Land base
In addition to those respondents who reiterate the CFLA concern that the land base was inappropriately reduced, one submission describes the land base as over-conservative.
Fifteen submissions question the inclusion of the Chapman-Gray watershed as part of the land base. Some specifically point out that Chapman-Gray is designated as a watershed reserve under Section 12 of the Land Act.
Visual quality objectives
Sixty percent of the submissions include comments on visual quality objectives for the Sunshine Coast Timber Supply Area; 25 per cent of those describe visual quality objectives as subjective.
Over 100 of the form letters are concerned that the assignment of visual quality objectives to 55 per cent of the timber harvesting land base will cause a loss of jobs and a reduction in the allowable annual cut.
Some respondents state that cost-benefit analysis has not been done. Given the 24 per cent reduction to the allowable annual cut in 1993, there is a concern that forest workers might be further affected by a harvest-level reduction.
One submission states that the licensee analysis uses a conservative estimate of expected changes to visual quality objectives, yet still indicates the current harvest level could be maintained for four decades. This projection even includes an increase in mid-term levels, relative to the base case.
Some submissions maintain a 5 per cent relaxation of visual quality objectives would allow the current allowable annual cut to be maintained or, possibly, increased. In contrast, other submissions state that a 5 per cent relaxation would not be beneficial; these respondents support an enhancement of visual quality objectives.
Some submissions express concern that the Preservation visual quality objective (as noted in the 1994 draft Sunshine Coast Timber Supply Area data package) has been deleted. These submissions recommend stringent visual quality objectives be reinstated and maintained.
Inventory information
A number of submissions from individuals, groups and industry stress the importance of having a reliable and technically correct inventory of all forest resources.
One submission recommends that inventory and yield studies be done for all timber types, including those identified as uneconomical because of high elevation, low site quality, or the presence of non-commercial species. In addition, it states the inventory should include the undercut reserve from the Small Business Forest Enterprise Program, plus a reserve of 9 000 cubic metres per year from the five per cent reduction associated with the transfer of tenure from Weldwood of Canada Ltd. to International Forest Products Ltd.
Another submission is concerned that both the short- and long-term supply forecasts were based on the original inventory; the 1991 reclassification, which was not verified by ground checks; and the determination of the twenty-year timber supply by forest licence-holders in their development plans.
One submission states that the present lack of inventory information concerning cultural heritage resources within traditional territory is a barrier to meaningful involvement in the land-use decision making process.
Two forest industry submissions and one by an environmental interest group express willingness to assist in the process of the next inventory. Another submission suggests using Forest Renewal British Columbia money to undertake an inventory and to project the results of intensive forestry.
Age class structure
One submission states that the retention and maintenance of a more substantial age class-based inventory is essential. To that end, an immediate reduction in the current allowable annual cut is crucial.
Site index estimates
Most of the forest industry submissions support the licensee analysis statement that old-growth site index values likely underestimate future growth. They assert the use of second-growth stands to determine site index is more reliable.
One submission states that by using existing stands to determine site index, the Timber Supply Analysis significantly underestimates site index for managed stands, due to the negative bias of over-mature stands. The respondent cites a paired-plot study by Pacific Forest Products in Gold River that shows a difference in site index of up to 9.2 metres at 50 years for hemlock and 5.5 metres for Douglas-fir.
Biodiversity
Over 25 submissions maintain that the Timber Supply Analysis does not adequately account for the multiple levels of biodiversity and wildlife values in the Sunshine Coast Timber Supply Area. A number of respondents note that the three alternative harvest scenarios project an overall reduction in natural diversity and a decline in species dependent on old growth. This is held to be unsatisfactory.
Two submissions recommend a four to ten per cent reduction in the land base to sustain natural ecosystems, riparian corridors and biodiversity.
Three submissions express concern about the effect on biodiversity and wildlife habitat of Coast Mountain Hardwoods' proposal to extract 500 000 cubic metres of deciduous timber in cutblocks of up to 200 hectares on low-elevation sites.
Old growth
In addition to the submissions concerned specifically with biodiversity and old growth, ten respondents further support conservation of old growth. Others urge that a full inventory of old growth be completed before any further harvesting is done.
Other technical comments
Three submissions recommend that tree farm licences be included in the analysis, as they contribute to employment and timber supply. One letter further notes that tree farm licenses 10 and 39 make up approximately 33 per cent of the district, with a combined harvest of 436 616 cubic metres. This is equal to 41.5 per cent of the timber supply area allowable annual cut, but it does not contribute to the allowable annual cut.
Many respondents express concern that changes outside the timber supply area are excluded from the impact analysis. They describe timber supply area logs as a vital part of coastal log trading and sales economy.
One submission recommends that a full range of reasonable interpretations of the factors involved in predicting timber supply be made available to the public and decision-makers.
