The Interior Lumber Manufacturers' Association prepared a comprehensive response to the Merritt Timber Supply Area Socio-Economic Analysis. Other comments regarding the Socio-Economic Analysis were received from the Merritt Forest Licencees and the Ministry of Environment, Lands and Parks.
Presentation of the data
The three submissions comment on the manner in which the data was presented to the reader in the Socio-Economic Analysis. Comments suggest the information was presented in a biased manner. The Merritt Forest Licencees state:
" The Socio-Economic Analysis understates the effects of a sustained or enhanced harvest level relative to the perceived benefits of a decreased harvest level "
The Interior Lumber Manufacturers' Association note:
"The economic and social impacts of the increased harvest option are unfairly described."
The Interior Lumber manufacturers also maintain that statements written in reference to the increased harvest scenario have negative connotations. They suggest the reader may develop a negative perspective due to:
• the significance of mill capacity being poorly reflected
• the suggestion that any new jobs from an increase in harvest may go to people outside the timber supply area rather than residents
• the implication that an increase in harvest could lead to an increase in population which could create "problems" in the community
The Interior Lumber Manufacturers' Association maintain that all leading statements should be substantiated or eliminated from future reports.
On the other hand, the Ministry of Environment, Lands and Parks indicates the results were biased in the opposite way:
• First Nations survey results emphasize employment concerns rather than environmental concerns
• a statement regarding grazing tenures leads the reader to believe 94 per cent of the timber supply area is grazed
• a statement implying timber supply area dependence on the livestock industry is contrary to the data presented which shows the industry accounts for four per cent of employment
• the benefits of selection management are overstated
Environmental impacts
The Interior Lumber Manufacturers' Association suggest that the concerns of the Ministry of Environment, Lands and Parks as presented in the Socio-Economic Analysis are not necessarily relevant to the Merritt
Timber Supply Area, and do not provide useful information for evaluating the effects of the various harvest scenarios. The Interior Lumber Manufacturers' Association requests that only environmental concerns specific to the timber supply area be provided in future analyses.
Employment
Both the submission from the Interior Lumber Manufacturers' Association and the submission from the Merritt Forest Licencees suggest that harvest dependent employment is underestimated in the Socio-Economic Analysis. They observe that Ministry of Forests employment also relies on harvesting timber and should not have been excluded from the employment figures.
The Interior Lumber Manufacturers' Association suggests that underestimated employment figures were due to:
• employment related to capital expenditures are not estimated
• Riverside Forest Products non-processing employment is excluded
• silviculture contractors residing outside the timber supply area are excluded
Two submissions indicate the Socio-Economic Analysis did not clearly identify direct forestry employment. Both state that it was unclear whether wood processing jobs were located under the manufacturing category.
The Interior Lumber Manufacturers' Association suggests that the size of the tourism industry relative to the forest industry is overstated. Upon examination of the 1995 Ministry of Finance paper on Economic Dependencies, the Interior Lumber Manufacturers' Association states:
"...each forestry job generates more than two and one half times as much after tax basic income as each tourism job does...this difference in after tax earnings can only be explained in one of two ways -- either the number of tourism jobs is overstated relative to number of forestry jobs or the level of annual earnings in the tourism sector is well below the poverty level."
The Interior Lumber Manufacturers' Association stresses that the provincial job multiplier used in the Socio-Economic Analysis is too low. A statement was made at the public meeting in Merritt (March 1, 1995) indicating that the figure for indirect and induced employment seemed low. One written submission from the public states:
"The Socio-Economic Analysis grossly underestimates the effect of forestry on the local economy."
Revenue
Both the Interior Lumber Manufacturers' Association and the Merritt Forest Licencees state that government stumpage revenue is greatly understated in the Socio-Economic Analysis. Both comment that government revenue does not take into account for the 136 per cent stumpage rate increase that occurred in 1994.
The Interior Lumber Manufacturers' Association state that federal government revenue impacts should be considered in the analysis.
Water and watersheds
Both the Interior Lumber Manufacturers' Association and the Merritt Forest Licencees are concerned about the discussion of water, community watersheds and the hydrological impacts of forestry activities in the Socio-Economic Analysis. The Merritt Forest Licencees state:
"The impacts referred to are worst case, alarmist, largely unsubstantiated, and in some cases, not true."
The Interior Lumber Manufacturers' Association refers to some of the information in the Socio-Economic Analysis as "alarmist" and "incorrect". Both the Interior Lumber Manufacturers' Association and the Merritt Forest Licencees claim that although some of the comments may be true in the worst case, they have not been provided in the proper context. The Interior Lumber Manufacturers' Association suggest that some of the concepts presented are unwarranted in light of new forest management requirements in riparian areas.
The Interior Lumber Manufacturers' Association notes the following specific problems in the Socio-Economic Analysis:
• the characterization of the relationship between logging and increased bacteria levels in streams
• the characterization of the relationship between loss of forest cover and reduction of overall water yield
Additionally, the Interior Lumber Manufacturers' Association observes that statements made regarding the impact of forest management on salmon are unsubstantiated.
