WEYERHAEUSER ENVIRONMENTAL IMPACT ASSESSMENT

In October 2000, CPAWS Saskatchewan's commented on Weyerhaeuser's 20-Year Forest Management Plan and Environmental Impact Assessment. Below is the submitted document.

Weyerhaeuser Forest Management Plan:

A Submission to SERM's Public Review Process for the Review of Weyerhaeuser's 20-Year Forest Management Plan Environmental Impact Assessement.

By: the Canadian Parks and Wilderness Society - Saskatchewan Chapter

October 2000

Content:

Introduction

CPAWS review comments

1. Ecosystem-based management

2. Public review process

3. Conclusions

4. Recommendations

5. Addendum - suggestions for harvesting in riparian areas

Introduction

The Canadian Parks and Wilderness Society (CPAWS), Saskatchewan Chapter, is an organization with membership across the province, committed to protection of natural wilderness areas and to sustaining biodiversity in Saskatchewan.

To maintain natural forest ecosystems, management must focus on preserving the complex, natural system of trees plants, and natural processes. A key component of this preservation involves setting aside natural areas that are off-limits to industrial activity. Protected areas must adequately represent natural areas within the FMA, and they must be large enough and to allow natural processes to continue. Outside of protected areas, forestry activities must take place when, and only when, there is reasonable assurance that harvesting practices are being conducted in a manner that will maintain the full compliment of native species of plants and animals.

Ecosystem-based management (EBM) represents the current state-of-the-art in forest management. It developed in response to changing societal values and accumulated scientific knowledge. There is an explicit recognition that forests are valued not only for their economic potential, but also for the biodiversity they contain, the ecological services they supply (e.g., clean air and water), and the recreational, cultural, and spiritual opportunities they provide.

The fundamental principle of EBM is that the integrity of the forest ecosystem as a whole must be maintained if the forest is to provide us with the wide array of benefits that we now desire from it, along with the flexibility to meet different needs in the future. There is also an explicit recognition that the forest has a finite ability to meet the demands placed on it.

A significant body of scientific literature now exists that defines the essential elements of EBM and the requirements for implementation. Much of this literature deals with the emulation of natural disturbances and the process of adaptive management. This body of scientific literature provides an appropriate guide for assessing the 20-year forest management plan (FMP) of Weyerhaeuser Canada Saskatchewan Timberlands (WCST).

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CPAWS Review Comments

In light of industrial forestry activity in Saskatchewan, it is recognized that long-term planning for our forest ecosystems is necessary and a responsible action towards keeping our forests healthy. It is also recognized that Weyerhaeuser's proposal to move towards EBM is a significant shift from outdated methods of forest management. It is profoundly unfortunate however, that the driving force behind Weyerhaeuser's Plan is a dramatic increase in harvest pressure.This increase in harvest pressure and the plan to implement it, threaten to destroy the forest ecosystems as we currently know them.

1. Ecosystem-based management

One need not delve into technical detail to determine that there are fundamental problems with the WCST implementation of EBM. Whereas EBM is designed to strike a balance between the need for timber harvest and requirements for maintaining biodiversity and ecological processes, in this case it is being used to justify an increase of over 2.5 times the previous rate of harvest.Ê The specific deficiencies of the FMP, arising from this excessive rate of harvest, are detailed below.

1.1. Liquidation of old-growth
There is a clear consensus in the scientific literature that structural diversity in boreal forests is greatest in old-growth stands.This structural diversity is associated with the highest levels of plant and animal diversity, relative to young and mature age classes. Consequently, the maintenance of old growth stands is a fundamental prerequisite to maintaining forest biodiversity.

