This Government of British Columbia document was obtained by the Sierra Legal Defense Fund through a Freedom of Information request.|
GREENPEACE REPORT: BROKEN PROMISES
ANALYSIS—MINISTRY OF ENVIRONMENT, LANDS AND PARKS
April 23, 1997
STREAMS AND RIPARIAN AREAS
The Greenpeace report states that 83% of streams in 1996 cutblocks were clearcut right to their banks, leaving no riparian zone.
For fish streams less than 1.5m in width, and for non-fish bearing streams, where there is the ability to maintain habitat, stream structure and integrity, the Forest Practices Code permits this practice. In other words, under the Code, this practice is not illegal.
Government’s regional review of the Sierra Legal Defence Fund’s document, Stream Protection Under the Code: The Destruction Continues, found that 30% of streams field-checked by government staff were not classified correctly. Nine streams (14%) were not identified at all. MELP is continuing to investigate.
Misclassification and non-identification of streams reflects a lack of understanding and training. Additional training may be needed to clarify what the Code does and does not do.
The Greenpeace report states that 82% of streams checked in the field were felled and yarded across, rather than away.
MELP and MOF staff, in a recent government audit of stream practices, indicated the need for a specific pre-logging assessment of non-fish bearing streams. Currently, the discretion left to company engineering staff to fall and yard away where possible is problematic.
The Greenpeace report refers to problems caused by logging on steep slopes, resulting in landslide debris clogging streams.
Historically, this has been a major problem in British Columbia. The Forest Practices Code proposes to address this where new harvesting is proposed by having these sites reviewed prior to harvesting by a professional geoscientist to ensure harvesting activity is appropriate. The province’s Watershed Restoration Program is intended to mitigate past damage.
Greenpeace notes that Forest Practices Code mechanisms intended to protect biodiversity have not been implemented, since there are no landscape units, old growth management areas, or sensitive areas. Greenpeace correctly notes that current government policy supports low biodiversity emphasis option as the provincial default until landscape unit planning establishes the range of high, intermediate and low emphasis options. Under low emphasis, the Biodiversity Guidebook indicates, “The pattern of natural biodiversity will be significantly altered and the risk of some native species being unable to survive in the area will be relatively high.”
MELP regards landscape units as critical to long-term conservation, since they address cumulative impacts of harvesting. Landscape units are also essential to implementation of the Code’s landscape-level biodiversity provisions.
Progress has been made to establish landscape units and objectives:
1) The landscape unit chapter (chapter 5) of the Higher Level Plans: Policy and Procedures document, has been revised to provide specific, legally binding Chief Forester direction on establishing landscape units, assigning biodiversity emphasis options and completing regional landscape unit planning strategies across the province by October 31, 1997. Regional technical staff of MELP and MOF are currently working cooperatively to meet the October deadline.
2) Recent government staffing and budget cuts will increase the time needed to complete landscape unit plans and objectives across the province. Until landscape units and landscape unit objectives are in place, low biodiversity emphasis remains as the default, and biodiversity conservation is in jeopardy in British Columbia.
Old growth management areas are a product of landscape unit planning. Until landscape unit objectives are approved and in place, no old growth management areas will be designated.
To avoid proliferation of too many types of planning areas, current legal and Chief Forester direction is that landscape unit objectives should be used to the extent possible, and that (small) sensitive areas should only be used where no other designation can apply. MOF and MELP are launching a small sensitive areas pilot project to investigate the best application of the sensitive areas designation.
While no landscape-level biodiversity provisions of the Code have yet been implemented, stand-level biodiversity is being managed through retention of wildlife tree patches and modifications to the riparian management zone. More people are being trained through a number of Code-related stand level courses (biodiversity, riparian, windthrow, wildlife danger tree assessment). The landscape level biodiversity course is now being offered. Improved understanding and training of government staff and others will improve biodiversity management and conservation.
Greenpeace states that MELP has claimed that the ministry has taken steps to protect biodiversity that are “second to none” in the world.
MELP’s report, Initiatives for the Conservation of Biodiversity in British Columbia (1996), describes all the government land use planning and resource management initiatives, e.g., the Forest Practices Code, Protected Areas Strategy, etc., that collectively will help conserve biodiversity in the province. The province has thus laid out the framework for protection of biodiversity; work to implement provisions of these initiatives is ongoing.
Greenpeace expresses extreme concern over the continuing widespread use of clearcuts as the predominant silvicultural system. Greenpeace also states that cutblocks in excess of 100 hectares are common, and that exceeding the 40-60 hectare limit for clearcuts is an outright violation of the Forest Practices Code.
This comment that exceeding the 40-60 hectare limit for clearcuts implies that the law is being broken; this is not true. Section 21(3)(b) of the Operational Planning Regulation provides flexibility to manage landscape level biodiversity. This section states that a district manager may approve cutblocks larger than 40 or 60 hectares if the DM is of the opinion that the cutblock design is consistent with the structural characteristics and the temporal and spatial distribution of natural openings. At this time, there are no audits to check if the reasons for exceeding the 40/60 hectare maximum cutblock sizes match the intent of the legislation, including retention of wildlife tree patches (stand structure).
