Merchantable timber in existing mature forests
Two industry submissions contend merchantable volumes in the existing mature forests are generally equal to or greater than inventory volume estimates. One suggests the allowable annual cut should not be adjusted until the completion of a new inventory and subsequent timber supply review.
Amount of riparian area
An industry submission states the Forest Practices Code will determine the impact of riparian management over the next few years. It recommends the estimate used in the Forest Service analysis be accepted until a full impact assessment is completed.
Rate of harvesting in older cedar–hemlock forests
The 36 form-letter respondents and an interest group submission maintain that lower-grade cedar, which was not included in the timber harvesting land base, is becoming increasingly valuable and should be included. An industry submission concurs and points to the recent commitment by quota holders to harvest the hemlock looper-killed timber in the northwest portion of the timber supply area as an example of a poor-quality wood source that will now be fully utilized.
A respondent from the Ministry of Environment, Lands and Parks questions whether the Interior Cedar–Hemlock types should have been included in the timber harvesting land base since they have been largely avoided by the major licensees to date. It also questions their use in the future given the wood profile requirements of these licensees.
One submission maintains many stands typed as leading spruce in the Interior Cedar–Hemlock zones are actually nearly pure western hemlock. This results in a considerable overestimate of merchantable volume because hemlock is under-utilized. It further states that these nutrient-poor and often subhydric sites may be very difficult to regenerate, compared to spruce-leading sites.
Partition
One industry respondent suggests that old cedar must be harvested every year along with other species because 17 per cent of the operable land base is cedar–hemlock.
Estimated number of harvesting entries
An industry submission contends the number of harvesting entries should be site-specific by drainage. The impact of harvesting-entry variations will be more fully known when the Robson Valley Round Table completes its management plan. Many of the partial-cut and selective logging systems allow removal of as much volume as a normal three-pass system.
Estimated unsalvaged timber losses
An interest group submits that harvesting should occur in all areas where severe insect infestation and resulting mortality has occurred, whether or not the area is affected by visual quality objectives.
Three industry submissions suggest that unsalvaged losses could be decreased with improved access to many areas. One also proposes the possibility that new logging systems such as helicopter or skyline will permit recovery of a higher percentage of pest, disease and wildfire losses. Two submissions note that this could increase the harvest level in the timber supply area. One states the aggressive salvage program at the western border of the timber supply area in hemlock looper-damaged timber will reduce unsalvaged losses.
One respondent disagrees with a temporary increase in the allowable annual cut to address the hemlock looper salvage situation. The higher the allowable annual cut, the more difficult for the local economy to adjust to a sustainable level of harvest.
Practices in caribou habitat
Several industry and one interest group submission contend that the restrictions for caribou management are very conservative. The respondents suggest that caribou habitat can be integrated with timber harvesting to maintain certain age classes, movement corridors and canopy closures to meet the needs of the caribou. The forested areas currently suitable to caribou habitat will not remain the same through succession.
Two industry submissions state that caribou management is undergoing considerable refinement as more complete data becomes available. On a site-specific basis, the Ministry of Environment, Lands and Parks has fine-tuned its elevation line, allowing harvesting in areas not included in the timber harvesting land base.
One submission recommends information be gathered to confirm the use of these areas as winter habitat. Another states that very few caribou utilize the Robson Valley. Another questions the need for a 250-year rotation in the "caribou medium" zone, noting that the caribou currently graze in clear-cuts in these areas like deer. Another respondent predicts logging methods that prove successful in the medium zones may eventually be allowed in the "caribou high" zones that currently allow no resource extraction.
Minimum harvestable ages
One industry submission accepts the range of minimum harvest ages used in the timber supply analysis, while a public submission suspects the minimum harvestable ages will be at least 20 years longer. Another public submission suggests the ages may be under-estimated for second-growth spruce due to severe leader weevil damage in the Robson Valley.
Combined impacts of integrated resource management practices
The 36 form letters state that, for the most part, the environmental restrictions used in the analysis are too stringent. The respondents submit that if operations can continue in all forested areas, it will be possible to manage for special values as well as maintain an acceptable level of harvest and construction.
The form letters and two other submissions recommend that old growth and standing dead timber be harvested, if still merchantable, to minimize losses to disease, blowdown, insects and fires. Large areas of overmature timber are likely a result of Forest Service fire protection, and would not have resulted if nature was left alone.
One submission questions whether all resources are considered before management decisions are made, because most of the lower-elevation forest is included in the timber harvesting land base.
Another submission urges the elimination of clearcutting, the encouragement of selective logging, and the banning of aerial spraying of pesticides.
Partial cutting
The industry submissions express concern over the potential impact of the visual quality objectives on timber supply. Several state that various forms of selective and/or retention harvesting and visual quality techniques would allow significantly increased opportunities for harvesting in the visually sensitive areas. One submission proposes that major licensees be given a portion of the Robson Valley corridor to manage under their forest licences for the purpose of developing selective harvest systems and expertise in:
• second-growth and old-growth stands
• conventional ground skidding
• steep slopes requiring cable systems
This will provide initiative to the companies to operate in a successful manner and, therefore, be able to retain their harvest levels.
An interest group submission notes that a significant area has been excluded from the timber harvesting land base as environmentally sensitive areas and proposes that partial cutting in all viable area in this classification be considered.
