the forest should be over 200 years old at all times.
Problem forest types
A significant portion of the Kamloops Timber Supply Area is classified as problem forest types and is not currently part of the timber harvesting land base. In recent times, practices and technology have changed to the extent that it may be possible to include these problem forest types in the timber harvesting land base. Some of the problem forest types have also recently been identified for allocation to Pulpwood Agreement 16.
Several respondents comment on problem forest types in the Kamloops Timber Supply Area. Two respondents raise the concern that bringing this land into the productive land base may have adverse affects on wildlife, suggesting it may be habitat for species which have been "forced out" of the rest of the forest.
On the other hand, a forest industry submission encourages the exploration of opportunities for bringing problem forest types into the land base. Another forest industry submission warns that some of the problem forest area is occupied by highly productive non-sawlog stands, and that if these areas are brought back into the timber harvesting land base the interests of pulpwood agreements must be taken into consideration.
Two submissions raise concern over the volume of timber available to fulfill the needs of pulpwood agreements. A submission from the public comments on the pulpwood industry’s interest in harvesting timber currently excluded from the land base. The submission states that the forest may not be capable of fulfilling all demands. A submission from the forest industry warns that the Forest Service should ensure that the land base available for pulpwood harvesting does not erode over time.
Decadent hemlock
Approximately seven million cubic metres of hemlock forests over 140 years old are excluded from the timber supply analysis because they have not been economical to harvest in the past. The Discussion Paper suggests that technologies are changing and it may be feasible to include this timber in the timber harvesting land base in the future. Five respondents comment on the decadent hemlock.
One submission from the forest industry states that the decadent cedar/hemlock does not offer an alternative source of supply to sawmills within the timber supply area. This is supported by the major licensee claim that no current manufacturing facilities can economically cut lumber from the scaled sawlog component of decadent hemlock.
On the other hand, another timber licensee expresses interest in harvesting the hemlock forests, stating it has opened a whole log merchandising and log chipping plant in Kamloops, which is tied to a veneer value-added manufacturing facility. Another forest industry submission maintains it is important that access be given to the non-sawlog timber in these forests (which is currently not part of the AAC) in order that these forests be replaced with healthy ones.
Submissions from the general public indicate concern that inadequate research has been undertaken on the utilization of this timber. One respondent opposes the use of hemlock for wood chips.
Allowable annual cut adjustment
Many suggestions are provided on whether and how the allowable annual cut should be adjusted. This input ranges from two suggestions that there should be no reduction, to three comments indicating that the allowable annual cut should be reduced in order to protect biodiversity and other forest values.
The major licensees insist that the current allowable annual cut is an irreplaceable fibre source for timber supply area mills. They maintain that the current allowable annual cut is sustainable for 80 years and oppose any reduction.
On the other hand, BC Environment staff recommend a significant reduction in order to protect biodiversity. Another respondent suggests the priority in setting the allowable annual cut should be to maintain biodiversity. A third respondent suggests setting the lowest harvest level that is feasible. Two respondents recommend that the priority should be to consider the long-term sustainable harvest rate and that economic and social objectives should be secondary to this.
Three respondents comment on the idea of a partitioned cut. One suggests providing an opportunity for a partitioned cut in age classes 3 and 4 stands (fir and pine) in order to capture mortality. Another forest industry submission suggests a partitioned cut of 100,000 to 120,000 cubic metres be set for age classes 8 and 9 hemlock stands, which are currently excluded from the timber harvesting land base. The submission estimates that with a two-pass logging approach and a 15-year green-up period, this volume could be harvested within 30 years. The major licensees submit that if there is a need to set a partitioned allowable annual cut, it must be structured so that it does not impair the existing alternative utilization. The licensees discourage the consideration of overlapping tenures.
