The BFWSS team has created a submission to provide input on Interfor’s TFL#8. This submission was sent to the Chief Forester of BC and to Interfor.
While we appreciate the opportunity to provide feedback and ask questions, the challenge to our group and groups like our across BC is that we are a volunteer-based, non-profit organization. We do not have professional foresters, hydrologists, or analysts on staff. BFWSS is fortunate to have some members with forestry backgrounds who understand the technical aspects of a TFL management plan. However, most small community groups do not have access to experts. This is a problem that the Province should be addressing: funding should be provided to set up an independent body of forestry experts with whom community groups can consult regarding technical forestry issues.
Provincial legislation is set up to allow professional foresters to make decisions about public land. Since this is the case, local citizens, community groups, and environmental groups should be provided with access to independent professional foresters not in the employ of corporations. This would allow for a level playing field and enable BC residents to protect their interests by providing technical input.
The entire submission can be read here: https://boundaryforest.org/wp-content/uploads/2020/06/BFWSS-TFL8-Comments-Final-2.pdf
To view the Interfor TFL8 Information Package provided by Interfor click here: https://boundaryforest.org/wp-content/uploads/2020/06/TFL8_Information_Package_03262020.pdf
Here are some of our specific concerns about TFL#8 methodology:
Why is Interfor using inferior VRI stand height data to calculate the ECA and adjacency rules for new blocks when they should be using the LiDAR instead?
Interfor in their information package for TFL-8 only models the adjacency requirements aspatially; likely because using actual spatial data would reduce their options of harvesting next to too many stands hence automatically reducing the AAC. This concerns us.
Interfor states in their TSR that they will do an ECA using “third order watersheds” that intersect the TFL and their adjacent harvest/height information to inform their ECA analysis. They should be using 1:20,000 “Assessment Units” from the Freshwater Atlas of BC.
The concern about this is that a) the third-order watersheds are out-of-date and 2) why is Interfor not using the LiDAR information that they paid for? Is it because LiDAR is showing that the stand heights are significantly lower than reported in VRI (which most often uses a growth model, rather than photo interpretation)? This question must be answered in detail or it looks suspicious.
If the entire Boundary (if not the Kettle) has LiDAR data, what is the reason that Interfor isn’t doing an analysis with it instead of VRI?
What formula did Interfor use for their TFL to come up with their ECA numbers?
If it is possible that in LiDAR data the trend is for lower heights in harvested areas than in VRI data this must be examined. We would like to see the differences in the data.
Isn’t Interfor professionally and ethically bound to use the best information available to them? They should use the best inventory information available to them (i.e. LIDAR) as appropriate in determining a new AAC for their TFL.