A range of input was received regarding the timber supply analysis, and can be summarized under the following topics:
Reliability of inventory data and estimates
One submission says the use of 1992 forest inventory data is not valid; another questions the quality of the current forest inventory.
Site productivity estimates
One submission states that regeneration success rates will be negatively affected by soil and water table degradation, changing rainfall and climate patterns resulting from extensive clearcutting, especially in the Chilcotin and higher elevation areas.
Another submission cautions that large, single-species plantations may be prone to severe insect and disease outbreaks and maintains this may affect forecasts of regeneration growth. The example of pine needle cast infections in plantations in this timber supply area is given.
An interest group submission maintains the model used in the analysis to predict growth is inadequate to deal with the risk and uncertainty inherent in future predictions. The authors say no scientific research is cited to support the projections made in the analysis.
In addition, this interest group asserts that much of the data and assumptions in the analysis is not accurate and current. They say the detailed information regarding the origin of, the rationale for, and the validity of, current management practices is not provided, yet these status quo management practices form the basis for projected future volume yields.
An individual submission maintains that site productivity losses are occurring because of the reliance on slashing, burning and planting, when natural tree growth would be faster and more reliable.
Size of the timber harvesting land base
Two submissions state that the reduction of 2.5 per cent of the land base for roads is insufficient, and doesnt account for soil degradation on skid roads, trails and landings where vehicle soil compaction and industrial activity occurs. One individual suggests the reduction should be 7.5 to 10 per cent of the timber harvesting land base.
The Ministry of Environment, Lands and Parks submission cites a lack of clarity in the way Pulpwood Agreement 16 was accounted for in the Forest Service analysis. The submission states this agreement has a very real impact on the location of sawlog cutblocks, due to the requirement that harvested blocks green up before adjacent blocks are harvested.
Ainsworth Lumber Co. Ltd. indicates support for the area reductions within Pulpwood Agreement 16, but notes further analysis is required so this reduction does not translate into a loss of available timber for harvest. The company states it does not support any inclusion of problem forest types into the sawlog harvest land base.
A forest industry submission suggests the problem forest type land base should be defined by measures such as minimum volume per hectare and minimum tree heights. Lignum Ltd. contends that approximately 400 000 hectares of the 700 000 hectares of problem forest type stands (classified as immature or pulpwood) are actually sawlog stands, and therefore should be included in the timber harvesting land base. Lignum says the same principle applies to the three Western Supply Blocks, where they expect the 500 000 hectares of problem forest types to include significant sawlog volumes.
Wildlife habitat
The exclusion of wildlife habitat from the timber harvesting land base was based on outdated wildlife data, according to one respondent. A comprehensive ecological assessment of habitats is required to ensure adequate habitat for wildlife.
The Ministry of Environment, Lands and Parks says the information used for excluding mule deer habitat was based on 1988 data, which is outdated because of extensive salvage logging in Douglas-fir forests attacked by the fir bark beetle. The ministry submission says estimates of timber volumes from these areas were overestimated and did not contain an allowance for catastrophic events.
An industry submission agrees a re-inventory of mule deer winter range areas is needed in order to develop realistic management plans that recognize the needs of mule deer and the current high level of Douglas-fir bark beetle harvest.
Insects, disease and fire
One respondent says the European experience of problems with monoculture should make the Forest Service very cautious, and states that no margin of safety for the forest health risks associated with monocultures was built into the Forest Service analysis.
Another claims that about 30 per cent of volume reductions province-wide are due to fire, pests and disease. Despite the efficient salvage and sanitation harvesting occurring in the Williams Lake Timber Supply Area, the one per cent estimated in the Forest Service analysis for unsalvaged losses may be far too low.
An interest group submission says the Forest Service analysis makes no comment on pine needle casts and blights, which are widespread in the Chilcotin. Also, no consideration was given in the analysis to the effects of global warming and climate change on diseases.
According to a forest industry submission, the Forest Service estimate of about 8.6 million cubic metres of mountain pine beetle-killed pine is low. The submission estimates 13 to 14 million cubic metres exist, with four to five million available for harvest. The group says this will support the salvage program for up to five more years at the current rate of harvest. The benefits of this include conversion to managed forests, reduced rehabilitation expenditures, enhancement of multiple uses (especially grazing), continued employment and contribution to Crown revenues. These significant salvage volumes indicate much is yet to be learned about the management of aging forests over long periods of time, according to the group.
Lignum Ltd. also supports the five-year extension of the beetle-kill licences, based on the above data as well as on their surveys which confirm the merchantability of the dead lodgepole pine.
Industry analysis
The industry analysis makes the following additional comments about the Forest Service timber supply analysis:
the Forest Service analysis does not address the fact that, although considerable mature timber is generally available, a very critical shortage is projected to occur between 15 and 35 years from now
the issuance of cutting permits should not be used as an indicator of timber availability, since permits are affected by other issues such as land use conflicts
change is the most significant resource management factor that requires study, but the Forest Service analysis has not analyzed the types and extent of changes occurring
the rapid change in utilization standards is not recognized in the Forest Service analysis. For example, wood previously usable only as pulpwood may now have other uses, yet the pulpwood agreement is tied to a particular land base rather than to the utilization options for the wood within it