Problem forest types
Ainsworth Lumber Co. Ltd. recommends the Forest Service continue to identify 137,000 hectares of problem forest types, separate from the allowable annual cut. The company says other licensees concerns about the effects of Ainsworths pulpwood agreement on their development plans are currently unfounded. These concerns, expressed also by the Ministry of Environment, Lands and Parks, relate to the availability of sawlog cutting areas when adjacent harvested pulpwood areas are not yet greened up. Ainsworth says in fact they have already experienced a reduced availability of pulpwood stands due to sawlog harvesting. The company also points out the harvest of problem forest types will increase the size of the timber harvesting land base, by converting some of these lands to the production of sawlogs.
Maintaining biodiversity and older forests
The submission from the Quesnel River Watershed Alliance says overcutting and past management practices have put conservation values at risk within the Quesnel River watershed. This has occurred through the conversion of older forests to younger forests, of intact forests to fragmented ones and of natural, diverse forests to managed, simplified plantations.
The Ministry of Environment, Lands and Parks expresses concern about the lack of representation of all age classes of Douglas-fir forests in the landscape through time. Their submissions say the proposed 50 per cent removal of volume at the first pass, followed by re-entries every 30 years, is unlikely to meet the needs of other non-timber resources.
Ainsworth Lumber maintains that meeting biodiversity goals requires the effective use of timber harvesting, rather than forest age restrictions (the restriction, for example, that 15 per cent of the forest must be older than 150 years at all times in the integrated resource management zone). Ainsworth is of the opinion such requirements for maintaining old growth forests should be eliminated. Their submission says adaptive management (management for specific attributes such as snags, coarse woody debris, etc.) can conserve or reproduce older forest values at little cost during harvesting. Ainsworth asserts that enforcing age requirements doesnt recognize the older forest values already present in protected areas, special management areas and riparian zones.
Ainsworth also maintains that protected areas threaten the working forest because they are a source of natural disturbances such as fire, insects and disease. The company recommends keeping protected areas small and moving them across the landscape as forests develop. Some forest management should be allowed within protected areas to protect forest values outside them.
The licensee association suggests that defining old growth forests on the basis of age doesnt account for management practices that mimic, conserve or create older forest attributes. They suggest that definition by age likely overcompensates for old growth forest values.
The Ministry of Environment, Lands and Parks also expresses concern about the definition of old growth forests, and remark that most scientific sources use 200 years as the minimum age for defining ecologically functional old growth forests. The Forest Service analysis uses 150 years of age to define the old growth. The Ministry of Environment, Lands and Parks expects this to lead to serious shortages of older forests at various points in the future.
Wildlife
The Ministry of Environment, Lands and Parks emphasizes that the maintenance of habitat is the only way to guarantee the protection of fish and wildlife populations; the success of other measures, such as stocking lakes or imposing new regulations, is not assured. With declining budgets, this agency says it is unable to undertake costly programs to offset negative impacts.
The Quesnel River Watershed Alliance maintains that the removal of wildlife habitat from the timber harvesting land base in the Forest Service analysis is based on outdated wildlife data and a comprehensive ecological assessment of habitats is now required. They point out that many wildlife species within the watershed are on the Ministry of Environment, Lands and Parks red and blue lists (endangered and threatened species).
Ainsworth Lumber predicts that their pulpwood agreement will enhance wildlife habitat in the following ways:
logging disturbance will maintain the presence of deciduous forests, important for wildlife
low quality pulpwood stands will be replaced by stands that provide improved wildlife habitat
They also state that pressures on wildlife from improved access can be controlled with access management plans.
Mule deer winter range
Ministry of Environment, Lands and Parks staff consider the information used to estimate areas and volumes reserved from harvesting within mule deer winter range areas to be outdated. Because many Douglas-fir stands have been salvage harvested as a result of fir bark beetle attacks, the actual area reserved is overestimated by 25 per cent in the Forest Service analysis. The Ministry of Environment, Lands and Parks recommends that a new regional mule deer strategy and fir re-inventory be done.
The licensee association states that existing and target mule deer populations have not been identified and much more work and analysis is needed to adequately address this issue.
Productivity estimates
One submission highlights the urgent need to monitor the long-term productivity of forest soils in order to confidently predict long-term tree growth. This respondent suggests that the extent of site degradation occurring in the timber supply area is not acknowledged in the Timber Supply Review and records a particular concern about thin, high elevation soils and soils that support both range and timber activities.
Minimum harvest age
The Ministry of Environment, Lands and Parks notes Douglas-fir has shown the ability to put on rapid growth at ages older than the defined minimum harvest age. This potential increase in volume, they point out, is lost if harvesting occurs at the defined minimum age.
Visual quality
Two individual submissions note the importance of the visual quality around major lakes and residential areas, such as Canim and Bonaparte Lakes and suggest visual quality be protected. They suggest clearcutting is not appropriate in these visible locations.