NATURE SASKATCHEWAN RESOLUTIONS AND RESPONSES

• Response to Norsask 20 year Plan
• Response to Saskfor/MacMillan 20 Year Plan
• Resolution: Deforestation of the Forest Fringe
• Resolution: Increased Timber harvest
• Comments on the National Forest Strategy

WHEREAS Reports issued this year by SERM, Parks Canada and the Canadian Wildlife Service demonstrate that deforestation has accelerated to crisis levels on the Saskatchewan forest fringe;

WHEREAS Present agricultural,crop insurance, and taxation policies still favour conversion of forested land to grazing or crop production even where the land has limited agricultural potential;

WHEREAS Saskatchewan mill operators have increased the demand for wood from "off FLMA" sources, encouraging an unsustainable harvest that is destroying natural ecosystems and valuable long-term timber supplies on the forest fringe; and

WHEREAS SERM has taken some positive steps, including a moratorium on softwood harvesting on designated Wildlife Habitat Lands, but the province has not developed an effective land use policy or comprehensive regulation of timber harvesting practices on the forest fringe

BE IT RESOLVED THAT

1. Nature Saskatchewan work to inform the public and demonstrate its concern to the Provincial Government about the deforestation crisis that presently exists on Saskatchewan's forest fringe;

2. Nature Saskatchewan urge SERM to give priority to an inventory of forest fringe ecosystems and timber supplies, and use it as the basis for developing a land-use plan for the forest fringe;

3. Nature Saskatchewan support adoption of programs that encourage retention of forest on private lands and assist wood lot owners to develop plans for sustainable harvest of timber;

4. Nature Saskatchewan support adoption of mandatory controls on timber harvest, including harvest limits and minimum riparian leave strips, on all lands, public and private, on the forest fringe; and

5. Nature Saskatchewan support adoption of ISO or similar standards requiring forest companies and mill operators in Saskatchewan to purchase wood only from sustainable sources.

WHEREAS the Provincial Government has announced that it intends to encourage a significant increase in the timber harvest in the Commercial Forest and has given notice that it is prepared to withdraw land from the Weyerhaeuser FLMA if the company does not take steps to increase its mill capacity and the harvest on its lands;

WHEREAS a study commissioned by SERM found that the Saskatchewan Forest Inventory, used to establish sustainable harvest limits, is potentially faulty due to inadequacies in inventory methods and reduced funding of the inventory; and

WHEREAS Saskatchewan has no audit of non-timber resources in the commercial forest similar to those developed in Ontario and British Columbia to assist in gauging the impact of harvesting on biodiversity and ecosystem integrity

BE IT RESOLVED THAT

1. Nature Saskatchewan oppose the construction of new mill capacity in Saskatchewan without a separate Environmental Impact Assessment of the effect of the harvest required to supply the new mill capacity; and

2. Nature Saskatchewan urge the provincial government to establish a system for auditing all ecosystem components across the Commercial Forest Zone, and to remedy inadequacies in the Saskatchewan Forest Inventory before taking any further steps to increase the timber harvest in the province.

12/11/96

NATURE SASKATCHEWAN

Review of the NorSask Environmental Impact Statement and Proposed Forest Management Plan

Perspective

The NorSask EIS is the first environmental assessment of a Forest Management Plan to be completed and presented to the public. We appreciate that EIS is new in this context, and that the IFRM concept it is intended to serve is still evolving. This has placed a heavy burden on NorSask. At the same time, because the NorSask experience may become a precedent, it is important to identify any weaknesses in the approach the company has adopted. That will be the main focus of the comments which follow.

Our assessment of NorSask's EIS and Management Plan reflects our goals and values. For that reason, it is appropriate for us to state our perspective. We support ecologically-based, sustainable IFRM in which multiple use of the forest takes place within constraints designed to protect the ecological integrity of the forest. Saskatchewan's forests are extensive, and in a relatively natural state. Management techniques that preserve natural ecosystems across the forest are both possible and desirable. Canada may be one of the few places where there is still an opportunity to preserve an ecosystem of global significance while developing it in a sustainable, economically productive manner. We also acknowledge that our perspective has been influenced by the "Natural Landscape Strategy" proposed by Booth, Boulter, Neave, Rotherham, and Welsh (1993. Forest Chronicle 69:141-145). In this approach

the objectives of our planning and our management will be to maintain the mix of ecosystems, age classes and stand types that provide:

• The habitat for all plants and animals living in the region.
• An aesthetically pleasing forest landscape for recreation.
• A healthy, vigorous forest to provide wood to meet the needs of society.

It should also be noted that the focus of our comments is on ecosystem sustainability. However, we believe that a healthy forest will create opportunities for a variety of human uses. We also favour co-management of resources whenever it is feasible to do so.

NorSask's approach to IFRM and sustainability

We have some concern about the general approach to IFRM adopted in the EIS and Forest Management Plan. The stated goal is to "optimize and equitably balance among all forest users the supplies of all forest resources.". However, the net effect of the option selected by NorSask is better described as constrained maximization in which one resource, the timber harvest, is maximized within the restraint provided by minimum targets assigned to other uses. In the long run, the stability and health of an extensively managed forest requires that all uses be equally constrained by the requirement that a natural pattern of ecosystems is maintained at stand, landscape, and management unit scales.

