SEAS submission to the Okg. TSA Timber Supply Review

Here is our submission to the process:


March 17, 2021 

2021 Okanagan TSA Timber Supply Review 

Comments on the Discussion Paper: 

Our organization has submitted numerous briefs to previous timber supply reviews calling for significant reductions to cut levels because we have long been concerned about overcutting. Sadly, despite our efforts, logging rates have remained high and will likely continue to remain high until most of the mature forests are gone. Nonetheless, we are submitting these comments on the Timber Supply Analysis Discussion Paper so that our concerns become part of the public record. 

Re: TSA Description 

It is appalling that this paper identifies all the land inside the TSA as being in the Okanagan. This description completely misses the fact that a sizable proportion (well over 1 million hectares) is in the Shuswap watershed, a completely distinct landbase that drains into the Fraser River, rather than the Columbia River and that contains distinctively different, wetter ecosystems than the Okanagan. It does not mention Shuswap Lake, nor the fact that the Shuswap includes eight rivers, whereas the Okanagan has but one. 

Re: Regional Economy 

The paper provides no data regarding the contribution that forestry has to the regional economy. Perhaps, this omission is due to the fact that the number of jobs in forestry and the percentage of forestry jobs has been steadily declining due to mill closures, technological improvements and automation. Thus, there is no economic justification for maintaining a high rate of cut, as the economic benefits to the region are no longer significant. 

Re: Land Base Classification 

Only 125,722 ha of OGMAs are listed, with just 55,379 ha in the net down, which apparently refers to the amount in the THLB. In the LRMP document, the table agreed to a total of 186,507 ha that includes 61,877 ha in the THLB (page 3-17). Why has the number of hectares of OGMAs been reduced? Mapping done for the Shuswap Watershed alone has identified 95,613 ha, thus there appears to be a discrepancy between agreed upon and currently mapped OGMAs and the number in the TSR analysis. 

Re: Species 

According to the graph, balsam and hemlock make up less the 25% of the volume and yet it is most likely that these two undesirable species make up a much larger percentage of the remaining timber that has not been logged. Thus, the volume of wood that remains is of inferior quality and high logging rates will only exacerbate the problem, as cutting continues to focus on the higher value species. Better analysis is needed to evaluate both the volume and value of the remaining timber available. Maintaining a high cutting level will result in the rapid depletion of any remaining high value timber and all that will be left for the future will be the low value hemlock and balsam stands. 

Re: “Thrifty” volume 

The paper provides no definition of what the “thrifty” volume is. I have since learned that “thrifty” refers to the unmanaged stands that are not old growth but may have had some logging occur in the past. The assumption that this volume will be able to represent a significant amount of the cut until the managed volume is old enough is complete speculation, without any real evidence to back it up. 

Re: Managed stands 

More pure speculation. It is highly unlikely that timber volume from managed stands will be equivalent to that from old growth stands, given the young age these trees are slated to be logged. More hectares will need be logged to allow for the equivalent about of volume. Plus, while some plantations are growing well, others are struggling to due to depleted soils, pests, diseases and drought. The graph that shows the projected reduction (from approximately 325 cubic metres per hectare to 275) is merely a projection that is not based on actual data.  

Re: Alternative harvest flows 

While the graphs that show a serious reduction in the AAC if the uplift is allowed to continue for another 30 years is concerning, it is likely not accurate as continued overcutting will more than likely result in a serious shortage of available timber within a decade. 

Re: Adjusted harvest flow sensitivity analysis 

Projecting benefits from management decisions that pose environmental risks should not even be considered, nor should it be modeled. Increasing the THLB, would result in less forest available for environmental values and thus should never be considered. So too, allowing logging to occur in very dry sites or problem forest types would also cause unacceptable impacts and result in degrading forest ecosystems to the detriment of forest health and other species. 

Re: Hydrological recovery 

It is pitiful that blocks are now allowed next to managed stands that have only achieved a height of two metres. In the data package, it is revealed that research shows that a two metre is not sufficient and the minimum should be six metres. Although, the study was just for pine, it is also probably valid for all species. It should be common sense that two-metre-tall trees do not provide adequate hydrological recovery. Allowing extensive areas of watersheds to be forested by trees just two metres and shorter could result in more flooding in the spring and water shortages in late summer. As well, these drier stands will be more susceptible to wildfire. The discussion paper notes that the base case used a constraint that in community watersheds no more than 30 % should be smaller than 6 metres, despite the fact that most companies ignore this rule because it is not legislated. 

