To: Mark Sloan, RPF, Sunshine Coast District Manager
cc: Klahoose First Nation Chief Steven Brown
cc: Nicholas Simons, MLA Powell River-Sunshine Coast
cc: Michele Babchuk, MLA North Island
cc: Discovery Islands Forest Conservation Project, Surge Narrows Forest Advisory Committee, Cortes Island Community Forest Cooperative
Good afternoon Mark,
I write to you regarding the newly amended Forest Planning and Practices Regulation (FPPR). Our project is concerned that section 9 of that regulation may not be properly considered in the issuance of cutting permits for logging in the Cortes Landscape Unit.
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 you know, one of the objectives set by government in the FPPR is for wildlife and biodiversity at the landscape level. Section 9 of the Regulation 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.”
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 confirmed 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 in the Cortes Landscape Unit should resemble natural disturbance on an island by island basis. 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 Cortes 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) and CWHdm biogeoclimatic zone variants is approximately 700 years. For the CWHvm variant it is 2000 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 CWHxm portion of the timber harvesting land base of the Cortes Landscape Unit could be cut in a year, on average, over a 700-year period. The same fraction applies to the CWHdm portion. In the CWHvm variant, only 1/2000 of that variant’s portion of the THLB could be cut, on average, each year.
In our view, the natural disturbance return intervals described in Standards for Assessing the Condition of Forest Biodiversity under British Columbia’s Cumulative Effects Framework should now be applied in your decisions about issuing cutting permits.
Our project has conducted some simple analyses based on information from your ministry’s RESULTS Openings database and the Cortes Landscape Unit Sustainable Resource Management Plan. The latter provides an estimate of the extent of the timber harvesting land base in the Cortes Landscape Unit. We have interpolated that number to estimate the THLB for each of the individual islands in the Cortes Landcape Unit where logging is occurring. Using that information we have determined that the spatial and temporal distribution of logging disturbance between 2004 and 2023 (20 years) significantly exceeded the predicted rate of natural disturbance in most of the landscape unit.
Here is what we found for the individual islands in the Cortes Landscape Unit:
West Redonda Island
Estimated THLB: 10,116 ha
Total cut: 1847.4 ha
Average cut per year: 92.37 ha
Available annual cut based on section 9 of FPPR: 14.4 ha
Cutting in CWHdm and CWHxm exceeded the natural disturbance rate by 6.4 times.
Cutting in CWHvm exceeded the natural disturbance rate by 18.3 times.
Maurelle Island
Estimated THLB: 3309 ha
Total cut: 503.7 ha
Average cut per year: 25.2 ha
Available annual cut based on section 9 of FPPR: 4.7 ha
Cutting in CWHdm and CWHxm exceeded the natural disturbance rate by 5.4 times.
Read Island
Estimated THLB: 3331 ha
Total cut: 223.1 ha
Average cut per year: 11.2 ha
Available annual cut based on section 9 of FPPR: 4.8 ha
Cutting in CWHxm exceeded the natural disturbance rate by 2.3 times.
Raza Island
Estimated THLB: 977 ha
Total cut: 327 ha
Average cut per year: 16.4 ha
Available annual cut based on section 9 of FPPR: 1.4 ha
Cutting in CWHdm exceeded the natural disturbance rate by 11.7 times.
Cutting in CWHvm exceeded the natural disturbance rate by 33.5 times.
Cortes Island
Estimated THLB: 7391
Total cut: 95.7 ha
Average cut per year: 4.8 ha
Available annual cut based on section 9 of FPPR: 10.6 ha
Cutting in CWHxm has been below the natural disturbance rate.
We note that logging on Read Island and Cortes Island was done in tenures that, under the Forest and Range Practices Act “need not be consistent” with a government objective that pertains to “temporal and spatial distribution of cutblocks”. Still, we expect that all tenures would recognize, as Cortes Island Community Forest Cooperative clearly has, that they, too, must operate within the ecological limits imposed by nature—and now by government.
Application of sections 64 and 65 of the FPPR by forest licensees in their forest stewardship plans have 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 Forest Planning and Practices Regulation has been in effect throughout that time.
This evidence shows that for many years now, the rate of logging in most of the Cortes Landscape Unit has far exceeded what is now understood to be the natural disturbance rate for CWHxm, CWHdm and CWHvm. 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 not being met.
In May, A&A Trading proposed an additional 190.5 hectares of logging in new cutblocks and road segments on West Redonda Island. If these were to be logged over the next three years, that would result in an average of over 63 hectares of forest being cut each year. The average available cut per year in order for logging on West Redonda Island to not exceed the natural disturbance rate prescribed by section 9 of FPPR is 14.4 hectares, as noted above.
As previously noted, 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 Cortes 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 14th, we will follow through with a complaint to the Forest Practices Board that your district may be failing to regulate the rate of logging in the Cortes Landscape Unit as required under section 9 of the Forest Planning and Practices Regulation.
Sincerely,
David Broadland for the Discovery Islands Forest Conservation Project
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