In particular, we note that the proposed harvest volumes during the term of the 20-year management plan are geared to meeting the capacity of existing mills. Because supply shortages of softwood are most apt to be a problem, it is noteworthy that the softwood harvest is scaled to meet the requirements of the NorSask saw mill, which was recently expanded from a capacity of 280 000 m³ to 514 000 m³. It would, of course, be desirable to maintain the supply of this mill, but its capacity was planned within the context of traditional sustained yield strategies. We have doubts that the management tactics proposed by NorSask can justify full capacity production while meeting the goals of IFRM.

Harvest levels can be maintained in the NorSask Plan only at the cost of significant reductions in the proportion of certain key forest associations and an increase in young growth. The only "indicator" species used by NorSask that makes significant use of a range of middle to late successional mixedwood stands (the fisher) is predicted to undergo a permanent population decline. Over the 20 year plan, timber stocks in general decline. Thus we agree with those reviewers who suggest that NorSask is not proposing a true sustained yield management program. We also concur that NorSask's method of reporting age distribution risks misrepresentation of the impact of harvesting.

NorSask argues that the present distribution of age and composition of forest communities is not stable or consistent with natural conditions. We do not believe a convincing case has been made. It is difficult to model a "natural forest", but the history of heavy exploitation of white spruce in Saskatchewan and the accumulation of lands not sufficiently restocked with spruce after harvest suggests that the proportion of mixedwood with a significant spruce component is unlikely to be seriously over represented. The stock of old forest is a more difficult matter. Fire suppression may be a significant factor, but the role of climate cycles and the heavy exploitation of mature spruce stands in accessible areas makes it unsafe to conclude that there is as much over representation of this community as NorSask and the industry as a whole believes.

NorSask also contends that recovery of stocks will occur in the long run. Long-term modeling is, of course, important in any ecologically-based management strategy. However, the long run should not be allowed to excuse short-run deficits. Recovery after an initial period of intense exploitation depends on a number of variables--- including regeneration rates and reforestation measures, and modeling of successional pathways. It is notable, therefore, that both the initial scale of NorSask's proposed silviculture effort and its modeling of succession have been criticized by reviewers. NorSask also places emphasis on bringing currently unforested land into production. This would mitigate the effect of heavy harvesting elsewhere, but it has not been demonstrated that yield targets from "productive unforested" lands can be met in practice. Intensive silviculture is costly, and results often fall short of the promise, even on recently-forested lands. Finally, we note that the scale of recent fires in the NorSask forest will compound the problem of reaching long-term yield goals. The impact of these fires was not considered in the EIS.

Silvicultural efforts, and in fact all efforts aimed at long-term sustainability, are usually regarded by the industry as costs with no direct return within the normal fiscal planning horizon. We are thus uneasy with a management plan that appears to defer sustainability targets. NorSask justifies heavy harvest in the short term with long-term promises. Historically, silviculture targets have often not been met on the ground; we fear that other long-range targets may similarly fail to be achieved.

We are also concerned that the EIS and Management Plan have failed to take the holistic, forest-wide view required by IFRM. The exclusion of non-productive lands from consideration is a shortcoming. We are uncertain whether this seriously compromises the EIS, but in any event, future guidelines for environmental assessment should require that the entire FLMA land base be brought into consideration. (In principle, planning should focus even more widely on natural units such as watersheds rather than administrative units, but we recognize the limitations imposed by the existing legal framework).

NorSask's approach to wildlife management

NorSask's wildlife and plant studies appear to us to be inadequate for the purpose of gauging impacts on ecosystem stability and biodiversity. The five "indicators" selected by NorSask do not sufficiently represent the diversity of the forest. Two of them, moose and white-tailed deer are species known to do well after conventional harvesting. Blueberries are an early successioinal plant that might also be expected to be less heavily impacted by harvesting than many other vegetation components. It is significant that proposed mitigation efforts would most successfully benefit white-tailed deer (an abundant species that entered the Saskatchewan forest in this century in the wake of human disturbance).

As noted above, the fisher is the only indicator for mid- to late successional mixedwood. A fisher population decline is thus likely an indicator of decreased diversity in this important ecosystem. No species that depends exclusively on "old forest" (spruce, spruce/fir) was adopted as an indicator. As an example of the consequence of failure to consider old forest wildlife, consider recent studies of song bird use of large blocks of mature woodland. Since many of these birds are under increasing pressure along migration routes and on wintering grounds, breeding habitat loss may tip the balance against survival. Deficits in modeling of caribou habitat have been noted by reviewers, though in this case, the state of knowledge at the time studies were planned may provide an acceptable explanation.

