Size of the timber harvesting land base
Submissions from the timber industry suggest the economic situation has changed since the early 1990s when the economical timber within the timber supply area was mapped based on the harvesting methods that were in use at the time. Although documentation is not provided, the timber industry contends that a portion of the 67,000 hectares excluded from the timber harvesting land base is now economically viable, leading to a five to 10 per cent increase in the size of the timber harvesting land base. They believe the analysis should take this dynamic situation into consideration.
Limited opportunities for alternative harvesting methods such as skylines and helicopters are included within the timber harvesting land base based on the current use of these methods. Submissions from the timber industry state there are additional areas where these methods could be used and, as this could increase the timber harvesting land base by as much as five per cent, it should be factored into the allowable annual cut determination, possibly as a partitioned cut. The areas where alternative methods could be used are not identified in the submissions.
Several timber industry submissions suggest establishing a partitioned cut to provide opportunities for harvesting in areas outside the identified timber harvesting land base.
Other submissions state that harvesting should not be permitted in sensitive, uneconomic or marginally economic areas for ecological reasons.
Forest management practices in visually sensitive areas
A major concern raised by the timber industry and the Fraser Coalition is the acceptable management practices defined for visually sensitive areas in the Fraser Timber Supply Area.
One submission from a timber company suggests the practices are too restrictive and a cost-benefit analysis should be done to justify the requirements. Other submissions suggest the requirements can be relaxed as the following practices are implemented:
use of terrain modeling technology to lay out cutblocks that meet landscape level requirements
special roadbuilding techniques and cutblock layout to increase access into these areas, and
smaller cutblocks and better practices which will be required under the Forest Practices Code.
The requirement that regenerated forests be at least five metres tall before adjacent areas are harvested is questioned. One submission suggests the use of larger seedlings and increased stand tending could reduce the length of time used in the Forest Service analysis for regenerated forests to reach the five metre requirement.
Another suggestion is to relax the requirements in the visually sensitive areas by five per cent which is perceived to maintain the viewscapes while providing a solution to the short-term timber supply deficit. The timber supply analysis critique tested the impacts of reducing the forest cover requirements in the visually sensitive and recreation zones to the same level as in the integrated resource management zone. This test indicates a 15,000 cubic metre per year increase in projected timber supply over the base case forecast in the first decade.
The submission from the Regional District of Fraser-Cheam questions the validity of the visual quality requirements if they will lead to reduced employment: "We are not convinced that it is desirable to apply one standard of logging to areas that can be seen and another standard to less accessible areas. A good forest practices code should be adequate for both of them." The Regional District also points to the British Columbia Forest Service's own analysis which indicates a five per cent reduction in visual quality requirements would remove the immediate need to reduce the allowable annual cut.
Other submissions indicate tourism is very important to the Fraser Timber Supply Area and some argue that clearcuts are simply not acceptable within viewscapes. On the other hand, comments from local government and some individuals suggest increased effort is required to help the public understand and accept that timber harvesting is an integral part of British Columbias economy and it should not be hidden from public view.
Deer winter range
The timber industry questions the requirements for deer winter range used in the timber supply analysis. The industry perceives that the inventory of deer winter range is inaccurate. They also question the application of winter range requirements throughout most of the timber supply area when winter range areas usually develop only in Douglas-fir forests. Industry also suggested that timber production should take priority over wildlife habitat requirements, or a more balanced approach is appropriate.
Analysis of management options
Some input was received which suggests the Timber Supply Review should explore management options as opposed to only analyzing current management practices.