Quotes from some of the independent forest experts hired by the Province
to review the Weyerhaeuser 20 Year Management Plan
(With some notes by this author)Review by the Expert Panel of:The draft: Review of Twenty-Year Forest
Management Plan of Weyerhaeuser Canada LTD, Saskatchewan DivisionDr. Rod Carrow
Paul Griss
Chris Wedeles
Dr. Jeremy WilliamsExpert Panel Members:
Dr. J. P. (Hamish) KimminsProfessor of Forest Ecology, UBC
Dr. Jim Beck Professor of Forest Management University of Alberta
Dr. Peter Duinker Professor and Director School for Resource and Environmental Studies, Dalhousie University
Dr. Thom Erdle Professor of Forest Management, UNB September“ We have drawn attention to several aspects of the Management Plan and the Review of the Plan. In closing our report, we would like to emphasize several key issues:
Successful planning for sustainable, ecosystem-based management requires much better inventory data than are currently available. This is certainly true of the timber resource, but the need is even more urgent for several other resource values. The management of these values cannot begin until forest management planners have access to reliable information concerning what resources are present, in what quantity, and in what spatial and temporal patterns. (emphasis added)
(Comment: In other words, the plan is flawed from the start because it is built on an outdated, incomplete and innaccurate forest inventory data base. They are trying to tell us the impact of harvesting on the forest when they don't even know what is in the forest to be impacted.)
The improved inventories must be related to an ecological site classification. Different ecosystem types respond differently to management practices. Until one has recognized the spatial patterns of ecological diversity - the stage on which nature's forest theatrre is played out - one cannot begin to manage for the various measures of biological diversity the "actors" who participate in the "play" - and their productivity.” (Emphasis added)
(Comment: The Weyerhaeuser plan purports to be based on an ecosystem based management model, but the experts are telling us right off the top that the basis for ecosystem based management, an ecological site classification, is not integrated in the model.)
“Adaptive management - one of the cornerstones of sustainable forest management - has one key shortcoming: in slowly growing forests such as the Canadian boreal, the evidence of the results of management actions is slow to accumulate. Every opportunity must therefore be taken to learn retrospectively - to look at the results of past practices and past experimentation as well as to monitor the results of current practices and their alternatives. Retrospective investigations, monitoring of current practices, and the establishment of long-term field trials of alternative practices must be a required component of forest licenses in Saskatchewan.”
(Comment: the Adaptive Management model supposes that changes that can not be anticipated, or that have not been properly predicted, will be addressed as they become apparent as issues in forest management. The problem is as stated by the experts, that the problem may not become evident until considerable and even irreparable harm has occurred.)
“If the white spruce and aspen related types are combined as a group, and the black spruce and jack pine (including the jack pine - aspen type) types are combined as a second group, the first group makes up 28.9 % or the merchantable land area yet accounted for 63.2% of the area harvested over the last 10 years, while the second group represents 66.8% of the merchantable land area but accounted for only 35.6% of the area harvested over the last 10 years. (Table 4.2, page 52 of Plan).” (Emphasis added)
“This is most likely related to fulfilling the WCL's timber supply, economic and infrastructure needs over the last ten years from the first group as a priority over the second group. Clearly, if the allowable cut is to be both sustained and used in the future, this can not continue. The Company will have to start to use a much higher portion of jack pine and black spruce. This past emphasis on the white spruce - aspen complex is most likely the reason why WCL wants to favor white spruce in its regeneration efforts and late seral stage targets. ” (Emphasis added)
(Comment: as suspected at Doré/ Smoothstone, and elsewhere in the FMA, WCL has been over harvesting mature white spruce and aspen stands to meet its own industrial supply needs and bottom line financial requirements rather than the need to maintain a natural balance and sustainability in the forest.)
“[R4.14]
We support the importance of a representative area network and are therefore in agreement with this Recommendation.” (Emphasis added)(Comment: Weyerhaeuser has refused to deal with the question of Representative Areas Network (RAN) protected sites either by creating adequate wilderness reserves within the FMA, or by working with the province and environmental groups to find suitable lands. No new RAN sites have been designated within the area being approved for the FMA.)