EBM uses the emulation of natural disturbances as a guide to determining the appropriate quantity of old-growth required to ensure the viability of all native species. In both Saskatchewan and Alberta the rate of fire since accurate records have been kept has been approximately 0.5 % per year (fire return interval = 200 years). The claim by WCST that the "natural" rate of fire in their forest management area is over 5 times greater than the recorded rate is without merit. It is based on a single study from a single site (Prince Albert National Park), and can hardly be considered representative of the long-term natural rate. More likely, these findings reflect the local impact of some large fires that occurred by chance within the park around the turn of the century. Furthermore, the study suffers from significant methodological deficiencies that make the results suspect (in particular, it is assumed that no stands are older than the oldest living trees). The argument that the low rate of fire observed since 1950 is due to the impact of fire suppression is also without merit. Even in Alberta, where fire suppression efforts have been much greater than in Saskatchewan, there is little evidence that suppression has been effective in controlling large fires that occur during so-called fire years (and which are responsible for the majority of the area burned).

One is forced to conclude that WCST's decision to use a fire return interval of 70 years primarily reflects timber supply considerations and not the emulation of natural disturbance patterns.

There is an additional problem with the FMP in that the old-growth targets defined in the Plan are not consistent with the 70-year fire return interval that was chosen. Assuming a negative exponential distribution and random fire ignitions, 24% of the forest should be over 100 years of age given a fire return interval of 70 years. However, WCST intends to maintain only 1-6% of stands greater than 100 years (12% for white spruce). As a consequence of these targets, and the high rate of harvest, the average age of stands is predicted to decline from about 120 years to about 65 years during the first 70 years of harvest.Ê Such a conversion is clearly inconsistent with the intent of EBM and in reality represents an unsustainable approach to forest management premised on the liquidation of old-growth.

1.2. White spruce
As noted in the FMP, the current amount of mature white spruce within the forest management area is probably disproportionately lower than before commercial logging began, as a consequence of the selective logging of this species. It is also noted that late and very late aspen/white spruce mixedwood forests possess the most diverse wildlife communities in the forest management area. Consequently, biodiversity concerns dictate that special management of white spruce stands is required. Special management should include strict limits on the harvesting of existing old-growth white spruce stands, and replacement of clear-cut harvesting and plantation management with silvicultural practices designed to enhance the recruitment of white spruce (i.e., mixedwood management techniques as described by Lieffers and others).Ê WCST's current plan to liquidate all but 12% of white spruce greater than 90 years of age is completely inconsistent with an approach based on EBM principles.

1.3. Harvesting in riparian areas
Riparian areas are unique in structure and composition, have high species richness, and play important ecological roles (e.g., as movement corridors). Because there is a lower fire risk associated with these areas they form important repositories of old-growth forest (especially for white spruce stands, which have very prolonged successional trajectories). Furthermore, as detailed in the FMP, riparian areas are very sensitive to harvesting practices. However, in spite of all these factors, and the fact that harvesting in riparian areas has traditionally never been permitted and is contrary to Weyerhaeuser Canada's corporate policy, WCST intends to initiate harvesting in riparian areas with this FMP. This again reflects a focus on maximizing timber volume, as opposed to maintaining ecological integrity.

1.4. Stand structure
Generally, stand-replacing fires kill most trees but do not consume them. The standing dead trees provide structural diversity to the stand for many decades, which is important to many species. Harvesting under EBM seeks to emulate this legacy by leaving a proportion of the trees on a harvest block as residual structure. The intent of WCST to leave only 3% of the trees on a site for this purpose is substantially less than what is required to have a meaningful impact.

1.5. Calculation of sustainable harvest rates
In addition to the aforementioned failures to adequately account for timber supply reductions associated with the implementation of EBM, there is also a concern that the rate of harvest will not be sustainable from the perspective of timber supply. First, given current average fire losses of 0.5% per year, the assumption that only 13.8% of harvestable stands will be lost over the next 200 years appears to be a gross underestimate. This is particularly so if the rate of fire increases due to global warming. Second, the assumption that managed stands will grow faster than fire-origin stands is without basis. If anything, the slow-growing forests of Saskatchewan are notable for regeneration failure (particularly conifer stands). Furthermore, given the proposed high rate of harvest, factors such as nutrient depletion are bound to have an important impact in the future.

