Silviculture practice in B.C. is in decline while the area under assault from pests and pathogens exceeds 13 million hectares. Yet the Roundtable does not specifically include silviculture among its four key areas of concern.
The WSCA recommends that restoring forest health through sound silviculture practices must be a priority in considering ways to sustain our forest based rural economies and the forests themselves. The province needs healthy forests upon which to base any strategies pertaining to markets, stumpage and tenure. Meanwhile today’s policies and practices may actually be contributing to the decline in forest health particularly tenure and stumpage. The current tenure system does not provide incentives to manage beyond simplistic free growing goals and considers those efforts a cost to be minimized by the tenants who rent the resource but do not own it.
We are hampered because Silviculture activities are poorly tracked and impair our analytic and strategic capacity. Ideally we should move so Silviculture is seen as an investment that rewards investors for full rotation management. Tenure should be land-based and include stewardship tenures. Any reforms should allow for a diversity of participants, in particular communities and innovative entrepreneurs in the emerging bio-energy and carbon sequestration sectors.
The stumpage system and the silviculture appraisal allowance also discourage long-term investment by license holders actually penalizing exemplary forest companies who operate above the minimum legal requirements to reforest. Stumpage incentives should be awarded for silviculture practices beyond minimums and silviculture appraisal allowances should be paid once actual reforestation has taken place to ensure prompt, effective regeneration. Silviculture activities need to be linked to the pre-harvest conditions and the harvest regime to ensure site productivity is taken advantage of contributing to shorter rotations if practiced with full rotation stewardship.
The province needs a better market pricing system to ensure we are getting the best price for our fibre and can afford the necessary silviculture treatments. Under the current regime the Softwood Lumber Agreement may be an impediment to effectively managing our forest resource. Silviculture needs to be recognized as important as milling, harvesting and marketing. The province should appoint a silviculture boss and an advisory committee to report to the minister. The original purpose of the tenure and stumpage system was to preserve the health and abundance of the forest landscape. Any recommendations from the Roundtable need to reassert this principle.
The WSCA is very pleased to be invited to participate in the Premier’s Working Roundtable on Forestry (WRF) and we fully endorse this policy consultation process. We have also been encouraged by Minister Bell and others to respond to your invitation. The deliberations of the WRF are of strategic interest to our members. Given the current declining state and practice of silviculture in B.C. we believe the work of the Roundtable to be timely and pressing. It gives us a needed opportunity to express our concerns and our hopes.
The WSCA is not coming to the WRF at this point with a detailed prescriptive plan or implementation strategy. We believe that level of detail is the work of future committees and consultation. Our membership very much wants to be engaged more frequently and regularly in the development of forest policy. The WSCA comes to the WRF in the spirit of co-operative and constructive commentary.
The WSCA is an 80 member-strong organization that employs 13,000 regular and seasonal employees across B.C. providing silviculture services and products to the province’s forest industry. Our members are largely small businesses based in communities around B.C.. Our workforce is drawn from across Canada and we generate a half-billion dollars in direct business activity annually. Silviculture work is an important part of the B.C. rural economy. It is an extensive and intensive undertaking including tree planting, seedling growing, stand tending, wildfire fighting, site preparation, surveying and planning services. These activities put our boots on the ground over 200,000 hectares annually. This year we celebrated planting the province’s six billionth seedling, an effort that has reforested over six million hectares of B.C. over the last 30 years.
Although we have a strong business stake in forestry we hope this submission is not seen as just another version of vested interest. If we are a vested interest we are vested in small business, community and the long term stewardship of the province’s forests.
The WSCA agrees with the WRF that BC’s forest industry is capable of being the most competitive, successful, sustainable, and productive in the world. The WSCA recognizes that BC forestry has, and will continue to contribute many valuable benefits to BC in terms of lumber, bio-energy, value added, carbon sequestration, conservation, water values, habitat, and other ecosystem services and products that aren’t imagined today. The WSCA believes that silviculture is very much part of the forest industry and like the rest of the sector benefits from stability and certainty i.e., a stable fibre supply and land base. We believe that Silviculture is an investment that provides that stability and certainty. However, under the present management paradigm it is regarded as an expense – an expense that is often minimized and, as a result, puts our businesses and the future forest at risk.