“There is inadequate continuity between (a) the stated management objectives, (b) the forest management strategy defined in the wood supply analysis, and (c) the treatment schedule proposed for on-the-ground implementation. All three should clearly fit together to maximize the likelihood that the outcomes of implementation will attain all of the ecological, economic, and social objectives stated in the plan. As noted by the review team. there are many inconsistencies in the current plan. For example, (a) there is no indication of the degree to which the late and very late seral stage targets are met under the proposed harvest level and sequence; (b) the seral stage targets are not consistent with the age class structure associated with a 70 year fire cycle; (c) the harvest volume and allocation to stand typos differ considerably between what is proposed for implementation and what was derived in the wood supply analysis; (d) there is no indication that the species and products forecast to result from the wood supply strategy are consistent with existing or expected mill requirements; and (e) the proposed on-the-ground harvest strategy is not based on the treatment schedule derived from the wood supply analysis. Given these inconsistencies, there is no clear demonstration that what is proposed to be done on the ground will meet the objectives set for the forest and therefore, no logical grounds exist for accepting the plan.” (Emphasis added)
(Comment: In other words, this plan is seriously and fundamentally flawed and must not be approved.)
“The prominence of the 70-year fire cycle age class structure as a management objective is questionable for three reasons. First, it is a somewhat arbitrary cycle; an 80 or 65-year cycle could equally have been justified, for example. Second, attainment of the age structure target by year 200 does not avoid any undesirable structures which may occur in the intervening years. Third, unless some treatment is prescribed which harvests stands before they are operable, it will not be possible to achieve a structure with progressively less area in progressively older
age classes. Given these points, the 70-year fire cycle may not be optimum, or even particularly useful, as a management goal. (Emphasis added)(Comment: The fire cycle theory of boreal forest succession is commonly held as the model for long term management. What this says, is that it is a seriously flawed theory, at least as applied to the WCL plan.)
In both WCL's and the Review Team's timber supply simulations, growing stock varies over time and reaches a minimum between years 50 and 65 years in the future (see pages 117 and 122 of Report). The low points in growing stock will be the "pinch point" regarding biodiversity maintenance, since at these, points, the pressure will be greatest on mature and older age classes. This demonstrates the importance of our previous point, that being the need to explicitly consider forest structure over time, not simply at the start and end of the 200 year planning horizon.” (Emphasis added)
(Comment: this seems to indicate that the forest already harvested over the past 5 to 20 years (i.e. those trees that will be harvested at 70 years of age “between years 50 and 65 years in the future”), has not been adequately restocked or regenerated and will be in short supply leading to pressure on both wood supply and biodiversity.)
“The Review Team points out (pages 98 and 99) a possible error with respect to stand age versus tree age for plots used in development of yield curves...
When tree ages are used and their ages are measured accurately, the resulting yield curves are based on tree age which can be simply corrected to stand age by using an appropriate regeneration lag. However a problem exists if there are errors in aging the trees.
If the error is random, with a mean of zero deviation from the true tree age errors will not cancel, contrary to common belief. Since one is looking at volume as a function of age, the random errors in age produce a bias in the volume function curve, which causes a steeper rise in the volume/ha curve as a function of age. This leads to curves which over estimate rate of volume accumulation, which in turn leads to underestimates of the age of maximum mean annual increment.
If the error is not random, and instead is biased to estimate tree ages less than they should be for the true tree age of the stand, the problems above are made even worse. They cause an underestimate of the ages of maximum mean annual increment and minimum merchantable volumes.
These two errors in combination are likely to cause significant overestimates of sustainable harvest levels in most timber supply models. Without the original data, it is not possible for us to estimate the presence and extent of this problem in the Plan. However, it bears some serious consideration because it is a potential source of error which would overstate the sustainable wood supply.” (Emphasis added)
(Comment: The plan is overstating the amount of wood available for harvest. In fact, we have no assurance that they really know what those numbers are. Under such circumstances, sustainable management is unlikely to occur.)
“[R5.6] We agree that the full time horizon should be considered when evaluating wood supply levels. However, if significant step-up harvesting occurs in the medium and long term, as is suggested in Section 5.6 of the Review Team's report, use of an average harvest over the full time horizon will be misleading. It will underestimate the available harvest in the long-run and, more importantly, it will overestimate the available harvest in the short-run”. (Emphasis added)
(Comment: Combined with the previous comment, here is the coup de grace for the spurious arguments of sustainablilty (as required by the Forest Resource Management Act). As this states, there may be a serious overestimate of available harvest in the short term. Combine this with an overestimate of the wood available, and you have a recipe for an ecological disaster.)