The wildlife species given in-depth consideration were chosen because of presumed importance as well as indicator utility. Three are game animals, one an important fur-bearer, and one a plant of some economic importance. Only two of the five have been significantly threatened by habitat loss. These choices reflect an approach to wildlife management in which, for the most part, wildlife means game or other economically valuable species. This is an outmoded view that misses the biodiversity of the forest. Protecting a few "important" species does not guarantee the health of the ecosystem. The EIS makes reference to conflicts between management goals for targeted species. In general, conflicts should be avoided by preserving functioning ecosystems that in turn set population levels rather than by managing for specific species.

Landscape level effects and concentration of the harvest

We also have some specific concerns about impacts at the FMU and local landscape scale. Historically, concentration of the harvest in core areas within the accessible woodland has exacerbated impacts. On balance, therefore, we believe that NorSask's plans to significantly expand the area accessible to harvest is positive. This brings with it, however, an increased responsibility to mitigate the impact of road construction and the increased level of human disturbance that accompanies it. Detailed plans for road closure and reclamation need to be developed. Plans to retire something less than half of the roads are likely not sufficient.

We also note that despite increased access, NorSask's Plan will still involve significant concentration of the harvest in the southern part of its forest. The Turnor Lake Block, which has some of the largest softwood reserves in the NorSask FLMA, will remain inaccessible, and was not included in the environmental assessment. Ecosystem supply is calculated at the FMU level rather than the local landscape level, and wildlife habitat supply is calculated on the basis of even larger units. In our view, the only manageable way to preserve biodiversity and ecosystem health is to maintain a supply of all native ecosystems in a natural range of ages at the local landscape level. Where the supplies are, and how they coalesce at the landscape level, are as important as the quantity of supply. Harvesting methods proposed by NorSask may go some distance toward ensuring that regeneration of a natural landscape pattern eventually occurs, but if dispersal of the harvest is not given significant weight in planning, young growth may be over represented at the landscape level in heavy harvested areas.

Even at the FMU level, harvest forecasts suggest that an imbalance of age classes will occur in some cases. For example, in the Canoe Lake FMU, over a twenty-year period, 41% of the land base presently under mixedwood (aspen-spruce and spruce-aspen) will be harvested. If fire takes a similar proportion, very little intact mixedwood more than 20 years old will remain in the FMU. NorSask is proposing an extensive management approach--- which we endorse--- but to be successful as an ecologically-based system, extensive management should be extensive in area as well as treatment.

Cut block design and habitat diversity

NorSask proposes mitigation measures at the cut block level that are impressive in many respects. We concur that a single-pass variable cut block system of harvest is generally preferable. The Landscape Management Manual prepared as part of the EIS is a good starting point for management of cut blocks. However, there are some matters that are not dealt with in an entirely satisfactory manner. Perhaps most important is a matter alluded to above. Cut block design must address the habitat needs of a wider range of species than those considered by NorSask. In particular, we are concerned with the needs of species that require large blocks of mature forest, wide connecting corridors and riparian buffers. We believe that failure to fully develop a riparian buffer strategy is a serious failing. NorSask admits that it took preliminary buffer recommendations from regulations in effect elsewhere. In many cases, the tentatively-recommended buffers are significantly narrower than those that have been found to be optimal for species of ecological and economic importance in Saskatchewan. We concur with reviewers who suggest that efforts should be made, perhaps in collaboration with SERM, to develop additional mitigation strategies.

Another concern is the preservation of "old forest". We believe that old forest should be dispersed throughout the working forest in places in which it is a normal landscape component. Setting aside preserves of old forest is one tactic, but not sufficient in itself. This would not achieve natural dispersion, and preserve stands will eventually be lost to fire. Likewise, concentrating old forest in riparian buffers is not a complete answer both because large blocks are part of the requirement and because old forest is not confined to riparian areas under natural disturbance regimes. In the result, we believe at least some old forest must be "cycled" along with other communities. Long rotations in some stands will be necessary to create old forest, and some old forest should be harvested. In this case, harvest methods other than clearcut may be appropriate to mimic natural disturbance.

Conclusions

In summary, we believe the NorSask EIS is not a good model for the environmental assessment process in Saskatchewan's forests, and that the NorSask Forest Management Plan is flawed in some important respects. However, we also recognize that the evolution of IFRM can be expected to take time, and will require dialogue between NorSask, SERM, and other stakeholders including the public. NorSask should be given an opportunity to revise its management plan. Many of the matters that are of concern to us have been outlined above. Key elements of an improved management plan will likely include:

(1)Adoption of appropriate harvest limits within the context of a multiple-use, ecologically sustainable strategy. While we do not suggest that it is necessary or desirable to maintain current proportions of all community ages and types, reconsideration of the proportion of mixedwood communities and old forest at the 20-year planning horizon is necessary. In setting limits, consideration should be given to plans to bring unforested lands into production and yield increases from intensive methods only as results are demonstrated in practice.

(2) More attention must be given to landscape level planning to ensure that an appropriate mix of age classes remains within localities in which harvest is occurring, and more attention must be given to provision of intact mature forest blocks, corridors, and other features that connect local landscapes into a larger pattern. Detailed prescriptions for adequate riparian buffers is required.

(3) More specific and extensive plans must be devised for retirement or closure of roads after harvest.

