The Kamloops Regional Integrated Resource Management Timber Harvesting Guidelines were utilized to divide the timber harvesting land base into management zones based upon specific forest cover guidelines and management practices. The Forest Service analysis is based upon the assumptions set forth by these guidelines.
Green-up
The green-up period is the estimated time required for trees in an area to reach a specified height after harvesting. For the Merritt Timber Supply Area, green-up heights are three metres in the ungulate winter range and integrated resource management zones, and 5.5 metres in the landscape management zone. The base case scenario indicates the green-up period ranges from 14 to 23 years. The Merritt Forest Licencees assert that the 14 to 23 year time spans to achieve green-up in the Forest Service analysis are too long. They claim a reduction by five years would maintain the harvest level for an additional 10 years.
Landscape management zone
The objective of the landscape management zone (as defined in the Forest Service analysis) is to maintain visual quality along corridors where people live, work, recreate and travel.
The Merritt Forest Licencees suggest that the guidelines used in establishing the landscape management zone result in harvest ages in excess of 200 years. They emphasize that the Merritt Timber Supply Area has a high proportion of mature lodge pole pine which is susceptible to infestation by mountain pine beetle. The Merritt Forest Licencees predict that this strategy may result in many visible areas covered with dead trees due to the length of rotation.
The Merritt Forest Licencees are also concerned with the application of the landscape management zone to the Three Brothers Trail in Manning Park and to Stoyoma Mountain. They maintain that the application of the landscape management zone to these areas does not reflect current practice.
Ungulate winter range zone
The objective of this zone and the selection management zone is to maintain or enhance forage by ensuring adequate forest cover for deer and other related species.
The Merritt Forest Licencees accept that no more than 20 per cent of the gross land base should be below green-up height, but they believe the figure should be adjusted for the gross to net area relationship. They suggest that areas which have been removed from the timber harvesting land base (i.e. riparian areas and environmentally sensitive areas) may also contribute to forest cover requirements. The Merritt Forest Licencees point out that selection management zones and problem forest type areas also contribute to ungulate winter range requirements.
Integrated resource management zone
The objective of this zone is management considering other resource values. The Merritt Forest Licencees state that the Forest Service analysis modelled the maximum gross area on the basis of 25 per cent of the forest being below green-up. Current guidelines specify that 30 per cent of the forest should be below green-up and the Merritt Forest Licencees maintain that current practices should be modelled.
Old growth
The Merritt Forest Licencees assert that it is appropriate that old growth requirements were not modelled in this analysis. They note that the Old Growth Strategy has been incorporated into the Protected Areas Strategy and that Protected Areas have not been finalized in the Merritt Timber Supply Area. They maintain that the Forest Service analysis should model current management practices. They assert that interim old growth reserves are unnecessary due to the large proportion of mature forests within the timber supply area.
A submission from the Ministry of Environment, Lands and Parks states that an old growth strategy should have been modelled in the Forest Service analysis. They consider that trees 140 years old meet the minimum requirement for old growth. They claim that 50 years from now only six per cent of the timber harvesting land base will be over 200 years of age. They maintain that 10 per cent old growth should be the desired goal.
Riparian areas
The Merritt Forest Licencees critique states that the Forest Service analysis exceeded the current requirements for riparian management.
In contrast, a submission from the Ministry of Environment, Lands and Parks suggests:
"A serious flaw of the current Timber Supply Review is that it does not take into account riparian or biodiversity management requirements under the Forest Practices Code or removals from the timber harvesting land base under the Protected Areas Strategy."
The Forest Service analysis is required to model current forest management practices or policies and procedures which are in place at the time of the analysis. The Ministry of Environment emphasizes that although these are not current management practices, they will be in the near future. They suggest that it would have been better to estimate the effect of these factors rather than to exclude them from the analysis.
Wildlife corridors
The Merritt Forest Licencees indicate that it is appropriate that wildlife corridors and Forest Ecosystem Networks were not modelled in the Forest Service analysis. The suggest the goals, objectives and attributes of wildlife corridors and Forest Ecosystem Networks must first be finalized.
Other technical comments
The Merritt Forest Licencees made a number of other points:
• regeneration delays of four to six years used in the analysis are conservative
• it is likely that unsalvaged losses will decrease as access is increased
• increased flexibility is required in harvest systems and cutblock layout. At present, locating sufficient blocks for Development Plans has not been constraining
