The only Conservation Assessment we have found for DL33 was carried out by Madrone Environment Services Ltd. in 2006 for the Ministry of Forests (download 27 pages in pdf format). Originating in a Forest Practices Board recommendation in 2005, the Ministry began an inventory of the CDFmm ecosystem. The Madrone Report evaluated two parcels of crown land, DL33 and DL117, for Douglas-fir/dull Oregon-grape Ecological Community and rated DL33 as a “Good” for Condition. We have been advised that “good” is the best in existence.
DL33 was described as:
- mostly mature forest with numerous older Douglas-fir trees and scattered vets
- previous logging mostly selective
- few non-native species (some holly)
- structural stage from 5 to 7, with a relatively large concentration of older Douglas-fir trees (structural stage 7)
- generally well-developed vertical structure
We have been advised by other biologists that this makes DL33 the best candidate for conservation. The Forest Practices Board in its report dated August 2005, states “The best sites in the second growth forests on southeast Vancouver Island are those with veteran trees and predominantly natural regeneration, particularly where the sites were only lightly disturbed by the original harvesting activities.” This description fits DL33 perfectly.(download Report - 20 pages in pdf format).
The Environmental Stewardship Division of the Ministry of the Environment, in its description of the Douglas-fir/dull Oregon-grape plant community as a “Species at Risk”, states:
“The Douglas-fir/dull Oregon-grape plant community is on the provincial Red List in British Columbia.”
and under “Trends: Almost gone. Less than 1% (possibly less than 0.5%) of the entire CDF zone remains in mature or old forest condition in British Columbia.”
and our government thinks it's quite OK to log this precious forest.
There is a document prepared by the professional biologists and foresters associations as guidance for resource professionals in dealing with Species at Risk (download Report - 22 pages in pdf format) wherein an RPF is to ask for guidance from a qualified biologist if not sure how to proceed. This was done in the case of DL33, however the advice that this cutblock was being laid out in red-listed plant communities (two are globally critically imperilled and one is globally imperilled and listed as Identified Wildlife) and in her professional opinion the stands within this licence should not be harvested, is being ignored.
DL33 has four CDFmm site associations:
The first zone (Series 01) is the Douglas-fir/dull Oregon-grape which is comprised of salal, dull Oregon-grape, red huckleberry, baldhip rose, trailing blackberry and western trumpet honeysuckle. It is dominated by Douglas-fir with a component of grand fir and western redcedar. This Series 01 is one of only two plant communities in the CDFmm recognized by the Minister of the Environment as a Species at Risk under the Forest & Range Practices Act, and is ranked G2 - globally imperiled.
The second zone (Series 02) is Douglas-fir/Shore Pine/Arbutus, where ocean-spray, Alaska oniongrass, broad-leaved starflower and white fawn lily grow. The stands are dominated by Douglas-fir and arbutus.
The third zone (Series 04) Grand fir/dull Oregon-grape is comprised of salal, dull Oregon-grape and red huckleberry. The trees in this zone are grand fir, Douglas-fir and western redcedar. Series 04 is ranked G1 - globally critically imperiled.
Lastly, the fourth zone (Series 06) Redcedar/Grand fir/Foamflower contains vanilla-leaf, three-leaved foamflower and western trillium, and swordfern. Here the combination of trees include Douglas-fir, grand fir, western redcedar, bigleaf maple and western flowering dogwood. Series 06 is ranked G1 - globally critically imperiled.
DL33 is clearly a combination of each of these zones by virtue of containing all of the species listed in the correct form of domination.
The wildlife which co-exists in CDFmm zones is plentiful and the following have all been documented on DL33:
Black-tailed Deer, Roosevelt Elk, Black Bear, Cougar, Marten, Mink, Red Squirrel, Deer Mouse, Wandering Shrew, Great Horned Owl, Saw-whet Owl, Barred Owl, Bald Eagle, Coopers' Hawk, Turkey Vulture, Blue Grouse, Canada Goose, Trumpeter Swan, Mallard, Pileated Woodpecker, Williamson's Sapsucker, Steller's Jay, Common Raven, Northwestern Crow, Northern Flicker, Varied Thrush, Dark-eyed Junco, Brown Creeper, Chestnut-backed Chickadee, Rufous-sided Towhee, Fox Sparrow, Rufous Hummingbird, Western Flycatcher, Brown Creeper, Brown Bat, Pacific Treefrog, Western Toad, Red-legged Frog, Western Garter Snake, Northern Alligator Lizard, Rough-skinned Newt, numerous species of Dragonflies and many more species of birds.
In addition, we have been told one area is Marbled Murrelet habitat, and there is also Northern Goshawk habitat, both of which are red-listed species. Extensive bird surveys would be required in order to confirm the presence of either species. There are also two blue-listed species that we are aware of: the red-legged frog (Rana aurora) and the western toad (Bufo boreas).
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In early January we discovered that there was a Proposed Land Use Objective which aimed to provide “enhanced stewardship for red-listed plant communities in the Coastal Douglas-fir moist maritime biogeoclimatic subzone.” This effort originated in a Forest Practices Board recommendation in 2007 “That government promptly finalize and implement an overall stewardship strategy for the CDF ecosystem and communicate its strategy to the public.” (download Report - 17 pages in pdf format)
Government then decided 1600 hectares was sufficient although this has nothing to do with conservation objectives but rather is a bureaucratic figure which approximates 1% of the entire CDF landbase. It will still leave the ecosystem at high risk of extinction and is therefore merely a PR exercise rather than the conservation strategy the Forest Practices Board envisioned.
