2024-06-04 Comment on TimberWest's planned logging on West Thurlow Island

June 4, 2024

To: TimberWest Forest Corp.

cc: Lesley Fettes, RPF, Campbell River district manager

I write in response to TimberWest’s proposed logging of 12 cutblocks and 16 road segments on West Thurlow Island, as indicated in the Forest Operations Map. In our project’s view the spatial and temporal nature of the proposed logging would compromise the objective set by government for wildlife and biodiversity at the landscape level contrary to the requirements of the newly amended section 9 of the Forest Planning and Practices Regulation (FPPR).

As you know, section 9 of the FPPR now states: “The objective set by government for wildlife and biodiversity at the landscape level is, to the extent practicable, to design areas on which timber harvesting is to be carried out that resemble, both spatially and temporally, the patterns of natural disturbance that occur within the landscape.” (“Practicable” has been defined by the Ministry of Forests as “Is possible and can be accomplished with known means and resources.”)

Our reading of that newly amended objective is that the rate of logging on West Thurlow Island must resemble the expected rate of natural disturbance (an island meets the ministry’s definition of “landscape level”). A critical consideration in determining that rate is the natural disturbance return interval at the landscape level. The most recent science-based assessment of the temporal dimension of natural disturbance in the biogeoclimatic zone variants that overlap the Thurlow Landscape Unit is contained in the 2020 Standards for Assessing the Condition of Forest Biodiversity under British Columbia’s Cumulative Effects Framework (please see the table in Appendix 3 on page 52).

That assessment shows that the average natural disturbance return interval for the CWHxm variant is 700 years and for CWHmm is is 1100 years. TimberWest’s logging on West Thurlow Island (2004-2023) has been in CWHxm (1317.5 ha) and CWHmm (67.6 ha).

We have consulted with a reputable forest ecologist who is an expert on natural disturbance return interval, and what that implies. She agrees with us that for logging to resemble natural disturbance at the landscape level in the CWHxm variant, both spatially and temporally, no more than 1/700 of the CWHxm portion of the timber harvesting land base on West Thurlow Island could be cut in a year, on average, over a 700-year period. For the CWHmm variant, no more than 1/1100 of the timber harvesting land base on West Thurlow could be cut in a year, on average, over an 1100-year period.

Our project has conducted a simple analyses based on information from the Ministry of Forests’ RESULTS Openings database and the estimate of the timber harvesting land base (THLB) for the Thurlow Landscape unit provided in the 2012 Ecora Resources timber supply review for TFL 47 conducted for TimberWest. We have interpolated that number to estimate the THLB for each of the four individual islands in the Thurlow Landcape Unit where logging has occurred 2004-2023. Using that information we have determined that the spatial and temporal distribution of logging disturbance significantly exceeded the predicted rate of natural disturbance in most of the landscape unit.

Here is what we found for TimberWest’s logging on West Thurlow Island:

Estimated THLB: 4187 ha

Total cut 2004-2023: 1385 ha

Average cut per year: 69.3 ha

Available annual cut based on section 9 of FPPR: 5.9 ha

Cutting in CWHxm exceeded the natural disturbance rate by 11.6 times.

Cutting in CWHmm exceeded the natural disturbance rate by 18.2 times.

TimberWest's inclusion of a reference to sections 64 and 65 of the FPPR in its forest stewardship plans appears to be all that is required for TimberWest to believe it has met the objective set by government in section 9 of FPPR. This is preposterous and has not resulted in the outcome for conservation of wildlife and biodiversity at the landscape level sought by the regulation.

We note that in at least 3 different cases (cutblock IDs =18367, 18375, 18370) in the proposed logging, a new cutblock would join together two recent cutblocks. In each case, replanting of the adjacent cutblocks was completed only 10 to 12 years ago. This is a far-fetched misrepresentation of the spatial and temporal pattern of natural disturbance on West Thurlow Island.

TimberWest’s current proposed logging on West Thurlow, as indicated by the map in the FOM portal, would see an additional 124.2 hectares of logging in new cutblocks and road segments. If these were to be logged over the next three years, that would result in an average of over 41.4 hectares of forest being cut each year. The average available cut per year in order for logging on West Thurlow Island to not exceed the natural disturbance rate prescribed by section 9 of FPPR is 5.9 hectares, as we observed above.

We also note that the iMapBC layer for the forest operations map shows an additional 9 approved but as yet unlogged cutblocks that TimberWest no doubt wants to log soon on West Thurlow Island. In all TimberWest has plans for logging 162 hectares. At the natural disturbance rate for West Thurlow Island, this must be spread out over an approximately 27-year period to meet the requirement for TimberWest to not compromise the section 9 objective for wildlife and biodiversity at the landscape level.

There are an additional 9 approved cutblocks totalling 38 hectares waiting to be logged by TimberWest

The newly amended section 52.05 of the Forest Act requires a district manager to refuse to issue a cutting permit for logging that would result in section 9 of the FPPR being compromised. We have alerted Campbell River District Manager Lesley Fettes to the above facts and have requested that she not issue cutting permits that would result in a rate of logging that exceeds the spatial and temporal pattern of natural disturbance.

Sincerely,

David Broadland for the Discovery Islands Forest Conservation Project