Response to Bill 8-Part 5 - Forests, Lands and Natural Resource Operations Amendments

In the past years we have seen Ministry of Forests Staff reduced by 25% while their mandate has been enlarged to include Lands and Natural Resources. Unfortunately nothing was done to ensure that they could achieve this expanded mandate with less personal and so the management of our forests has suffered during a time of unprecedented beetle kill, when firm management was needed more than ever. We now have a situation where:

  

• Our aging inventories are now next to useless over millions of hectares.
• The annual allowable cut has not been, and cannot reliably be, re-evaluated due to these massive areas that have completely outdated inventories. 
• The priority to replant devastated areas has been removed.

The decision in Bill 8 Part 5 to allow volume based tenures to be converted to area based tenures could help with this as it gives incentives to the license holder to update inventories and perform enhanced silviculture to improve mid-term timber supply on the forest that they are managing.

 

However, the changes presuppose that the current AAC must be maintained.  This negates one of the best reasons for converting to area based tenures. The license holder should be required to update the inventories and to recalculate the AAC based on this better knowledge. Only in this way can we ensure mid and long range stability in the forest industry.

 

Also, the bill  implies that the license holder will assume the management on behalf of the gov't at their own cost. This appears to be an attempt to off load gov't responsibilities. There must be some form of tax credit back to the licensee to off-set the cost of management of these licenses. These areas should see an increase in value and therefore increased stumpage dollars coming back to the province due to innovative silviculture and management. This should make it possible to offer tax credits without increasing net costs. (These would need to be done for the extra managment only and be done in keeping with the Softwood Lumber Agreement).

 

I am not convinced that this change will do enough to enlarge our community and first nations forests both in size and number. Also, further to promoting area based tenures, I would make 2 other changes to insure increased value from our forests.

• We must return to scale based billing rather than cruise based billing. The move to cruise based billing has removed the incentive to sort out the higher grade logs for greater value use. The costs of scaling will be more than off-set from the increased value that will be captured.
• For the next few years we need to greatly enlarge the small scale salvage program to deal with the clean up of our current forest situation and extract maximum value from our damaged wood.