A range of input was received regarding the timber supply analysis conducted by the Forest Service. The input can be summarized under the following topics:
inclusion of small pine stands
Two submissions support the inclusion of previously-excluded small pine stands in the timber harvesting land base, but express concerns about the resulting timber supply projections. A forest industry submission states that only about 20 per cent of the formerly excluded small pine stands in the western part of the timber supply area can be economically utilized, whereas the base case forecast indicates a 95 per cent increase in the initial harvest level. Another industry submission questions the fact that the land base was only increased by 14 per cent, yet the initial harvest level increased by 95 per cent.
The interest group submission asserts these areas of small pine forests and other problem forest types have never been identified on a map, and it is skeptical about their existence at the volumes predicted. The group formally requests the provision of a map showing actual ground locations of these types, as well as an analysis of the environmental impacts of including these types in the inventory. An individual submission also questions the inclusion of small pine stands in the timber harvesting land base. Most of these are unmerchantable, according to the respondent.
deciduous land base
A forest industry submission states that poor inventory data leads to poor definition of the timber harvesting land base, particularly in the classification of areas with low productivity or non-merchantable forests. It believes significant area could be added to the deciduous land base with better inventory data. The submission also states the bias toward coniferous species is reducing the deciduous land base through conversion to coniferous forests and through the protection of conifers in the understory of pure aspen stands. Good fire protection is also contributing to a decline in the deciduous land base, in the respondent's opinion.
Another industry submission contends it is possible to maintain or even increase the deciduous land base by allowing some mixed coniferous-deciduous stands (approximately 10 per cent) to change to deciduous-leading stands. The Forest Service analysis, based on current management assumptions, doesn’t allow for this natural succession to occur and, therefore, perpetuates the trend towards a decreasing deciduous land base, according to the respondent. This submission also maintains the decrease in herbicide use will lead to more deciduous-leading sites, and questions whether deciduous trees are considered acceptable species in assessing regeneration success. If they were to be considered acceptable, as they should be, the respondent says the deciduous harvesting land base would increase.
definition of merchantability
A forest industry submission maintains the use of 140 cubic metres per hectare as the cut-off for merchantability for both coniferous and deciduous is inconsistent with the Dawson Creek Timber Supply Area where 120 cubic metres per hectare is used. Using 140 cubic metres as the cut-off excludes all poor sites, the company says, yet some of these sites are harvestable.
extent of not satisfactorily restocked areas
An individual submission states the not satisfactorily restocked area was underestimated in the Forest Service analysis. A forest industry respondent agrees and describes the 2 per cent reduction in the productive land base to account for these areas as too low, given the extent of not satisfactorily restocked patches within plantations.
deductions for future roads and landings
A forest industry respondent notes that road rights-of-way have historically been wider than 20 metres, and asserts the deduction for existing roads is low since it was based on a 20-metre width. Another industry submission states the reduction for roads in deciduous areas is excessive. It maintains most of these areas have been heavily explored, and access for harvesting will be from already developed roads or seismic lines.
uncertainty about boreal forest management
The interest group contends that since the processes at work in boreal forests are not well understood, this uncertainty should be addressed through an appropriate reduction in the size of the land base.
estimate of coniferous volumes
A forest industry submission asserts estimates of future volumes may be inflated by the use of very high initial stocking levels (1600 stems per hectare) in the Forest Service analysis. It reports that one major licensee generally plants 1400 stems/hectare, and regeneration surveys typically show 800 to 1000 stems/hectare. This latter average is what should be used in estimating future volumes, according to the respondent.
Another industry submission states that the Forest Service analysis overestimates the harvest volumes to be achieved, particularly for forests older than 150 years. This opinion is based on a comparison of its own harvesting records with the estimates used in the base case.