The WSCA has always been concerned with the health of B.C.’s forests as a matter of diligence. It is healthy forests that provide the diversity, quality, and quantity of products that are needed for a sustainable forest industry and a sustainable rural economy. Naturally then, the WSCA is alarmed about what we see unfolding on the landscape today.
Forestry is a three-legged stool of harvesting, manufacturing, and silviculture. The WSCA has noticed that The Premier’s mandate to the WRF does not directly and explicitly concern itself with this third leg, our leg, silviculture. In our opinion this oversight speaks to the degree to which silviculture and the forest, past and present, are taken for granted. This is evident in the ongoing general failure to support a coordinated and strategic long term investment in the public forest and specifically the lack of an active silviculture response to the mountain pine beetle plague.
The WSCA is not an organization of futurists. We do not presume to predict what our children may want or make of our future forests. But we do know that without establishing healthy forests today we diminish opportunities for tomorrow. Silviculture is fundamental to the success of the future forest industry. However, in our opinion, the current tenure and stumpage systems are an impediment to good silviculture and the proper stewardship of B.C.’s forests.
WSCA Key Issues
The current tenure and stumpage systems emphasize and minimize silviculture as a cost following harvest. Silviculture should be viewed as an investment in future forest harvests within the tenure and stumpage systems. Those investments above the minimums should be rewarded. Conceptually this was the intent of Section 52 of the Forest Act. However the reality is this portion of the Act has been poorly utilized.
The current tenure system is analogous to a landlord and a renter agreement where there is very little incentive for the tenant to invest in the property owned by the landlord. Similarly the landlord is too busy paying the mortgage on health and education and other social imperatives to invest in the forest resource. The effect of this relationship has limited our ability to maintain the forests outside the free-growing period. As such it has allowed forest health to deteriorate, fire risk to increase, and habitat and other resource values to degrade over time.
Even management to free-growing has been eroded to the minimums permitted by legal requirement. This has not developed in the short term but has accrued over the decades of the forest industry development in various parts of the province. This is evident not just in the absence of a silviculture response to the MPB but also in the shifting species profile on the Coast, the lack of basic silviculture, the absence of incremental silviculture and the long term ecological and forest health effects of wildfire suppression. We now are managing with a tenure system that is working at cross purposes to its original intent. That contradiction now jeopardizes future forest health in B.C.
The tenure system needs to directly recognize site productivity. Recognition of site productivity is more than just reforestation. It comprises things like species selection and the entirety of crop tending activities through to the final harvest.
Any changes contemplated to the tenure system therefore must include the following key elements:
• provide incentives for investments outside the free-growing period;
• be an area-based tenure system that elevates accountability on a given parcel of land through the full rotation cycle;
• require a higher legal standard of management that emphasizes quality, maintains and maximizes site productivity and ensures abundance and diversity guided by an overarching stewardship framework for all forest ecosystem values;
• secure tenure and access to rotation age fibre predicated on a legal and regulatory framework that applies across the entire rotation;
• ensure diversity of tenure that could include bio-energy tenures, stewardship tenures and value-added tenures.
Linked to tenure and the success of any silviculture investments is market pricing of the fibre. Market pricing in British Columbia has been defined most recently by the market pricing system designed by the provincial government and implemented by BC Timber Sales. While this system has been implemented to counter the American trade lobby allegation of subsidy the number of tenure holders and the size of licenses appears to be limiting the development of a true market system. In other words there is still uncertainty that the highest and best price is being paid for BC fibre. Not receiving the highest price for the fibre potentially limits investments in silviculture and acts as a disincentive for good stewardship. The Softwood Lumber Agreement has often been used as an excuse by industry to limit response to the mountain pine beetle and other forest health imperatives.