1.6. Ecological benchmarks / protected areas
The existence of an ecological benchmark, in which natural processes such as fire are maintained, is essential for monitoring the impact of industrial activities on the managed land base. Simulation studies of the fire regime in Alberta have determined that protected areas in the western boreal forest should be at least 5,000 km2 (5,000,000 ha) in size if they are expected to maintain a natural fire regime. Prince Albert National Park is ideally suited to serve as a benchmark for the WCST forest management area; however, it would need to be enlarged from its current 3,800 km2, and a buffer zone would need to be implemented.

Proposed harvest levels in WCST's plan severely impact the size and number of protected areas in Weyerhaeuser's lease area. CPAWS and others have been told that 40,000 ha is the ceiling for new protected lands in the FMA. This 40,000 ha limit has nothing to do with EBM, but rather, it has to do with satisfying the increased harvest levels in the FMA. This proposed management policy for Weyerhaeuser's FMA is inconsistent with EBM.

The need for additional protected areas within the WCST forest management area will likely be required as part of a caribou management strategy. Furthermore, ecologically important and representative areas within the FMA, as identified in 1998 by World Wildlife Fund (WWF) through their conservation values analysis, require protection as well. The new Wapawekka protected area, although outside of Weyerhaeuser's FMA, is an excellent choice for protection in the region.Ê SERM has been negotiating for other new protected areas in the FMA for at least 5 years in the Dore / Smoothstone region. Proposed sites at Selenite Point, Budd lake and Caribou Flats, although small, are good beginnings, but WCST does not acknowledged these or any new protected areas.

Conservation biology teaches that core protected areas must be linked with one another if they are to remain healthy and maintain the natural flow of wildlife movements and processes. Core protected areas also require carefully managed buffer zones around them to protect the ecological integrity of the cores.Ê Without buffer zones and linked cores, a flawed system of protected areas is created that seriously risks losing ecosystem integrity through loss of wildlife species. A management plan claiming EBM must address these conservation issues. WCST's plan and the provincial RAN program fail to do this.

1.7. Woodland caribou
As noted in the FMP, woodland caribou is the species that is probably in the greatest danger of serious population decline. The combined effects of habitat change and road impacts are of special concern for the scattered small bands of woodland caribou that remain within the forest management area. The failure to define an appropriate caribou strategy in the FMP, beyond road hunting closures, is a serious deficiency of the Plan.

1.8. Retention of natural burned areas
The burned dead trees that remain after a fire represent important habitat for a number of species, such as the black-backed woodpecker. The FMP fails to provide for the habitat needs of these species, as the salvage protocol does not ensure that some dead trees are left in place.

1.9. Safety reserves
Proposed harvest levels in the FMP virtually eliminate any safety cushion for ecological impacts from significant events like big fires, poor forest regeneration and global warming -- all of which are quite likely to occur at some future date. A management plan claiming EBM must consider and plan for such events. This necessarily calls for a reduction in proposed harvest levels.

1.10. Ecosystem-based modeling vs. wood supply modeling
To fully implement EBM, spatial patterns of stand distribution (type, age, size) need to be considered when harvest blocks are selected. The reliance of WCST on an aspatial wood supply model (FORMAN) represents a deficiency in this regard.

1.11. Investigation into cumulative ecological impacts from all FMA's in the southern boreal forest
Weyerhaeuser's activities, when combined with other harvesting activities in the southern boreal (i.e. cumulative impacts from Weyerhaeuser, Mistik, Pasquia-Porcupine, etc), are likely to impact overall forest health. It may not be WCST's responsibility to determine what these cumulative impacts are, but the Weyerhaeuser plan must recognize that what happens in the Weyerhaeuser lease area, impacts the forest as a whole. Government should be considering this, if they wish to maintain a well-managed healthy forest in Saskatchewan. The Weyerhaeuser FMP plan must have flexibility to respond to these concerns.