(4) Strategies for preserving biodiversity must be further developed to demonstrate that mitigation measures will benefit a larger range of boreal plants and animals than those given in-depth consideration in the EIS.

(5) A strategy for maintenance of an appropriate old forest component that is naturally dispersed should be developed. This should include commitment to preserves, but also long rotation and selective harvest tactics for dynamically integrating old forest into the landscape.

(6) Reassessment of short-term to middle-term silviculture goals to insure that heavy harvest of softwoods will not contribute to the backlog of "not sufficiently stocked" land.

COMMENTS ON THE NATIONAL FOREST STRATEGY (1998 DRAFT)

Prepared by Michael Finley for the NATURE SASKATCHEWAN conservation committee

[Editor's note: The National Forest Stategy is a statement of values, principles, and required action that is being drafted by the Canadian Council Of Forestry Ministers ]

The National Forest Strategy is an important initiative. There can be no doubt that the principles it adopts represent a significant improvement in forestry policy and philosophy in Canada. We fully endorse the concept of ecologically sustainable, integrated management it reflects. The values and vision statement that preface the document are articulate.

There is much in the draft with which we agree. However, most of the comments below focus on matters about which we have reservations or suggestions for improvement. Our general concern is that the initiative represented by the document will come to make a real difference in the way forests are managed in Canada. Writing in 1993, Paul Gries (former executive director of the Canadian Nature Federation and a member of the National Forest Strategy Coordinating Committee), warned that

"To date this commitment [to the NFS] has been met with enthusiasm and good will. However, the really tough decisions have yet to be made and a number of impediments to progress, many unforeseen, will need to be overcome to satisfy the raised expectations they have created. Achieving the goals of the NFS will require substantial political will and innovative approaches to the planning and funding of forest management".

The main task of ensuring that the strategy does lead to progressive change will come after the strategy has been adopted. However, the language used in the document may make a difference. It should strive for clarity in expressing goals, and avoid formulae which hide controversy or lend themselves to misinterpretation. It is these things that we will concern ourselves with here.

Strategic Direction 1 -- Forest Ecosystems

The emphasis on identifying, monitoring and enhancing the ecological diversity of forests is appropriate and important for the future of our forests. The "principles" state that "comprehensive, accurate inventories that include information on key forest values are essential for sustainable forest management". The "framework for action" refers to "broadening the scope of inventories and information on key forest characteristics, including the impact of natural and human activities on forest ecosystems, non-timber features and growth and yield of forest resources, that are needed to manage the forest sustainably for a wide range of values and to forecast changes in the forest." While these formulae are not inaccurate descriptions of what is required, the language should more clearly signal the necessary changes if we are to move toward management that sustains ecosystems rather than timber supply alone.

Inventories of timber supplies have long been a key forest management tool in most parts of Canada, but there is evidence (see e.g. the Saskatchewan State of the Resource report (SERM)) that funding cuts and lack of innovation have compromised accuracy. For that reason, it would be desirable to explicitly call for "improved inventories of timber resources" as one element of the "comprehensive and accurate" inventories required for ecosystem-based management.

Existing inventories are concerned only with timber supplies. The draft identifies the need for a broader inventory. What is required is an inventory of all elements in forest ecosystems mapped at the landscape level. Initiatives in this direction have been undertaken in some provinces. In Saskatchewan, however, industry argued during the course of recent reviews of forest management agreements that that there is currently enough information about non-timber ecosystem elements to make ecosystem-based management possible. If this is a defence of a "best effort" at planning given the current state of knowledge, the position is defensible. If it becomes an argument that present knowledge is equivalent to an inventory of ecosystem components, it is not acceptable. The language of the draft may not be precise enough to make clear the need for a proper inventory of all ecosystem components of known significance. Reference to "key forest values" is ambiguous. In discussion of its management plan, Weyerhaeuser introduced the notion of "valued ecosystem components", which involved a ranking of a deliberately limited list of species according to presumed economic and social value as well as ecological significance. Certainly, we should be interested in species that are valued in economic and social terms, but the knowledge base necessary to preserve ecosystem integrity must go beyond value in this sense. Reference to "key forest characteristics" is perhaps less ambiguous, but addition of the phrase "including the impact of natural and human activities on forest ecosystems" may be read as limiting the scope of inventory. Perhaps what is missing is a clear statement that a primary purpose of inventory of non-timber ecosystem components is to make possible modelling of ecosystems in all their diversity and complexity.

Strategic Direction 2--Forest Management

This section begins with the proposition that "The challenge is to continually refine land use, forest management planning and forestry practices so that they reflect key forest values and maintain the health of the ecosystems". The framework for action refers to the need for "an ecosystem approach to forest management". These are appropriate goals. The text, principles, and framework for action contain much that reflects these goals. However, the focus is diluted in several key respects.