The other fundamental issue with stumpage is that the cost of silviculture is accounted for as a harvesting cost not as an investment in the future forest. While this legally requires reforesting a stand following harvest it provides no incentive to manage the forest in the long term. In fact it can be seen as a deterrent to full-rotation stewardship. The present stumpage appraisal system makes us think backwards about silviculture rather than forwards.
Any changes to the stumpage system should:
• remove basic silviculture as a credit within the stumpage system;
• provide incentives within the stumpage system for any additionality above and beyond those stipulated by the basic legal and regulatory requirements.
Silviculture Appraisal Allowance:
Linked to the stumpage system is the silviculture appraisal allowance. This calculation works by averaging silviculture costs across licensees. In practice it provides no benefit for licensees who implement a higher standard of silviculture. In fact it penalizes exemplary players. This contradiction has the potential to even erode the minimum overall standard of practice.
Any changes to the silviculture appraisal allowance must:
• create accountability for the credit and the actual investment in the ground;
• ensure that silviculture allowances are directed to actual silviculture activities. The silviculture appraisal allowance is of specific interest to the WSCA as identified in instances where licensees have received the allowance and then become insolvent leaving contractors unpaid after completing silviculture work.
As we have repeated throughout this submission under the present management regime silviculture is considered a cost. Meanwhile, B.C. has aspired to be one of the leaders of forest stewardship in the world. However, the recent forest health crisis suggests that our standards are not where they need to be. It is the view of the WSCA that we must look at forests as an investment opportunity rather than a cost of doing business. This shift is essential if we are to live up to our expectations.
We have looked at policy and regulatory issues that have negatively impacted investments in silviculture throughout the province. The WSCA believes that to successfully address the forest health crisis and sustain a healthy forest into the future silviculture must rise in importance to the level of other elements in the forest sector: harvesting, milling, and marketing.
Silviculture must be directly and explicitly a part of reforming tenure, stumpage and appraisal. To achieve the highest standard of area-based forest management we must improve and refine the public record-keeping systems to account and credit for investments in silviculture. Prudent management of any investment portfolio requires a method of accurate and timely reporting on its elements.
Historically and continuing in the present the record keeping on Crown land has been inadequate in the timely tracking of our activities at a stand level and linking it to silviculture success or failures. We need to be able to link the pre-harvest stand conditions, the harvest, and post harvest regime in order to ensure that appropriate site values are achieved through silviculture practices.
Any reformation to silviculture practices in B.C. should include:
• establishing a silviculture “boss” to ensure that silviculture is directly involved and considered in reforming the forest sector and to report to the Minister on the current state of forest health and silviculture investment and activities across the province;
• establishing a special advisory committee on silviculture to the Minister of Forests and Range comprising the brightest and most creative minds in silviculture to report on a regular basis and recommend innovative changes to policy and regulation that guide silviculture practice in B.C. into the future;
• ensuring that the WSCA is recognized as a shareholder and peer in the development of forest policy and involved accordingly.
What is the vision for the forests of tomorrow?
With at least 12 million hectares currently under assault from the mountain pine beetle and another million hectares attacked by other pests and pathogens it is time for our leaders to lay out a vision and a strategy built on a clear idea of what we want the future forest to look like. In the past when leaders realized the resource was not infinite and needed to be managed they, in their wisdom, created policy tools such as tenure and stumpage. The purpose of those tools was to preserve the health of the forest landscape and through that ensure the well being of society. Today in the midst of this crisis we need to review these policies to see if they are accomplishing the goals for which they were originally intended.
In recommending changes to the stumpage and tenure systems the Working Roundtable on Forestry should:
• reassert the original purpose of the stumpage and tenure system to preserve and maintain the forest resource in perpetuity for the greater good;
• urge government to define a clear vision and lay out a strategic plan that will shape the forests of the future and act as a goal to which we can define our priorities and measure our success;
• ensure changes lead to coordinating silviculture activities to achieve desired outcomes and effects on a landscape scale composition;
• put the forest back in forestry policy.