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2. Public Review Process

CPAWS severely criticizes the public review process for the 20-year forest management plan and EIA. Major decisions for three million hectares have been made without meaningful and comprehensive public input. Furthermore, the process to educate and invite comment from the public on the 20-year plan is flawed because it has failed to reach the public and give full disclosure of what the plan proposes. Deficiencies in the public review process are listed below.

2.1. Land use planning
The Forest Resources Management Act states that the Minister shall ensure that an integrated forest land use plan is prepared for every management unit for the purpose of coordinating policies, programs and activities to guide and regulate existing and potential uses of land within that management unit. It is presumed that the intent of this section is to ensure that there is thoughtful planning for a management area, supported by Saskatchewan people who have had opportunity to look at all of the different land use issues and concerns for that area. There is no integrated forest land use plan (IFLUP) for Weyerhaeuser's forest management area. People have not had opportunity to look at the collage of land use issues that affect them and the forest. Furthermore, it is unsettling to read in Weyerhaeuser's plan "With the greater emphasis on short-term economic gain from SERM, there is increased uncertainty that harvest operations will cease if environmental or social concerns conflict with timber supply needs". This forest management plan / EIA is being rushed through the approval process, with little regard for the other land use issues in the forest.

Eco-tourism is one good example of a non-forestry land use that would benefit from a land use plan. Eco-tourism is one of the largest, undeveloped opportunities for our north. It is an industry that, if carefully and thoughtfully managed, offers long-term benefits to the northern economy. There is no provision in the WCST plan to preserve places within the FMA that offer special, natural features / formations that would be extremely important to the ecotourism industry (e.g. beautiful beaches (and neighbouring forest), heights of land, unique bird-watching areas, etc.). SERM must be proactive in preserving these areas by completing an immediate inventory of such sites. Sites need protection by adequate buffer zones and recognized as 'off-limits' in cutting plans. Sites could be catalogued and recorded in a provincial directory.

2.2. Public review
A management plan for three million hectares of forest land has been developed and is poised for approval without properly and effectively consulting (educating and notifying) the residents of Saskatchewan. To suggest that a 60-day review period of a 10-volume, highly technical document is going to be adequately reviewed by the general public is totally unreasonable. This is even more true, when the advertising for this 60-day event was so minimal that very few members of the general public are even aware of the plan and its review process. The public review process is flawed because it assumes that if people do not comment on a technical document such as this, then they don't care, or they are satisfied with the plan. In reality, most people are not foresters or forest ecologists, they have limited knowledge about forest practices and their impacts on ecosystems, and as such, they are unlikely to attempt to read such a document. There have been no public meetings to tell people what the plan says, and most importantly, to tell what the review-experts (SERM staff, the expert review panel, Weyerhaeuser, and many others) are saying about the plan's deficiencies. This review process has been extremely inadequate, if it's goal is to solicit informed response from the public.

2.3. Decision-making
Management of the local forest has been effectively removed from the local people. Processes, such as co-management meetings, have been steered by government and based on their 'consensus model' ofÊ decision-making. During public consultation at Weyerhaeuser co-management meetings, local people were unable to influence what they wanted in their area. Weyerhaeuser could veto anything they wanted, anytime. When committee members voted against something industry favoured, a consensus could not be reached, the issue was tabled and the status quo remained. Consensus is a good thing, but when consensus cannot be reached, a democratic vote by majority must follow to ensure fair decision-making.

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3. Conclusions

Although WCST has adopted the goals of EBM as the basis for its management of the forest, it has failed to design an implementation strategy capable of achieving these goals. In fact, in the addendum to the FMP, WCST essentially admits this to be the case. There continues to be an overriding priority placed on fiber extraction and only the most superficial consideration is given to the maintenance of biodiversity and other core elements of EBM. To label the implementation plan contained in the current FMP as EBM is, in short, misleading.

