Lakes, Summary of Public Input

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Technical critique


The technical critique states the base case is an overly conservative estimate of the available timber supply because it does not reflect current forest management practices or the best available information. The critique concludes that the allowable annual cut can be increased without jeopardizing future opportunities or the environment.

The following specific points are raised in the technical critique.

The critique contends that ESA categories 1 and 2 should have been defined separately, as reductions for 2 should be less than for 1. It adds that reductions for recreation are unnecessary since the inventory is current for landscape and recreation features. It also notes that reductions for soils are excessive compared with other areas. The critique concludes that an additional 20 000 hectares should be retained in the land base after the reductions for ESAs.

The critique states that licensees have historically harvested from stands that have been excluded from the timber harvesting land base. It notes that including these stands would effectively increase the timber harvesting land base.

The critique recommends the development of new definitions for PFTs that account for improvements in milling and harvesting pulpwood and marginal timber. These improvements have enabled licensees to harvest timber in many stand types previously classified as problem forest types:

The technical critique further states the Forest Service should have assessed each deciduous stand for its harvesting potential, instead of excluding all deciduous-leading stands.

The technical critique contends that road reductions are overestimated for two reasons. One, stands younger than 80 years without a logging history may have been mistakenly deducted. Two, an adjustment to the land base was not made to reflect an increase in productive land resulting from road rehabilitation.

The critique notes the Timber Supply Analysis results exclude the land base of existing woodlot licences (6700 hectares). The licensees contend that this land base should have been included since woodlot volumes are apportioned out of the allowable annual cut.

The technical critique contends the area associated with the caribou must be included in the allowable annual cut determination, since a Cabinet decision on exclusion has not been made.

The technical critique recommends the difference in maturity age by species be considered in the assessment of old growth in pine-dominated forests.

Old-growth requirements should have no impact on the timber supply for the Lakes TSA. In addition, by accounting for old growth from outside the timber harvesting land base, additional area will be available for harvest from within the timber harvesting land base.

The technical critique asserts there will be no further impacts from the implementation of the Forest Practices Code, since many of the inputs to analysis have already included these considerations, through the Interim Timber Harvesting Guidelines for the Interior Portion of the Prince Rupert Forest Region.

The technical critique maintains that VQOs significantly reduce access to timber in the retention and partial retention management zones. It asserts these stands will grow into a state of extreme susceptibility to mountain pine beetle infestation and general stand decadence. By allowing harvesting activity to occur at modestly increased rates in these zones, the potential loss of currently valuable timber to insects could be avoided. In addition, by allowing the overmature pine stands within the VQO zones to be converted to young stands, the short- and long-term harvest could support an increase while still respecting the long-term health of the forest.

The technical critique states the non-net areas (productive forest areas excluded from the timber harvesting land base) may meet the requirements for forest cover constraints related to a given zone. It adds this is especially true for habitat requirements related to old-growth retention and thermal cover. As well, the critique contends about 144 400 hectares of productive forest are not part of the timber harvesting land base in non-VQO zones. A component of this area will be available for non-timber requirements such as biodiversity, riparian areas and migration corridors.

The technical critique states site index estimates do not provide a realistic estimate of site productivity. In addition, the range of the site index equations is unreliable at older extremes. The critique contends long-term (and possibly mid-term) productivity will increase when corrected site productivity is included in timber supply analysis.

The technical critique asserts that productivity in managed lodgepole pine stands has been underestimated. Results from the paired-plot study, based on a considerable amount of research data gathered and evaluated by the Ministry of Forests Research Branch, should be included as a component of the base case. The critique notes the Timber Supply Analysis indicates a short-term increase of at least 18 per cent is possible when the analysis includes the correction factors for managed pine stands. In addition, the analysis projects an increase in the annual harvest if the minimum rotation age is reduced.

The technical critique asserts the 6.5-metre requirement for green-up height in visually sensitive areas is 30 per cent greater than the 5.0-metre limit used in other timber supply areas. It adds that green-up ages are likely to be reduced in response to the correction factors for managed lodgepole pine stand productivity.

The technical critique accepts the estimates of losses as reasonable, but states that limiting access to mature and overmature pine stands (especially in visual management areas) will increase the likelihood of future losses to pine beetles and fire.

The technical critique notes that one licensee has a commercial thinning cutting permit in place with harvest scheduled for 1996. It notes this treatment is consistent with the statement made by the Minister of Forests in his letter to the chief forester regarding commercial thinning as an appropriate means of improving economic conditions. In addition, it notes that stocking control is maintained as part of all silviculture plans. This will ensure that historical productivity losses in pine stands due to over-stocking will be replaced by productivity improvements, as indicated in the paired-plot study.

The critique states licensees have demonstrated they practice better utilization than the required standards. Stump heights on average are below 30 centimetres, and undersized material and pulpwood are currently being utilized. This has an upward effect on short- and long-term timber supply.

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