The licensee analysis expresses concern that the information presented in the Timber Supply Review process highlights significant downward pressures on the AAC.
Land base
The licensee analysis questions the land base used in the Timber Supply Analysis. It discounts the Forest Service concern that the timber harvesting land base may have been overestimated and claims that the exclusion of 50 per cent of the productive forest resulted in an underestimate of the land base. In particular, it states the land base reduction for roads, landings and trails is excessive and should be significantly less.
According to the licensee analysis, a significant portion of the areas removed from the land base were environmentally sensitive areas assumed to be inoperable or non-merchantable at the time of the analysis. The analysis asserts that much of this land is now operable due to new harvest technology.
In addition, not only will technology increase the operable land base, but the expense of roads and the restrictions of the Forest Practices Code will result in less forested land lost to roads, landings and trails in the future. The analysis recommends a sensitivity analysis to examine a 20 per cent increase in the land base to account for the effect of these variables.
Forest cover requirements
The licensee analysis suggests some forest cover requirements may be satisfied by the 50 per cent of the forested land base considered unavailable for timber harvesting. It contends that the contribution of these areas has not been recognized, except in the case of the visually sensitive areas. Forest cover constraints should have been adjusted for the gross/net area ratio in the analysis.
In addition, the licensee analysis asserts that due to the size of the land base reductions, measures to account for retention of old growth and extended green-up periods are unnecessary. Indeed, intensive forestry will reduce regeneration delays in the future. It also suggests that the removal of 50 per cent of the land base may compensate for the 18 additional community watersheds identified since the release of the data package.
The analysis also questions the viability of a five-pass harvest system, considering the current land base deferrals. It asserts that, due to the topography and fragmentation of the Lillooet Timber Supply Area, a two-pass system may in fact be the most common reality. Furthermore, the use of five-pass harvesting systems in the forested types typically found in this timber supply area will be detrimental to maintaining healthy and vigorous stands.
Finally, the analysis states that the visual quality objectives in use have not undergone public review and may not be representative.
Existing volumes
The licensee analysis contends that the existing inventory may underestimate mature volumes. In its view, base case stand volumes appear dramatically low. It states there are dramatic changes in timber supply projections if the mature volumes are estimated to be 20 per cent higher than the base case scenario. The uncertainties around this issue should be resolved prior to establishing the harvest level.
Other issues
The licensee analysis contends the methodology used to model past mountain pine beetle infestations may not accurately represent the age class of these forests
The deferral of the Mid-Stein and Spruce Lake has caused polarization of opinions and a high degree of uncertainty in the forest industry. The analysis recommends these issues be resolved through a public process prior to a reduction in the allowable annual cut.
The analysis adds that the method of assessing selection management should be addressed in future Forest Service analyses.
The licensee analysis concludes that the current harvest level can be maintained in the short term without affecting the long-term harvest level. It recommends maintaining the current harvest level for five years in order to facilitate a public process to resolve outstanding land-use issues.