The failure by both WCST and SERM to accept the need for true ecosystem sustainability is extremely short sighted, given current public sentiments concerning the forest. Recent market developments clearly demonstrate that in coming years the ability of forestry companies to access markets will be dependent on the demonstration of true commitment to EBM.Ê Now is the time for WCST, and the province of Saskatchewan, to become leaders in sustainable forest management. The WCST FMP represents an ideal opportunity to do so, particularly given that capacity expansion has not yet occurred.

The public review process for WCS's 20-year plan has failed to provide fair opportunity for Saskatchewan residents to provide meaningful input into the planning process. The fact that there is no integrated land use plan for the entire FMA strongly suggests that public needs, input and concerns are secondary to what industry and government want. Furthermore, the fact that decision-making processes used during public consultation processes (i.e.. Dore / Smoothstone) were deemed ineffective and unfair by the majority of participants clearly indicates a serious problem. Finally, SERM's (or Weyerhaeuser's) failure to publically tell Saskatchewan residents both sides of the story -- i.e. what the plan says and what qualified reviewers are saying about the plan -- is a failure to complete the information exchange that is required in a responsible and transparent public review process

CPAWS is extremely concerned that government will approve this 20-year plan and justify their approval by attaching conditions-for-improvement. Conditions cannot fix the problems in this plan because the plan is fundamentally flawed -- harvest levels are so high they threaten biological diversity, ecosystem-knowledge is too incomplete to support planning for such intense harvesting, and not enough land is being set aside (protected) from industrial harvesting to aid in preservation of biodiversity and act as meaningful ecological benchmarks. The guide to assess approval of this plan - ecosystem based management -- cannot be achieved under these failings.

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4. Recommendations

4.1. Ecosystem-Based Management
As stated at the beginning of this review, EBM requires that the forest ecosystem as a whole must be maintained if the forest is to provide us with a wide array of benefits that we now desire from it, along with the flexibility to meet different needs in the future. There is also an explicit recognition that the forest has a finite ability to meet the demands placed on it.

This 10-year FMP does not promise to maintain the whole ecosystem. Nor does it allow for flexibility to meet different needs in the future. The plan demands so much from the forest, there is significant risk that we will over-step the forest's ability to withstand the impacts placed on it.

This plan cannot be approved as it is. WCST and government must revisit key issues that will help them to move closer to the goal of ecosystem-based management.

4.1.1. Harvest rates
Reduce harvest rates. Recalculate harvest rates using more conservative estimates of tree growth.Ê In particular, the growth rates of regenerating stands should not be assumed to be greater than natural rates until better understanding of regeneration rates and succession is available (particularly for coniferous stands).

4.1.2. Fire return interval
Given the current fire return interval of 205 years, the fire return interval used to guide harvest rates on the forest management area should be no less than 100 years. Targets for old-growth retention should be based on this cycle (e.g., 37% of stands greater than 100 years of age if a 100 year fire cycle is used). This will obviously entail a substantial reduction in the annual rate of harvest from that which is currently proposed. However, maintaining a large proportion of the land base in the old-growth phase will minimize disruption (both for the ecosystem and for timber flow) in the event that a very large fire occurs in the forest management area.

4.1.3. Special management of white spruce
Implement special management of white spruce stands. This would entail harvesting restrictions designed to ensure no net loss of old-growth white spruce. It would also entail changing from the current clear-cut and plant approach to true mixedwood management (as described by Lieffers and others).

4.1.4. Harvesting in riparian areas
Maintain a prohibition on harvesting in riparian areas, or at the very least, conduct minimal harvesting based on carefully researched and accepted harvest methods proven to be ecologically safe. Reducing or eliminating the harvest in riparian areas will necessitate a reduction in the annual rate of harvest from that which is currently proposed. Further Details in Addendum.

4.1.5. Green-tree retention in harvest blocks
Conduct studies to determine the appropriate amount of green-tree retention required in harvest blocks to maintain biodiversity and ecological processes. In the interim, a minimum of 10% of trees should be left on harvest blocks, in clumps of varying size.

4.1.6. Protected areas / ecological benchmarks
Enlarge Prince Albert National Park to at least 5,000 km2 and formally incorporate it into an adaptive management strategy. Ensure a buffer is place around Park boundaries.

