(2024-05-20) The rate of logging on Quadra Island is much greater than the Forest Planning and Practices Regulation allows

To: Lesley Fettes, RPF, Campbell River Natural Resource District Manager

Dear Ms Fettes,

I write to you regarding the newly amended Forest Act and the Forest Planning and Practices Regulation (FPPR). Our project is concerned section 9 of that regulation is not being properly considered by TimberWest in its proposed logging for Quadra Island. This applies generally to all the landscape units that overlap with TimberWest’s TFL 47. In this letter I will confine my comments to the Quadra Landscape Unit.

Section 52.05 of the recently amended Forest Act states “The minister must refuse to issue a cutting permit if one or more of the following circumstances applies: (a) the minister determines that, taking into account prescribed matters, if any, issuance of a cutting permit would compromise a prescribed government objective…”

As you know, one of the objectives set by government in the Forest Planning and Practices Regulation (FPPR) is for wildlife and biodiversity at the landscape level. Section 9 of the Regulation 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.”

As you also know, the clause limiting the impact of this objective on the timber supply of BC has recently been removed by an amendment to the FPPR. By that action the government of BC has made clear its intention that cutting permits should only be issued for logging that resembles natural disturbance—both spatially and temporally—at the landscape level.

Our reading of that newly amended objective is that the rate of logging across BC should resemble natural disturbance at the 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 in which TFL 47 overlaps the Quadra 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 (1 and 2) biogeoclimatic zone is approximately 700 years.

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 timber harvesting land base of a landscape unit could be cut in a year, on average, over a 700-year period. As you know, the 1995 BC Forest Practices Code Biodiversity Guidebook estimated the natural disturbance return interval for CWHxm at 200 years (see page 22). The science that supported that has since been advanced by Price and Daust, Daniels and Gray, and others. In our view, the natural disturbance interval of 700 years for CWHxm (1 and 2) as described in Standards for Assessing the Condition of Forest Biodiversity under British Columbia’s Cumulative Effects Framework should now be applied in your decision-making.

Our project has conducted some simple analyses based on information from your ministry’s RESULTS Openings database and TimberWest’s 2012 timber supply analysis for the landscape units in TFL 47, performed by Ecora Resource Group Ltd. The latter provides an estimate of the extent of the timber harvesting land base in the Quadra Landscape Unit. Using that information we have determined that the spatial and temporal distribution of logging disturbance since 2004 significantly exceeds the predicted rate of natural disturbance, whether the natural disturbance return interval used is 200 years or 700 years.

Here is what we have found for the Quadra Landscape Unit.

The Crown land base on Quadra Island that is in TFL 47 is about 11,000 hectares. To arrive at that number we used the numbers given on TimberWest’s own map of Block 12 and corrected that for an error the map contains (248-hectare Lot 488 is not part of TFL 47).

The timber harvesting land base of TFL 47 in the Quadra Landscape Unit is about 7000 hectares. We used the 2012 Ecora timber supply review to obtain that number (see page 6).

Based on that information we determined that the annual area of logging on the timber harvesting land base of TFL 47 in the Quadra Landscape Unit that would temporally resemble natural disturbance is 35 hectares at a natural disturbance return interval of 200 years, or 10 hectares at a natural disturbance return interval of 700 years.

In the TFL 47 portion of the Quadra Landscape Unit in the 20 years between 2004 and 2023, 1694.5 hectares were cut. That averages out to 84.73 hectares per year (1694.5/20).

The average yearly cut over those 20 years (84.73 hectares per year) is 2.4 times higher than the natural disturbance rate if the natural disturbance return interval used is 200 years.

The average yearly cut (84.73 hectares per year) is 8.5 times higher than the natural disturbance rate if the natural disturbance return interval used is 700 years.

Application of sections 64 and 65 of the FPPR by TimberWest in its forest stewardship plan have clearly not resulted in the outcome for conservation of wildlife and biodiversity at the landscape level sought by the regulation. We have used the last 20-year period because the area of TimberWest’s TFL 47 in the Quadra Landscape Unit has not changed during that time, and the Forest Planning and Practices Regulation has been in effect throughout.

This evidence shows that for many years now, the rate of logging in the TFL 47 portion of the Quadra Landscape Unit has far exceeded (8.5 times) what is now understood to be the natural disturbance rate for CWHxm. Even using the old natural disturbance return interval from the Forest Practices Code era, it was 2.4 times faster. During that period (and the 20 years previous to that) there has been significant degradation of wildlife habitat and loss of biodiversity as a result of this overcutting. The objective set by government for wildlife and biodiversity at the landscape level in 2004 through the FPPR is clearly not being met.

This is particularly alarming given that a significant portion of Quadra Island was established as a special management zone in 2000 by the Vancouver Island Land Use Plan. Under the summary version of that plan the “primary objectives” in SMZ 19 were to be biodiversity, visual resources, recreation resources, tourism resources and wildlife. “Timber” was considered as a “secondary objective”. The Vancouver Island Land Use Plan is still in effect.

We also did this analysis for the entire timber harvesting land base of the Quadra Landscape Unit including the 11 woodlots. Although those woodlots are exempt from meeting the section 9 objective, it is interesting to note that they are being logged at a rate similar to TFL 47. This makes it even more critical that you act quickly to reduce the rate of logging in the TFL 47 portion of the Quadra Landscape Unit.

This excessive rate of logging on Quadra Island is impacting the sense of security and safety of many islanders on at least three levels. It is especially concerning in light of the known connections between logging and loss of wildlife habitat and loss of biodiversity, between logging and carbon emissions and between logging and the higher fire hazard of clearcuts and young plantations during extreme fire weather compared to mature and old forest.

In 2024, TimberWest has logged an additional 22 cutblocks as of May 18, continuing to greatly exceed the rate of natural disturbance (about 76 hectares). On April 3, TimberWest proposed through the Forest Operations Map portal an additional 18 new cutblocks and several road segments totalling about 37.4 hectares. If these were to be logged at the rate TimberWest has logged recently, they will clearly not meet the section 9 objective set by government in the FPPR.

As we pointed out above, section 52.05 of the newly amended Forest Act states “The minister must refuse to issue a cutting permit if one or more of the following circumstances applies: (a) the minister determines that, taking into account prescribed matters, if any, issuance of a cutting permit would compromise a prescribed government objective…”

As the minister’s designate, we expect that you will refuse to issue any cutting permit in the Quadra Landscape Unit that would compromise the objective set by government for wildlife and biodiversity at the landscape level.

Please let us know as soon as possible what action you intend to take on this issue. We will wait 10 business days to hear back from you. If we have not heard from you by June 5th, we will follow through with a complaint to the Forest Practices Board that your district is failing to regulate the rate of logging in the Quadra Landscape Unit as required under section 9 of the Forest Planning and Practices Regulation.

Sincerely,

David Broadland for the Discovery Islands Forest Conservation Project