To: Lesley Fettes, RPF, Campbell River District Manager
cc: We Wai Kai Nation Chief Ronnie Chickite
cc: Michele Babchuk, MLA North Island
cc: Discovery Islands Forest Conservation Project, Surge Narrows Forest Advisory Committee
Good afternoon Lesley,
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 Thurlow 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.” (“Practicable” has been defined by the Ministry of Forests as “Is possible and can be accomplished with known means and resources.”)
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 Thurlow 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 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 and the CWHdm variant is 700 years, for the CWHmm variant is 1100 years and for the CWHvm variant 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 on any one island could be cut in a year, on average, over a 700-year period. The same fraction applies to the CWHdm portion. In the CWHmm variant, only 1/1100 of that variant’s portion of the THLB could be cut, on average, each year. 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 a simple analyses based on information from your ministry’s 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 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 TFL 47 portion of the Thurlow Landscape Unit:
Sonora Island
Estimated THLB in TFL 47: 9104 ha
Total cut 2004-2023: 942.4 ha
Average cut per year: 47.12 ha
Available annual cut based on section 9 of FPPR: 12.9 ha
Cutting in CWHxm exceeded the natural disturbance rate by 3.6 times.
Cutting in CWHmm exceeded the natural disturbance rate by 5.7 times.
East Thurlow Island
Estimated THLB: 5379 ha
Total cut 2004-2023: 944 ha
Average cut per year: 47.2 ha
Available annual cut based on section 9 of FPPR: 7.7 ha
Cutting in CWHxm exceeded the natural disturbance rate by 6.1 times.
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.
Hardwicke Island
Estimated THLB: 5253 ha
Total cut 2004-2023: 1826 ha
Average cut per year: 91.3 ha
Available annual cut based on section 9 of FPPR: 5.6 ha
Cutting in CWHdm exceeded the natural disturbance rate by 12.2 times.
Cutting in CWHvm exceeded the natural disturbance rate by 34.8 times.
Cutting in CWHmm exceeded the natural disturbance rate by 19.1 times.
We would be happy to share with you the data and methodology we used for these assessments.
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 and these four islands have been in TFL 47 during those years.
This evidence shows that for many years now, the rate of logging in the TFL 47 portion of the Thurlow Landscape Unit has far exceeded what is now understood to be the natural disturbance rate for CWHxm, CWHdm, CWHvm and CWHmm. 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 has been compromised.
In May 2024, TimberWest proposed an additional 124.2 hectares of logging in new cutblocks and road segments on West Thurlow Island. 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.
Logging on the four islands of the Thurlow Landscape Unit in Johnstone Strait, 1984 to 2023
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 Thurlow Landscape Unit, or any of the individual islands in that LU, 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 17th, 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 Thurlow 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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