The public review period for the LUO which proposed to protect this 1600ha of CDF forest in 5 polygons began December 2, 2009 and ended February 15, 2010. We were surprised that DL33 was not included and were advised that it wasn't really CDF but rather CWH (this in spite of the 2006 Madrone report assessing it as mature CDF forest in “good condition”). The Ministry of Forests research ecologist and the ILMB planner involved in the Land Use Objective threw up a smoke screen around the ecosystem classification, and managed to suggest DL33 somehow was inferior and not deserving of protection.
The Committee determining the criteria for protection decided size was the overriding requirement and even if DL33 was “worthy” it wasn't large enough. This in spite of numerous scientific reports which stated the very rare mature CDF forests (less than 0.5 percent of the entire CDF ecosystem remains), such as DL33, are needed for conservation. Rachel Holt, who prepared a Conservation Planning report for the ILMB in 2007 (download Report - 36 pages in pdf format) states:
“Typically, maximising immediate benefit is the best strategy, to maintain condition as high as possible in the short-term....Few options for capturing high condition old growth remain...An alternative approach to considering 'condition' is to include all the other factors...and identify some measure of the 'probability of persistence'....These include size of the patch....”(p.26 & 27)
She goes on to say that “The literature suggests that all other things being equal, larger sized patches are more effective for conservation in the long-term than are small patches.” BUT all other things aren't equal. DL33 is one of the few remaining mature old growth forests with the highest conservation value found, while the larger, chosen polygons have a lower conservation value. We suspect it was more important to ensure the most valuable remaining CDF is available for harvest.
The LUO committee also ignored repeated professional opinions that the entire remaining CDFmm on Crown Land needs to be protected in order to preserve the biodiversity of this ecosystem, and measures to encourage conservation on public land are needed as well. In other words, they knowingly decided to go for the high risk option in deciding 1600 hectares was sufficient.
July Update - After being repeatedly told by the Ministry of Forests that DL33 failed to meet the primary criterion of size and thus did not qualify for protection, we learned that 2 of the 5 chosen polygons are in fact SMALLER than DL33. Considerably smaller. Hurtado is 40ha and Nanoose is 29ha, while DL33 is 64ha. To date we have had no explanation for this.
In a report dated July 22, 2009 the Chief Forester advises on page 43 (download Report - 57 pages in pdf format) of a commitment that no new licences to harvest CDFmm would be issued:
“In 2007, BCTS committed to refrain from harvesting in the CDFmm until a provincial management strategy has been developed. The SIFD has also agreed not to award any additional tenures in the CDFmm, most of which have been Woodlot Licences in the past.”
and again:
“Provincial government agencies recognize the importance of protecting and conserving the CDFmm biogeoclimatic zone and are in the process of establishing legally-binding provisions for the management of these endangered forests. In the absence of legal provisions, BCTS and MFR staff are managing conservation of the CDFmm at an operational level by not harvesting and not issuing any new licences that would permit harvesting.”
FURTHER, the Background Information attached to the BC Timber Sales Forest Stewardship Plan (which approved DL33 for harvest), dated April 2007, states:
“Note: Although there are areas identified in Forest Development Units within the CDFmm biogeoclimatic zone, there BC Timber Sales does not plan to pursue harvest opportunities in this area until such time as government provides further direction on activities.”
In spite of these commitments, a five-year NonReplaceable Forest Licence to harvest DL33 was issued to the Nanoose First Nations on November 6, 2009.
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The Ministry of Forests and Range did not following the commitment that CDFmm not be harvested nor would any additional licences be issued, until a legally-binding conservation strategy was in place, and
The Proposed Land Use Objective which invited public comment, commencing December 2, 2009 and ending on February 15, 2010 was a sham, not a public process. The fact that the licence to harvest DL33 was given in November 2009 suggests the Ministry lifted the moratorium before the establishment of legally-binding provisions, and even before the public review process began because the parcels of land had already been chosen and it really didn't matter what the public had to say.
The Forest Practices Board report issued on June 17, 2010 confirmed the foregoing. The government broke its commitment not to harvest or issue new harvest licences in the CDF, the government was not required to enter into public consultation, nor did they, and the LUO leaves the CDF at high risk of extinction (download Report - 9 pages in pdf format). The FPB offered more information in a Backgrounder (download Backgrounder - 2 pages in pdf format) and a Press Release (download Press Release - 1 page in pdf format).
Land Use Order Update: On July 30th MOFR issued a Press Release announcing the new Land Use Order, increasing protection of the CDF from 5% to 6%. There was no mention of DL33 at all and of course it was not included. The wood is obviously much too valuable to be preserved for conservation purposes. We know there were many letters, including those from the RDN and the AVICC (representing 51 municipalities on Vancouver Island and the Sechelt) in support of preserving DL33 and other remaining CDF forests on Crown land.
Other than taking a small piece of the Linley Valley polygon out for First Nations reasons, and two small pieces of the Bowser polygon for seniors' housing, the LUO as passed was exactly that submitted for public review. i.e. it didn't matter at all what the public had to say (and Minister Bell says there were 1000 letters submitted, not to mention the motions by local governments) about the chosen polygons or the process. The government did exactly what they intended to do. And THIS IS A RECIPE FOR EXTINCTION, not a conservation strategy. Not one accredited biologist will support logging DL33 or say the 6% will reverse the trend to extinction.
It is a valid question why scarce taxpayer dollars should be spent on such a sham. Almost 3 months of receiving public input, and another 5 months of “studying” this input, to end up where they started. Incredible!
We who know and love this special forest are still asking our government and our politicians to save this forest. The LUO door has closed and the cut permit has been approved, but it is still not too late to stop the chainsaws.
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