Re: Forest Health 

The estimated losses due to forest health issues are inadequate. As climate change intensifies, most projections call for a marked increase in wildfires and yet the data package only projects that 60-100 hectares of unlogged THLB will be lost each year. There is inadequate consideration of the impact of armillaria (only a 5% reduction predicted) given that TIPSY points to sizeable reductions in future volumes (30% reduction in stands with low incidence and up to 63% reduction in stands with high incidence). 

Previous comments on the data package: 

Given the number of landslides just last year in the Shuswap, a major concern for some rural homeowners would be the number of hectares of unstable and potentially unstable land that is deducted from the THLB. The data package shows that only 20 percent of the potentially unstable land is off limits to logging, that is why Tolko has the right to proceed with its plans to log on the steep hillsides above Swansea Point at Mara Lake, where there already have been two massive slides. Clearly, a much larger percentage of all potentially unstable land should be made unavailable for logging, especially considering there are greater risks now due to the higher frequency of intense storms with heavy rainfalls. 

Some of the key information that is missing from the data package includes the amount of mature timber remaining to be logged and the number of years left before the second growth can be harvested.  The data package focuses on hectares of land excluded from logging, while the goal is to determine how many cubic-metres of timber can be logged every year. There is no estimate of the amount of timber that is logged per hectare, which varies with the size of the trees. Given that the trend has always been to log the best timber first, what timber remains is likely inferior and yet there is no consideration for this steady decline in the quality and volume of the remaining mature timber. Thus, the public is expected to provide input without receiving key information about the current status of available timber. 

Another key factor in the cut level determination is how well the plantations are growing, as knowledge about the timing for when this second growth will be ready to log and what volume would be expected is required to ensure forestry is sustainable. The ministry uses extrapolation data obtained from sample plots to estimate future tree growth, which only provides an estimate. Actual inventory data is woefully inadequate, as funding for this work has been insufficient for over a decade. 

One important issue that is missing in the data package is the impact of climate change, which has the potential to negatively impact the health of the plantations and the remaining mature forests. Increasing summer temperatures along with longer periods of drought increase the chances for more wildfires and more diseases and pest outbreaks. The uncertainties from climate change should be incorporated into the timber supply review. A recent article in the MDPI journal, Forests, reports on the results of a study that shows how warming temperatures result in stresses that cause four times the impact on lodgepole pine growth rates previously considered ( 

Whether a court case involving the “blacklisting” of a consultant for pointing out discrepancies with the data and models used to determine AAC will be allowed to proceed will not be heard until July. However, I have been briefed about these issues and the main concern is that the uncertainty involved in the AAC determination is not properly accounted for. As a result, assumptions are being used to increase the AAC despite the uncertainties surrounding them, while the assumptions that could be used to decrease the AAC are not used with the reason given that there are too many uncertainties. Thus, forest health issues and climate change issues are avoided in timber supply calculations, whereas questionable data for growth and yield and the volume present in the remaining mature forms the basis of the modeling used to determine the AAC. 

The rationale for maintaining high rates of logging has always been to protect forestry jobs, despite the fact that our region’s economy has been steadily diversifying and the number of jobs in forestry has been steadily decreasing due to a combination of automation and the growing decline in timber volume and quality. Given the number of jobs being created now in adventure tourism and the increase in damage caused by logging on steep slopes, it would be prudent to focus more on non-timber values when making the decision on how many trees will be logged in the future. The Chief Forester is well aware of these concerns and it remains to be seen if politics continue to override sustainability goals. 


Undoubtedly, given what has resulted from previous reviews, the AAC will either remain the same or will be increased again without regard for the future. The best decision you could make given the pressure to continue overcutting is to use the base case for the AAC. 

Comments prepared by Jim Cooperman, SEAS President

Note as well these two other excellent submissions:

Dear Sir/Madam

The Okanagan basin like its neighbouring basin to the East, the Kettle River basin, is badly over-logged.  Reforestation is problematic as are forest health and wildfires in both areas — the Okanagan TSA and the Boundary TSA.
In part problems with reforestation are caused by industrial clear-cut logging in the interior Douglas-fir zone.  Many problems with forest health are related to climate change.  The extent of intense wildfire even in plantations is a result in part of industrial clear-cut logging. Perhaps for local residents, the most costly consequence of industrial clear-cut logging at an excessive rate is its direct relationship to flooding.
In both TSAs, residents have experienced an increase in the frequency, magnitude and duration of peak flows, and excessive sedimentation of drinking water as a direct result of clear-cut logging.   The cost of the resulting damage to personal property, to public infrastructure and to ratepayers for treatment of drinking water is extensive.
Climate change is likely exacerbating flooding and contributing to the damage caused by clear-cut logging.  But the chief forester does not consider climate change as a contributing factor; nor does she consider clear-cut logging as the cause of the increased frequency, magnitude and duration of peak flows.
The chief forester is not obligated to feed the 21 local mills at the expense of local residents and provincial taxpayers.  She is obligated to balance the social and economic benefits of 21 mills with the societal cost to residents of feeding those mills at an ecologically unsustainable rate of logging.  In both the Okanagan and Boundary TSAs, the social and economic costs as a direct result of clear-cutlogging now far exceed the benefits.
Accordingly, I ask that in the Okanagan AAC determination, the chief forester scale back the rate of logging in some watersheds and stop logging altogether in community watersheds and in areas above the snow-line.
Thank you for the opportunity to comment.
Anthony Britneff
[Note – Anthony is a retired senior government timber supply analyst]