A shift in focus is evident in the first principle in this section, which states that "sustainable forest management recognizes a forests' [sic] potential to sustain a range of values and the needs and rights of all users, and strives to find the best balance of uses based on the relative benefits and impacts of management alternatives". Multiple use and balancing of interests are appropriate and important concepts, but as a definition of sustainable management the first principle is incomplete. The primary focus of sustainable management is sustaining ecosystem integrity. In a true ecosystem approach, multiple use follows from preservation of intact ecosystems, and balancing of interests is achieved through and within the constraints imposed by the goal of maintaining diversity. The principles section should be revised to clearly place emphasis on ecosystem-based management that strives to sustain ecosystem integrity as well as the values, needs, and rights of users. It should be made clear that appropriate management is management that achieves the social and economic goals of multiple use by preserving ecological diversity .

Use of the unqualified term "sustainable forest management" rather that "ecologically-based sustainable management" or "ecological sustainability" is itself somewhat problematic. A study commissioned by the Prince Albert Model Forest noted that many forest managers still confuse ecologically-based integrated forest management with sustained yield. Sustained yield is a timber-based approach that sustains the timber supply rather than ecosystems. A shift away from traditional sustained yield management is a key component of the emerging forest strategy. To effectively signal the change in philosophy, a less ambiguous term than "sustainable forest management" may be necessary.

The focus on ecological sustainability is most seriously compromised by the treatment of intensive management. While the framework for action appropriately refers to "developing and implementing forest management strategies and guidelines to ensure long-term genetic, species and habitat diversity", the text appears to contradict these goals. A significant door to large-scale intensive management has been left open. Thus it is suggested that intensive management is appropriate for "reforesting difficult sites or where forest plans require intensive management to meet specific wood supply needs." and that "breeding and genetic techniques can also help to develop trees that are resistant to certain diseases". There may be a place for intensive management in reforesting difficult sites, but as a matter of policy, it should not be relied upon as a means of increasing yield to justify harvest levels that are not sustainable in a true ecosystem approach to management. Intensive management decreases biodiversity. Replacement of natural ecosystems with plantation-style "tree farming" should be avoided in most contexts. As Booth et. al. ("Natural forest management: A Strategy for Canada". (1993). Forest Chronicle 69) suggest:

"In Canada we have no shortage of land, a very sparse population, and slow growth rates make returns on intensive silviculture low on many sites. Forest landscape management requires more planning, a lower intensity of land use, but more total area in use. . . . We have one of the few countries where such an extensive forest management approach makes economic sense. It maintains Canada's competitive position and yet is a "green" approach. Canada has been trying to mimic European intensive forest management practices despite having significantly different environmental, social and economic conditions. Unlike other countries, Canadian forests are extensive [and] relatively intact. . . . Much of the intensively managed plantation in Canada requires heavy investment, often yields low financial returns and results in a forest with low biological diversity".

The draft should be revised to reflect a strong preference for extensive, ecologically based management over intensive, plantation style management.

However, appropriate silvaculture remains a priority in Canada. While the draft notes that "tree planting will continue to be an important practice in ensuring prompt renewal", insufficient attention is given to identifying methods of ensuring regeneration after harvest. It has been estimated in Saskatchewan that 66% of the land base harvested since 1975 is failing to regenerate to accepted standards. The situation is similar in other parts of Canada. The industry has tended to regard silvculture as a pure cost of doing business rather than an investment: Trees planted today will not be harvested within the realistic fiscal planning horizon of the industry. As a result, regeneration targets have been consistently missed. For that reason, the draft should give more attention to regeneration. In particular, it should identify elimination of the backlog of land "not sufficiently stocked" after harvest as a priority.

Strategic Direction Three ---Public Participation

The importance of public participation is well recognized in the draft. We have comments on two specifics in the framework for action. The framework for action calls for "convening a national meeting of government, industry and non-government organization education specialists, to coordinate efforts and minimize duplication in providing the public with comprehensive and balanced educational programs on Canada's forests" with a lead role taken by the Canadian Forestry Association ". While such an initiative should be encouraged, it should not be regarded as the primary focus of the public awareness and education strategy. There is not, nor will there likely ever be, complete consensus about the future of our forests. Debate and controversy can be creative, and are the life blood of decision-making in a democracy. Our concern is that a coordinated, consensus-based effort of this sort does not lead to decreased funding and access to schools and other forums for a range of opinion. From this perspective, the reference to coordination of efforts and minimization of duplication is problematic.

The framework for action refers to "ensuring that timely results of formal reviews of licenses or agreements for timber harvesting on public forest lands are made available to the public". This is of course a necessary component of public participation. However, it may be too narrow. In Saskatchewan, public access to draft management plans, EIA's and results of technical reviews is established policy. Once technical review is complete, a 60 day window for public comment opens. In practice, however, this has proven inadequate.

The preparation of management plans and EIA's typically takes years. Technical review takes months. Management plans and associated documents are typically more than 1000 pages long.. Environmentalists and other stake-holders need more than 60 days to review documents. Public meetings held by the applicant company during course of preparation of plans are apt to be long on rhetoric and short on hard information. One company (Weyerhaeuser) proved to be accommodating, making access to documents available in a variety of ways during and before they went to technical review. Another (SaskFor/MacMillan) would do no more prior to completion of technical review than allow documents to be viewed in their offices at Hudson Bay, Saskatchewan. It is not enough to commit to making results of reviews public. All planning documents submitted to government should be widely available to the public from the time they are submitted for review.