Establish Budd Lake and Caribou Flats as legally protected areas. These must be identified in the 20-year plan. Expand the network of protected areas in Weyerhaeuser's FMA, so that the 'conservation areas' identified by World Wildlife Fund are legally protected. These must be identified in the 20-year plan.

Establish 'special management' buffer zones around protected areas to ensure ecological integrity of core protected areas.

Establish 'special-management' corridors between protected areas to aid in wildlife movements.

Declare the entire Dore / Smoothstone area to be a 'demonstration management zone', where excellence and innovation in forestry management take place (see attached letter). This must be identified in the 20-year plan.

Establish a minimum, one-kilometer, special-management buffer zone around Dore and Smoothstone Lakes (see attached letter). This must be identified in the 20-year plan.

4.1.7. Caribou management
Develop a management plan for caribou designed to ensure the viability of this species within the forest management area. This will likely involve the establishment of special caribou reserve areas.

4.1.8. Salvage logging
Develop a wood salvage strategy to ensure that the habitat requirements of species needing burned wood are met.

4.1.9. Modeling
Utilize a fully spatial model for future harvest planning. Models capable of incorporating ecological outcome variables are now being developed by Basket and Jordan.

4.1.10. Cumulative impacts
Conduct a province-wide EIA of cumulative impacts of all industrial development in the commercially harvested forest.

4.2. Public input

4.2.1. Land use planning
Develop a land use plan for the entire Weyerhaeuser Forest Management Area, prior to establishing harvest levels. This plan must address the other needs of forest users.

4.2.2. Public and government consultation
Tell Saskatchewan residents, including Caucus, what the experts are saying about this 20-year plan. Do not approve this plan until Saskatchewan people have good information to make an educated contribution to the planning process. Invoke fair decision-making practices in co-management and land use planning processes, so that if consensus decision-making fails, there is a move to a vote by majority.

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Addendum: Suggestions for harvesting in riparian areas

If any harvesting occurs in riparian areas, it should be minimal. Only minimal harvesting in riparian areas will prevent the creation of a network of clearings along riparian areas that cause excessive unnatural hazards for wildlife. For example, harvest activities necessitate an infrastructure of landings relatively close to the water, for piling logs. Landing are openings that become hazards to wildlife who use the riparian areas for feeding, drinking, etc. Landings attract predators and human activity.

No mechanized logging should be allowed in riparian areas. WCST suggests harvesting with 'soft-footprint' equipment, but in high-water years, travel lanes are created by such equipment. The lanes necessarily approach the water-bodies, at near-perpendicular angles to landing sites located outside of the riparian zones. The equipment and lanes cause compaction and ruts in riparian areas which lead to erosion.

No clear-cutting should occur in riparian areas. High-grading must not occur either (i.e. selection of the biggest and best trees). Equal amounts of small, medium and large trees must be taken and replaced (replanted). WCST must be encouraged (enforced) to find a way to utilize the smaller trees in their milling processes. Leaving too many fallen, small trees in the riparian zone threatens to cause problems for animal movements within the zone.

Riparian harvesting should only take place in the winter to reduce surface damage.

No harvesting should be done until a successful planting program for riparian areas is firmly established and accepted.

Intensive site preparation (for planting) should not occur in riparian areas. Planting must occur immediately after harvest or before harvesting.

Planting 10 years prior to harvest would help to establish new seedlings. Then harvesters could go in 10 years later and remove an equivalent amount of trees.

Selective and non-mechanized harvesting coupled with careful planting programs in riparian areas are likely not something that WCST will be eager to embrace. A timber ranger/riparian specialist, employed by SERM will be needed to monitor forestry activity in riparian areas to ensure that things are done properly. Riparian areas are far too important ecologically to 'assume' that the industry will do the right thing on their own.

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LEARN MORE:

CPAWS Work in the Forest An overview of CPAWS Saskatchewan's conservation work in the forest.