Good forestry practices cannot be equated to a specific cutblock size. Biodiversity is more closely linked to retention of stand structure within cutblocks. Good management to maintain biodiversity and forest ecosystem function and health would dictate that a variety of cutblock sizes and shapes be used to emulate patterns of natural disturbance, as specified in the Biodiversity Guidebook.
ENDANGERED SPECIES AND WILDLIFE
Greenpeace notes that Forest Practices Code mechanisms intended to protect endangered species and critical wildlife species have not been implemented, i.e., there are no identified wildlife species and no wildlife habitat areas.
The Forest Practices Code Managing Identified Wildlife Strategy documents are expected to be approved and signed off by the Chief Forester and Deputy Minister, MELP, within the next month. This will mean that the first group of “identified wildlife species” will be designated. Once this has been done, wildlife habitat areas may be established which will lead toward protection of critical habitats for these 41 species. Forest practices and levels of protection for these and future identified wildlife species are all constrained by a 1% cap on impact on timber supply, previously set by Cabinet.
Greenpeace also regards as inadequate provisions for protection and management of several important wildlife species, including grizzly bear and mountain caribou.
Grizzly bears currently have a provincial management strategy and are included in Volume I of the Managing Identified Wildlife Strategy. However, the 1% impact cap on identified wildlife means that additional protection, through strategic land use plans and higher level plans, will be required for this and other wide-ranging species, such as mountain caribou.
Currently, mountain caribou are not protected in British Columbia through a provincial management strategy or inclusion in Volume I of the Managing Identified Wildlife Strategy. Caribou are being considered for inclusion in a future Volume 2, but may be excluded owing to the 1% timber impact cap. Mountain caribou are also not adequately dealt with in many current strategic land use plans, e.g., Cariboo/Chilcotin Land Use Plan or other similar plans. It should be noted that the Kamloops LRMP did designate Resource Management Zones with priority management for mountain caribou.
The Greenpeace report states that the government of B.C. refuses to pass endangered species legislation.The province has chosen to protect endangered species and their habitat through other mechanisms, e.g., the Protected Areas Strategy and the Forest Practices Code (landscape units, identified wildlife). It should be noted that these mechanisms do not apply to private lands or other non-provincial forest lands. Several important threatened and endangered species occur on lands on eastern Vancouver Island and in the Okanagan, and are threatened by urbanization and agriculture. Some other legislative mechanism would be needed to extend protection beyond areas covered by the Code and Protected Areas.
RATE OF CUT
Greenpeace state that the unsustainable rate of cut is the single biggest ecological forestry problem we have, and that accessible old growth is targeted for harvesting and will be liquidated before sufficient second growth forest becomes available for logging.
The Forest Practices Code Timber Impact Analysis acknowledged a 6% reduction in timber supply as a result of implementing measures to protect biodiversity, riparian and wildlife resources.
Ministry of Environment, Lands and Parks staff are becoming more involved in Timber Supply Review. MELP will be working to contribute information related to environmental risks, to more accurately quantify risks associated with rate of cut. Retention of old growth is increasingly becoming less of an option, and government is now having to consider rebuilding old growth over three rotations while still continuing to harvest old growth as a priority.
As logging in the province shifts from old growth to second growth, the rate of harvest will decline. This decline, termed “fall-down,” is well known to every forester and biologist in the province. The impacts of fall-down will exceed the impacts of the Forest Practices Code (6%) and forest withdrawals under the Protected Areas Strategy. Fall-down is the result of intentional overharvesting of British Columbia’s old growth to capture maximum economic benefit from high-volume old growth trees. Risk to environment is related to the rate of harvest decline to long-term harvest levels. The role of fall-down is not being adequately discussed or acknowledged outside of Timber Supply Review.
PROTECTED AREAS (PAS)
Greenpeace notes that the original primary (conservation) goal for establishment of protected areas, i.e., ecosystem representation, has not been met in protected areas established to date, and that 61.2% of new protected areas have been established in subalpine or alpine areas (“rock and ice”).
Greenpeace’s analysis is based on protected areas approved to date. This points to a weakness in application of the conservation goals. Protected areas are still being established in some areas of the province, and this trend could be adjusted in ongoing and future Land and Resource Management Plans (LRMPs).
In discussion of industry complaints that the Forest Practices Code has greatly increased their costs, Greenpeace notes that costs related to habitat destruction and ministry manpower to deal with environmental problems are difficult to quantify and incorporate into the equation.
The Ministry of Environment, Lands and Parks is constantly faced with this valuation problem on non-market goods and services. MELP continues to seek ways to incorporate ecosystem products and services into economic debate.
Greenpeace expresses great concern about the amount of discretion given to Ministry of Forests District Managers, particularly that this discretion allows the District Manager to disregard Code provisions for riparian and biodiversity. Greenpeace prefers to replace discretion with fixed, measurable standards in legislation.
The discretion afforded the decision-maker (usually the District Manager) allows management practices to be adapted to match the complexity and variation of ecosystems across the province. The decision-makers must be fully accountable for their decisions and exercise of professional judgment, otherwise the potential for misuse of the power and mismanagement of the resource could remain unchecked.
The complexity of resource decisions dictates that more than Professional Foresters need to be accountable for management decisions. An example would be that Professional Biologists also be held accountable for decisions related to biodiversity, fisheries and wildlife in operational plans.
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