Strategy four--- Economic Dimensions

Growing consumer awareness and concern of our trading partners about global threats to forests are combining to make some form of certification of forest products an economic necessity as well as an ecologically sound idea. Endorsement of certification in the draft is therefore welcome. However, the draft may be somewhat behind developments in this area. The framework for action suggests "working with other nations to develop and implement multi-country product standards and to gain international recognition of Canadian product and building codes, standards and certification systems" and the text refers to "the participation of the forest industry in efforts to develop certification standards". In fact, momentum has carried certification beyond the planning stage suggested by the draft. There are already models that have won wide international acceptance. The Forest Stewardship Council has established guidelines that have been widely adopted in Europe. The Smartwood certification standards developed by environmentalists (and approved by FSC) are gaining increasing recognition in the US. In Canada, similar guidelines have been devised by the Silva Forest Foundation. It should also be noted that all these models were developed with significant input from environmentalists, but have gained wide acceptance from consumers, industry, and government. The EEC is a major sponsor of the FSC. In Canada, industry appears to be waiting for progress by the CSA, a process that has not be endorsed by environmentalists because it is heavily weighted in favour of industry input.

Against this background, two changes in the draft appear to be appropriate. First, reference to "the participation of the forest industry in efforts to develop certification standards" should be broadened to include reference to the public and environmental organizations. Second, in addition to calling for "working with other nations", the draft should call for the industry to adopt certification programs that have already gained wide international recognition. The time has already arrived to move from discussion to implementation of certification.

Strategy Direction Eight--- Woodlots

The attention given to development of strategies to encourage a viable, sustainable woodlot sector is welcome. Two brief comments are in order.

1. The draft supports changes in income tax law to place woodlot operations on an equal footing with other uses of forest land. The draft should similarly recognize that other provincial and federal policies need to be reviewed. Provincial tax law and incentive programs for agriculture still favour conversion of forested land to agriculture, even when the land is marginal for annual crop production. A study commissioned by the Saskatchewan Farm Woodlot Association calculated that the most profitable course of action for a woodlot owner is to cut and sell all the timber, and use the proceeds to prepare the land for wheat. This conclusion was dictated by taxation and incentives, not the price of wood or the best use of the land.

2. More emphasis should be placed on the need to develop inventories and land-use plans globally outside commercial forest areas. The draft seems ambiguous on this point. Does it propose inventory and planning of woodlots, or of regions in which there is woodlot activity? The latter is necessary if ecological sustainability in forest fringe areas is the goal.

PRELIMINARY OBSERVATIONS ON THE SASKFOR MACMILLAN DRAFT 20-YEAR FOREST MANAGEMENT PLAN FOR THE PASQUIA-PORCUPINE AREA

Michael Finley
Chair Saskatoon Nature Society Conservation Committee

Garth Nelson
Chair Nature Saskatchewan Conservation Committee

We have serious reservations about the Saskfor MacMillan Limited Partnership (SMLP) draft Twenty-Year Forest Management Plan. The draft plan does not provide sufficient rationale for the harvest strategy it proposes, and fails to implement the goals of ecologically-based integrated resource management (IRM) adopted by the Government of Saskatchewan.

The deficiencies in the plan do not mean that the timber harvest in the Pasquia-Porcupine area cannot be sustained, or perhaps even increased. But sustainable forestry is possible only if the principles of ecologically-based IRM are consistently and conscientiously applied. The fact that one of the SMLP partners (MacMillan Bloedel) has recently publicly committed to more ecologically-sound management gives us real hope that the deficiencies in the draft plan will be corrected. On the other hand, we note that the Pasquia-Porcupine area has been exploited longer than any other forest region in the province, and has suffered more from inadequate management. Ecologically sound management in the region is difficult, but, we believe, possible and economically feasible.

1. Harvest Volume Schedule

In order to supply existing and proposed mill capacity, SMLP plans to move toward full utilization of a harvest volume schedule (HVS ) calculated on the assumptions of its "preferred option". A significant increase in the harvest during the life of the 20-year plan is proposed. Several of the assumptions made in determining the HVS are questionable. Because the proposed harvest appears to be approaching the limits of sustainability, any deficiencies in the model could have serious long term-consequences. For that reason, we are not convinced that SMLP is proposing sustainable forestry. There may be enough wood in the FMA to meet realistic demands, but SMLP has failed to demonstrate this proposition.

(a) Modelling fire and insect damage. In modelling to determine the HVS under a variety of harvest/regeneration strategies, SMLP did not take losses due to fire and budworm damage into consideration. This seriously compromises the value of the model as a planning tool. Fire loss can be estimated from historical data, and budworm losses are identified by SMLP as a significant problem. Failure to take known disturbances into account inevitably leads to misrepresentation of the dynamics of the managed forest.

It is an understatement of considerable magnitude to suggest, as SMLP does, that the plan will require " highly effective fire and budworm protection programs". The plan states that "[because] no fire loss allowance has been incorporated into the proposed annual harvest . . . SMLP will recalculate the sustainable annual harvest level at least every ten years, sooner in the event of significant disturbances by fire or other influences". This is characterized as a planning approach "consistent with the principles of adaptive management". In our view, this is peculiar and singularly inappropriate application of the concept of adaptive management.