Dear Ministry:

I am writing as a member of the public and resident of the Okanagan Timber Supply Area, to provide input on the Timber Supply Review discussion paper and allowable annual cut for the next ten years.

This review comes at a critical time for the future of our planet, as climate change is underway, and we have a short window to correct course.  Forests play an important role in the health of many ecosystems, and can be both carbon sinks and emissions sources, depending on how they are handled.  The stakes for setting parameters for the next decade could not be higher, and forestry review requires bold approaches, not calculations as usual.

As the December 2019 BC Sierra Club report called “Clearcut Carbon” describes, “B.C.’s officially reported emissions (primarily from burning fossil fuels, not counting forest emissions) were about 65 million tonnes of carbon dioxide in 2017. Considering the 42 million tonnes of carbon dioxide emissions caused annually by logging and the 26.5 million tonnes of foregone capture of carbon dioxide per year together, their combined impact on our climate exceeds the impact of B.C.’s officially counted emissions.”

There are examples of other approaches that are more resilient and sustainable, such as the Slocan Integral Forestry Cooperative, which can be modified for other regions.  Forests with mixed species are the most resilient and resistant to climate change stress.

The Okanagan Timber Supply Analysis Discussion Paper recognizes many concerns, but fails in two main areas.  First, it does not explicitly identify climate change concerns, which at a minimum should be enumerated and addressed.  We expect to see changing species of both flora and fauna, increased fire risks, anticipated new pest risks, effects of forestry practices on snow retention and floods, the need to retain carbon sinks, and the emissions costs of forestry practices such as clear cutting and slash and burn; how might the timber available for harvest be truly sustainable under these changing conditions?

Secondly, the projections for timber harvest of different ages of trees all assume that all the older trees will be removed, leaving an ongoing steady state younger cohort of trees for harvest.  There is substantial research on the benefits of old growth trees and forests, summarized in the BC Old Growth Strategic Review, with many recommendations, including “The province should declare that managing for ecosystem health and minimizing biodiversity risk are key priorities of its provincial land management framework”.

I did not see that these recommendations were reflected in the discussion paper, but strongly urge they be incorporated.

There are a number of other reports raising alarms.  The Forest Practices Board issued a paper in 2020 concerning dry Douglas Fir forest regeneration, recommending improvements in current forestry practices to maintain a healthy forest.  The Forest and Range Evaluation Program (see FREP Extension Notes 38 and 41) has reported on the importance of small streams, indicating that many small streams have been left in poorly functioning condition from forestry practices.  Clearcutting practices have affected hydrology of the basin and damaged the water system in Peachland already, in addition to effects on fish and wildlife. The Okanagan Basin Water Board (OBWB) has sent a letter to the Province of BC, is calling for change, including a review of how it manages Okanagan lake levels, since the current management plan doesn’t accommodate for climate change.  Severe seasonal flooding has already become a problem for our valley, and forestry practices share some responsibility.

The Okanagan has lots of dry forest areas and many small streams, and any determination of AAC needs to take these reports into account.

Given these considerations, I urge the Ministry to:

1.        Manage forests for biodiversity and ecosystems health as the most important goal.

2.       Explicitly assess anticipated effects of climate change on projections of forest health and sustainability, and make adjustments NOW, as time is short.

3.       Review the role of forests in contributing to greenhouse gas emissions (such as clearcutting, burning, removing old trees), as well as preserving biodiversity and ecosystem health (Canadian forests are important carbon sinks), and plan for carbon neutrality at a minimum.

4.       Fully implement the recommendations of the Old Growth Strategic Review.

5.       Do not continue AAC calculations based on business as usual.  Reduce the AAC and preserve trees wherever possible.

6.       Do not allow clear cutting.

Our forests are a benefit to everyone, but old paradigms that allow companies to extract our resources for their own profit and then move on are dangerous and must change.  This Timber Supply Review will set out plans for the next decade, a decade like no other, as the Intergovernmental Panel on Climate Change warns us.  The time for change is now.


Khati Hendry, MD

Penticton BC