Given the newness of commercial forestry in boreal forests, the interest group submission contends predicting an increase in harvests from regenerated forests may not be justified. In its view, estimates of future volumes should be proven before being included in a timber supply analysis. The respondent requests justification of the revised growth estimates. An individual submission supports the inventory audit finding that mature pine volumes were overestimated in the timber supply analysis by 15 to 20 per cent.
estimates of deciduous volume
A forest industry submission maintains there is simply not enough data to support the reduction in projected volumes from second-growth deciduous forests. The submission also questions the factors used to account for decay and waste, saying there is little data to support the numbers used in the Forest Service analysis, and local factors need to be developed. In addition, it contends the same productivity estimates should not be used for aspen as for conifers, since aspen matures at a much younger age.
Another industry respondent expresses the opinion that deciduous volume estimates seem high, based on its work.
regeneration delay
According to a forest industry submission, the anticipated regeneration delay used in the Forest Service analysis is too short for cutblocks that have brushed in. The normal natural succession on these wetter areas means conifer stocking in a reasonable time frame is uncertain without site preparation and planting.
An individual submission states that while the climate of this area is complex and not well understood, regeneration should not take five to seven years to achieve except in extreme weather conditions.
The interest group suggests the regeneration delay used in the Forest Service analysis may be overly optimistic, given staff concerns about vegetation management success and given the current extent of not satisfactorily restocked areas (55,000 hectares). In its opinion, the use of chemical herbicides must be sharply curtailed in the future, and the analysis should include the resulting deciduous stages as a wildlife requirement. The impact of reduced herbicide use on regeneration delay should be considered in this analysis.
reliability of inventory data
Two industry submissions express concerns about the reliability of inventory data used in the Forest Service analysis and urge a commitment to updating the inventory. The interest group agrees, but urges that consideration be given in the meantime to the fact that the recent audit of the timber inventory suggests the base case forecast may have overestimated the size of the timber harvesting land base. This submission asks the chief forester to provide a scientific justification for the data used in this analysis, including a thorough inventory audit, prior to any increase in the allowable annual cut.
An individual respondent also questions the reliability of the inventory and states that it tends to overestimate existing volumes.
timber utilization
A forest industry submission agrees that the minimum diameter for deciduous should be 12.5 centimetres. Another industry respondent supports reducing the minimum diameter and height requirements for pine.
harvestable ages
A forest industry respondent declares a lower harvest age (less than 80 years) should be used for deciduous forests. Aspen clones start to deteriorate after 50 to 65 years, not at 120 years as stated in the Timber Supply Analysis. The respondent maintains the goal should be to lower the harvest age for managed stands to reduce decay losses and ensure good suckering.
An individual submission states it is impossible to harvest anything at 40 years, even if it is protected and fertilized.
Another industry submission recommends forests be harvested at their culmination age (when growth starts to flatten out) and declares there is a discrepancy in the culmination ages used in the analysis. Another industry submission expresses satisfaction with the culmination ages used.
losses to fire and wind
A forest industry respondent believes future unsalvaged losses will be lower than assumed in the Forest Service analysis, due to the recent record of successful salvage harvesting and the increasing presence of road access throughout the timber supply area.
Another industry submission recommends average fire losses be calculated using a longer period than 10 years. One large fire can skew the average, and this timber supply area has a history of large fires.
The view of the interest group is that, because of past fire history, it must be assumed that fire will continue to be a dominant force in the timber supply area, even with improved fire suppression. It recommends a substantial volume netdown to account for the effect of fires consuming older age classes, both mature and immature.
As a general comment about the timber supply analysis, the interest group states that a pro-timber bias exists in the Forest Service analysis. It declares that factors leading to an increase in timber supply (such as inclusion of small pine stands in the timber harvesting land base and productivity estimates for regenerated forests) are included in the analysis, despite uncertainty about their accuracy. However, those factors that might exert a downward pressure on timber supply (such as the Forest Practices Code or the Protected Areas Strategy) are not factored into the analysis, despite knowledge about their effects.