(b) Regeneration. The SMLP "preferred option" differs from other realistic alternatives considered in modelling future harvests primarily in that it includes an ambitious regeneration program. We are therefore somewhat concerned that SMLP assumes 100% regeneration to accepted standards in many stand types, including spruce-aspen mixedwood in which poor softwood regeneration has been an historical problem. We are even more concerned that the "preferred option" requires reforestation of large tracts of "productive non-forested land" and conversion of some currently non-merchantable stands to commercial status. Historically, regeneration targets have all too often not been met in Saskatchewan, and intensive silviculture is all too often proposed by industry as a means to sustain harvests despite evidence that such methods are often less successful than predicted.

We believe that increases in the wood supply from intensive methods and reforestation of non-forested land should not be taken into account in calculating the future timber supply unless and until actual success has been demonstrated on the ground. We are also concerned that SERM is assigned responsibility for reclamation of the extensive "insufficiently restocked" lands in the FMA. We are unaware of any detailed plans for this effort, and fear that adequate funding may not be available.

(c) Inventory.  SMLP has made use of the SERM forest inventory, supplementing it with some additional information. While much of the inventory data is likely sound, SERM has acknowledged deficiencies. Mill closures due to lack of wood have occurred twice in the last decade in the Pasquia-Porcupine area, suggesting that some of the inventory data for the area is flawed. As the harvest approaches the limits of sustainability, deficits in the inventory become more significant than in the past. Our concern is further increased by the fact that SMLP proposes a "surge cut" of hardwood in the short-term. Because of increasing harvest rates in the first years of the plan, opportunities to correct errors in assumptions are significantly reduced, and may be beyond the capacity of adaptive management to correct.

2. Age distribution

Except in sensitive watersheds, SMLP adopts a conventional "oldest first" harvest strategy. Such an approach is acceptable only if modified to ensure that older age classes continue to be represented across the landscape at a frequency approaching that which would exist under a natural disturbance regime. The SMLP plan will not achieve this goal.

We are particularly concerned about the supply of late successional upland forest (White spruce/aspen or white spruce stands developing into white spruce/balsam fir in stands that escape disturbance for more than a century). Such "old forest" accounts for only a small percentage of the midboreal forest, but is ecologically important. In the Pasquia-Porcupine region, high-grading of spruce prior to adoption of modern practices prevented succession to old forest in many accessible stands. Since then, older spruce/aspen, spruce, and spruce/fir stands have continued to be heavily harvested, and recent damage to spruce due to selective harvesting of hardwoods has been documented. Thus it might be expected that, despite fire suppression, "old forest" is not as over-represented as other late successional forest types.

(a) Supply of older age classes and the assumed fire cycle. SMLP has assumed a short fire cycle (40 years over the FMA as a whole, 25 years in areas managed for moose and elk) in setting age distribution targets for the managed forest. This assumption is based on inadequate data, and, we believe, misinterpretation of the available information. A study in the Prince Albert National Park, referred to in the draft plan, did find evidence of a very short fire cycle in the 19th century. However, the same study estimated the fire cycle in the 20th century before fire suppression became an important factor at approximately 75 years. This suggests that the natural fire cycle is a composite, segmented by climate cycles into periods of higher and lower fire frequency. We believe that fire cycle estimates, though important, should be used more critically in planning than SMLP has used them.

In our view, it would be sounder to retain the proportion of older forest that would exist under a 75 year fire cycle regime than under a 25-40 year fire cycle regime. This would increase the supply of older mixedwood and white spruce above that contemplated by the plan. Such a prescription would conform to the best evidence of the fire cycle under recent climatic conditions. However, we do not make this suggestion entirely or even primarily for that reason. At present, there is evidence that species of animals and plants that require older forest are more threatened in Saskatchewan than those that do not. For that reason, it is difficult to accept the proposition that the current supply of older forest can be significantly reduced while preserving the biodiversity of the midboreal region. We do not know what the pre-European contact forest was really like, and cannot recreate it in any event. We do know that many species of plants and animals that depend directly or indirectly on older forest are presently at risk.

Why many late successional species are under pressure is uncertain, but even the best of managed forests is an imperfect mimic of natural conditions. Forest fragmentation may, for example, make it more difficult to utilize remaining older forest even if the total supply is maintained at "natural" levels. Consider, for example, the effect of fragmentation on song birds. Song bird decline may be a direct result of cow bird nest parasitism, which increases when large contiguous blocks of forest are fragmented.

We do not accept the arguments of some preservationists that old forest was once much more extensive than at present, or that it should all be relegated to preserves. We do, however, believe that the proportion of spruce/aspen, spruce, and spruce/fir forest in older age classes should not, given the present state of knowledge, and the known pressure on species characteristic of old forest, be significantly reduced below that which would be expected under a fire cycle regime of approximately 75 years. Long rotations and selective harvesting may be required in designated areas to ensure that an appropriate "old forest" component is maintained and cycled across the forest landscape over time.

