Technical input was received from the Shuswap Okanagan Forest Association and the Shuswap Environmental Action Society (both of which completed independent timber supply analyses); the Ministry of Environment, Lands and Parks; and the International Woodworkers Association-Canada.
The Shuswap Okanagan Forest Association maintain that their analysis and the Forest Service analysis modelled very conservative approaches to forest management. The association’s analysis confirms that, at a minimum, the current harvest level can be maintained until the next allowable annual cut determination is carried out within five years.
However, the association and some forest licensees suggest the Forest Service analysis was too conservative. They submit that the current level can be maintained for much longer than the Forest Service analysis projects and will have to decrease only slightly 90 years from now. This is accomplished by modifying the assumptions used by the Forest Service for:
• estimates of mature volume
• green-up age (the time required for trees to attain a certain height)
• the maximum area allowed to be below green-up height at any time
• minimum harvestable ages
The Shuswap Okanagan Forest Association says each of the above factors extends the current harvest level by 20 to 40 years.
The Shuswap Environmental Action Society suggests the provincial Timber Supply Review process is based on questionable modelling techniques. They advocate an area-based, geographically-referenced analysis. They also suggest analyses should be done for smaller areas, preferably the size of a Forest Service district
The Shuswap Environmental Action Society also completed an independent analysis, using a spatial approach focused on the short-term timber supply for the Salmon Arm District (one of the three districts in the Okanagan Timber Supply Area). Their analysis shows the current harvest level cannot be maintained in Salmon Arm for the next 20 years without having a detrimental effect on other values such as biodiversity, recreation, visual quality and water quality and quantity. The Society’s analysis also indicates that if the current harvest level is maintained for 20 years, little forest land will remain for harvesting. The Society concludes that the same conditions apply to the remainder of the Okanagan Timber Supply Area.
Comments were made on the following specific issues in the timber supply analysis:
Estimates of existing forest volumes
Based on a survey of 175 cutblocks in the timber supply area, the Shuswap Okanagan Forest Association suggests that the Forest Service analysis underestimates existing volumes. A comparison of actual harvested volumes with Forest Service estimates shows the actual volumes to be 11 per cent higher than was estimated. The Shuswap Okanagan Forest Association did not incorporate this increase in mature volume into their analysis.
In contrast, the Shuswap Environmental Action Society suggests mature forest volumes are overestimated. They state that forest companies have harvested the best quality, highest volume timber and that remaining forests are of a lower quality and volume.
Many submissions mention the need to update forest inventories and that the issue of volume estimates must be resolved.
Estimates of future forest productivity
The Shuswap Okanagan Forest Association suggests that the future growth of regenerated forests is underestimated in the Forest Service analysis due to tree species assumptions and the use of site productivity information from overmature forests. In addition, the association suggests that estimating volume projections for regenerated stands should be applied to all forests under the age of 20, not just existing plantations.
Size of the timber harvesting land base
The Shuswap Okanagan Forest Association states that the reductions used in the Forest Service analysis to account for roads, landings and for riparian areas were too high, and therefore the size of the timber harvesting land base is underestimated.
Harvestable ages
The Forest Association states that the minimum harvestable age used in timber supply analysis should be based on specified minimum volume and/or piece sizes requirements; other criteria for harvest priority are not acceptable.
Forest management practices
The Forest Service analysis is based on the current Okanagan Timber Harvesting Guidelines. Both the Shuswap Environmental Action Society and the Ministry of Environment, Lands and Parks suggest that it is erroneous to assume these guidelines adequately protect non-timber values.
Within the Okanagan Timber Supply Area, the timber harvesting land base is divided into management zones on the basis of forest cover guidelines and management practices. In their analysis, the Shuswap Okanagan Forest Association changed the assumptions used in the Forest Service analysis regarding forest management practices in the landscape, wildlife winter range, community watersheds and timber harvest emphasis zones.
The association also notes that the Forest Service analysis used a very restrictive, artificial harvest and retention pattern. In addition, the Forest Service analysis assumes that oldest forests are harvested first and the association feels this doesn't represent the current practice.
Green-up requirements
The green-up period is the time required for an area to reach a desired condition after harvest. For the Okanagan Timber Supply Area, the standard green-up requirement is for trees to be eight metres tall to before harvesting is allowed on adjacent blocks to ensure the forest canopy is sufficiently closed to return the area to a fully functioning watershed. The Shuswap Okanagan Forest Association suggests adjacent forests can be harvested earlier by applying partial hydrologic recovery criteria as opposed to the full hydrologic recovery criteria used in the Forest Service Analysis.
The International Woodworkers Association-Canada notes that timber supply projections are very dependent on the length of green-up periods.
Visual quality objectives
Management practices, as modelled in the Forest Service analysis, for visually sensitive areas in the Okanagan Timber Supply Area are not accepted by the Shuswap Okanagan Forest Association, individual licensees and the International Woodworkers Association-Canada. The latter suggests no biological reason exists for the 15 per cent maximum clearcut area specified for the Landscape Zone. They note that relaxing this guideline to 20 per cent has a significant effect on short-term timber supply.
Watershed management
The Ministry of Environment, Lands and Parks submits that there are over 100 watersheds of significance to the province's fisheries program; watersheds identified in the Okanagan Timber Harvesting Guidelines and modelled in the timber supply analysis only cover those of concern to Federal Fisheries.
The Ministry of Environment, Lands and Parks suggests the Forest Practices Code standards for community watersheds will reduce timber availability and this will affect short-term timber supply.
The Shuswap Environmental Action Society states there are a number of watersheds where maximum permitted clearcut size has been exceeded.
Biodiversity and old growth
The Ministry of Environment, Lands and Parks states that the old growth and biodiversity standards incorporated in the Forest Service analysis do not adequately reflect landscape connectivity, the Protected Areas Strategy or other strategic planning initiatives.
Wildlife habitat
The Ministry of Environment, Lands and Parks notes that Forest Practices Code protective measures for endangered or threatened species have not been adequately considered in the Forest Service analysis.
The Shuswap Okanagan Forest Association states that the Forest Service analysis uses a conservative, artificial harvest or retain constraint to model winter range for deer and related species.
Salvage programs
The Shuswap Okanagan Forest Association promotes existing harvest levels as adequate for control of mountain pine beetle. The Shuswap Environmental Action Society suggests wood volumes harvested to control beetle attacks, along with other salvage harvesting, should be included within the allowable annual cut. They also state that the Forest Service analysis does not indicate the consequences temporary harvest increases have on the environment (as in 1987 to 1993).
The Shuswap Okanagan Forest Association observes that unsalvaged wood volume losses should become lower as forest access improves and forests across the timber supply area become younger.
