Biodiversity
The Ministry of Environment, Lands and Parks states that neither landscape or stand-level biodiversity have been addressed in the analysis. It claims stand-level biodiversity will have an immediate impact on the short-term timber supply.
Old growth
The submission also notes that according to the base case scenario, less than four per cent of the timber harvesting land base will be old-growth forest in 200 years. It claims this does not meet either the Old-Growth Strategy or Forest Practices Code old-growth objectives. The submission maintains the old-growth sensitivity analysis is a better strategy to maintain old-growth attributes.
Community watersheds
Ministry of Environment staff express concern about the 18 additional community watersheds identified in the timber supply area since the release of the data package. (13 have since been officially designated.) Their submission notes that this results in an additional 24,000 hectares of community watershed that were not factored into the base case scenario.
Riparian areas
The submission contends that riparian areas and fisheries values were not factored into the analysis. It maintains that Forest Practices Code regulations will impact the short-term timber supply. Further timber supply reductions may be necessary to account for green-up within watersheds with fisheries value.
Wildlife habitat
The Ministry of Environment submission claims that ungulate winter range, grizzly bear habitat and endangered species habitat have not been adequately modelled in the timber supply analysis. It suggests that although the forest cover constraints applied address the requirements of some species, habitat for mule deer, moose and grizzly bears is not covered. A number of suggestions are provided as to how habitat for these species should be modelled. Concern is also expressed about the possible impact of helicopter logging and other non-conventional logging methods on mountain goat winter range.