(b) Regeneration and old forest. Maintaining an appropriate supply of late successional mixedwood and white spruce/balsam fir stands obviously requires an effort to ensure that white spruce regenerates after harvest in mixedwood and old forest stands. For that reason, we are concerned that SMLP is currently using (and intends to continue using) black spruce to regenerate mixedwood stands. What the long-term ecological consequences of this strategy will be is simply unknown. While some experimentation with black spruce as a substitute for white spruce may be justified, we are of the opinion that this strategy is unacceptable at present.

(c) Planning for wildlife. An age distribution that mimics a short fire cycle is justified in part in the SMLP plan as a means of managing for elk and moose. Because of the economic importance of these game animals, we recognize that wildlife management strategies geared toward these species may have a role in management of the Pasquia-Porcupine region. However, we believe the SMLP plan gives too much emphasis to management for these species to the detriment of others. Moreover, it appears on preliminary analysis that the harvest will be heavy in the first 5 years in areas designated for moose and elk management, thus accentuating the immediate impact of the proposed game management strategy on the age distribution of the forest..

Little attention is given in the plan to identification of indicator species that depend in whole or part on late successional stages, nor have specific strategies been developed to protect habitat for them. Note for example, that the marten and fisher (valuable fur-bearers as well as potential indicators) have been drastically reduced in numbers across the commercial forest as a whole. They are, however, more abundant at present in the Pasquia-Porcupine Hills than elsewhere in the midboreal forest. More attention should be given to these species, or better still, wildlife management goals should be premised on maintenance of the full range of age and community types that characterize the midboreal forest, thus insuring that habitat for all species will be retained.

(d) Location of supplies.  Older age classes should be represented at the local landscape level in various sized stands that meet the needs of both species that use them as refuge and species that require large blocks of mature forest. It is not enough to relegate late successional stands to preserves or riparian leave strips. For that reason, we are concerned that SMLP appears to have set age distribution targets at the FMA rather than the landscape level, and intends to include SERM preserves and leave strips as part of the contribution to the total in assessing compliance with age distribution targets. Coupled with adoption of a short fire cycle model, we fear the result may be the disappearance of the older age classes over significant parts of the FMA.

3. Other concerns

(a) Protected areas.  We believe that the best strategy for preserving a healthy forest in which all community types are appropriately represented is good management of the working forest. Nevertheless, some preserves in which harvesting is banned or restricted also have a role. In particular, the goals of the Representative Areas Network (RAN) should be respected. The SMLP management plan does not propose creation of any protected areas in addition to those identified in the Pasquia-Porcupine Land Use Plan. Thus the management plan and the land use plan must be assessed together.

The RAN target is protection of 12% in each ecoregion. Much of the midboreal lowland is contained in the FMA. We are somewhat concerned that RAN sites and potential RAN sites in the Pasquia-Porcupine region amount to only 9% of the area. This includes the largest contiguous proposed RAN site (Lobstick Lake), whose status in fact remains uncertain.

We are more concerned that the RAN sites identified in the Pasqua-Porcupine area may not be truly representative. The protected area includes recreational parks that have been (and will continue to be) significantly modified by a variety of non-traditional uses. The basis for selection of new RAN sites has not been made clear by SERM, and does not appear to have been geared toward protection of a truly representative cross-section of community types. Instead, areas of low commercial potential appear to have been given preference.

In addition, the level of protection afforded RAN sites may not be adequate in all cases. Thus, for example, timber harvest will be continue to be permitted in Wilderness Parks "based on specific management plan for the site" and on SERM Reserves "based on a plan that meets vegetation management goals". Grazing will be permitted on SERM reserves. Commercial outfitting will be allowed on new RAN sites. The latter in itself is perhaps not troublesome unless baiting and permanent tree-stands are also allowed. The draft land-use plan would allow neither, but we have learned that SERM is considering reversing its position on these issues.

The level of protection contemplated for RAN sites may deprive many of them of a role as bench-mark communities free from non-traditional human disturbance. In our opinion, at least some RAN sites, chosen to be properly representative, should be specifically afforded a higher level of protection.

(b) Riparian leaves and watershed protection. It is now widely recognized that riparian and lakeshore buffer prescriptions that are focused on protection of game fish are inadequate to provide habitat for other species that use riparian and shore zones. For that reason, we are concerned that SMLP is proposing to do no more than adhere to established leave strip requirements that are geared to game fish protection, and does not intend to establish any leave strip prescription for streams that are not known to support game fish. In our view, this approach is not consistent with the principles of ecologically-based integrated resource management.

The Pasquia-Porcupine Land Use Plan identifies sensitive areas, mostly steeper slopes, that require special treatment to ensure that erosion and other damage to watersheds does not occur. SMLP appears to have responded to this identified need by imposing some restrictions on the size and method of harvest in sensitive areas. We are not in a position to properly access these proposals. However, we note that erosion problems have been documented by residents in the Pasquia-Porcupine area. For that reason, it is imperative that SERM carefully analyse the SMLP proposals to ensure that they are adequate to prevent further damage.