The Discussion Paper prompted input on several issues.
Allowable annual cut adjustment
Many respondents offer comments regarding the allowable annual cut.
Nine forest industry submissions recommend that consideration be given to a combination of the following to allow the current allowable annual cut of 1.1 million cubic metres to be maintained from one to ten decades:
• re-aggregation of analysis units
• sensitivity of model differences in projecting the base case
• revised volume estimates for unmerchantable stands
• the use of special site indexes, where available,
One of these submissions states that the licensee analysis and other industry reports confirm that the use of increased volumes through commercial thinning, intensive forest practices, and intensive silviculture leading to shorter rotations, would allow the allowable annual cut to be maintained for another decade.
Another submission supports the conclusion in the licensee analysis that the removal of the Tetrahedron area, revised allowable annual cut classification and the use of licensee analysis units and volume predictions would allow the current harvest to be maintained for 10 decades while still providing enough elasticity to absorb additional reductions associated with the Forest Practices Code.
Two submissions point out that the Timber Supply Analysis examines harvest flow projections in which the initial harvest level is increased, left constant, and reduced; the Socio-Economic Analysis, in contrast, only considers those projections with the initial harvest level left constant and reduced.
Some respondents express concern that the allowable annual cut is based on outdated information.
A number of respondents state that the allowable annual cut should not be lowered and express concern that a reduction in the allowable annual cut could suppress wages for loggers. Eleven form letters urge that the cut not be reduced any further, due to the effects on communities and lifestyles. Many letters note that the cut was reduced by 24 per cent in 1993.
Eight submissions refer to the report, A Silviculture Analysis of Subalpine Mountain Hemlock Forests, and recommend that a separate allowable annual cut for the Mountain Hemlock biogeoclimatic zone be established. Others are concerned that the Mountain Hemlock zone, which is the last remaining habitat for the marbled murrelet, will be consumed in a generation or less.
Three submissions state that the Coast Mountain Hardwoods proposal to harvest deciduous was not considered.
Fourteen submissions recommend that the allowable annual cut be reduced. A number of these express concern that corporate pressure may influence the setting of the allowable annual cut, to the detriment of non-timber resources. One submission also points out that the current harvest level is 20 per cent above the low point (876 000 cubic metres per year) of the base case projection.
One submission asserts that the maintenance of the current harvest level over the next ten years would have devastating effects on all non-consumptive functions and values.
Another submission notes that one of the harvest forecasts in the Timber Supply Analysis projects a long-term harvest level around 600 000 cubic metres per year; it is suggested that this is the most appropriate and sustainable forecast of those modelled.
Base case
One respondent expresses concern that the base case compromises biodiversity, social values and the economics of high-value wood production.
Two respondents state that the sensitivity analyses do not take into account two of the biggest variables in assessing demands for timber in the future—fluctuations in log prices and prices for finished products in the domestic and world markets.
One submission comments that the harvest forecasts in the Timber Supply Analysis are more sensitive to changes that decrease timber supply than to those that increase it.
A number of submissions are concerned that the Tetrahedron is discussed in the Discussion Paper but not taken into account in the Timber Supply Analysis.
Timber utilization
Four submissions recommend that the high-value green-label certified wood products procedure that has been developed in the Vernon Forest District be applied in the Sunshine Coast Forest District. Many respondents state that timber should provide value-added local jobs.
One letter supports redesigning fibre flow patterns so all timber harvested in the timber supply area could be processed within the timber supply area.
Intensive silviculture
Many respondents comment that the timber supply review documents do not address the issue of improved yields due to commercial thinning and intensive forestry.
One respondent further states that silviculture treatments such as commercial thinning are not being developed in a meaningful way to assist displaced unionized forest workers.
A few respondents assert that intensive silviculture could result in more timber supply area employment.
Unsalvaged losses
One submission declares that much could be done to utilize an existing 24 000 cubic metres of unsalvaged losses.
Integrated resource management
Four submissions state that forest management should consider ecological sustainability first, then economic sustainability. One respondent is concerned that integrated resource management principles mean that all other values and uses have to accommodate logging.
A number of respondents assert that the Clayoquot Sound Scientific Panel is on the right track and that the precautionary principle should be invoked.
Several respondents are concerned that Local Resource Use Plan areas were included in the review. One further states that watershed units with prior commitments under Local Resource Use Plans involving local residents should be removed from the timber harvesting land base, pending the completion of the planning process(es).
An industry submission concludes that the 24 per cent reduction to the allowable annual cut in 1993 absorbed the impact of the shift to integrated resource management. Accordingly, upward pressures on timber supply mean the current harvest level could be maintained for some time.
Other
Three submissions state that the map on the cover of the Public Discussion Paper suggests Tsy-los Park is in the Sunshine Coast Timber Supply Area.
Public Involvement
Four submissions comment on public involvement in the timber supply review. One asserts that the Sunshine Coast Forest District does not have a good track record of public involvement. By example, the respondent cites the recent transfer of Tree Farm License 10 to International Forest Products Ltd. without First Nations consultation. Another submission states that the Ministry of Forests must adopt a more effective strategy to advise the public regarding the nature of a timber supply review, because most of the individuals the respondent had canvassed did not realize the effect of the review. Another letter suggests the public involvement process should represent all groups, not just some.