Harvesting forests currently not considered harvestable
An industry submission suggests that since the timber supply analysis was initiated all timber has become more valuable and economical to harvest and that this could lead to an increase in timber supply. The respondent lists the following opportunities:
• the use of alternative harvesting methods on steep slopes and in environmentally sensitive areas. Some of the alternative methods are currently being used in the timber supply area
• a reduction in the operability minimum volume per hectare. Again, there are examples where harvesting has occurred in areas having less volume than the minimums
• the rehabilitation of problem forest types
The 36 form-letter respondents and an industry submission predict new methods of harvesting will be developed to increase access into and the merchantability of areas currently classified as inoperable. The form-letter respondents and an interest group submission state that deciduous species that were not included in the timber harvesting land base are becoming increasingly valuable and should be included.
Silviculture
Industry submissions suggest that reducing the regeneration delay from four years to two years could increase the long-term timber supply by more than 2 per cent, based on an analysis completed by a consultant. Companies are already achieving a two-year delay in some cases. The submissions predict that intensive silviculture activity may increase timber supply in the future.
One submission comments that regenerating forests need to be well tended, specifically by brushing and weeding to remove unwanted species.
Commercial thinning
Two industry submissions maintain that commercial thinning will increase in the future and may increase timber supply.
Environmental and socio-economic objectives
One submission stresses the importance of maintaining biodiversity and healthy ecosystems and states that this must be a primary consideration of the chief forester. The respondent recognizes that the economy is important, but feels that it should not be given weight over all other interests because many people value the lifestyle provided by the non-timber values of the forest.
An industry submission questions whether the needs of recreation and tourism are not already reasonably met for this area due to the proximity of large parks. Another industry submission states that tourism is rated far too highly.
Several submissions comment on the importance to tourism of preservation of viewscapes, old growth, and riparian and wildlife habitat. One respondent states that timber harvesting, performed carefully and at a greatly reduced rate, could benefit tourism.
Two submissions recommend that the high economic value of old-growth timber be recognized in forest management and in the manufacturing of forest products, and that the emphasis should be on quality rather than quantity. One respondent remarks that the goal should be to increase the area of old growth.
One submission urges the province to provide employment brushing new forests, while another recommends that small operators be supported in order to create jobs. Another respondent predicts that if more riparian and wildlife areas are protected, employment will be created to enforce fish and wildlife regulations.
Three respondents raise the possibility that value-added manufacturing could provide jobs. One suggests an artificially high harvest level and the overcapacity of the large local mills discourage economic diversity. Another respondent remarks that more of the harvested wood fibre could be utilized.
An interest group submission predicts that reforestation of non-commercial cover and not-satisfactorily-restocked areas, rehabilitation of low-growing-potential and non-merchantable areas, and better utilization of waste wood on logged sites (at reduced stumpage rates) would help create employment within the timber supply area as well as increase the allowable annual cut. Funding could come from Forest Renewal B.C.
One submission supports increased stumpage rates to fund re-training of displaced forestry workers, Forest Service research, and other forestry-related activities.
One submission calls for enforcement of Section 110 of the Fish and Wildlife Act to eliminate vehicular hunting access to all de-activated roads, thereby reducing the documented negative impact of increased hunter access to wildlife.
Allowable annual cut adjustment
The industry submissions, 36 form letters, a few individuals and one interest group recommend maintaining the current allowable annual cut to allow time for the economy to diversify and to explore options that will increase timber supply. The chief forester should await development of a Land and Resource Management Plan before any adjustments occur. One respondent suggests that the high proportion of older forests will, in the short term, support higher harvest rates than the sustainable long-term harvest level. One industry submission states the only reasons for a reduction in the allowable annual cut should be technical and scientific in order to maintain sustainable forest development for the area. Another submission asserts that the rate any reductions will take place is critical in minimizing impacts.
One submission recommends reducing the harvest by 10 per cent per year over the next 10 years to minimize the impact on the communities. The respondent says there has been little economic growth historically, and a slow reduction in the timber harvest may be offset by slow tourism growth.
Another submission contends the primary consideration of the chief forester must be to ensure that the resource is being managed sustainably. To accomplish this, the respondent recommends the allowable annual cut be reduced to 500,000 metres immediately, with a further 50,000-metre reduction every two years until the allowable annual cut is 20 per cent below whatever the long-term timber harvest level is established to be at that time.
In order to maintain other forest values and reduce the eventual fall-down effect, one submission supports an allowable annual cut in the vicinity of the existing average annual harvest of about 480,000 cubic metres per year
To preserve the environment and quality of life and to minimize the loss of biodiversity, three submissions support a 40 per cent reduction to the allowable annual cut. One other supports either a 17 per cent or 40 per cent reduction. Another submission declares the present rate of cut is not sustainable in the long term, so it should be lowered by 40 per cent to allow diversification of the economy before the downfall of the timber industry.
One submission supports an immediate allowable annual cut reduction in order to preserve options.
Two public submissions support an allowable annual cut reduction of about 50 per cent. One suggests that the environment will not sustain the current rate of harvest and that there is no way to prove tree plantations will produce wood fibre for the industry. The other states that this is the only way non-timber values in the timber supply area can be protected.
One public submission recommends the allowable annual cut be lowered by 75 per cent because the balance of nature will be badly disrupted in the next 50 years. It contends that biodiversity will be destroyed, and expresses concern about the effect of harvesting on wildlife populations and habitat.
A spokesperson for the Mennonite community states they will work with whatever decision is made.
